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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. K1K2
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. U1U3U5U9U10
Both countries
Per deposit
Reporting and acceptance depend on deposit-specific evidence and professional responsibility. Portfolio coverage requires a report-to-inventory crosswalk. K3K4K8U9U10
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.
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
Stage
Kazakhstan
Ukraine
1. Archive coverage
Large bounded delivery
4,818,836 priority units reported digitised; the denominator is the planned priority tranche, not every archival object. K1K2
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. U1U3U4U5U15
2. Usability & access
Post-scan work remains
Structuring, cataloguing, georeferencing and conversion to machine-readable form are identified as the next stage before investor use. K1K12
Access chain unresolved
Coverage, portal availability, file-level declassification, copying rights and machine-readable structure require reconciliation. U5U6U8
3. Reporting architecture
Domestic CRIRSCO framework
KAZRC and its professional architecture have operated since 2016; later rules define deposit-level state-accounting routes. K3K6K7
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. U9U11U12U13U16U17
4. Portfolio restatement
No national share
Accepted-report totals do not establish unique deposits or the share of the state balance restated. A GKZ/KAZRC crosswalk is missing. K4K8
No national share
Public JORC and NI 43-101 examples exist, but no national census or defensible restatement share was found. U18U19 DKZ guidance does not permit direct mechanical translation. U10
Dimension
Kazakhstan
Ukraine
Principal archive issue
Structuring and usability after scanning
Completion, access, declassification and structuring
Reporting/reconciliation route
Applicant-led and deposit-specific
Applicant-led and deposit-specific
National restatement programme
Not evidenced
Not evidenced
National conversion percentage
Not defensible
Not defensible
Professional capacity
Current eligible CP pool and QMR/reader capacity not established
Eligible CP/QP pool not established; eligibility remains person- and code-specific
Cost benchmark
Deposit-specific; no national restatement benchmark
Deposit-specific; no national restatement benchmark
Automation boundary
OCR, GIS-filtered structuring and predictive modelling evidence; not reserve conversion
Structured entry reported; OCR and AI remain roadmap-stage; no category conversion evidenced
Commercial diligence bottleneck
Crosswalk, usability and CP capacity
Archive/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. K1K2
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. K3K4K8
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. K3K4K5
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. K9K10K11
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
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. K13K14
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. U3U5
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. U4U15
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. U6U7
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. U11U12U13
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. U10U5U14
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. U16U17
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.
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
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
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