The 2020 reporting cycle for Canada’s Extractive Sector Transparency Measures Act (ESTMA) brought with it a unique and, in some respects, unexpected development. As mining companies and other extractive firms submitted their annual disclosures, a new category of payments began to feature in their reports—community support contributions made in response to the COVID-19 pandemic. This marked an evolution, albeit an emergent one, in the relationship between resource companies and the communities in which they operate. The question for both policymakers and firms, though, is what this shift might mean in practical terms for social license to operate, regulatory oversight, and broader corporate reporting practices.
For firms preparing their ESTMA filings, the inclusion of pandemic-related community payments was not mandated in a formal sense. ESTMA’s original design focused on transparency around payments to governments—taxes, royalties, fees, and similar transfers intended to prevent corruption and ensure public accountability. But the sudden and severe impact of COVID-19 on resource-dependent communities created new pressures. Many companies found themselves stepping into roles that straddled corporate responsibility and community stabilization, funding medical supplies, supporting food security programs, or even contributing to temporary housing initiatives. And, while these payments fell outside the narrow legal definition of ESTMA-reportable payments to government entities, an increasing number of firms chose to disclose them voluntarily. It was, perhaps, a recognition that transparency could serve a broader purpose in maintaining trust during a period of acute uncertainty.
The availability of open payment data, particularly through platforms maintained by the Canadian Securities Administrators (CSA), offered companies a way to situate their efforts within a wider context. By reviewing CSA data on payments reported by peers and industry counterparts, firms could benchmark their own contributions, identify gaps or overlaps in community support, and, crucially, pinpoint the recipient communities most in need or most affected. For some firms, this process was straightforward—those with long-standing community engagement programs often had the internal data systems to map payments efficiently. For others, the exercise was less familiar, involving a degree of manual reconciliation between CSA data, internal records, and external feedback from community partners or local authorities.
The use of CSA data in this way was not without its challenges. The data, while comprehensive in its original purpose, was not designed to capture the nuances of COVID-19 community support. Payment categories were often broad; recipient identifiers lacked the granularity needed to distinguish, say, between a provincial health authority and a small local health cooperative. In some cases, firms had to augment public data with their own records or with direct communication from recipient communities. There was also the matter of timing. CSA databases are updated on reporting cycles that do not always align neatly with the pace of pandemic-related support efforts. This created a certain lag in data availability, complicating efforts at real-time benchmarking or peer comparison.
Building on this data, companies faced the additional task of structuring their public disclosures in a manner that was both meaningful and manageable. The development of model “community support” tables became an emerging practice. These tables typically listed key payment categories—medical supplies, food programs, education support, infrastructure assistance—alongside recipient names, geographic locations, and, where feasible, a brief description of the intended use of funds. Some firms went further, linking these disclosures to indicators of social license continuity, such as measures of community satisfaction, partnership agreements renewed during the reporting period, or feedback collected through town halls or consultation meetings. There was no uniform template, no official model dictated by regulators. Instead, firms navigated a space where expectations were still forming, balancing a desire for transparency with operational constraints and, at times, genuine uncertainty about how best to present the information.
It would be misleading to suggest that these efforts were universally well-received or uniformly successful. In some instances, community groups expressed appreciation for the transparency and support, citing disclosures as evidence of corporate responsiveness. In others, skepticism remained, with concerns raised about whether payments were adequate, equitably distributed, or tied to broader commitments beyond the immediate crisis. For policymakers observing these developments, the trend raised broader questions about whether ESTMA’s scope might one day evolve to encompass a wider range of community-related payments, or whether a parallel reporting framework might emerge to capture such data more systematically.
Within the firms themselves, the experience of disclosing COVID-19-related community payments has, in many cases, sparked internal reflection. Questions about the role of voluntary transparency, the utility of open data in community engagement strategies, and the connection between disclosure and social license have taken on a new immediacy. For extractive companies operating in regions where trust is fragile or contested, the decisions made during 2020 may well set precedents for how community relationships are navigated in the years ahead. Whether these reporting practices persist beyond the immediate context of the pandemic remains to be seen, but their introduction marks a notable chapter in the evolving intersection of extractive sector transparency and corporate-community relations.