Opening the July 2026 session of the International Seabed Authority Council, Secretary-General Leticia Carvalho called for deep-seabed rules that are “science-based, implementable and enforceable.” She also made an important distinction:
Regulations alone do not make a governance system.
Leticia Carvalho, Secretary-General of the International Seabed Authority, July 2026
Her statement goes to the heart of the ISA’s work on the Mining Code. Environmental obligations must be legally robust, but they must also be capable of being translated into operating plans, monitoring programmes, decision criteria and regulatory follow-up.
The challenge is therefore not only to agree on environmental requirements. It is to ensure that those requirements can be applied, verified and enforced before any commercial exploitation is allowed to begin.
The Secretary-General’s opening remarks to the Council provide a timely starting point for considering how this could be achieved.
From principles to practical requirements
The draft exploitation regulations remain under negotiation. At the conclusion of the July session, the Council reiterated that commercial exploitation should not take place without the necessary rules, regulations and procedures. It requested a new roadmap and an advanced negotiating text to support further work (Council Decision ISBA/31/C/38).
The remaining issues include environmental goals and objectives, environmental threshold values, standards and guidelines, and arrangements for inspection, compliance and enforcement. These are not separate regulatory subjects. Together, they must form a connected system.
A general requirement to protect the marine environment provides direction, but it does not by itself establish what a contractor must do during planning and operations. Operationalisation requires clear responsibilities, environmental objectives, monitoring parameters, data-quality requirements and defined responses when results differ from predictions or exceed agreed thresholds.
What ISO 14001:2026 can contribute
ISO 14001 does not determine whether deep-sea mining should proceed. Nor does it establish acceptable environmental impacts or scientifically valid thresholds. These matters must be decided through UNCLOS, the Mining Code and decisions of ISA Member States.
The recently published ISO 14001:2026 can nevertheless provide useful management-system guidance. The revised standard places greater emphasis on environmental context, biodiversity, leadership accountability, management of change, value-chain oversight and measurable environmental performance.
Its relevance lies in the connection between requirements and evidence. Environmental objectives should be measurable. Operational controls should address identified risks and compliance obligations. Monitoring should establish whether controls are effective. Audits and management reviews should consider actual performance, while non-conformities should result in corrective action and verified improvement.
Applied to the Mining Code, these principles could strengthen the relationship between Environmental Impact Statements, Environmental Management and Monitoring Plans, contractor management, operational controls, monitoring data and regulatory decisions.
ISO provides a framework for asking whether these elements work together. It does not provide the environmental rules themselves.
Responding to environmental concerns
Environmental organisations continue to raise fundamental concerns about limited scientific knowledge, biodiversity loss, cumulative impacts and uncertainty about the ability of deep-sea ecosystems to recover.
During the July session, WWF called for a global moratorium. The Deep Sea Conservation Coalition’s recommendations similarly called for a precautionary pause or moratorium, citing environmental, social, economic and geopolitical risks.
ISO 14001 cannot resolve these objections or substitute for scientific evidence and political decisions. It can, however, help address concerns that environmental commitments may remain too general, difficult to enforce or disconnected from operations.
Its principles could support stronger requirements for independent audits, contractor and supplier oversight, transparent monitoring, management of operational changes and evidence that corrective actions are effective. Monitoring results could be linked more clearly to decisions to modify, suspend or stop an activity.
This would allow regulators, Member States and other stakeholders to see not only what a contractor has promised, but what has been implemented, what the data show and how the contractor and the ISA respond when performance differs from expectations.
Building a system capable of implementation
The Secretary-General also emphasised the importance of standards and guidelines in carrying the regulations into practice. These technical instruments can evolve as science, technology and good practice develop.
Her remarks at the Sustainable Seabed Knowledge Initiative event reinforced the importance of scientific evidence, international cooperation and access to deep-sea data. These elements will be essential if environmental controls and monitoring requirements are to remain relevant as knowledge develops.
The Mining Code must therefore provide more than a set of environmental obligations. It must establish a traceable chain from environmental goals and impact assessment to operational controls, monitoring evidence, compliance evaluation and regulatory response.
ISO 14001:2026 cannot supply the content of that chain. It can provide a useful test of whether the individual elements are connected and capable of producing measurable, auditable and enforceable environmental performance.
Bruncell Larsen Strategic Advisory supports organisations in translating regulatory and environmental requirements into practical management arrangements, assurance activities and compliance evidence. If you would like assistance in assessing whether environmental requirements are effectively integrated into a project or operational framework, please contact me.
