You probably have noticed it by now. Since last year there has been a series of significant new policy and regulatory developments in Zimbabwe. It has been typical in recent months to hear of a new gazette notice or ministerial directive. Some of these instruments have been particularly material in reshaping the investment landscape in Zimbabwe. It is imperative to understand these instruments to adjust or position yourself rightly as a prospective investor. It is evident that the government has been redrawing how capital enters Zimbabwe. It has also been evident that the government is enhancing local participation. Understanding all these dynamics is now a precondition for deploying capital here. Let us discuss more.

SI 215 Of 2025 (Reserved Sectors)

SI 215 of 2025 was gazetted on 11 December 2025. It reserves seventeen sectors of the economy exclusively for Zimbabwean citizens. These span retail and wholesale trade, passenger transport, grain milling, bakeries, tobacco grading, advertising, employment agencies, pharmaceutical retailing and several service trades. Foreign-owned businesses already operating in those sectors must now offload a minimum of twenty-five percent equity to Zimbabweans every year. This applies till foreign equity is twenty-five percent and local is seventy-five percent. There is of course conditional foreign participation that is still possible in some sectors. It is now conditioned on meeting minimum investment and employment thresholds set out sector by sector. Plus, submitting a credible business plan is also part of the conditions. Affected businesses were given a three-month window (January to March 2026) to regularize. ZIDA's own 2026 first-quarter data attributed a significant drop in investment licence value partly to this instrument.

Small-Scale Gold Mining Reservation

Then, on 22 May 2026, government reserved small-scale gold mining exclusively for Zimbabwean citizens and wholly Zimbabwean-owned entities. Small-scale gold mining now refers to operations producing up to twenty kilograms of gold a month or carrying capital investment up to fifteen million US dollars. Foreign operators currently inside that tier must recapitalize into large-scale status. Otherwise, they would have to exit entirely by 1 January 2027. This policy is also explicit about the structures it is designed to outlaw. These are nominee arrangements, proxy ownership and undisclosed beneficial control. Such structures are now unlawful mechanisms for circumventing the reservation. A re-registration exercise is underway to verify citizenship, ownership and financing across the sector. A further requirement is that ninety-eight percent of senior and middle management roles must now be held by Zimbabweans.

Mineral Classification & Declaration

Government also announced a minerals classification framework. This added a separate layer of state controls over how mineral resources are held and developed. This policy comes with three core implications. One, for every classified mineral, the State via Special Purpose Vehicles (SPVs) will hold a mandatory minimum stake in its exploitation. Two, any classified mineral cannot be exported in raw or non-beneficiated form. Exporting it in raw form can only happen backed by a ministerially approved transitional plan with a specific local beneficiation timeline. Three, all applications for mining rights on classified minerals require prior approval from the Minister of Mines and Mining Development. This mineral classification framework sits on top of the ownership dynamics we discussed earlier. This means a project can clear the citizenship and beneficial ownership aspects and still face additional conditions because of what it is mining.

Additional Related Instruments

On 17 February 2026, the Ministry of Mines suspended exports of all raw minerals and lithium concentrates with immediate effect. This measure even applied to cargo that was already in transit. It accelerated the lithium export restriction that had been scheduled for January 2027. Reasons cited were malpractice, leakage and smuggling in the export chain. Only firms with beneficiation capacity in place have been permitted to keep exporting since then.

It is also noteworthy to cite the Mines and Minerals Bill. It cleared a parliamentary committee stage in early June. That development meant that we are getting closer to laws such as a digital cadastre and stricter "use it or lose it" enforcement. The 2026 Finance Act (effective from January) has also now tightened oversight of mineral export pricing and revenue capture.

The Apparent Regulatory Or Policy Pattern

On the surface, each instrument seems like a sector-specific intervention. However, when you look at all the instruments together there is an apparent pattern. Government is closing the gap between who holds title to an asset and who controls and benefits from it. Scale is being used as the sorting mechanism throughout. As in, participation below a given threshold is earmarked for Zimbabwean ownership. Then participation above that threshold remains open to foreign participation.

Does This Make Zimbabwe Less Investable?

This is the most topical question given the policy environment that is now prevailing. Well, it does not necessarily make Zimbabwe less investable. Think of it this way if you are a foreign investor. For gold mining, you are still allowed to participate in large-scale mining. For classified minerals you still can participate provided you adhere to the three conditions that apply. With respect to reserved sectors, there are still sectors where you can conditionally participate. Just as long you adhere to the applicable conditions. The bottom line is there is still vast room for you participate in.

What This Means in Practice

You must treat applicable conditions as a structuring decision to be made at the outset. It should not be an exercise completed under pressure. It is also strategic to build capital and production levels with deliberate headroom. Essentially, it should be above whatever classification threshold applies to your sector. Positioning yourself at the border line is not that smart. Always engage the relevant regulator before you are required to. Voluntary engagement is always perceived positively as opposed to reactive compliance. Do not regard local partnership in management and ownership as a concession. Rather, think of it as a competitive advantage. Above all, always track these instruments so that you stay abreast and compliant with what is in effect.

Where This Leaves You

Certain things have not changed. Zimbabwe's resource base is still significant. Zimbabwe’s position in regional supply chains is also still significant. More importantly, the scale of capital still required is still significant. What has changed is the government’s terms regarding foreign and local participation. What is important for you to do is to position yourself rightly. It is essential that you are knowledgeable enough to make decisions on where and how to participate. That has been the whole intention of this discussion.

Our Role As IHC

At Investor Hosting Centre (IHC), our thrust is to bridge the gap between capital and credible, investment-ready projects. Our primary focus is on driving economic development in Zimbabwe and across Africa.

Every regulatory or policy shift we discussed herein is unpacked in the detailed sector intelligence we publish to our Resource Library:

https://www.investorhosting.com/resources-library/

That same analysis is factored into our development of business cases and conducting of risk assessments for our live opportunities.

Are you ready to put capital to work in Zimbabwe, bring an opportunity to market, or offer your services into our pipeline? Kindly go to investorhosting.com to sign up as an investor, opportunity owner or service provider. For more information you can email on info@investorhosting.com or call +2638677010683.