Precious Metals Due Diligence: Your 2026 Obligations
The regulatory framework around precious metals is tightening considerably. Between the European conflict minerals regulation, anti-money laundering directives, and new duty of care requirements, due diligence obligations are becoming unavoidable for all jewelry industry players.
This guide details your current and upcoming obligations, with concrete processes to implement to remain compliant.
The 2026 Regulatory Framework
Overview of Regulations
| Regulation | Scope | Entry into force | Jewelry impact |
|---|---|---|---|
| EU Regulation 2017/821 | Conflict minerals | 2021 | High if direct import |
| AMLD 6 | Anti-money laundering | 2021 | High (gold transactions) |
| CSRD | Sustainability reporting | 2024-2026 | Medium to high |
| CS3D (Due Diligence) | Value chain | 2026-2027 | High |
| Deforestation regulation | Forest products | 2024 | Low |
The Conflict Minerals Regulation (2017/821)
Who is affected? EU importers exceeding annual thresholds:
- Gold: 100 kg
- Tin: 5,000 kg
- Tantalum: 100 kg
- Tungsten: 1,000 kg
Main obligations
- Responsible sourcing policy
- Supply chain due diligence
- Third-party audits
- Annual reporting
In practice for jewelry Most jewelers don't import directly. But if you buy from refiners or dealers, request proof of their compliance.
Anti-Money Laundering Directives (AMLD)
Who is affected? All high-value goods dealers, including gold trade professionals.
Main obligations
- Customer identification (KYC)
- Enhanced vigilance for unusual transactions
- Document retention
- Suspicious activity reporting if necessary
Vigilance thresholds
| Transaction | Obligation |
|---|---|
| Any gold transaction | Traceability |
| Over EUR 10,000 cash | Declaration |
| Over EUR 15,000 | Enhanced identification |
| Suspicious transaction | Suspicious activity report |
The Due Diligence Directive (CS3D)
Application timeline
| Date | Companies affected |
|---|---|
| 2027 | Over 5,000 employees and revenue over EUR 1.5B |
| 2028 | Over 3,000 employees and revenue over EUR 900M |
| 2029 | Over 1,000 employees and revenue over EUR 450M |
Key obligations
- Identify potential negative impacts on human rights and environment
- Implement prevention and mitigation measures
- Establish a complaints mechanism
- Communicate publicly
Even if you're not directly affected, your large corporate customers will ask you for proof of compliance.
Due Diligence Principles
The OECD Framework
The OECD has established a reference framework for minerals due diligence:
The 5-step process
| Step | Description | Actions |
|---|---|---|
| 1. Management systems | Establish structures | Policy, organization, resources |
| 2. Risk identification | Map the chain | Supplier analysis, risk zones |
| 3. Mitigation | Reduce identified risks | Action plans, supplier engagement |
| 4. Independent audit | External verification | Third-party audit |
| 5. Reporting | Communicate publicly | Annual report |
Risks to Identify
Due diligence must cover several risk categories:
Human rights risks
- Forced or child labor
- Dangerous working conditions
- Financing of armed conflicts
- Population displacement
Environmental risks
- Water and soil pollution
- Deforestation
- Use of toxic products (mercury)
- Impact on biodiversity
Governance risks
- Corruption
- Money laundering
- Tax fraud
- Smuggling
High-Risk Zones
Certain geographic origins present elevated risks:
| Region | Main risks |
|---|---|
| Democratic Republic of Congo | Conflict, forced labor |
| South America (artisanal mines) | Mercury, informal labor |
| West Africa | Laundering, informal |
| Southeast Asia | Traceability, documentation |
For these origins, enhanced due diligence is necessary.
Implementing Your Process
Step 1: Establish the Policy
Draft a written responsible sourcing policy:
Essential elements
- Management commitment
- Scope (which materials, which suppliers)
- Unacceptable risks
- Decision process
- Responsibilities
Model structure
1. Introduction and commitment
2. Scope
3. Sourcing principles
4. Non-tolerated risks
5. Due diligence process
6. Governance and responsibilities
7. Review and improvement
Step 2: Map the Chain
Identify all actors in your supply chain:
Level 1: Direct suppliers
- Refiners
- Metal dealers
- Stone wholesalers
Level 2: Your suppliers' suppliers
- Mines / operations
- Collectors
- Intermediate processors
Information to collect
| Information | Level 1 | Level 2 |
|---|---|---|
| Identification (name, address) | Mandatory | If possible |
| Certifications (RJC, LBMA) | Mandatory | Desirable |
| Declared material origin | Mandatory | Mandatory |
| Available audits / reports | Request | If available |
Step 3: Assess Risks
For each supplier, assess the risk level:
Assessment grid
| Criterion | Low risk | Medium risk | High risk |
|---|---|---|---|
| Certification | RJC CoC / LBMA | RJC COP | None |
| Declared origin | Safe zones | Mixed | Risk zones |
| Transparency | Complete | Partial | Low |
| Track record | No incidents | Minor incidents | Major incidents |
Classification
- Low risk: Standard monitoring
- Medium risk: Enhanced engagement
- High risk: Immediate action or disengagement
Step 4: Act on Risks
For each identified risk, define measures:
Low risk
- Maintain relationship
- Annual monitoring
- Documentation retention
Medium risk
- Request clarifications
- Require improvement plan
- Quarterly monitoring
- Visit or audit if possible
High risk
- Suspend purchases
- Require immediate corrective measures
- Consider disengagement
- Document reasons
Step 5: Document and Retain
Documentation is crucial in case of inspection:
Documents to retain
| Document | Retention period |
|---|---|
| Purchase invoices | 10 years |
| Certificates of origin | 10 years |
| Risk assessments | 5 years |
| Supplier correspondence | 5 years |
| Audit reports | 5 years |
| Policy and procedures | Current version + history |
Step 6: Report and Communicate
Depending on your size and obligations:
Internal reporting
- Annual process review
- Monitoring indicators
- Improvement actions
External reporting
- Sustainability report (if CSRD)
- Website communication
- Responses to customer questionnaires
Due Diligence Tools
Recognized Certifications
| Certification | Issuer | Coverage | Recognition |
|---|---|---|---|
| RJC Chain of Custody | RJC | Gold, PGM, diamonds | Very high |
| LBMA Good Delivery | LBMA | Gold, silver | Very high |
| Fairmined | ARM | Artisanal gold | High |
| Swiss Better Gold | SBGA | Gold | High |
In practice: Prioritizing certified suppliers significantly reduces the due diligence burden.
Supplier Declarations
Ask your suppliers to complete declarations:
Typical content
- Material origins
- Risk commitments
- Held certifications
- Possible subcontractors
Frequency
- Annual for regular suppliers
- At each new relationship
- At any significant change
Audits
For medium or high-risk suppliers:
Audit options
- Remote documentary audit
- On-site visit
- Third-party audit
- Participation in group audit
Indicative cost
- Documentary audit: EUR 500-1,500
- On-site visit: EUR 2,000-5,000
- Complete certified audit: EUR 5,000-15,000
Penalties for Non-Compliance
Regulatory Sanctions
| Violation | Potential sanction |
|---|---|
| Conflict minerals non-compliance | Fine + import ban |
| Money laundering | Criminal sanctions, closure |
| CS3D non-compliance | Fine up to 5% of revenue |
| Traceability failure | Product recall, fine |
Commercial Risks
Beyond legal sanctions:
- Loss of contracts with major clients
- Reputation damage
- Exclusion from certain markets
- Difficulty obtaining insurance
Recommended Action Plan
If Starting from Zero
Months 1-2: Foundations
- Appoint a due diligence manager
- Draft sourcing policy
- List all metal/stone suppliers
Months 3-4: Assessment
- Collect supplier information
- Assess risks
- Identify priorities
Months 5-6: Action
- Address high risks
- Implement regular monitoring
- Train relevant teams
If You Already Have Basics
Annual review
- Update supplier mapping
- Reassess risks
- Address new risks
- Improve processes
How LIINK Facilitates Due Diligence
LIINK includes useful features for compliance:
Lot traceability Each material lot is tracked from receipt to use, with history retention.
Centralized documentation Supplier certificates, origin declarations, and compliance documents are stored and accessible.
Complete history In case of inspection, find all movements and exchanges related to an order.
Conclusion: Due Diligence as Standard
Due diligence on precious metals is no longer an option reserved for large houses. It's a growing legal obligation and market expectation.
But beyond the constraint, it's also:
- Protection against reputational risks
- A commercial argument for demanding customers
- A contribution to a more responsible sector
Better to anticipate than endure.
Further Reading
- RJC Certification: The Complete 2025 Guide for Responsible Jewelry
- Gold Traceability in Jewelry: From Ingot to Finished Piece
- Precious Materials Stock Valuation in Jewelry
Need to structure your materials traceability? LIINK helps you document and track your supplies. Discover LIINK