Zimbabwe Mining Policy Brief: Q3 2026 Review and Q4 Outlook

Based on publicly available information as at 30 September 2026.

Key points

• Mineral export earnings rose 84% to US$2.53 billion in the first half of 2026, with value-added products accounting for most of the increase.
• Exports of antimony and tungsten have been suspended, extending the list of minerals that cannot leave Zimbabwe in raw form.
• The ban on lithium concentrate exports is scheduled to take full effect on 1 January 2027. Producers have requested an extension, and the government has not granted one.
• Small and medium scale gold operators must re-register with the Ministry of Mines by 1 January 2027, with checks on citizenship, ownership and financing.
• Chrome policy is moving towards ferrochrome exports and regional processing hubs. No timeline has been set for ending concentrate exports.

1. Export earnings: beneficiation is showing in the numbers

The Minerals Marketing Corporation of Zimbabwe (MMCZ) reported mineral export earnings of US$2.532 billion for January to June 2026, up 84% from US$1.376 billion a year earlier [1]. PGM matte, spodumene concentrate and PGM concentrates together accounted for more than 74% of earnings. MMCZ attributed the increase to the beneficiation policy and higher commodity prices, and said it expects to exceed its annual target.

Implications. Part of the increase reflects prices, not policy alone. The result still gives the government a measurable return from beneficiation, which reduces the likelihood of the policy being reversed. Asset valuations should assume that raw mineral exports will remain restricted.

2. Critical Minerals: the export restriction list widens

Under the Ministry of Mines' statement of 22 May 2026, fourteen minerals, including chrome, lithium, copper, nickel, PGMs, antimony and tungsten, are declared Critical Minerals [2]. For these minerals, the State takes a mandatory minimum shareholding through designated special purpose vehicles, applications for mining rights require the Minister's prior approval, and raw exports require a Minister-approved transitional plan.

In September, the Ministry confirmed that exports of antimony and tungsten ores and concentrates have been suspended, following a letter from the Secretary for Mines to MMCZ dated 21 July 2026 [3].

Implications. Restrictions have been extended to additional minerals twice this year. Any structure involving a declared Critical Mineral should provide for State participation, ministerial approval and in-country processing from the outset.

3. Chrome

Raw chrome ore exports remain prohibited, and the government has not relaxed this restriction as it did for lithium. In May, the Minister of Mines, Dr Polite Kambamura, stated that Zimbabwe will move from exporting chrome concentrate to exporting ferrochrome and other chrome alloys, without giving a date [4]. The Ministry has announced regional beneficiation hubs, with chrome-producing areas designated for ferrochrome and chromium alloy production [5], and government has stated that new smelting capacity should rely on its own power generation rather than the national grid [6]. In June, the Minister said measures for small-scale chrome miners were being prepared, including toll processing through government facilities [7].

For title holders. The value of chrome ground increasingly depends on its access to a domestic smelter or processor. Investors are likely to assess offtake and processing routes alongside grade and tonnage.

For investors. Capital requirements in chrome are moving from mining to smelting and power. Structures that depend on concentrate exports carry the risk of a future move to ferrochrome-only exports.

4. Lithium

Lithium concentrate exports were suspended in late February 2026. In April, the government introduced individual export quotas for six large-scale producers, subject to 11 conditions, including written commitments to build lithium sulphate plants before 1 January 2027 [8]. From that date, concentrate exports are scheduled to stop. In June, the lithium producers' association requested an extension to mid-2027, stating that most major producers would not be ready [9]. The government has not announced an extension.

For title holders. Under current rules, export quotas are available only to the six approved large-scale producers. Holders of smaller lithium titles depend on supply arrangements with processors.

For investors. Under the current timetable, lithium concentrate will not be exportable after 1 January 2027. Opportunities should be assessed against that date unless the government announces a change.

5. Gold

Gold deliveries to Fidelity Gold Refinery totalled approximately 31.2 tonnes in the first eight months of 2026. August deliveries were 5.12 tonnes, up 20.7% on August 2025, with small-scale producers supplying 77.7% of the month's total [10].

Under the Ministry's policy of 22 May 2026, the small and medium scale gold sector, defined by production and capital thresholds, is reserved for Zimbabwean citizens and wholly Zimbabwean-owned entities [2]. All operators in that category must re-register by 1 January 2027, with verification of citizenship, beneficial ownership, financing structures and production levels. The policy states that nominee and proxy arrangements designed to avoid it are unlawful. It also requires senior and middle management at gold and other mines to be 98% Zimbabwean, and requires an approved ESG framework and Environmental Impact Assessment before any mining project begins. Detailed implementation guidelines are still awaited.

On 30 September, the Zimbabwe Miners Federation called for support for small-scale mining to be turned into access to finance, modern equipment and formalisation measures [11].

For title holders. Operators in the small and medium scale category should assemble their re-registration records now: title documents, ownership and financing details, and tax, labour and environmental compliance.

For investors. Ownership, control, financing and management composition will be examined during re-registration. Structures should be reviewed against the policy before 1 January 2027.

6. Title administration

The Ministry's Mashonaland Central office required holders of small and medium scale blocks registered before 2001 to submit survey-grade coordinates for the cadastre land folio exercise by 2 October 2026 [12].

Implications. The Ministry is actively updating its title records. Clean, current registration is the starting point for any transaction, and holders of older titles should confirm their status with their provincial mining office.

Dates to monitor

MZM's position

MZM structures its chrome and lithium mandates under the Critical Minerals framework, including State participation and in-country processing, and does not present structures that depend on exporting raw material. MZM's gold engagements are structured in full compliance with the 22 May 2026 participation policy, and each party's eligibility is verified before an engagement proceeds.

Registered title holders and investors who want to understand how these developments affect a specific asset or structure can contact the MZM team. MZM will publish its next brief once the lithium deadline and the gold implementation guidelines are confirmed.

This brief is based on publicly available information as at 30 September 2026 and is provided for general information only. It is not legal, tax or investment advice. Policies referred to may change, and readers should obtain professional advice on their own circumstances.

Sources

1. NewsDay, "MMCZ mineral exports jump 84% to US$2.53bn in H1", 17 July 2026. newsday.co.zw
2. Ministry of Mines and Mining Development, Press Statement on Mineral Classification and Declaration, and Policy Statement on Participation in Zimbabwe's Small and Medium Scale Gold Mining Sector, 22 May 2026. MZM summary
3. Bloomberg, "Zimbabwe Suspends Antimony, Tungsten Exports in Processing Push", 8 September 2026. bloomberg.com
4. OPIS, "Zimbabwe to Expand Export Ban to Chrome Concentrate", 4 May 2026. opis.com
5. Mining Zimbabwe, "Zimbabwe Pitches Smelting, Refining Deals to Australian Investors", August 2026. miningzimbabwe.com
6. Mining Zimbabwe, "Zimbabwe Chrome Smelters to Generate Their Own Power as Beneficiation Drive Intensifies", 16 April 2026. miningzimbabwe.com
7. The Herald, "Pricing boost for small-scale chrome miners", 3 June 2026. heraldonline.co.zw
8. Mining Zimbabwe, "Only large-scale lithium concentrate producers have been approved for export", 14 April 2026. miningzimbabwe.com
9. Mining Zimbabwe, "Zim Lithium Producers Seek Extension of 2027 Export Ban Deadline", 19 June 2026. miningzimbabwe.com
10. Mining Zimbabwe, "Zimbabwe Gold Deliveries Rise 10% in August as Small-Scale Miners Lead", September 2026. miningzimbabwe.com
11. Mining Zimbabwe, "ZMF Calls for Finance, Equipment to Scale Up as Mnangagwa Backs Small-Scale Mining", 30 September 2026. miningzimbabwe.com
12. Mining Zimbabwe, "Mash Central Mines Ministry Orders Pre-2001 Miners to Submit Coordinates", September 2026. miningzimbabwe.com