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Managing conflicts of interest at the International Seabed Authority

Under new leadership and with rising global interest in deep seabed mining, the International Seabed Authority, like any regulator, must address corruption and conflict-of-interest risks to uphold integrity and equity in its governance of the common heritage of humankind. Stronger procedural safeguards and administrative mechanisms are needed to ensure that decisions taken on behalf of all people remain impartial, accountable, and beyond reproach.

2 March 2026
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Managing conflicts of interest at the International Seabed Authority

Main points

  • The mandate and structure of the International Seabed Authority (ISA) under the UN Convention on the Law of the Sea (UNCLOS) has certain features that expose it to perceived or actual conflicts of interest. These require management via administrative mechanisms, many of which have not yet been addressed by the ISA.
  • The ISA has received public criticism from high profile media outlets for conflict-of-interest transgressions that erode legitimacy and public trust. Losing support from primary stakeholders threatens fragmentation of global governance of shared resources and undermines multilateralism. The ISA must strengthen governance and procedural safeguards to ensure that decisions taken by its state membership on behalf of all of humankind remain impartial and accountable.
  • Timing is right for reform. In 2026, the ISA is at a critical juncture: new leadership, global ‘critical mineral’ debates intensifying and companies pushing to mine the deep seabed for the first time – with some states threatening to do so outside the ISA’s permitting framework. Together these factors provide an opportunity, and necessity, for the ISA to establish stronger governance and manage potential conflicts of interest.
  • The stakes are heightened by the ISA’s role as a possible institutional precedent for the new multilateral governance bodies being established under the Biodiversity Beyond National Jurisdiction (BBNJ) Agreement, which came into force in January 2026.

Cite this publication


Lily, H.; Forster, R. 2026. Managing conflicts of interest at the International Seabed Authority. Bergen: U4 Anti-Corruption Resource Centre, Chr. Michelsen Institute (U4 Issue 2026:5)

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About the authors

Hannah Lily

Hannah Lily is a British lawyer with 25 years of professional experience in good governance, working now as an independent expert in the regulation of deep seabed mining. She has been a regular participant at the International Seabed Authority for more than a decade, supporting many delegations in the negotiations.

Robert Forster is an adviser with U4, specialising in governance and addressing unequal development, with a regional focus on the Middle East. His work at U4 centers on anti-corruption efforts related to climate, environmental management, and natural resource extraction.

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