The Annual Mining Report (RAL) is a legal obligation for all holders or lessees of mining titles and utilization permits in Brazil. Regardless of the operational status of the mines, submitting the RAL to the National Mining Agency (ANM) is mandatory. The document provides an annual overview of mining activities, detailing production, sales, tax collection, and other information.
The RAL is submitted exclusively electronically, through the RALWeb system, available on the ANM website. The form is filled out screen by screen, and submission is done at the end of the process. To access the system, it is necessary to log in through the GOV.BR system.
The deadlines for submitting the RAL vary according to the type of mining title:
- Mining manifest, mining decree, mining ordinance, mining group, mining consortium, license registration with an economic utilization plan approved by the ANM, artisanal mining permit, extraction registration, and titled areas with utilization permit: by March 15th of each year.
- License registration without an economic utilization plan approved by the ANM: by March 31st of each year.
However, the submission of the annual mining report has been yet another chapter of difficulty for Brazilian mining companies. The well-known RALWEB system is the current protagonist in the stage of instabilities of the ANM systems.
Extension of the RAL deadline
On March 13, 2025, the ANM announced the extension of the RAL (Annual Mining Report) deadlines. The new deadlines were set as March 21, 2025, for cases provided for in Article 70, item I, and April 4, 2025, for cases under Article 70, item II, both of Ordinance 155/2016. The decision was motivated by the implementation of a new area management system, SIGAREAS. Although this change is not directly perceived by users, SIGAREAS is expected to significantly streamline the complex area analyses carried out by the ANM.
In the last week, the RALWEB system presented slowness, initially attributed to the typical congestion near the final submission deadline. However, the instability intensified, with intermittent access to the platform, revealing a problem more serious than simple access overload. In response to the demonstrations of several users and a letter sent by the Brazilian Association of Mineral Exploration and Mining Companies (ABPM), the ANM decided to extend the deadline again. The new deadline for submitting RAL 2025 was then set for April 17, 2025, both for cases provided for in Article 70, item I, and for those in item II, of Ordinance 155/2016.
It is important to note that the alleged congestion seems to have been foreseen by the mining administrator, the ANM (formerly DNPM), as evidenced in Article 71, § 4, of Ordinance 155/2016:
“§ 4º Possible difficulties presented by the RALweb Application, especially due to the congestion of accesses to the DNPM website in the last days for the delivery of the RAL, will not remove the imposition, by the DNPM, of the administrative sanctions that are applicable.”
This legal provision raises some important questions:
a) Prior knowledge of demand: The ANM, knowing the number of valid mining titles and, presumably, having statistics on access to RALWEB, has (or should have) knowledge of the number of accesses it needs to guarantee for the proper functioning of the system.
b) Shortened effective deadline: The congestion of the system forces mining title holders to submit the report weeks in advance, since, close to the deadline, submission may become unfeasible. This, in practice, shortens the actual delivery deadline.
c) Responsibility of the titleholder in case of system failure: Even if the non-submission of the report is caused by a deficient infrastructure of the system, the titleholder will be fined and cannot use the system failures as justification, as the ordinance itself establishes.
This does not seem to be coherent since it is evident that the ANM system failures are recurrent. The ANM Digital Protocol Unavailability Report proves this reality with multiple records of interruptions. In 2024 alone, system unavailability totaled 2037 hours and 5 minutes, which corresponds to 84 days, 21 hours and 5 minutes. The longest of these interruptions, which occurred between 04/08/2024 (20:31) and 05/15/2024 (13:59), reached 36 days, 17 hours and 29 minutes.
Given this scenario, it is urgent that the ANM invest significantly in robust and reliable technological solutions. Such investments are crucial to ensure the continuity and stability of services, minimizing losses to the sector. Transparency in the disclosure of unavailability reports, although relevant, does not solve the inconveniences, lost time, and additional costs faced by users. Effective action is needed to ensure the system’s operability.
