Critical minerals in Central Asia

Environmental, Social and Governance (ESG) considerations in Central Asia’s mining sector

Environmental considerations

Mining and processing are responsible for a range of environmental and sustainability challenges, including in Central Asia. Among them are land degradation, high greenhouse gas (GHG) emissions - some being hard-to-abate - water and air pollution, biodiversity loss and hazardous waste (Eurasianet, 2024[99]) (East Asia Forum, 2025[100]) (Global Voices, 2024[40]) (OECD, 2026[101]). Mining activities can also require intensive use of water resources, which is a challenge in regions already under severe water stress (The Times of Central Asia, 2025[102]). Central Asia has already experienced major environmental disasters such as the desiccation of the Aral Sea and is currently facing numerous environmental challenges, such as the receding levels of the Caspian Sea (OECD, 2025[94]), desertification (World Bank, 2023[103]) (UNCCD, 2023[104]) and glacier melt (France24, 2024[105]) (Jouberton, 2025[106]).

The detrimental impact of mining on sustainability creates a paradox at the core of Central Asia’s critical minerals agenda: net‑zero pathways rely on a rapid expansion of mining and processing to supply transition minerals, yet current practices are highly carbon‑ and resource‑intensive and can aggravate climate and environmental risks in an already fragile region. Central Asia aims to expand the supply of critical minerals for global industrial value chains, including those supporting the energy transition. However, mining and processing in the region remain highly carbon-intensive with weak environmental controls. Without major upgrades in decarbonisation, resource efficiency and waste/pollution management to international standards, these efforts risk contradicting the climate and sustainability goals they are meant to advance (Mining Digital, 2024[107]).

GHG emissions

State of play

Central Asia’s mining sector is emissions-intensive due to reliance on fossil fuels, ageing infrastructure and energy-intensive extraction and processing. Operations often depend on diesel-powered equipment and electricity-intensive processes, and many mines operate in remote or weak-grid locations. These characteristics are particularly relevant for “hard-to-abate” segments such as iron, aluminium and zinc in Kazakhstan, copper in Uzbekistan, and gold across the region.

Central Asian countries have adopted increasingly ambitious economy-wide climate targets. Kazakhstan has introduced explicit GHG reduction objectives for major mining and metallurgical enterprises under its 2024-2030 Action Plan for the Green Economy; and operates an Emissions Trading System (ETS), covering about 42.9% of national emissions (Kazenergy, 2023[108]; UNFCCC, 2025[109]). Uzbekistan has committed to a 30% reduction in emissions by 2030 and net-zero by 2055, and some large mining SOEs, such as Almalyk MMC (AMMC), are developing internal emission-reduction strategies (UNFCCC, 2025[110]). The Kyrgyz Republic’s updated Nationally Determined Contributions (NDCs) include industrial decarbonisation initiatives and GHG reduction targets, though mining is not explicitly targeted.

Challenges

Central Asian countries have adopted increasingly ambitious climate commitments, yet mining-specific decarbonisation policies remain limited across the region. Critical mineral development strategies tend to prioritise production expansion and value‑addition, with limited integration of climate objectives. Environmental impact assessment frameworks do not systematically account for GHG emissions from mining projects, and emissions from mining activities often do not require dedicated ecological permits. While Kazakhstan’s ETS is evolving and Uzbekistan is developing the legal basis for one, regulatory coverage remains incomplete, and the Kyrgyz Republic relies primarily on emission quotas rather than market‑based instruments (Adilet, 2023[111]) (Lex.uz, 2025[112]).

Water management

State of play

Central Asia faces significant water stress driven by transboundary dependence, inefficient water use and ageing infrastructure. Kazakhstan relies on external sources for around 44% of its surface water, while river flows have already declined by 27% due to climate change and rising demand in upstream countries (FAO, 2022[113]) (World Bank, 2024[114]). Uzbekistan depends on upstream inflows for nearly 80% of its water resources and could face a 30-40% decline in water availability in the coming decades (World Bank, 2024[115]) (World Bank, 2025[116]). Although the Kyrgyz Republic possesses relatively abundant water resources and plays a key role in supplying downstream countries, access to safe drinking water remains uneven domestically (The Times of Central Asia, 2025[117]) (World Bank, 2024[118]).

Kazakhstan, the Kyrgyz Republic and Uzbekistan have established regulatory frameworks governing water abstraction and wastewater discharge for industrial activities, including mining. In Kazakhstan, large-scale water abstraction projects require government approval, while water discharge from industrial facilities is regulated through environmental permits. In the Kyrgyz Republic, water use requires licences or concessions, and wastewater discharge must comply with strict pollution standards. Uzbekistan also regulates water abstraction through quotas based on technological needs and requires permits for both abstraction and discharge, applying the “polluter pays” principle to compensate for pollution.

Challenges

Despite these regulatory frameworks, national water management strategies rarely define mining-specific objectives or quantitative targets for water use, recycling or pollution reduction. Policy priorities often focus on other sectors, particularly hydrocarbons in Kazakhstan and irrigation in Uzbekistan, while environmental strategies in the Kyrgyz Republic do not include specific water-management targets for mining. As mining activity expands, particularly in the critical minerals sector, water demand could increase in already water-stressed contexts without clearer sector-specific objectives and monitoring mechanisms.

Mining waste and tailings management

State of play

Central Asia hosts numerous active and legacy mining waste and tailings storage facilities, many of which contain hazardous or radioactive materials. These sites are particularly concentrated in major mining regions of Kazakhstan, the Kyrgyz Republic and Uzbekistan, reflecting the long history of metal and uranium extraction in the region (Business and Human Rights Centre, 2022[119]) (The Times of Central Asia, 2024[120]). Poorly managed tailings pose significant environmental risks, including contamination of soil and water resources. As the development of critical mineral mining expands, the volume of mining waste is expected to increase, potentially exacerbating existing risks, particularly in areas vulnerable to heavy rainfall, landslides and seismic activity.

Central Asian governments have begun strengthening legal frameworks and policy planning related to mining waste and tailings management. Kazakhstan, the Kyrgyz Republic and Uzbekistan rely on environmental and subsoil legislation that regulates the storage, handling and disposal of mining waste, increasingly incorporating provisions for monitoring, safe storage and resource recovery. In Kazakhstan, mining residues must be stored in authorised sites and treated as potential secondary resources, and national planning documents include targets such as increasing industrial waste recycling to 50% by 2030 and reprocessing several mining-waste deposits. In the Kyrgyz Republic, legislation requires strict monitoring of tailings facilities, safe storage of hazardous and radioactive waste, and land reclamation financed through dedicated funds; national strategies also aim to secure legacy uranium tailings and conduct risk assessments of existing sites. Uzbekistan similarly requires waste-processing and recovery measures in mine closure plans and has introduced targets to rehabilitate land degraded by mineral extraction.

Challenges

Important gaps remain in the monitoring and reduction of mining waste across the region. Reliable data on hazardous mining waste treatment remain scarce, with Kazakhstan being the only country providing relatively recent official statistics, while comparable data are limited or unavailable in the Kyrgyz Republic and Uzbekistan. In addition, most national strategies focus on general waste management and environmental rehabilitation without establishing clear sector-specific targets for reducing unrecycled mining waste or increasing circularity in the mining sector. While Kazakhstan has introduced recycling targets and provisions for reprocessing mining waste, policy frameworks in the Kyrgyz Republic and Uzbekistan place greater emphasis on monitoring and safe storage rather than large-scale recovery of valuable materials from legacy tailings.

Social considerations

Labour rights

State of play

Central Asian governments have made tangible strides in advancing labour rights in their mining sectors, particularly through legislative updates, strategic frameworks and international alignments. Kazakhstan has updated its labour code to strengthen occupational health and safety provisions and launched the 2024–2030 Concept of Safe Labour, which aims to reduce workplace accidents common in the mining sector (World Bank, 2023[121]). In the Kyrgyz Republic, 2022 reforms aimed at expanding employment in the critical minerals sector also require employers to implement safeguards to protect workers’ life and health. Uzbekistan has acceded to several ILO conventions and substantially revised its labour code in 2023, while increasing funding for labour inspections and introducing digital safety monitoring systems in mines. At the same time, SOEs such as AMMC and NMMC have begun publishing non-financial reports that include information on workplace accidents (Business and Human Rights Resource Centre, 2025[122]).

Challenges

Yet, significant gaps remain in health and safety protection, labour rights frameworks and the effectiveness of grievance mechanisms. In Kazakhstan, industrial accidents and fatalities continue to occur, including the 2023 Kostenko methane explosion that killed 46 miners (The Diplomat, 2023[123]). Trade unions have raised concerns about possible under-reporting of workplace accidents, and collective bargaining and strike rights remain limited (World Bank, 2023[121]) (Human Rights Watch, 2025[124]). Migrant workers have also reported cases of discrimination, wage theft and coercion. In the Kyrgyz Republic, an estimated 10-15 mining fatalities annually point to ongoing safety challenges (World Bank, 2023[17]). Chinese companies operating in the Kyrgyz Republic have also been accused of discriminatory employment practices toward Kyrgyz workers (World Bank, 2023[17]). In Uzbekistan, labour rights concerns include restrictions on freedom of association and a gender pay gap estimated at 39% (OECD, 2025[125]). Workplace safety in the mining sector also remains a concern; at AMMC alone, authorities recorded 728 health and safety violations in early 2024, alongside reports of worker abuse and several fatal accidents.

Meaningful engagement of local communities

State of play

Central Asian governments have established legal frameworks requiring community involvement in mining projects. In Kazakhstan, environmental and subsoil legislation mandates Environmental Impact Assessments (EIAs), public consultations and hearings, and Community Development Agreements for projects near settlements (World Bank, 2023[126]). The Kyrgyz Republic requires mining companies to conclude social package agreements with local authorities and allows public review of EIAs (World Bank, 2023[17]). Uzbekistan has introduced provisions for early public consultations and Public Environmental Expertise hearings, while SOEs are required to provide grievance mechanisms and citizens can submit appeals through the national Ombudsman (Lex.uz, 2025[127]) (Uzbekistan Authorized Person of the Oliy Majlis for Human Rights, 2026[128]).

Challenges

Despite these provisions, implementation gaps remain in transparency, enforcement and the effectiveness of community participation in mining governance. In Kazakhstan, EIAs are not always fully disclosed and consultation processes may be poorly publicised, while Community Development Agreements are sometimes negotiated without direct community involvement (World Bank, 2023[126]) (OECD, 2025[125]). In the Kyrgyz Republic, concerns about corruption in licensing and tighter controls on civil society have weakened dialogue with communities (PWYP Kyrgyzstan, 2024[129]). Public EIA reviews remain advisory, and communities are often excluded from consultations after the initial approval stages, contributing to distrust toward some foreign companies (World Bank, 2023[17]). In Uzbekistan, consultation practices still fall short of international standards. Public Environmental Expertise hearings remain consultative, grievance mechanisms are uneven among private firms, and community influence in decision-making remains limited (Lex.uz, 2025[127]).

Governance and Responsible Business Conduct considerations

State of play

Central Asian governments have begun to introduce Responsible Business Conduct (RBC) and sustainability standards in their mining sectors through international commitments, national strategies and enterprise‑level initiatives. Kazakhstan has adhered to the OECD Declaration on International Investment and Multinational Enterprises and the OECD Guidelines for Multinational Enterprises on RBC, and established a multipartite National Contact Point supporting a National Action Plan on Business and Human Rights (OECD, 2025[130]) (OECD, 2026[131]). The country also participates in transparency and international co-operation initiatives such as the Extractive Industries Transparency Initiative (EITI) and the Forum on Resource Geostrategic Engagement (FORGE) (OECD, 2018[132]) (EITI, 2025[133]) (US Dept of State, 2026[134]). The Kyrgyz Republic has demonstrated commitment to transparency through early EITI adoption and disclosure of production and revenue data (EITI, 2024[135]), while Uzbekistan has strengthened anti‑corruption and SOE governance frameworks (Ministry of Investment, Industry and Trade of the Republic of Uzbekistan, 2026[136]) (OECD, 2025[125]). Across the three countries, some major mining and metallurgical companies are voluntarily undergoing international assurance processes and introducing ESG roadmaps, due diligence systems and reporting that can progressively raise expectations for responsible mineral supply chains in the wider region.

Challenges

Perceptions of opacity and corruption, as well as the predominant role of SOEs, continue to weigh on mining governance and investment attractiveness in Central Asia. In Kazakhstan, corruption risks persist in public administration, procurement and large infrastructure projects, including cases of illegal granting of mining rights, gaps in lobbying regulation and weaknesses in enforcement mechanisms. SOE dominance through Samruk-Kazyna and Tau-Ken Samruk, combined with ministries that both own and regulate companies, creates potential conflicts of interest and risks of competitive distortions (OECD, 2025[137]; OECD, 2024[138]) (World Bank, 2023[121]). In the Kyrgyz Republic, anti-corruption frameworks exist but enforcement remains uneven, while increased state participation in the mining sector following the nationalisation of Kumtor has raised concerns about transparency and investor confidence (World Bank, 2022[139]). In Uzbekistan, some large contracts are reportedly awarded to offshore-linked companies. A 2024 assessment of AMMC also identified significant gaps in RBC practices, particularly in supply-chain due diligence, including difficulties in identifying high-risk suppliers and countries of origin or transit (The CopperMark, 2026[140]).