Progress towards deep sea mining (DSM) is driven by projected demands for metals and the desire for economic development. DSM remains controversial, with some political leaders calling for a moratorium on DSM pending further research into its impacts. This paper highlights the need for governance architectures that are tailored to DSM. We conceptualise DSM as a type of complex orebody, which encompasses the breadth of environmental, social and governance (ESG) risks that make a mineral source complex. Applying a spatial overlay approach, we show that there are significant data gaps in understanding the ESG risks of DSM. Such uncertainties are compounded by fact that there are no extant commercial DSM projects to function as a precedent – either in terms of project design, or the impacts of design on environment and people. Examining the legislation of the Cook Islands and International Seabed Authority, we demonstrate how regulators are defaulting to terrestrial mining governance architectures, which cannot be meaningfully implemented until a fuller understanding of the ESG risk landscape is developed. We argue that DSM be approached as a distinct extractive industry type, and governed with its unique features in frame.