What Is Form SD? Conflict Minerals Compliance Under SEC Rules

Form SD (Specialized Disclosure Report) is a mandatory SEC filing under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, introduced in 2013. It requires public companies to disclose the use of conflict minerals—tin, tantalum, tungsten, and gold (3TG)—particularly when sourced from the Democratic Republic of the Congo (DRC) or adjoining countries. These minerals often fuel armed conflict and human rights abuses, making transparency in sourcing a critical corporate responsibility.

Form SD Filing Deadline for 2025

All companies subject to SEC reporting requirements must file Form SD by May 31, covering the previous calendar year.

Who Must File Form SD?

Any company that:

• Files 10-K or 20-F reports under Exchange Act Sections 13(a) or 15(d)
• Manufactures or contracts to manufacture products
• Uses 3TG minerals necessary to product functionality or production

must conduct due diligence and file Form SD.

Key Components of the Form SD Filing Process

• Reasonable Country of Origin Inquiry (RCOI)

Companies must conduct an RCOI to determine whether any 3TG used in their supply chain may have originated from the DRC or other covered countries. This step includes supplier outreach and use of the CMRT (Conflict Minerals Reporting Template).

• Conflict Minerals Report (CMR)

If the RCOI shows sourcing from covered countries, or it’s undeterminable, companies must file a CMR as an exhibit to Form SD. The CMR includes:

• Supply chain due diligence steps
• Descriptions of the products involved
• Risks identified and actions taken
• Independent Private Sector Audit (IPSA)

An IPSA is only required if the company declares its products “DRC Conflict Free.” Most filers do not need an IPSA unless voluntarily making this declaration.

• Due Diligence Standards

Filers must follow a recognized framework—most commonly the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Tools, Templates, and SEC Guidelines

• CMRT (v6.5) – Download from RMI
• Form SD & CMR Filing Instructions – SEC
• OECD Due Diligence Framework

Data Collection, Risk Mitigation & Documentation

Data Collection for Form SD

Use CMRTs and secure supplier portals to collect:

• Smelter/refiner details
• Country of origin
• Source types (scrap/recycled or primary mining)

Data Validation for Form SD

Employ supply chain compliance tools like Acquis to:

• Cross-check smelters against the RMI Conformant Smelter List
• Flag red flags in supplier disclosures
• Automate follow-ups with low-response suppliers

Documentation Retention for Form SD

Maintain all Form SD-related records (supplier responses, CMRTs, email logs, CMR drafts) for a minimum of 5 years, in accordance with best practices.

Common Challenges of Form SD and How to Overcome Them

SEC and EU Conflict Minerals Regulations: What's the Difference?

The Strategic Value of Form SD

• Boosts investor confidence
• Strengthens brand reputation
• Demonstrates supply chain transparency
• Reinforces human rights and ESG goals

A well-implemented Form SD process isn’t just compliance—it’s leadership in responsible sourcing.

How Acquis Simplifies Form SD Compliance

Acquis provides a cloud-based Conflict Minerals Compliance Program designed to:

• Track and map multi-tier supply chains
• Collect and validate CMRTs
• Flag smelters and non-conformant suppliers
• Generate audit-ready reports
• Educate suppliers and support them through filing

Speak to a compliance advisor to simplify your Form SD reporting before the May 31, 2025 deadline.

Conflict minerals compliance is no longer optional—it’s integral to responsible business. Filing Form SD with transparency, integrity, and completeness demonstrates not just regulatory alignment but ethical leadership.

Let’s build a traceable and trustworthy supply chain—one declaration at a time.