#2025-851Decree No. 2025-851 of August 27, 2025, on Mining Titles and Underground Storage Titles
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The decree establishes regulations concerning mining titles and underground storage titles in France, focusing on the exploration and exploitation of mineral substances including hydrocarbons. It outlines the application process for obtaining research permits and concessions, requirements for technical and financial capabilities, environmental considerations, and the establishment of monitoring commissions to oversee adherence to safety and environmental standards throughout the project lifecycle. The decree emphasizes the necessity for public consultations and environmental assessments when applying for these titles and establishes mechanisms for addressing potential conflicts with existing mining operations.
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Key Changes
- Introduction of detailed requirements for technical and financial qualifications of applicants for mining and storage permits.
- Establishment of monitoring commissions to oversee compliance with environmental and safety regulations.
- Increased public consultation and participation in the permitting process.
Obligations
What this law requires
All applicants for mining or underground storage titles must submit technical capability documentation including: (1) titles, diplomas and professional references of company executives responsible for work conduct and monitoring; (2) list of exploration/exploitation work completed within the last 10 years with summary descriptions of major projects; (3) description of human and technical resources for execution and monitoring; (4) firm commitments from third parties if relying on their resources, accompanied by relevant documentation.
All applicants for mining or underground storage titles must submit financial capability documentation including: (1) annual accounts for the last three years or alternative appropriate proof; (2) off-balance sheet commitments, guarantees, collateral provided, pending litigation and financial risk evaluations; (3) guarantees and collateral received plus third-party participation commitments with supporting documentation.
Applicants seeking research permits (permis exclusif de recherches) must submit an environmental, economic and social memorandum (mémoire environnemental, économique et social) as provided in Article L. 114-2 of the mining code, including an environmental component with elements specified in Article R. 122-20 of the environmental code.
Applicants seeking concessions must submit an environmental, economic and social feasibility study (étude de faisabilité environnementale, économique et sociale) as provided in Article L. 114-2 of the mining code, including an environmental component with elements specified in Article R. 122-20 of the environmental code.
Applications concerning substances of atomic energy interest must be submitted to the Atomic Energy Committee (Comité de l'énergie atomique) for opinion within one month; failure to issue an opinion within this deadline results in a deemed favorable opinion.