Social protections overlooked in Mongolia–UK critical minerals cooperation www.eastasiaforum.org
In June 2025, Mongolia and the United Kingdom announced a strategic roadmap on critical minerals cooperation. The agreement, concluded soon after the countries marked 60 years of diplomatic relations, sets out an ambitious plan to collaborate on the exploration, extraction and processing of critical minerals.
Yet the plan risks moving ahead with limited regard for Mongolia’s weak environmental and social protections, particularly for the rights and livelihoods of herders.
The partnership aligns closely with the UK Critical Minerals Strategy and Mongolia’s efforts to diversify beyond coal to ensure economic stability. For the United Kingdom, supply of critical minerals is considered a national security issue that cannot be fulfilled entirely by domestic production.
Mongolia is a source of at least 11 critical minerals, including copper, fluorspar, graphite, rare earth elements and lithium. Currently, the gold and copper mega mines in Omnogovi Province, Oyu Tolgoi, operated by Rio Tinto, represent the largest investment and operation of a UK company in Mongolia.
The initiative to advance a critical minerals partnership was preceded in 2024 by the confirmation of a Memorandum of Understanding (MOU) on critical minerals after diplomatic visits in 2023. The MOU outlines the intent to partner on surveying critical mineral resources, promoting trade partnerships and ‘upholding Environmental, Social and Governance standards and promoting transparency initiatives’. Likewise, the 2025 UK’s Critical Minerals Strategy includes direct reference to the importance of ensuring ‘responsible and transparent supply chains’, including ‘greater adoption of responsible business practices that protect the local environment and surrounding communities’.
These developments appear to ignore the Mongolian government’s poor record of environmental and social governance in the extractives sector. Mongolia’s mining sector currently lacks clear regulations or implementation of internationally recognised mechanisms for social safeguarding practices.
In 2024, a World Bank report raised concerns that Mongolia lacks comprehensive legislation on land acquisition, land-use restrictions and involuntary resettlement, and that legal inconsistencies produce inequitable outcomes for affected citizens. Social impact assessments are currently done on a voluntary basis. They are usually based on investor standards required by entities like the International Finance Corporation and European Bank for Reconstruction and Development, which have invested in only a minority of mining operations.
The vast majority of over 2700 mineral licenses issued across Mongolia do not account for local impacts or include coherent processes to restore livelihoods, establish grievance mechanisms or share information with affected communities. In February 2023, the Mongolian government issued Decree Number 58, requiring the designated ministry to finalise regulations on social impact assessment. Yet this process has stalled for over two years, with no progress towards requiring or implementing social impact assessment standards in national law.
Since 2020, UN human rights mechanisms have repeatedly identified Mongolia’s poor record in protecting herder rights due to the expansion of mineral extraction industries on pastoral land. In the 2020 Universal Periodic Review report for Mongolia, the UN Office of the High Commissioner of Human Rights expressed concerns that nomadic herders’ rights to their pasture, hay land and water resources were continuously infringed upon due to mining activities on their traditional lands. Herders’ free, prior and informed consent was not obtained, while compensation to herders affected by extractive industry projects was inadequate.
In a 2022 report, the UN Economic and Social Council called for ‘effective human rights and environmental impact assessments and meaningful consultations with affected local communities’.
In 2024, a UN report on mobile indigenous peoples stated, ‘in Mongolia, mining is harming herders’ livelihoods, livestock, traditional knowledge, water quality, pastures, sacred sites and cultural practices’. During the August 2025 Universal Periodic Review pre-sessions, Mongolian civil society organisations highlighted weak legal protections for herders facing land acquisition, displacement and cultural loss, including damage to sacred sites and exclusion of women herders from decision-making.
In Mongolia, rural land is formally state-owned but functions in practice as a shared pastoral commons. Herders rely on a mobile system of customary land use, moving seasonally and over long distances. Formal land titles apply only to small, fixed areas such as winter and spring camps and do not reflect how herders actually use land.
As a result, when land is expropriated for mining and related infrastructure, it fragments the wider grazing system, reducing access to pasture and water resources and undermining herders’ livelihoods, even where formally titled land is limited or absent.
Because the government grants mining licenses from the capital of Ulaanbaatar, local herders often discover that their seasonal pastures have been reclassified for industrial use only after exploration begins. When notified of a license being issued, local governments are given a short period of time to respond but have no recourse to reject or reverse the decision. Mongolia’s lack of legal requirements to assess impacts on livelihoods or to obtain the consent of affected people demonstrates the structural exclusion of rural communities from decisions that reshape their lives.
As the United Kingdom advances its vision for critical minerals cooperation with Mongolia, it must ensure that the recognition and protection of indigenous herders’ rights stand at the centre of its agenda.
For years, the UN, civil society organisations and academics have documented Mongolia’s poor record in safeguarding herders’ rights. A truly green future cannot be built on the displacement of mobile indigenous herders or damage to their livelihoods, culture and ancestral homelands.
By
Ariell Ahearn is Departmental Lecturer in Human Geography at the School of Geography and the Environment, University of Oxford.
Bayarsaikhan Namsrai is Director of Steps without Borders NGO, Mongolia.
Published Date:2026-01-21





