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In brief. The Additional Minerals Reporting Template (AMRT), maintained by the Responsible Minerals Initiative (RMI), is not a one-time submission. RMI released AMRT v1.31 on 17 April 2026 and expects v1.4 in autumn 2026. Most downstream customers now request an AMRT refresh annually, with event-driven updates in between. Regilient tracks template version alignment, supplier response status, and product-to-mineral mapping in a single AMRT workflow.
Why one-time AMRT is a myth
Most compliance teams treat their first AMRT submission like a milestone. The customer asked, you responded, the file is filed. Six months later a different customer asks for the same minerals with a slightly different scope, and the original response no longer fits.
That is not a documentation problem. It is a cadence problem. AMRT sits on the same calendar rhythm as CMRT and EMRT, and the answers behind it (which smelters, which sourcing regions, which minerals in scope) change faster than most suppliers assume.
This guide covers what actually forces AMRT updates, how RMI's own release schedule feeds into your cycle, and the review discipline that keeps responses defensible when a customer, an auditor, or an investor starts asking harder questions.
What is AMRT?
The Additional Minerals Reporting Template (AMRT) is a free, standardised due-diligence tool developed by the Responsible Minerals Initiative (RMI) for supplier reporting on minerals outside the scope of CMRT and EMRT. It was launched on 11 November 2022 as the Pilot Reporting Template (PRT), rebranded to AMRT in October 2024, and now sits at version 1.31, released on 17 April 2026.
- Scope: Any mineral not covered by CMRT (tin, tungsten, tantalum, gold) or EMRT (cobalt, mica, copper, natural graphite, lithium, nickel). Users define the mineral set and can input up to ten minerals per template.
- Governance: Maintained by RMI. Aligned to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
- Legal status: AMRT itself is voluntary. The underlying due-diligence expectations arrive through customer scorecards, ESG disclosure regimes, and emerging critical-minerals regulation such as the EU Battery Regulation.
Because scope is user-defined, no two AMRT responses look identical, and no submission expires on a public schedule. The clock is set by RMI's template releases and by your customers, not by a regulator.
How often RMI updates AMRT
RMI updates AMRT on a roughly annual cadence, sometimes twice in a year. Version 1.2 arrived on 4 October 2024, v1.3 on 17 October 2025, and v1.31 on 17 April 2026. Version 1.4 is expected in autumn 2026.
Each release changes something practical: smelter reference lists, ISO country codes, declaration-tab fields, or product-list columns. AMRT v1.31 alone refreshed the Standard Smelter List, standardised ISO short names for countries and provinces, and fixed a date-input handling issue on the Declaration tab.
The operational consequence is that a supplier who responds on an older template is submitting a technically valid file that no longer matches the customer's current data model. Downstream teams flag mismatched fields, drop responses into a rework queue, and ask for a re-submission on the current version.
Three practical rules follow:
- Use the RMI-recommended version for the reporting year. As of mid-2026, that is AMRT v1.31 or higher.
- Do not accept supplier responses on templates more than one version behind without a rework plan.
- Track version alignment centrally, not survey-by-survey.
The four triggers that force an AMRT refresh
Regulation is not the trigger. Change inside your product, your supply base, and your customer's expectations is the trigger. Four categories cover almost every real case.
Product changes. New product introductions, redesigns, battery-chemistry changes, and material substitutions all shift the mineral profile of what you ship. An AMRT response tied to last year's bill of materials becomes silently wrong the moment a component is re-sourced.
Supplier changes. Added or replaced suppliers, sourcing shifts across regions, and Tier-2 or Tier-3 changes can invalidate prior assumptions even when your Tier-1 list looks stable. AMRT is only as accurate as the last supplier survey behind it.
Portfolio changes. Mergers, acquisitions, and business-unit consolidations expand scope. What was a narrow response covering one product family suddenly needs to cover three, and the original submission was never structured for that.
Customer programme maturity. Even without internal change, downstream customers expand their ESG programmes year over year. Scorecards evolve, reporting depth increases, and the same customer who accepted a partial response last year now expects full smelter-level coverage this year.
Self-assessment worth running now: how many of these triggers has your organisation seen in the last twelve months, and how many of them prompted an AMRT refresh? If the gap is more than one, your response has drifted.
The AMRT review cycle that actually works
There is no legal schedule for AMRT. In practice, a defensible cycle combines four review types:
- Annual scheduled review. Refresh the response every reporting year against the RMI-recommended template version. This is the baseline, and it aligns AMRT with the CMRT and EMRT calendars most teams already run.
- Event-driven review. Trigger a partial refresh whenever a product, supplier, or portfolio change hits the trigger list above. This prevents silent drift between annual cycles.
- Comparative review. When a customer benchmarks your response against peer suppliers, re-verify smelter coverage and sourcing narrative before responding. Comparative reviews are where inconsistencies get exposed publicly.
- Targeted review. When an inconsistency is flagged between two customer submissions, reconcile the underlying data before either response goes out again.
Most programmes struggle here because AMRT lives outside the CMRT workflow. It is treated as a bespoke request, not an operational cycle. The result is duplicate outreach to the same suppliers, contradictory answers across submissions, and no version control on what the current response actually says.
Regilient's AMRT compliance software tracks template version alignment, supplier response status, and product-to-mineral mapping in a single view, so the four review types run on shared data rather than parallel spreadsheets.
Manual process vs an automated AMRT workflow
Requirement | Manual process | Regilient |
|---|---|---|
Template version tracking | Check RMI portal each cycle; re-issue surveys if version drifts | Automated version detection; supplier surveys always issued on the RMI-recommended release |
Supplier data collection | Email chains, PDF attachments, ad hoc reminders | Structured supplier portal with response tracking and reminder logic |
Change detection | Human review of prior responses against new BoMs | Automated diff against prior AMRT baseline and BoM changes |
Smelter validation | Manual cross-check against RMI Standard Smelter List | Live validation against the current RMI smelter reference list |
Historical context | Spreadsheet archive; often lost across team changes | Persistent audit trail per response, per supplier, per version |
Customer request handling | Rebuilt from scratch each time | Pre-approved response set filtered to the customer's specific mineral scope |
What proactive AMRT programmes get right
Suppliers who run AMRT well share three habits. They accept recurrence early and treat AMRT as a recurring workflow, not a one-off. They define update triggers in advance, so refreshes are scheduled rather than scrambled. And they retain historical context so responses stay consistent across cycles rather than contradicting each other.
The operational cost of getting this right is far lower than the reputational cost of getting it wrong. A late or inconsistent AMRT response signals to a downstream customer that the underlying supply-chain data is unreliable, which is a much harder problem to fix than a version mismatch.
Regilient's AMRT compliance software supports supplier outreach, template version alignment, smelter validation, and response history in a single AMRT workflow, so annual and event-driven reviews run on shared data rather than being rebuilt from scratch each cycle.
Regilient provides agentic sustainability software for product compliance, supplier engagement, and regulatory intelligence across REACH, RoHS, PFAS, CMRT, SCIP, CBAM, and global chemical regulations.
