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In response to the gazetting of the long-awaited Zimbabwe Mines and Minerals Bill, 2025, the country’s biggest body that represents artisanal and small-scale miners (ASM), the Zimbabwe Miners Federation (ZMF), has announced plans to convene a high-level stakeholder and technical workshop to critically analyse the implications of the Bill—particularly for the ASM sector, Mining Zimbabwe can report.
By Rudairo Mapuranga
ZMF President Ms. Henrietta Rushwaya confirmed that the federation has assembled a specialised technical and legal team tasked with unpacking the Bill clause by clause. The team will focus on areas that directly affect grassroots miners who contribute significantly to the country’s gold output and rural economic empowerment.
“First and foremost, I would like to commend the Government of Zimbabwe for gazetting the much-awaited Bill. As the Zimbabwe Miners Federation, we have assembled a technical and legal team which will analyse the Bill in detail,” said Rushwaya.
Key Focus Areas for the ZMF Technical Team
Among the top agenda items to be interrogated is the proposed simplification of mining titles, which seeks to reduce the existing classes to just three, supported by the establishment of a Mining Cadastre Register—a digital system intended to streamline and centralise mining title administration.
Other areas of concern include the composition of the Mining Affairs Board, which, while more inclusive than the previous structure, still raises questions about equitable representation of ASM interests.
Additionally, the Bill introduces new environmental obligations and civil penalties, particularly through the Mining Industry Environmental Protection Fund (MIEPF). These provisions could impose heavy compliance burdens on ASM operators if not tailored to their scale and capacity.
Strategic Minerals and Foreign Access to ASM Land
One of the most contentious issues flagged by ZMF relates to Clause 6 of the Bill, which introduces the designation of strategic minerals and special conditions attached to their exploitation. While the Bill provides a pathway for small-scale miners to mine strategic minerals, it also grants the Minister significant discretionary power to determine access—including for foreign investors—through special agreements.
“What exactly are we saying about strategic minerals? Does the Bill give exclusive entitlement and authority to the Minister to issue titles? These are the questions that need clarity,” Rushwaya queried.
Furthermore, Rushwaya raised concerns about potential contradictions within the Bill, particularly around land size allocations. Although the Bill intends to preserve smaller mining blocks (under 40 hectares) for citizens and permanent residents, it allows foreigners access to these areas under certain conditions—specifically if they can demonstrate the intent to scale up to ordinary mining leases.
“Clause 31 says EPLs below 40 hectares are for citizens or permanent residents only, but there is a provision allowing foreigners who prove they will operate beyond small-scale to access the same land. That’s a contradiction we need to interrogate,” she said.
Advocacy for Inclusivity and Accessibility
The ZMF president further highlighted high licensing costs, bureaucratic hurdles, and technical barriers that ASM operators face, particularly around environmental certification, staking, and inspection requirements.
“Are these issues addressed in the Bill? If not, then we must advocate for adjustments to ensure ASM players can operate without being overburdened by red tape,” said Rushwaya.
The workshop will also scrutinise the lack of a defined tier system in the Bill. While the draft Bill simplifies mining title categories, it does not explicitly distinguish between artisanal, small-scale, and large-scale operations—a gap that risks subjecting all miners to uniform regulations despite stark differences in their operational capacity.
Gender, Youth, and Disability Inclusion
ZMF will also evaluate whether the Bill adequately addresses the inclusion of women, youth, and persons with disabilities in mining. Rushwaya noted the importance of affirmative measures to ensure these groups are not left behind in the formalisation and modernisation of the sector.
“Have these issues been addressed? Gender, youth, people with disabilities, and the farmer–miner land conflicts? These are the realities our miners face daily,” she noted.
Call for Affirmative Action and Simplified Processes
Rushwaya concluded by urging policymakers to ensure that the Mines and Minerals Bill becomes a tool for inclusive development, not exclusion.
“This Bill marks a positive step for Zimbabwe’s mining sector, but its success hinges on balancing modernisation with inclusivity and access. We urge government to reduce compliance burdens, clarify tiers, and protect small-scale and indigenous interests,” she said.
The upcoming stakeholder workshop, which will bring together miners, policymakers, legal experts, and civil society stakeholders, aims to consolidate the ASM sector’s official position for submission to Parliament during the public consultation process.
As the leading voice of Zimbabwe’s ASM sector, ZMF’s proactive engagement shows a commitment to ensuring that the final legal framework governing the country’s mineral wealth is inclusive, practical, and empowering for all Zimbabweans.
