Gold · Canada · Australia · Global gold buyers
PLG vs. mining concession: the most common misrepresentation in Brazilian gold deals
Every month, gold offers from Brazil reach buyers in Toronto, Perth and Dubai described as a licensed gold mine with a mining concession. Many of them hold something else entirely: a PLG, a small-scale garimpo permit capped in size and term, held by individuals and built for immediate extraction without a defined deposit. The process numbers are real. The asset is not what the seller says it is. This guide shows you how to tell the difference before you spend a dollar on travel or lawyers.
Key takeaways
- A PLG (Permissão de Lavra Garimpeira) and a mining concession (Concessão de Lavra) are different legal regimes with different value, risk and buyer pools.
- A PLG is capped at 50 hectares for an individual holder, runs for up to five years renewable at the ANM's discretion, and requires no prior exploration.
- A mining concession sits at the end of Brazil's full permitting chain: exploration permit, approved final exploration report, economic development plan and environmental licensing.
- The usual inflation is not a fake process number. It is a real PLG described as a concession, an area rounded up, several titles presented as one, or a licence that has expired.
- Everything in this article can be checked from public ANM records using one identifier: the process number.
In this article
Brazil is one of the most interesting gold jurisdictions in the world. It has underexplored greenstone belts, a long artisanal mining history, established operations run by Canadian and international producers, and a regulator whose records are largely public. That combination also makes it fertile ground for offers that sound better than they are.
When an international buyer hears mining concession, they picture a defined deposit, a mine plan approved by the regulator and the legal right to extract for as long as the deposit lasts. When a Brazilian seller uses the same words for a garimpo permit, the gap between expectation and reality can be worth tens of millions of dollars. Sometimes the seller is deliberately inflating. Often the asset has passed through two or three intermediaries and each one has rounded the description up a little.
Either way, the buyer pays for the misunderstanding. This article explains both titles in plain terms, sets them side by side, walks through a real anonymised case and gives you a checklist you can run yourself. If you are evaluating a specific project, our gold projects for sale in Brazil page explains how we screen assets before they are offered.
§ 01 · The problem
Why one word changes the valuation
In Brazil the subsoil belongs to the Federal Union. Nobody owns a gold deposit simply because they own the farm above it. The right to extract minerals is granted by the federal mining regulator, the ANM (Agência Nacional de Mineração), through specific legal regimes. Each regime gives its holder a different set of rights, obligations and limits.
Two of those regimes are relevant to almost every gold offer you will receive. The mining concession is the industrial route: it is what Kinross, Hochschild, G Mining and other producers operate under in Brazil. The PLG is the garimpo route: it was created to formalise small-scale and artisanal mining of minerals that occur in irregular, shallow and often alluvial deposits.
The difference is not cosmetic. A concession implies that someone has explored the ground, delivered a final exploration report, had it approved, and convinced the regulator that a deposit can be mined economically. A PLG implies none of that. It authorises extraction without a defined resource, on a small area, for a limited time.
The lie is rarely in the existence of the process. It is in the qualification of the process.
BRAZIL MINE verification desk
That is why a buyer who only asks whether the process exists will be reassured every time. The right question is: what regime is this process in, who holds it, how large is it, and is every licence current?
§ 02 · Regime one
What a PLG actually is
The Permissão de Lavra Garimpeira was created by Law 7.805 of 1989 and is regulated by Decree 98.812 of 1990. It is designed for minerals whose nature, size and distribution make immediate extraction viable without prior exploration work. In the ANM's own words, it applies where the mineral occurs irregularly and in small volume, so investing in a full exploration programme would not be justified.
| Feature | PLG rule |
|---|---|
| Legal basis | Law 7.805/1989 and Decree 98.812/1990 |
| Who may hold it | Brazilian nationals, or garimpeiro cooperatives authorised to operate as mining companies |
| Maximum area | 50 hectares, except when granted to a garimpeiro cooperative |
| Term | Up to 5 years, renewable for further 5-year periods at the ANM's discretion |
| Prior exploration | Not required |
| Environmental licence | Required before the permit is granted |
| Transfer | Possible, with ANM approval, to a party that meets the legal requirements |
The regime is limited to what the law calls garimpável minerals. Gold is the most important of them. The list also includes diamond, cassiterite, columbite, tantalite and wolframite in alluvial, eluvial and colluvial form, as well as scheelite, other gemstones, rutile, quartz, beryl, muscovite, spodumene, lepidolite, feldspar and mica.
What a PLG does not give you
- No defined deposit. There is no approved final exploration report behind it, so there is no regulatory acknowledgement that an economic deposit exists.
- No scale. Fifty hectares is a small footprint for anything beyond shallow, selective mining.
- No long-term security. Each renewal depends on the ANM, and five-year horizons are hard to finance.
- No obvious home for a corporate buyer. Because the regime is built for individuals and cooperatives, a foreign-backed Brazilian company cannot simply step into it the way it would acquire a concession. Structure must be confirmed with Brazilian counsel case by case.
§ 03 · Regime two
What a mining concession actually is
The mining concession, granted by a federal ordinance known as the Portaria de Lavra, is the most mature title in the Brazilian system. It is regulated by the Mining Code (Decree-Law 227 of 1967) and its current regulation, Decree 9.406 of 2018. Getting there is a sequence, and every step leaves a public trace at the ANM.
- 01
Exploration application (Requerimento de Pesquisa)
A request for a defined polygon. It is a place in the queue, not a right.
- 02
Exploration permit (Alvará de Pesquisa)
A real right to explore for a fixed, extendable term, with an annual per-hectare fee (TAH) and a duty to report results.
- 03
Approved final exploration report (Relatório Final de Pesquisa)
The regulator accepts that a deposit exists. This is the main value inflection before production.
- 04
Mining application (Requerimento de Lavra)
Filed after approval of the final report, with an economic development plan (PAE) for the mine.
- 05
Mining concession (Portaria de Lavra) and operating licence
The concession authorises commercial extraction. Operation also needs the environmental installation and operating licences (LI and LO).
Under the Federal Constitution, a mining concession can only be held by a Brazilian national or by a company incorporated under Brazilian law with its head office and management in Brazil. Foreign capital participates through shareholding in that Brazilian company, which is the standard structure. We cover it in detail in Can foreigners buy a mine in Brazil?.
A concession has no fixed expiry. It remains valid while the holder mines in line with the approved plan, pays the federal royalty (CFEM, 1.5% for gold) and complies with environmental and regulatory duties. That durability is precisely what makes it bankable, and precisely why sellers want their asset to be described as one.
§ 04 · Comparison
PLG and mining concession side by side
Put the two regimes next to each other and the valuation gap becomes obvious. This is the comparison we run on every gold asset before it is offered to a buyer.
| PLG (garimpo permit) | Mining concession | |
|---|---|---|
| Purpose | Immediate small-scale extraction | Industrial mining of a defined deposit |
| Exploration behind it | None required | Approved final exploration report |
| Typical holder | Brazilian individual or garimpeiro cooperative | Brazilian-incorporated mining company |
| Area | Up to 50 ha (individual) | Defined by the explored polygon |
| Term | Up to 5 years, renewable at the ANM's discretion | No fixed term while compliant |
| Mine plan | Simplified | Economic development plan (PAE) approved by the ANM |
| Bankability | Low | Can support project finance once a compliant resource exists |
| Natural buyer | Local operators | Mining companies, funds, strategic investors |
Neither column is automatically good or bad. A well-run PLG operation can generate real cash. But the two assets belong to different markets, attract different buyers and should be priced on completely different logic. A concession is valued on the deposit. A PLG is valued, at best, on the cash flow it produces today.
§ 05 · Case study
How the misrepresentation happens: an anonymised case
In 2026 an offer for a gold operation in Mato Grosso reached our desk. It had been circulated in English and described as a licensed mine with a mining concession over 300 hectares, a single owner and a valid operating licence. The process numbers were provided. Here is what the public ANM records showed.
What the offer claimed
- Mining concession
- 300 hectares
- A single owner
- Valid operating licence
- A going concern
What the registry showed
- Nine processes, every one a PLG
- 267 hectares in total
- Four different holders, five processes in the name of a deceased person's estate
- Operating licence expired in 2020, a new one only applied for in 2026
- A mine closure plan filed in 2022
Notice that nothing here was invented from thin air. Every process existed and was active. The deception was layered: the regime was upgraded, the area was rounded up, nine titles became one asset, four holders became one owner, an estate became a seller and an expired licence became a valid one. Each layer on its own might pass a casual check. Together they describe a completely different asset.
The five inflation patterns to look for
PLG sold as concession
The most valuable upgrade and the easiest to verify. Check the regime field first.
Hectares rounded up
Sum the AREA_HA of every process yourself. Do not accept a single round number.
One owner on paper, many in reality
List the registered holder of every process. Multiple holders mean multiple negotiations.
Titles held by an estate (espólio)
Nothing can be transferred cleanly until the inheritance is settled and every heir agrees.
Expired operating licence
A title without a current LO cannot operate legally. Ask for the licence, not a description of it.
§ 06 · Method
How to verify a Brazilian gold title in 30 minutes
You do not need a law firm to run the first screen. The ANM publishes the core data, and it is enough to separate a serious asset from an inflated one before any meeting is booked. The starting point is always the ANM process number, written in the format 000.000/0000 (for example 866.904/1995).
- 01
Ask for every process number in writing
No number, no conversation. A seller who cannot produce it is not in a position to sell.
- 02
Check the regime and phase
In the ANM's public geographic system (SIGMINE) and the Mining Registry (Cadastro Mineiro), look at the phase field: exploration permit, mining application, mining concession, PLG or licensing.
- 03
Record the holder of each process
Compare the registered holder with the party offering the asset. If they differ, ask for the signed mandate.
- 04
Sum the real area
Add the official hectares of every process and compare with the offer.
- 05
Read the event history
Look for renewals, fee payments, fines, assignments, closure plans and licence events.
- 06
Verify the environmental licence separately
Get the licence number, the issuing state agency and the expiry date, and confirm it with the agency.
Minimum file before you take a call seriously
- ANM process numbers for every title in the asset
- Regime and current phase of each process
- Registered holder of each process and the seller's mandate
- Total official area in hectares
- Current environmental operating licence with expiry date
- Land registry numbers (matrículas) for the surface
- Any NI 43-101, JORC or CBRR technical report, or a clear statement that none exists
§ 07 · Perspective
When a PLG asset can still make sense for a buyer
None of this means you should walk away from every PLG. It means you should price it as what it is. There are three situations where a buyer can rationally engage with garimpo-stage ground.
As a geological signal
Artisanal gold in a district is evidence of mineralisation. Many Brazilian gold discoveries started where garimpeiros had worked for decades.
As part of a wider land package
A buyer may combine a PLG area with exploration permits over the surrounding ground and build a proper exploration programme.
As a small cash-flow business
For a local operator, a well-licensed PLG can be a legitimate small mine. It is a different business from a resource company.
What does not make sense is paying concession value for PLG rights, or building a corporate acquisition plan on a regime that was designed for individuals and cooperatives. In every case the legal structure needs Brazilian counsel and the geology needs a qualified person. Our role is to make sure you know which asset you are actually looking at, on day one.
If your mandate requires a producing or construction-ready asset, the questions in How to verify a mining concession before you buy take the next step. If you need resource figures that will stand up in Toronto or Sydney, read NI 43-101 and Brazilian gold projects.
Received a Brazilian gold offer?
Send us the process numbers. We will tell you which regime each title is in, who holds it and whether the description matches the registry, before you commit time or capital.
Request a confidential review§ FAQ
Frequently asked questions
Is a PLG the same as a mining licence?
No. A PLG (Permissão de Lavra Garimpeira) is a specific regime for small-scale extraction of garimpável minerals such as gold, without prior exploration. A mining concession (Portaria de Lavra) is granted only after an approved final exploration report and an economic development plan. They carry very different rights and value.
How large can a PLG be?
Up to 50 hectares when granted to an individual. The limit does not apply when the permit is granted to a garimpeiro cooperative.
How long does a PLG last?
Up to five years, renewable for further five-year periods at the discretion of the ANM.
Can a foreign company buy a PLG?
The regime is designed for Brazilian nationals and garimpeiro cooperatives, so a foreign-backed company generally cannot simply step into it the way it would acquire a concession through a Brazilian subsidiary. Any structure must be confirmed by Brazilian counsel.
How can I check whether a Brazilian gold title is a PLG or a concession?
Ask for the ANM process number and check its phase in the ANM's public SIGMINE system or the Cadastro Mineiro. The phase field states whether the title is a PLG, an exploration permit, a mining application or a mining concession.
What royalty does a gold mine pay in Brazil?
The federal mining royalty, CFEM, is 1.5% for gold. The surface owner is also entitled by law to a participation in the results of mining, equal to 50% of the CFEM amount.
Mathematician, Land Surveyor and Licensed Real Estate Broker · CRECI-TO 4631
BRAZIL MINE — Mining & Minerals
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