TMC's $7 Stock: The $23.6B Permit Play

The immediate catalyst for TMC is a high-stakes, near-term regulatory event. In the wake of last week's executive order, the company has submitted a trio of applications to the National Oceanic and Atmospheric Administration (NOAA) under the Deep Seabed Hard Mineral Resources Act (DSHMRA). This is a tactical move designed to accelerate the timeline for its flagship NORI-D project, but it arrives with significant legal and political headwinds.

The applications are specific: two exploration licenses and one commercial recovery permit. The latter is the critical piece. The commercial recovery permit application covers a proposed area of 25,160 square kilometers in the Clarion Clipperton Zone, referred to as TMC USA-A_2. This area is not just a blank slate; it includes regions that contain the company's already-indicated and measured resources, effectively locking down the core of its project.

The timeline is tight and binary. NOAA has a 60-day review period for the commercial permit application. This will be followed by a public comment period and hearings that extend through February 2026. The outcome of this process is a clear on/off switch for the project's U.S. regulatory path. Success would validate TMC's decade of preparation and its claim to leadership, while a prolonged review or denial would stall the entire $23.6 billion venture.

This is a classic binary event. The permit applications are the first concrete step toward unlocking the project's value, but they also invite scrutiny and opposition. The company's aggressive timeline-submitting ahead of its original target-shows it is betting that the new administration's pro-mining stance will outweigh the inevitable legal challenges and public hearings. For now, the stock's fate is tied to NOAA's clock.

The Mechanics: Valuation and Immediate Risk/Reward

The setup here is a classic speculative trade: a massive valuation gap meets a near-term binary event. The stock's recent performance underscores the high-risk, high-reward bet investors are making. After a 450% surge in 2025, the shares have already climbed 17% in 2026 to about $7. That's a 700% potential upside if the market's current valuation of roughly $3 billion ever aligns with the project's estimated worth.

The economic potential of the NORI-D project is what justifies that speculative leap. Two assessments show a combined project value of $23.6 billion. The core of that value is a Net Present Value of $5.5 billion for the NORI-D area alone, backed by 51 million tonnes of probable reserves. The company's target is to begin commercial production in the fourth quarter of 2027, assuming it gets the permit. That's the immediate catalyst: the outcome of the NOAA review and public comment period, which concludes in late February 2026. A positive decision would validate the U.S. bypass strategy and likely trigger a significant re-rating. A delay or denial would stall the entire timeline.

The primary risk is the legal and political backlash over the U.S. strategy. The International Seabed Authority has already stated that any action outside the multilateral ISA framework undermines the international legal regime governing the seabed. This creates a clear vulnerability. A formal challenge or sustained political pressure could force NOAA to extend its review, adding months or even years of uncertainty. For now, the stock's price reflects a bet that the new administration's pro-mining stance will prevail. The next few weeks will test that bet.

The Setup: The 700% Upside Play

The math here is stark and the trade is clear. The market is valuing TMC at roughly $2.9 billion. Two technical assessments show the combined project value of its NORI-D area and other resources is $23.6 billion. That implies a potential upside of over 700% if the project is fully realized. For event-driven traders, this is the core proposition: a massive valuation gap betting on a single, near-term binary outcome.

The immediate catalyst is the NOAA decision, which will be the next major price mover. The agency has a 60-day review period for the commercial recovery permit application, with public comment and hearings extending through late February. A positive ruling would validate the U.S. bypass strategy and likely trigger a significant re-rating. A delay or denial would stall the entire timeline and force a reassessment of the project's viability.

Yet the setup is fraught with a fundamental legal vulnerability. The International Seabed Authority has formally stated that any action outside the multilateral ISA framework undermines the common heritage of humankind principle. This creates a clear headwind. A formal challenge or sustained political pressure could force NOAA to extend its review, adding months or even years of uncertainty. The stock's recent volatility-up 17% in 2026 after a 450% surge last year-reflects this high-stakes bet on the new administration's pro-mining stance prevailing over international law.

The bottom line for traders is a classic event-driven play. The stock is priced for a high probability of success, but the ISA's stance introduces a material risk of a prolonged regulatory fight. The next few weeks, culminating in the late-February decision, will test whether the market's optimistic view is justified or if the legal headwinds are about to surface.