Ministry of Mines Policy Announcements — 22 May 2026: What They Mean for Foreign Investors
On 22 May 2026, Zimbabwe's Ministry of Mines and Mining Development issued two policy statements that materially change the conditions for foreign investment in Zimbabwe's mining sector. This post sets out what each instrument says, who it affects, and MZM's position.
Instrument 1: Mineral Classification and Declaration
The Ministry has formally declared the following as Critical Minerals:
Lithium, Nickel, Cobalt, Graphite, Copper, Rare Earth Elements, Chrome, Platinum Group Metals, Manganese, Antimony, Uranium, Ruthenium, Tungsten, and Niobium.
Metallurgical Coal has been declared a Special Critical Mineral.
Gold, Diamonds, Coal, Iron Ore, Limestone, Potash, Phosphorus, Pyrites, and Oil and Gas have been declared Strategic Minerals.
What this means in practice:
The State now holds mandatory minimum shareholding in the exploitation of Critical Minerals, exercised through designated Special Purpose Vehicles. No person may export any Critical Mineral in raw or unbeneficiated form without a conditional transitional plan approved by the Minister of Mines, which must include a specific timeline for local beneficiation beyond concentrate stage. Applications for mining rights on Critical Minerals require prior ministerial approval.
This does not close Zimbabwe's critical minerals sector to foreign investment. It structures it. Foreign investors who want to participate in chrome, lithium, copper, nickel, or PGMs must do so through a compliant SPV that includes State co-investment. Investors who attempt to structure around this requirement will not achieve regulatory clearance.
Instrument 2: Reservation of Small and Medium Scale Gold Mining
With immediate effect, the small and medium scale gold mining sector is reserved exclusively for Zimbabwean citizens and wholly Zimbabwean-owned entities.
Small and medium scale is defined as operations producing up to 20 kilograms of gold per month and/or with capital investment up to $15 million.
What this means for foreign investors:
Foreign individuals, foreign-controlled companies, and entities with foreign beneficial owners may not acquire, hold, or control any mining title in the small or medium scale gold category. They may not participate directly or indirectly in the operation or management of such activities. Tribute arrangements, joint ventures, syndicates, or partnerships that confer economic or operational control over small-scale gold activities are explicitly prohibited. Proxy and nominee structures intended to circumvent the policy are unlawful.
All foreign operators currently in the small-scale gold sector must, by 1 January 2027, either increase production above 20 kilograms per month and recapitalise above $15 million — thereby qualifying as large-scale — or exit the sector.
What remains open to foreign investors in gold:
Large-scale gold operations above the prescribed thresholds remain accessible to foreign capital. The Government has confirmed its commitment to maintaining a secure and investment-friendly environment for responsible foreign investment in large-scale mining, beneficiation, exploration, and infrastructure development.
MZM's Position
MZM's two active investor-ready projects are chrome and lithium. Both are structured under the Critical Minerals SPV framework as required by the 22 May instrument. Neither project has been affected by the gold reservation policy.
MZM does not facilitate foreign investment in small or medium scale gold mining. Any gold-related engagement MZM undertakes is confined to large-scale operations that qualify above the statutory thresholds. MZM will confirm investor eligibility for any gold structure before proceeding.
Investors with existing exposure to small-scale gold in Zimbabwe should take independent legal advice on their compliance position and transition obligations before 1 January 2027.
MZM will update this page as implementation guidelines and compliance procedures are issued by the relevant ministries and regulatory authorities.
Sources: Ministry of Mines and Mining Development — Policy Statement on Mineral Classification and Declaration, 22 May 2026. Ministry of Mines and Mining Development — Policy Statement on Participation in Zimbabwe's Small and Medium Scale Gold Mining Sector, 22 May 2026.