The tracker · United States

Dodd-Frank Act, Section 1502 (Conflict Minerals)

In forceUnited StatesEntry updated September 2026

The original supply chain disclosure statute, requiring conflict minerals reporting from SEC filers since 2014.

Status
In force
Enacted
July 2010
First compliance deadline
May 2014 filings
Companies in scope
SEC-reporting companies using tin, tantalum, tungsten or gold necessary to their products
Maximum penalty
Securities law penalties for false or misleading filings
Civil liability
Through securities litigation
Enforcement body
US Securities and Exchange Commission

Latest movement

Calendar year 2025 filings fell due on 1 June 2026; the regime and the SEC enforcement posture are unchanged.

In plain language

What this law does

Section 1502 requires SEC-reporting companies to determine whether their products contain tin, tantalum, tungsten or gold originating in the Democratic Republic of the Congo or adjoining countries, and to file conflict minerals reports describing their due diligence. The regime built the smelter-level audit infrastructure that later laws now rely upon.

Its lessons are studied as much as its text: a decade of filings shows both the possibilities of supply chain transparency and the limits of disclosure without consequences, a debate that continues to shape newer due diligence laws.

Obligations

What it asks of companies

  1. Reasonable country of origin inquiry

    Filers must conduct a good faith inquiry into whether covered minerals originated in the covered countries.

  2. Due diligence and Form SD filing

    Where origin is covered or unknown, OECD-aligned due diligence and an annual Form SD filing are required.

July 2010

Dodd-Frank Act signed into law.

August 2012

SEC adopted the implementing rule.

May 2014

First conflict minerals reports filed.

Changelog

Entry history

September 2026

Reviewed after the 1 June 2026 filing deadline for calendar year 2025; no regime changes to report.

January 2026

Annual review completed; no material regime changes.

Sources

Primary documents

Same jurisdiction

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