The Department of Mineral and Petroleum Resources (DMPR) has issued a significant new guideline that will reshape how mining companies approach organisational change. Published on 20 June 2025 and effective from 1 October 2025, the guideline introduces a mandatory Code of Practice (COP) on change management. This development marks a critical compliance milestone for all mining operations in South Africa.
Key aspects
Critical compliance requirement:
All mining employers must implement a change management COP by 1 October 2025. Failure to comply will constitute a breach of the Mine Health and Safety Act (MHSA).
Scope:
The guideline addresses significant health and safety risks associated with organisational change across all areas of mining operations. The changes covered include operational, structural, regulatory, market-driven, and cultural transformations. The framework accommodates both traditional and innovative approaches, and allows employers to implement established methodologies such as MOC, SATCAP, or Prosci.
Implementation requirements
Leadership structure:
Mining companies must establish robust governance frameworks with clearly defined accountability structures. Key requirements include:
- Senior leadership accountability: A senior leader must be specifically designated to oversee change management at the mine.
- Governance structure: A tailored governance framework must be implemented to oversee and support change initiatives.
- Defined roles and responsibilities: The roles of all stakeholders must be clearly documented and communicated.
Training:
Comprehensive training programmes must be implemented for all personnel involved in change management. Employers are required to ensure ongoing competence through continuous professional development and to invest in building a capable workforce equipped to manage and lead change effectively.
Risk management integration:
The change management processes must be integrated with existing MHSA risk assessment frameworks. The COP must clearly set out how material risks identified during the change process will be managed, following the hierarchy of risk control, namely: elimination, control at source, minimisation, and use of personal protective equipment.
Key takeaways for employers
Immediate action required:
Mining operations must develop and implement a compliant change management COP by 1 October 2025.
Compliance considerations:
The COP must be developed in consultation with health and safety structures and employee representatives. Drafting committees should be established as a matter of urgency, with appropriate representation across employee levels.
Ongoing obligations:
Employers must establish processes for ongoing monitoring, auditing and evaluation of the COP. All employees must be made familiar with the parts of the COP relevant to their roles and responsibilities.
This regulatory development reflects a broader shift in the mining industry towards more sophisticated risk management practices. Employers should not view the new change management COP merely as a compliance requirement, but rather as an opportunity to embed operational resilience and strengthen their strategic positioning in an increasingly dynamic operating environment.
