What Goes Into a Form SD Package — and How Long Should It Take?

If your company is an SEC registrant that manufactures or contracts to manufacture products where tin, tungsten, tantalum, or gold are necessary to the functionality or production of those products, you are required to file Form SD annually with the US Securities and Exchange Commission.

For many compliance teams at UK subsidiaries of US-listed companies, Form SD is the annual exercise that nobody looks forward to. It typically lands in Q1, involves chasing suppliers for CMRT data, and culminates in a scramble to produce documentation that satisfies both the SEC and your legal team.

Here is exactly what goes into a Form SD package — and how modern compliance software makes the process significantly faster.

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What Is Form SD?

Form SD is the Specialized Disclosure Report filed with the SEC under Rule 13p-1, which implements Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

It is filed annually, due on May 31, covering the prior calendar year. It is a public document — filed on EDGAR and accessible to investors, customers, and NGOs.

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The Two Possible Outcomes

When you complete your supply chain inquiry, Form SD leads to one of two conclusions:

Outcome 1: Not Required to File a Conflict Minerals Report

If your supply chain inquiry determines that your products are “DRC conflict free” — meaning your 3TG did not originate from the DRC or adjoining countries, or originated from recycled or scrap sources — you file a streamlined Form SD without a separate Conflict Minerals Report.

This requires you to document your reasonable country of origin inquiry (RCOI) and retain supporting evidence, but the filing itself is relatively brief.

Outcome 2: Required to File a Conflict Minerals Report (CMR)

If your inquiry cannot confirm DRC conflict-free status — or if 3TG from the DRC or adjoining countries is identified in your supply chain — you must file a full Conflict Minerals Report as an exhibit to Form SD.

This is the more demanding outcome and the one that most compliance teams need to prepare for thoroughly.

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What a Full Conflict Minerals Report Contains

A compliant Conflict Minerals Report filed with Form SD must include:

1. Description of Products Covered

A description of the products manufactured (or contracted to be manufactured) for which conflict minerals are necessary to functionality or production. This typically maps to specific product lines or SKUs.

2. The Countries of Origin

The countries from which the conflict minerals in your products originated, to the extent you can reasonably determine. This requires tracing your supply chain to smelter level, because smelters are the point at which country of origin can be verified.

3. The Smelters and Refiners

A complete list of smelters and refiners in your supply chain. Each smelter entry should include:

• Smelter name
• Metal processed
• Country of location
• Certification status (RMAP or equivalent)

This is typically the most labor-intensive part of the process. It requires collecting CMRT data from all Tier 1 suppliers, consolidating duplicate smelter entries, standardizing smelter names (which vary between CMRTs), and checking each against the RMAP Active Smelter List.

4. Due Diligence Measures Undertaken

A description of the due diligence measures you took on your supply chain, conforming to a nationally or internationally recognized framework — in practice, the OECD Due Diligence Guidance.

This section should demonstrate that you followed each of the five OECD steps: established management systems, identified and assessed risk, responded to risk, supported third-party audits, and reported.

5. An Independent Audit (if required)

If your CMR is not “DRC conflict free” — i.e., you cannot conclusively determine that conflict minerals did not originate from conflict-affected areas — the CMR must be audited by an independent private sector auditor. This is a significant additional requirement that creates its own timeline pressures.

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The Supporting Evidence You Need to Retain

The SEC requires you to retain supporting documentation for five years. This includes:

• All CMRTs received from suppliers, with dates received
• Any supplier communications related to conflict minerals
• RMAP smelter list exports showing certification status at your reporting date
• Internal risk assessment documentation
• Records of any supplier escalations or remediation steps
• Board or senior management sign-off on the compliance report

An audit trail that lives in email threads and shared spreadsheets is technically compliant but extremely difficult to produce under time pressure. A structured compliance system maintains this documentation automatically.

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How Long Should This Take?

For companies managing Form SD manually with spreadsheets:

Task	Typical time (manual)
Chasing suppliers for CMRT responses	3–6 weeks
Consolidating and deduplicating smelter data	1–2 weeks
Validating smelters against RMAP list	3–5 days
Drafting due diligence description	2–3 days
Legal review	1–2 weeks
Total	6–12 weeks

For companies using Auditraks:

Task	Typical time (Auditraks)
Importing CMRT data from suppliers	Hours
Automated smelter deduplication and matching	Automatic
RMAP validation (live list integration)	Automatic
Generating the compliance report	Minutes
Legal review	1–2 weeks
Total	1–3 weeks

The legal review time is essentially fixed — your legal team needs to review the output regardless of how it was produced. The time savings come from everything that happens before that point.

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The Most Common Form SD Errors

Incomplete smelter lists. The most common finding in peer reviews is smelters that should be on the list but aren’t — because a supplier’s CMRT wasn’t processed, or because smelter data was lost in a spreadsheet merge.

Stale RMAP data. The RMAP Active Smelter List is updated quarterly. Smelters gain and lose certification. Using a list that was current in January but filing in May means your certification data may be out of date.

Inconsistent smelter names. The same smelter may appear under three different names across CMRTs from different suppliers. Without deduplication, your smelter list contains duplicates — which creates questions in review.

Missing documentation for the five-year retention requirement. If you cannot produce the original CMRTs you relied on, your compliance program cannot be verified.

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If Your Form SD Deadline Is Approaching

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References: SEC Rule 13p-1; Dodd-Frank Act §1502; SEC Conflict Minerals Compliance and Disclosure Guidance; RMAP Active Smelter List (Responsible Minerals Initiative)