What is the PTM and when does Circular 000009 de 2025 really apply?

The PTM (Plataforma de Trazabilidad de Minerales, the Mineral Traceability Platform) is the system of the Agencia Nacional de Minería (ANM, Colombia’s National Mining Agency) that records mineral sale transactions in Colombia online, to verify the lawful origin of the mineral sold. It was created by Resolución 759 de 2024 (Resolution 759 of 2024), and its go-live schedule (modified by Circular 000009 de 2025) is still in partial implementation: the process to approve the private technology operators that must support it was declared void in July 2026, so the “official” date of January 2026 does not necessarily reflect what is happening in practice.

What exactly does the PTM record?

It is not a technical mining operation plan; that is the PTO. The PTM is a transactional record: every mineral sale must be entered there, through a Mineral Traceability Technology Operator (OTTM, for its Spanish acronym) approved by the ANM, so that the authority can verify in real time the quantity of mineral sold and its origin against the mining title or legal instrument that covers the extraction.

What changed with Circular 000009 de 2025?

The circular, signed on June 25, 2025, adjusted the schedule originally set in Resolución 759 de 2024, in line with Resolución 1549 de 2025. The official schedule by segment was set as follows:

It also extended the technical testing period for OTTMs and added new services the platform had to support before going into production (registration of opening balances, purchases without exact identification of origin, closing due to transformations, among others).

What the circular could not foresee: the approval process has restarted several times

Between the date of this circular (June 2025) and today, the call to approve private OTTMs went through at least three cycles of opening, suspension and reopening. The most recent: on July 8, 2026, the ANM declared the current approval call void, after rejecting the last applicants in the process. This means that, on paper, Stage 1 should have been operating since January 2026, but the infrastructure of private operators that supports that record was still unresolved six months later.

For a mining operator or trader, this has a concrete implication: it is not enough to look at the date that appears in the resolution. You need to check directly on the ANM website (Circulares section, or the email trazabilidad@anm.gov.co) the current status of the approval process before assuming that the obligation already applies in practice to your segment.

What should an operator have ready in the meantime?

Although the schedule has moved, the direction of the regulation does not change: every mineral sale transaction will eventually have to be recorded with verifiable traceability of origin. It is worth starting before the obligation becomes enforceable:

• Verify that the associated processing plants are registered in the RUCOM (Registro Único de Comercializadores de Minerales, the Single Registry of Mineral Traders).
• Have the Documento de Acreditación de Procedencia Lícita (certificate of lawful origin) of the mineral organized and available per transaction.
• Confirm with the chosen OTTM (once a current list of approved operators exists) the technical integration requirements.
• Do not assume go-live dates without confirming them directly with the ANM; the recent history shows that they move often.

Frequently asked questions

Are the PTM and the PTO the same thing?

No. The PTM records mineral sale transactions. The PTO (Programa de Trabajos y Obras, the Works and Operations Program) is the technical execution plan of the mining operation. They are completely different instruments, governed by different regulations.

Is the PTM already operating?

Partially, and with delays against the original schedule. The process to approve private technology operators was declared void in July 2026. We recommend checking the current status directly with the ANM before taking for granted that the obligation applies to your segment.

Who must record transactions in the PTM?

Authorized Mineral Traders and processing plants registered in the RUCOM, through an OTTM approved by the ANM.

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If you want to review the traceability compliance status of your operation, write to us at hello@bluberri.io.