What is the mining PTO and what does ANM oversight require today?

The PTO (Programa de Trabajos y Obras, the Work and Works Program: the mine plan filed with the ANM) is the technical document through which a mining titleholder declares to the Agencia Nacional de Minería (ANM, Colombia’s National Mining Agency) how it will carry out its operation: geological model and reserves, mining method, sequence by period, associated infrastructure and progressive closure obligations. It is the legal reference point against which the mining authority compares what actually happens on site, and its regulatory framework comes from Ley 685 de 2001 (Código de Minas, Colombia’s Mining Code) and from Resolución 18 0859 de 2002, which set the terms of reference for preparing it.

What exactly does oversight review in the PTO?

During the construction and assembly stage, and later during exploitation, the ANM assesses the PTO on two fronts:

Document review: mining insurance policies, payment of economic considerations, the PTO and the other applicable technical instruments (PTI, PTE), environmental permits, and the update and reconciliation of resources and reserves.

Field inspection: that the works carried out match what was approved in the PTO (roads, pits, waste dumps, plants, deposits) and that the production reported in the Formato Básico Minero (FBM, the Basic Mining Form) is consistent with what was declared for royalties.

The gap between what was planned in the PTO and what was carried out in the field is exactly what each oversight visit reviews.

What is changing?

Two concrete things are already underway, and a third is on its way:

Already in force: digital filing (Circular 000007 de 2025): the ANM implemented the ZETA platform for filing and assessing technical documents such as the PTO, PTI, PTE, PTOC and PTOD. Since April 2025, these documents are no longer submitted on paper or through scattered channels; everything goes through a single digital repository, which means that the information supporting the PTO must also be in a digitally searchable and traceable format.

Already in force: cross-checking of production (Resolución 371 de 2024): the ANM requires periodic reporting to the Production Control platform, to compare what was declared in the PTO against the volumes actually sold and the royalties paid.

In progress: new general oversight guidelines: the Ministerio de Minas y Energía (Ministry of Mines and Energy) has a draft resolution underway that would replace Resoluciones 40008 de 2021 and 40182 de 2022. The text under discussion tightens the traceability requirement for technical data: periodic review of the PTO terms of reference, a dashboard of compliance indicators, and greater weight for technology tools to capture and reconcile information in the field. To date, this draft has not come into force, and the 2021 and 2022 resolutions still apply, but it clearly marks the direction: less discretion, more verifiable digital evidence.

What operational capacity does this require in practice?

Beyond the paperwork, sustaining a PTO under oversight requires real installed capacity:

• Periodic measurement of physical progress: surveying or photogrammetry at a defined cadence, not isolated campaigns before each visit.
• Reconciliation of resources and reserves comparable between periods, same datum, same method: aligned with the CRIRSCO/ECRR standard (Resolución 100 de 2020, article 328 of Ley 1955 de 2019).
• Records with date and traceability of origin: who measured, when, with which equipment.
• Georeferenced visual evidence of the state of slopes, waste dumps and deposits.
• Reconciliation between the approved PTO and actual execution, ready to explain any deviation at the moment it is requested, not a year later.

An operator that already flies its site at a regular cadence and stores the derived products with complete metadata arrives at oversight with defensible material. One that reconstructs the information at the last minute does not.

What should you do first?

Start with an inventory of what already exists: which surveys there are, which method was used, whether they are comparable with each other and whether they have verifiable traceability of origin. That diagnosis almost always reveals that the problem is not a lack of data, but data that cannot hold up before an authority that audits.

Frequently asked questions

Are the PTO and the PTM the same thing?

No. The PTO (Programa de Trabajos y Obras) is the technical plan for carrying out the mining operation. The PTM (Plataforma de Trazabilidad de Minerales, the Mineral Traceability Platform) is a different system, created by Resolución 759 de 2024, that records mineral trading transactions.

Is it mandatory to file the PTO through the ZETA platform?

Yes, since ZETA came into operation in 2025, under the ANM’s Circular 000007 de 2025.

What happens if the PTO does not match what was carried out in the field?

The deviation must be explained and supported before the mining authority. Unreported or repeated deviations can lead to formal requests and, in serious cases, to sanction proceedings.

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If you want to see how this applies to your operation, write to us at hello@bluberri.io.