AUGUST 01, 2025

Mining Investment Registry

CIRCULARS

Mining Department Report | Mining Investment Registry.

On July 23, 2025, Resolution 59/2025 of the Ministry of Mining was published in the Official Gazette, replacing the annex to Resolution 30/2018 of the former Secretariat of Mining Policy, previously replaced by Resolution 21/2023 of the Ministry of Mining (the “Annex“). The Annex regulates the procedure for registration in the Mining Investment Registry created by Law No. 24,196 on Mining Investments (the “LIM” for its acronym in Spanish), as well as the conditions for the maintenance, modification, suspension, and deregistration of said registry. Resolution 59/2025 entered into force as of its publication and is applicable to the procedures in progress on that date.

The main modifications are detailed below:

1-Affidavits: Deadlines, Content and Regularization

-Resolution 59/2025 clarified that the works and investments that must be reported through the affidavit required by Article 25 of the LIM are those projected for the year corresponding to the year of their submission.

-The failure to submit, or the late submission of, the affidavit under Article 25 of the LIM for years prior to 2024 will be deemed remedied if the affidavit under Article 18 of the LIM (reporting actual works and investments carried out) for the relevant or corrected period has been filed.

-The annual affidavit related to tax stability must be submitted by March 31 of the year following the end of the declared fiscal year. This deadline aligns with the deadline to file the affidavit under Article 25 of the LIM.

-Resolution 59/2025 clarified that those registered as mining producers or developers who also provide mining services as a secondary activity are not required to submit the affidavit of article 10 of the Annex (which certifies that at least 60% of total turnover relates to mining services).

2-Registration, Modification and Cancellation Procedure

-Decision-making authority over applications for registration, modification, and deregistration in the Mining Investment Registry is assigned to the National Directorate of Mining Investments (Dirección Nacional de Inversiones Mineras or “DNIM”). The scope of the DNIM’s authority varies by case, and in some instances, it is granted full decision-making powers.

-The option to accredit mining rights through an affidavit expressing an intention to obtain formal mining titles in the future is eliminated.

-For mining service providers that maintain essential equipment for mining operations, the requirement to submit contracts or other documents evidencing continuity or the non-occasional nature of the service is removed.

-The information required to access the VAT refund regime may now be included in the registration application.

-Deadlines previously imposed on the DNIM to issue decisions on registration, modification, or deregistration requests have been eliminated.

-The requirement for prior registration with the former RUMP is also removed.

3-Suspension and Removal from the Mining Investment Registry

-The consequences of failing to file the annual affidavits are modified. For example, (a) failure to submit all the affidavits under Article 9 for two consecutive years may result in ex officio deregistration; (b) a new cause for deregistration consisting of the non-existence of declared mining projects is incorporated; and (c) these powers will be exercised by the Ministry of Mining through the DNIM.

-The sanctioning regime applicable to mining service providers is modified. For example, (a) it is no longer sanctioned not to comply with the minimum turnover of 60% and it is now sanctioned not to file the affidavit and not to prove compliance with the minimum turnover; (b) the fine is eliminated as a “sanction” applicable in these cases, maintaining only the suspension and deregistration from the Mining Investment Registry; and (c) the DNIM is granted authority to order the suspension and deregistration of those registered who do not comply with said requirement.

Alejandro Poletto

Manuel Frávega

Juan Pablo Perrino