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Comparative assessment of public evidence

Ukraine & Kazakhstan | Evidence cut-off: Kazakhstan 4 September 2026; Ukraine 6 September 2026

Ukraine & KazakhstanMineral inventories

Where the public record supports commercial reliance and where further evidence is needed

The evidence points to different diligence priorities: Kazakhstan’s reported scanning delivery and established KAZRC route focus attention on data usability and deposit coverage; Ukraine also requires file access and rights checks. This assessment connects reported progress to the records needed to scope validation, professional work and cost.
Kazakhstan
4.819m
Priority units reported digitised; completion refers to the defined tranche. K1 K2
Kazakhstan
>380
KAZRC reports reported accepted by October 2025; not unique deposits. K8
Ukraine
No current reconciled %
No current archive-wide scanning, machine-readable-data or CRIRSCO-family restatement share is defensible. U1 U3 U5 U9 U10
Both countries
Per deposit
Reporting and acceptance depend on deposit-specific evidence and professional responsibility. Portfolio coverage requires a report-to-inventory crosswalk. K3 K4 K8 U9 U10

Use this assessment to scope the next enquiry. It identifies the records needed to test archive usability, reporting coverage, professional capacity and cost for an asset or portfolio.

Contents

  1. Diligence priorities differ
  2. The deposit coverage gap
  3. Archive access needs file-level evidence
  4. Evidence to request before reliance
  5. Scope, method and source register

Priorities for commercial reliance

Diligence priorities differ

Reported delivery, access evidence and reporting uptake support different starting points for enquiries. Kazakhstan requires tests of usable data and deposit coverage; Ukraine also needs file-level clearance, availability and reuse checks.

Established in the inspected public record Partial or bounded evidence Not established
StageKazakhstanUkraine
1. Archive coverageLarge bounded delivery

4,818,836 priority units reported digitised; the denominator is the planned priority tranche, not every archival object. K1 K2

Progress, no national measure

The 2019 audited baseline, a UGS-reported 6,000-book delivery and a separate UGS-reported 60,000-unit programme do not form one completion series. U1 U3 U4 U5 U15

2. Usability & accessPost-scan work remains

Structuring, cataloguing, georeferencing and conversion to machine-readable form are identified as the next stage before investor use. K1 K12

Access chain unresolved

Coverage, portal availability, file-level declassification, copying rights and machine-readable structure require reconciliation. U5 U6 U8

3. Reporting architectureDomestic CRIRSCO framework

KAZRC and its professional architecture have operated since 2016; later rules define deposit-level state-accounting routes. K3 K6 K7

International routes, no NRO

International professional routes exist, and domestic law permits applicant-requested international standards; no Ukrainian CRIRSCO NRO is listed. Separately, the 2025 UNFC-2019 reform is state-led, not CRIRSCO-family public reporting. U9 U11 U12 U13 U16 U17

4. Portfolio restatementNo national share

Accepted-report totals do not establish unique deposits or the share of the state balance restated. A GKZ/KAZRC crosswalk is missing. K4 K8

No national share

Public JORC and NI 43-101 examples exist, but no national census or defensible restatement share was found. U18 U19 DKZ guidance does not permit direct mechanical translation. U10

DimensionKazakhstanUkraine
Principal archive issueStructuring and usability after scanningCompletion, access, declassification and structuring
Reporting/reconciliation routeApplicant-led and deposit-specificApplicant-led and deposit-specific
National restatement programmeNot evidencedNot evidenced
National conversion percentageNot defensibleNot defensible
Professional capacityCurrent eligible CP pool and QMR/reader capacity not establishedEligible CP/QP pool not established; eligibility remains person- and code-specific
Cost benchmarkDeposit-specific; no national restatement benchmarkDeposit-specific; no national restatement benchmark
Automation boundaryOCR, GIS-filtered structuring and predictive modelling evidence; not reserve conversionStructured entry reported; OCR and AI remain roadmap-stage; no category conversion evidenced
Commercial diligence bottleneckCrosswalk, usability and CP capacityArchive/access/declassification, crosswalk and CP capacity
Implication for enquiries: begin Kazakhstan work with archive usability, the GKZ/KAZRC crosswalk and live CP/reader capacity. In Ukraine, establish file coverage, clearance, retrieval and reuse rights alongside the reporting route.

Reporting adoption and portfolio visibility

The deposit coverage gap

Reported archive delivery and KAZRC uptake establish activity. A dated link between state-balance entries, signed reports and acceptance outcomes is still needed to assess deposit coverage and scope further work.

Priority digitisation tranche
4.819m

Primary units reported digitised by September 2026. The claim is bounded to the defined tranche. K1 K2

KAZRC uptake snapshot
>380

Reports reported accepted by October 2025. The figure counts reports, not necessarily unique deposits. K8

State-balance restatement share
Not established

No dated national deposit/report crosswalk or valid denominator was found.

What >380 demonstrates

Material reporting activity within an established domestic KAZRC framework, supported by a legal route into state accounting. K3 K4 K8

What it cannot demonstrate

A count of unique deposits, the share of the Soviet-era state balance restated, a standard quantity adjustment or a national conversion schedule.

The register remains hybrid

Resolution No. 874 and the administrative algorithm define when GKZ or KAZRC information may enter state accounting. The accounting rules preserve separate GKZ and KAZRC information; acceptance is deposit-specific, with corresponding account changes. K3 K4 K5

A September 2026 government review reported 795,800 tonnes of C2-category reserves at Irgiz. This is contemporary public evidence that GKZ categories remain operational; it is not a CRIRSCO-family restatement. K1

Implication: institutional integration is real, but it does not produce a public portfolio crosswalk by itself.

The missing current capacity picture

Public snapshots cite 106 self-certified CPs in 2023, more than 80 report authors and 40 QMR holders in April 2025, and 522 total members displayed in September 2026. These are different measures and dates, not a current commodity-specific eligible-signatory pool. K9 K10 K11

Implication: schedule risk requires a live roster, specialty map and backlog check.

01 | RETRIEVE

Archive object

Confirm stable identifiers, availability, restriction status and retrieval performance.

02 | STRUCTURE

Usable data

Catalogue, georeference, extract and quality-control the record. Scanning alone does not satisfy this gate. K12

03 | RECONCILE

Deposit crosswalk

Join GKZ protocol, KAZRC report, effective date, author, reader and acceptance outcome.

04 | RELY

Scoped opinion

Commission CP work, validation, modelling and additional studies required by the asset.

Automation boundary: OCR, GIS-filtered structuring and predictive modelling may improve search, extraction and targeting. They are not evidence of automated reserve classification or code-compliant sign-off. K13 K14

Minimum Kazakhstan reliance package

Dated archive manifestScan, structure, OCR, georeference, access and QC status.
GKZ/KAZRC crosswalkDeposit, protocol, report, effective date and acceptance.
CP pool + QMR/reader capacityCP eligibility by commodity and method; QMR/reader availability, conflicts, backlog and lead time.
Scoped cost evidenceRetrieval, validation, modelling, drilling and modifying-factor work.

Coverage, clearance and retrieval

Archive access needs file-level evidence

Ukraine’s published figures describe different dates, collections and units. Scoping work on an asset requires an archive record connecting identifiers to clearance, retrieval, reuse rights and evidence available for professional reporting. U2

2019 audited baseline
55,631

Geological reports, occupying 167,416 storage units; 4,574 computer copies represented 8.2% of reports at that date. U1

2024 pilot delivery
6,000

UGS-reported digitised and mapped online; public availability was not independently verified. UGS described access as temporarily restricted, and NACP later found relevant data absent from the portal. U3 U5

Funded phase
60,000

UGS-reported 60,000-unit, EUR1.8m scope over 30 months; not a completed total. EBRD independently confirms the approved cooperation, not the amount. U4 U15

Archive-wide completion
Not established

The three measures cannot be added or converted into a current national percentage.

Legal change | 2025

Specified restrictions removed

SBU Order 207 deleted two nationwide secrecy-list provisions covering specified mineral-reserve and prospect information. U6 U7

File-level question

Clearance still must be mapped

Declassification does not establish that every underlying report is cleared, unrestricted or available for copying.

Commercial question

Publication rights are separate

Article 39 provides an inspection basis and applicant-funded digital copying, but not a demonstrated bulk-release or onward-publication right. U8

The professional route and its evidence

No Ukrainian National Reporting Organisation is listed by CRIRSCO. International professional routes remain available: UAG participates in the European Geologist process, and JORC recognises EFG at EurGeol grade, subject to person-specific experience, responsibility and consent. U11 U12 U13

Article 45 allows international standards at the applicant’s request. U9

What the automation evidence supports

DKZ guidance rejects direct mechanical translation from historical categories into CRIRSCO-family reporting. State structured-entry delivery and OCR/AI roadmaps do not establish a deployed system producing signed, code-compliant Resources or Reserves. U10 U5 U14

A Q2 2026 oversight record also found relevant digitised data absent from the portal, underscoring the distinction between scanning and usable access. U5

Separate state-led track: Ukraine’s 2025 UNFC-2019 classification reform is a separate state-led exercise. It is not evidence of CRIRSCO-family public reporting or portfolio-wide restatement. U16 U17
The extra Ukraine gate: before technical restatement can be scoped reliably, a user may need to establish what the archive contains, whether a file is cleared, whether it can be retrieved, and what reuse rights attach to it.

Minimum Ukraine reliance package

Archive manifestStable identifiers joined to report, book, page, scan, OCR and portal status.
Declassification & rights scheduleFile-level restrictions, clearance, copying and publication terms.
DKZ/reporting crosswalkState-balance entry, signed report, code, effective date and acceptance.
Eligible CP/QP rosterRecognised standing, commodity experience, availability, conflicts and lead time.

Scoping the next enquiry

Evidence to request before reliance

The country findings translate into six document and capability checks for scoping due diligence. They define evidence requirements; denominators, commodities and legal contexts remain insufficiently harmonised for a single country score.

Aletheia commercial usability framework: apply the same evidence states to every country - established, partial, not established - while keeping archive scale separate from commercial readiness.
01

Archive manifest

Can each report, volume and dataset be identified against a current denominator?

KZ: priority tranche bounded; archive-wide usability manifest needed.
UA: national denominator and reconciled series needed.

02

Rights & retrieval

Can a user obtain, copy and lawfully reuse the relevant material in predictable time?

KZ: test platform and retrieval performance.
UA: add file-level declassification and rights schedule.

03

Structured evidence

Are metadata, assays, collars, intervals, maps and models queryable and quality-controlled?

Both: scanning and OCR are inputs, not proof of analytical usability.

04

Reporting route

Is there a recognised code, acceptance mechanism and accountable professional route?

KZ: domestic KAZRC architecture established.
UA: international routes exist; domestic NRO absent.

05

Professional capacity

Are eligible professionals available by commodity and method, with known lead times?

Both: live capacity is not established by membership or historical snapshots.

06

Asset crosswalk & cost

Can state inventory, signed report, acceptance outcome and work programme be reconciled?

Both: no defensible national conversion percentage or restatement cost benchmark.

Investors

Scope validation and cost

Request asset identifiers, current signed reports and an inventory reconciliation. Test retrieval and data quality, then use scoped professional quotations to assess remaining work and timing.

Governments

Publish evidence of usability

Publish manifests, rights status, machine-readable schemas, retrieval service levels and deposit/report crosswalks. Build professional capacity alongside archive programmes.

Development institutions

Test usable delivery

Tie delivery assessment to sampled retrieval, extraction quality, publication rights and source lineage. Record completed pilot outputs and professional acceptance alongside document counts.

Kazakhstan: next diligence priorities

Archive structuring, performance-tested access, a dated GKZ/KAZRC deposit crosswalk and a live capacity map for CPs, QMR holders and readers.

Ukraine: next diligence priorities

A reconciled archive manifest, file-level declassification and reuse-rights mapping, tested portal access, then the reporting crosswalk and eligible CP/QP capacity.

Commercial reliance rests on a traceable asset record: identifiable source material, usable data, documented rights and reconciliation to a report signed by an eligible professional.

Evidence discipline

Scope, method and source register

Reading the evidence labels. Status describes support for the specific claim within the inspected record. An established report of delivery is not independent verification of that delivery. Source notes distinguish official or company reporting, independent audit and unresolved access or scope.

Method

This assessment of public evidence compares two Aletheia country briefs using the same commercial-usability questions. It connects reported progress to the records required for reliance. Kazakhstan sources were cut off on 4 September 2026; Ukraine sources on 6 September 2026.

“Established” means supported within the inspected public record. Reported delivery figures are not necessarily independently audited. “Not established” means not evidenced in that record, not proof that no unpublished activity exists.

Interpretation boundaries

Counts of units, reports, books, pages, deposits and accepted reports are not interchangeable. KAZRC report totals do not equal unique deposits. UNFC or national state-balance classifications do not equal CRIRSCO-family public reporting.

This is not a reserve estimate, legal opinion, investment recommendation or country ranking.

Read this comparison first; the Ukraine and Kazakhstan assessments provide full registers and case evidence.

For an example of the Aletheia system’s analytical output, see our internal screening assessment.

Selected sources cited in this brief

  1. K1. Government review: archive, Irgiz and geological works — Kazakhstan Prime Minister’s office.https://primeminister.kz/ru/news/reviews/poslanie-prezidenta-za-dva-goda-v-kazahstane-otkryto-54-novyh-mestorozhdeniya-31833Russian · 2 Sep 2026
  2. K2. Committee statement reported by DK News: 4,818,836 priority units — DK News.https://dknews.kz/ru/v-strane/399490-kazahstan-polnostyu-ocifroval-geologicheskiy-arhivRussian · 4 Aug 2026
  3. K3. Government Resolution No. 874.https://primeminister.kz/assets/media/prilozhenie-rus2.pdfRussian PDF · 23 Oct 2024
  4. K4. Committee algorithm for KAZRC state accounting.https://www.gov.kz/memleket/entities/geology/documents/details/874851?lang=ruRussian · 24 Jul 2025
  5. K5. State-accounting rules, consolidated text — SPINFORM legal-database copy.https://base.spinform.ru/show_doc.fwx?rgn=107851Russian
  6. K6. Kazakhstan admitted as CRIRSCO’s tenth member — SRK.https://www.srk.com/en/press-releases/criisco-welcomes-kazakhstan-as-10th-memberJun 2016
  7. K7. KAZRC Code, English version.https://mrmr.cim.org/media/1055/5110-kazrac-june-2016.pdfJun 2016 PDF
  8. K8. Ten years of KAZRC/PONEN; more than 380 reports — AGMP.https://agmp.kz/kazrc-i-ponen-desyat-let-sistemnyh-izmenenij/Russian · 16 Oct 2025
  9. K9. PONEN / MINEX 2023: reports, membership and CP snapshot.https://ponen.kz/en/news/press/perehod-na-standarti-kazrc--ozhidaniya-i-riski-minex-2023English · published 2 Apr 2024; figures at 1 Apr 2023 and end-2022
  10. K10. PONEN / MINEX 2025: reports, CP participation and QMR.https://ponen.kz/news/articles/ponen-at-minex-kazakhstan-2025-ethics-competence-and-implementation-oRussian · 22 Apr 2025
  11. K11. PONEN public member directory — 522 members displayed at evidence cut-off.https://ponen.kz/become-member/membersRussian · checked 4 Sep 2026
  12. K12. NGS chair on archive structuring and access — Inbusiness.kz.https://www.inbusiness.kz/ru/news/nacgeosluzhba-razrabotaet-eshe-odnu-bazu-geologicheskih-dannyhRussian · 27 Feb 2024
  13. K13. Ministry’s up-to-90% AI recognition claim — Kursiv.https://kz.kursiv.media/2025-04-09/zhnb-aigeoinform/Russian · 9 Apr 2025
  14. K14. Ministry AI participants, GIS-filtered structuring and planned outputs — Ministry of Industry and Construction.https://www.gov.kz/memleket/entities/mps/press/news/details/1196715?lang=ruRussian · 2026
  15. U1. Audit of state geological study and rational use of subsoil — Accounting Chamber of Ukraine.https://rp.gov.ua/storage/zvit-8-3-2019.pdfUkrainian · 9 Apr 2019; relevant archive figures at pp. 46-47
  16. U2. 2024 annual overview — State Service of Geology and Subsoil of Ukraine (UGS).https://www.geo.gov.ua/wp-content/uploads/presentations/ukr/annual-report-2024.pdfUkrainian · 2024 reporting year
  17. U3. 6,000 books of geological reports digitised and mapped online — UGS.https://www.geo.gov.ua/6000-knyh-heolohichnykh-zvitiv-otsyfrovano-y-rozmishcheno-onlayn/Ukrainian · 26 Apr 2024; agency-reported delivery and temporary access restriction
  18. U4. EUR1.8m, 60,000-unit digitisation programme — UGS.https://www.geo.gov.ua/en/ebrd-invests-e1-8-million-in-ukraine-to-digitise-geological-data/English · 17 Jun 2025; agency-reported scope and amount
  19. U5. State Anti-Corruption Programme measure 2.2.2.4.2 — NACP.https://dap.nazk.gov.ua/zahid/51/Ukrainian · Q2 2026 monitoring; status 13 Aug 2026
  20. U6. Order 207: amendments to the State Secrets List — Security Service of Ukraine.https://zakon.rada.gov.ua/laws/show/z0879-25Ukrainian · effective 11 Jun 2025
  21. U7. State Secrets List, SBU Order 383 — official legislation database.https://zakon.rada.gov.ua/laws/show/z0052-21Ukrainian · relevant 2025 amendment
  22. U8. Subsoil Code, Article 39: geological information — Verkhovna Rada of Ukraine.https://zakon.rada.gov.ua/laws/show/132/94-%D0%B2%D1%80Ukrainian · article as revised by Law 2805-IX of 1 Dec 2022; inspected 5 Sep 2026
  23. U9. Subsoil Code, Article 45: state expertise and assessment — Verkhovna Rada of Ukraine.https://zakon.rada.gov.ua/laws/show/132/94-%D0%B2%D1%80Ukrainian · article as revised by Law 2805-IX of 1 Dec 2022; inspected 5 Sep 2026
  24. U10. Guidance on applying the CRIRSCO Template classification — DKZ.https://www.dkz.gov.ua/files/normatyvno-pravova-baza/tverdi-goryuchi-ta-rudni-korysni-kopalyny/652d1f6a86f8e.pdfUkrainian · approved 27 Dec 2017
  25. U11. CRIRSCO members.https://crirsco.com/members/English · current roster checked 5 Sep 2026
  26. U12. European Geologist application procedure — European Federation of Geologists.https://eurogeologists.eu/application-procedure/English · checked 5 Sep 2026
  27. U13. Competent Persons and Recognised Professional Organisations — JORC.https://jorc.org/competent/English · current page; RPO list dated 15 Feb 2023
  28. U14. Big Data for applying AI in geology — UGS.https://www.geo.gov.ua/big-data-dlia-zastosuvannia-shtuchnoho-intelektu-v-heolohiyi/Ukrainian · 8 Oct 2024
  29. U15. Ukraine: reform and development of critical raw materials sectors, TCRS 15440 — EBRD.https://www.ebrd.com/home/work-with-us/projects/tcpsd/15440.htmlEnglish · disclosed 11 Feb 2025; confirms approved cooperation, not the EUR1.8m amount
  30. U16. Resolution 1197 amending the classification of mineral reserves and resources — Cabinet of Ministers of Ukraine.https://zakon.rada.gov.ua/go/1197-2025-%D0%BFUkrainian · 25 Sep 2025; effective 2 Oct 2025
  31. U17. UGS explanation of UNFC-2019 implementation — UGS.https://www.geo.gov.ua/oleh-hotsynets-zminy-do-klasyfikatsiyi-zapasiv-korysnykh-kopalyn-krok-do-intehratsiyi-ukrayiny-u-svitovu-systemu-upravlinnia-resursamy/Ukrainian · 14 Oct 2025
  32. U18. Shymanivske NI 43-101 Preliminary Economic Assessment — Black Iron Inc.https://blackiron.com/preliminary-economic-assessment-pea/English · effective 21 Nov 2017; amended report published Mar 2020
  33. U19. Full-year 2025 results and Mineral Resource and Reserve statement — Ferrexpo plc.https://www.ferrexpo.com/media/yo2jxkc3/ferrexpo-full-year-financial-results-for-2025-combined-for-website.pdfEnglish · 3 Sep 2026; balances at 1 Jan 2026

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