HARARE – Zimbabwe has with immediate effect reserved the small-scale gold mining sector exclusively for citizens and citizen-owned companies, while simultaneously declaring gold, diamonds, lithium and a range of other minerals as strategic or critical assets subject to new state controls.
The measures, announced by mines minister Polite Kambamura on May 22 represent the most sweeping overhaul of Zimbabwe’s mining regulatory framework in recent years, affecting both small operators and major foreign investors across multiple mineral categories.
The new policy on participation in the small and medium-scale gold mining sector, states that no foreign individual, foreign-controlled company, or foreign beneficial owner will be permitted to acquire, hold or control any mining title in the small-scale gold category. The ban also extends to indirect participation through tribute agreements, joint ventures, syndicates or partnerships.
For purposes of the policy, small and medium-scale gold mining is defined as operations producing up to 20 kilograms of gold per month and/or carrying capital investment of up to US$15 million.
Foreign operators currently active in the sector have been given until January 1, 2027, to regularise their operations – but only through upscaling, not through divestiture.
The ministry requires them to increase production beyond 20 kilograms per month and/or recapitalise beyond the US$15 million threshold, thereby qualifying for operation under the large-scale mining framework, which remains open to foreign investment.
The policy explicitly targets fronting and proxy arrangements, stating that “nominee arrangements, proxy ownership structures, undisclosed beneficial ownership arrangements, or other mechanisms intended to circumvent this policy shall be unlawful and subject to cancellation and enforcement action.”
All existing operators, local and foreign, are required to re-register with the ministry by the same January 2027 deadline, submitting to citizenship and beneficial ownership verification, disclosure of corporate and financing structures, and confirmation of compliance with environmental, tax and labour laws.
The ministry has also moved to localise the management of gold mines, requiring that senior and middle management staff across all gold and other mining operations be constituted of 98 percent Zimbabweans. The ministry said it expects “immediate compliance.”
In a related measure, the ministry warned that idle foreign-owned gold mining assets held for speculation would face follow-up action, and urged all heap-leaching gold mines to immediately register with the minister’s office and declare their monthly production and elution plants.
The mines ministry also formally declared two tiers of high-value minerals – critical minerals and strategic minerals – each subject to tightened state oversight.
Critical minerals include lithium, nickel, cobalt, graphite, copper, rare earth elements, chrome, platinum group metals (PGMs), manganese, antimony, uranium, ruthenium, tungsten and niobium. Metallurgical coal has been separately designated as a “special critical mineral.”
Strategic minerals, a broader category encompassing resources central to domestic industry and food security, include gold, diamonds, limestone, potash, phosphorus, iron ore, pyrites, oil and gas, and coal.
For all declared minerals, the state will exercise a mandatory minimum shareholding through designated Special Purpose Vehicles (SPVs). The ministry did not specify the minimum percentage.
Exports of any declared mineral in raw or unbeneficiated form are now prohibited unless authorised under a conditional transitional plan approved by the minister of mines, and only where such a plan includes a specific timeline for local beneficiation beyond the concentrate stage.
Applications for mining rights over declared minerals will require prior ministerial approval.
Kambamura cited widespread conflicts between foreign investors, local communities, miners and farmers as a driver of the small-scale mining reservation policy. He also pointed to unsustainable mechanised and non-standard mining practices by foreign investors as a concern.
The critical and strategic minerals classification was framed around global energy transition demand and Zimbabwe’s need to leverage its position as a significant holder of reserves in several of the listed mineral categories.
Kambamura reaffirmed Zimbabwe’s commitment to foreign investment in large-scale mining, value addition, beneficiation, exploration and infrastructure development.
