Pakistan's Mineral Title System: What Foreign Partners Actually Need to Understand

Most of the confusion I hear from overseas partners boils down to one thing. They're reading Pakistan's mineral title system through a federal lens, and it isn't federal. It's provincial. And in Gilgit-Baltistan, where our 16 concessions sit, it's a slightly different animal again.

So let me walk through what a mineral title in Pakistan actually is, how the layers stack, and where I see foreign JV partners get tripped up before the first drill turns.

The Three Things People Confuse

A concession, a lease and surface rights are not the same document. They're not even the same government process. I've had serious buyers from the Gulf and from China arrive assuming that once you hold an exploration licence you can start trucking material out. You can't. Different layer, different permission.

Here's the honest breakdown as it works on the ground:

Reconnaissance Licence (RL). Short duration, usually up to one year. Non-exclusive. Gives you the right to walk the ground, sample, do airborne geophysics if you can get the clearance. You cannot mine or export from an RL. Full stop.

Exploration Licence (EL). This is where real work happens. Term is typically three years, renewable in defined blocks (the specifics vary between Balochistan, KP, Sindh, Punjab and GB). Grid drilling, trenching, bulk sampling within limits. Exclusive to the holder. Most of what GBX holds sits in this category, moving toward mining lease conversion on the concessions that have passed feasibility.

Mining Lease (ML). The production title. Usually 30 years in initial term, renewable. This is what off-take counterparties want to see referenced in a JV — an ML or a clear, documented path from EL to ML with the JORC-style or equivalent resource work behind it.

And then, separately, sitting on top of all of that — surface rights.

Surface Rights Are Where Deals Actually Stall

Here's the thing nobody puts in the pitch decks. Holding a mineral title does not automatically give you the right to occupy the surface above it. In Gilgit-Baltistan especially, this matters. Much of the land is either state land, khalisa, shamilat (village common land) or held under customary tenure that predates any modern land record.

I got this wrong on our first concession, honestly. We assumed the mineral lease was the hard part. It wasn't. The hard part was sitting with a village jirga in a valley outside Skardu for the better part of six weeks, agreeing terms for camp access, water use and a road spur. That relationship is worth more than the paperwork, and if you skip it, no licence in Islamabad will save your programme.

So when a foreign partner asks me "is the title clean," my honest answer is: the title is one of three things you need to check. The other two are the surface arrangement and the community agreement. All three, or you don't have a project.

How It Actually Works in Gilgit-Baltistan

GB has its own mineral concession framework, administered through the GB Department of Mineral Industries under the GB Mines and Minerals Act. It's aligned in spirit with the National Mineral Policy 2013 and follows the same RL–EL–ML structure, but the granting authority sits in Gilgit, not Islamabad and not Quetta.

A few practical points that matter for foreign investors:

• Titles are granted to Pakistan-registered entities. A foreign company partnering with us typically comes in through a JV SPV registered with SECP, with the mineral title either held by the SPV or held by the Pakistani partner and contributed under a properly drafted mining and off-take agreement.
• Royalty rates in GB run in the 2–5% range depending on the mineral, paid on pit-mouth value. Critical minerals like antimony and tungsten sit toward the lower end in current schedules, which matters when you're modelling.
• Export permissions are a separate track. Federal — through the Ministry of Commerce and, for certain minerals, the Strategic Export Control Division. Tungsten concentrate, for example, needs paperwork most people don't budget time for.
• Environmental approval (IEE or EIA depending on scale) goes through GB-EPA. For anything above a certain throughput, expect a full EIA with public hearing. Budget six to nine months, realistically.

The 16 concessions we hold cover copper, antimony, molybdenum, tungsten, gold (both lode and placer blocks on the Indus and Gilgit river reaches), lead-silver, bauxite, nephrite around Skardu and Bunji, and architectural granite from the Karakoram batholith. Each one sits at a different stage in that RL–EL–ML pipeline, and any serious partner should ask to see the specific title document, the granting notification, the current renewal status and the royalty schedule attached. If someone shows you a glossy summary without the actual gazette reference, walk.

What I'd Tell A Serious Buyer Sitting Across The Table

Look, the Pakistan mineral title system is not opaque. It's federated, it's paper-heavy, and it rewards operators who understand that a licence is a permission slip, not a project. The project is built between the licence, the surface, the community and the export corridor.

The countries that have figured this out on the ground — I'd put the Chinese majors first, some of the Gulf trading houses second — aren't smarter than anyone else. They just showed up, sat down, and did the three-layer check before they wired money. Everyone else keeps sending lawyers to read the mineral concession law in isolation and wondering why the deal doesn't close.

If you're evaluating a Pakistani mining lease or an EL-stage concession for JV or off-take, what's actually on your due diligence list beyond the title document itself?