Who would lift the deep, what each one does, and the source for every claim — a standing companion to The Waypoint's seabed-mining investigation.
The seabed-mining investigation argues that the one commons the world agreed to hold in trust is being carved up in the open — lawfully, in public filings, before the rulebook is written or the science is in. This page lays that out plainly: the actors, organised by the part they play, each beside the source that establishes it, and measured against the courts that drew the line. It is not a charge sheet. Almost everything recorded here is entirely legal — which is precisely the point.
How to read this ledger
LAWFUL BUT UNSUSTAINABLE — Legal activity that the published record shows risks grave and, in the deep sea, likely irreversible harm to a commons we have barely begun to study. This is most of the list.
INDEPENDENT RECORD — A finding from independent, peer-reviewed science or a neutral body, reproduced rather than asserted.
ACTION ON RECORD — A specific authority or court has taken a formal step — an inquiry opened, a ruling issued; that step is cited.
No party here is accused of a crime, and no official is accused of taking a bribe. Where a state both sponsors a miner and profits from the mining, that is a disclosed conflict of interest — lawful, and recorded in public filings. Where a question of conduct is unresolved, it is attributed to the body that raised it and recorded as a question, not a finding. Nothing here is an unproven allegation.
I · The miners — Those who would lift it
The Metals Company (TMC) · TMC USA
LAWFUL BUT UNSUSTAINABLE
Founded in Vancouver in 2011 as DeepGreen; Nasdaq-listed. Seeking to mine the Clarion–Clipperton Zone via a 1980 US statute, outside the International Seabed Authority. NOAA found its application fully compliant in May 2026; the company hopes for a commercial permit by early 2027.
Source: TMC SEC filings and press releases (2025–26); NOAA notices; A&O Shearman.
NORI (Nauru) · TOML (Tonga)
LAWFUL BUT UNSUSTAINABLE
TMC's ISA-contract subsidiaries, sponsored by Nauru and Tonga. NORI's exploration contract expires 21 July 2026, with an extension pending at the July session.
Source: International Seabed Authority; U.S. Congressional Research Service R47324.
COMRA · China Minmetals · Beijing Pioneer
LAWFUL BUT UNSUSTAINABLE
China's three state-controlled contractors, holding five ISA exploration contracts between them — more than any other nation. China Minmetals won the ISA's first-ever environmental sign-off for a nodule-collector trial in 2025. The third, Beijing Pioneer, is reportedly tied to China Merchants Group.
Source: Asia Maritime Transparency Initiative; U.S.–China Economic and Security Review Commission; ISA.
GSR / DEME (Belgium) · DORD (Japan)
LAWFUL BUT UNSUSTAINABLE
ISA exploration contractors that announced a joint demonstration-test plan in 2026 — the field beyond the two great powers.
Source: A&O Shearman, "Deep Sea Mining in 2026."
Deep Sea Mining Finance (BVI)
LAWFUL BUT UNSUSTAINABLE
The British Virgin Islands–registered successor to the bankrupt Nautilus Minerals, holding the Papua New Guinea Solwara 1 lease. Its 2024 activity appears in Section VIII.
Source: DSM Observer; Mongabay.
II · The financiers and enablers — Those who pay for the descent
Allseas (Netherlands)
LAWFUL BUT UNSUSTAINABLE
Offshore-engineering group; invested around US$150 million from 2019 and converted a drillship, the Hidden Gem, into the vessel built to lift nodules off the seafloor.
Source: TMC 10-Q; company records.
Korea Zinc (South Korea)
LAWFUL BUT UNSUSTAINABLE
Bought roughly five per cent of TMC for about US$85 million in 2025; a refining partner evaluating the company's nodules for battery-metal processing.
Source: TMC 8-K; Mining Technology.
United States Government
LAWFUL BUT UNSUSTAINABLE
Executive Order 14285 directs evaluation of offtake, stockpiling and possible federal investment in seabed minerals; reporting ties this to a strategic-mineral reserve.
Source: The Diplomat; U.S. Congressional Research Service.
III · The sponsor and host states — Those who lend the cover
Nauru
LAWFUL BUT UNSUSTAINABLE
Sponsors NORI — and is also, by the terms of its SEC-filed agreement, a direct financial beneficiary of the mining proceeding: set payments, a per-tonne fee, an option on TMC shares and "continuity benefits," much of it routed to a national trust fund. A disclosed conflict of interest, lawful and on the record. No bribery is alleged.
Source: RNZ Pacific; EJIL:Talk! (2025); Foreign Policy.
Tonga
LAWFUL BUT UNSUSTAINABLE
Sponsors TOML; updated its sponsorship terms in 2025.
Source: TMC filings; U.S. Congressional Research Service R47324.
Cook Islands
LAWFUL BUT UNSUSTAINABLE
An exclusive-economic-zone host with one of the richest nodule fields on earth — nodules that need no ISA permission to exploit. Signed a seabed-minerals memorandum with China in February 2025 and a minerals agreement with the United States; currently prohibits mining in its waters while it assesses.
Source: The Diplomat; CSIS; AFP / Gulf News.
Kiribati
LAWFUL BUT UNSUSTAINABLE
Holds one of the largest ocean territories on the planet. Ended its TMC (Marawa) arrangement in early 2025 and has discussed collaboration with China; a Western company left, and Beijing's interest followed.
Source: Radio Free Asia; The Diplomat.
IV · The permitting authorities — Those who hold the gate
International Seabed Authority
LAWFUL BUT UNSUSTAINABLE
The UNCLOS body charged with governing the Area "for the benefit of humankind." Adjourned its March 2026 Council with no Mining Code and no mining approved, and has opened a compliance inquiry into TMC's subsidiaries (Section VIII).
Source: ISA; IISD Earth Negotiations Bulletin.
NOAA (United States)
LAWFUL BUT UNSUSTAINABLE
Issuing exploration and recovery determinations under the 1980 Deep Seabed Hard Mineral Resources Act — outside the ISA — for mining in international waters that the treaty reserves to the shared institution.
Source: NOAA notices; TMC filings.
V · The great powers — Those who would own the floor
United States
LAWFUL BUT UNSUSTAINABLE
Not a party to UNCLOS. Declared seabed minerals a national priority and backs the frontal route around the ISA, via domestic law — asserting a right to a commons it never signed onto.
Source: The Diplomat; U.S. Congressional Research Service R47324.
China
LAWFUL BUT UNSUSTAINABLE
A full UNCLOS member; holds more ISA contracts than any nation and shapes the Mining Code from within, while delaying the move to extraction and pursuing bilateral EEZ deals as a side-door. A question over the dual-use of its deep-ocean research fleet is recorded in About these sources.
Source: Asia Maritime Transparency Initiative; US Naval Institute Proceedings; Just Security.
VI · The tribunals — Those who drew the line
ITLOS Seabed Disputes Chamber (2011)
INDEPENDENT RECORD
At Nauru's own request, ruled that states sponsoring deep-sea miners owe a duty of due diligence, that the precautionary approach is part of it, and that the obligations are owed to everyone.
Source: ITLOS Advisory Opinion, Case No. 17.
ITLOS · Small Island States (2024)
INDEPENDENT RECORD
On a request by small island states, found that greenhouse-gas emissions are marine pollution under UNCLOS and that states owe due-diligence duties to protect the marine environment.
Source: ITLOS COSIS Advisory Opinion.
International Court of Justice (23 July 2025)
INDEPENDENT RECORD
Ruled that states must protect the environment for present and future generations, and that intergenerational equity requires "due regard for the interests of future generations." The case was begun by Pacific law students and carried to the UN by Vanuatu.
Source: ICJ Advisory Opinion on the Obligations of States in Respect of Climate Change.
VII · The independent record — What the science already shows
The recovery test
INDEPENDENT RECORD
A patch of Pacific seabed scraped by a mining experiment in the 1970s had still not recovered four decades later; removing the nodules may remove, permanently, the only hard surface much of the life down there depends on.
Source: long-term Clarion–Clipperton recovery study (2025); DISCOL literature.
The map we do not have
INDEPENDENT RECORD
As of April 2026, only 28.7 per cent of the global seafloor is mapped to modern resolution; the ocean is, by its own custodians' account, the least-understood environment on Earth, and the UN declared a Decade of Ocean Science (2021–2030) to begin closing the gap.
Source: Seabed 2030 / GEBCO; IOC–UNESCO; United Nations.
"Dark oxygen"
INDEPENDENT RECORD
A 2024 finding that the nodules themselves may produce oxygen in total darkness. The mechanism is unresolved, the survey was industry-funded, and the result has been rebutted and disputed — recorded here with its dispute, not as settled fact.
Source: Nature Geoscience (2024) and its published rebuttals.
Vanuatu — the Global Scientific Assessment of Deep-Sea Ecosystems
INDEPENDENT RECORD
Having withdrawn its proposed resolution on the Active Protection of Deep-Sea Ecosystems at UNEA-7 (Nairobi, December 2025) when consensus could not be reached, Vanuatu launched an independent global assessment to gather existing scientific and Indigenous knowledge of the deep sea and identify the critical gaps — formally announced after a three-day convening at UNEP headquarters on 10–12 June 2026, and run in partnership with the Deep-Ocean Stewardship Initiative (DOSI). The stated premise is precautionary: that decisions affecting the deep ocean are accelerating while it remains among the least-understood environments on Earth. A renewed resolution is intended for UNEA-8.
Source: Vanuatu Daily Post; UNEA-7 record.
VIII · Contested conduct and inquiries — Where the conduct is questioned
ISA compliance inquiry · NORI / TOML
ACTION ON RECORD
The ISA's Legal and Technical Commission is examining whether TMC's subsidiaries breached their obligations by pursuing the US route while holding ISA contracts; its report is due at the July 2026 session.
Source: ISA; Deep-Sea Conservation Coalition.
Papua New Guinea · Solwara 1
ACTION ON RECORD
Coastal communities sued for the project's documents; the Mineral Resources Authority spent public funds trying to block release and lost in court. PNG carried a loss of more than US$100 million when Nautilus went bankrupt.
Source: RNZ Pacific; Australian Mining; BankTrack.
Deep Sea Mining Finance (2024)
INDEPENDENT RECORD
Reporting found that the BVI-registered lease-holder conducted exploration near Solwara 1 that surprised PNG authorities and, critics say, breached the country's moratoria. Recorded as a question raised by reporting, not a finding.
Source: Mongabay (2024).
Nauru's dual role
LAWFUL BUT UNSUSTAINABLE
Cross-referenced from Section III: a disclosed conflict of interest, lawful and set out in public filings. No bribery is alleged.
Source: See Section III.
About these sources
This Ledger consolidates the sourcing of the seabed-mining investigation, Nobody’s Sea, and is maintained as the underlying assessments, inquiries and rankings are revised. Source names below carry the link; nothing here is an unproven allegation.
REGULATORY RECORD & THE MINING CODE
International Seabed Authority; IISD Earth Negotiations Bulletin; Deep Ocean Stewardship Initiative; Deep-Sea Conservation Coalition; U.S. Congressional Research Service (R47324).
THE US ROUTE & NOAA
NOAA, deep seabed mining; Mining Technology.
THE CORPORATE RECORD
Australian Mining; BankTrack; DSM Observer; Deep Sea Mining Campaign.
THE CHINESE STATE PLAYERS
Asia Maritime Transparency Initiative; U.S.–China Economic and Security Review Commission; US Naval Institute Proceedings; CSIS; Just Security.
THE PACIFIC & THE EEZ ROUTE
The Diplomat; Radio Free Asia; Te Ipukarea Society; Cook Islands Seabed Minerals Authority.
GOVERNANCE, FINANCE & ACCOUNTABILITY
RNZ Pacific; EJIL:Talk!; Foreign Policy; Mongabay.
TRIBUNALS & THE LAW OF FUTURE GENERATIONS
ITLOS (Seabed Disputes Chamber; COSIS); International Court of Justice.
SCIENCE & THE UNMAPPED DEEP
Nature, long-term Clarion–Clipperton recovery study (2025); Nature Geoscience, the contested “dark oxygen” paper (2024); the marine scientists’ moratorium statement; Seabed 2030; GEBCO; UN Ocean Decade (IOC–UNESCO); Vanuatu Daily Post, Vanuatu launches a global scientific assessment of deep-sea ecosystems; Vanuatu Daily Post, Vanuatu leads global shift toward deep-sea science cooperation at UNEA-7.
A joint investigation raised the question of whether China’s deep-sea-mining research fleet may also serve other purposes; the companies did not respond, and the matter is recorded here as a question raised by reporting, not as a finding. China rejects characterisations of its maritime activity as military in nature.
Every actor here is named for a documented role. Entries marked Lawful but unsustainable describe legal activity; entries marked Action on record point to a formal step taken by an authority or court. Nothing in this Ledger is an unproven allegation of criminal conduct against a named party.
Tied to the investigation Nobody’s Sea.