Outdated laws and weak oversight are leaving Zimbabwe’s mining sector exposed to repeated violations, prompting ENM Advisory Group to recommend urgent legislative reform to modernise the framework, introduce enforceable performance indicators, and equip inspectors with clear sanctioning powers, Mining Zimbabwe reports.
By Ryan Chigoche
The 2023 Responsible Mining Audit was launched as a pilot, using coordinated inspections across multiple Ministries, Departments and Agencies.
Building on this, the 2024 audit expanded to 728 sites nationwide, showing the potential of multi-agency enforcement while also exposing its limitations. The audits remained largely reactive, focused on regulatory compliance, and lacked integration with broader sustainability and development goals.
These operational realities set the stage for the findings of the Responsible Mining Audit (RMA) Gap Analysis Report 2025 by ENM Advisory Group.
While the previous audits successfully identified violations across labour, environmental and operational areas, the report notes that the framework struggles to translate these findings into sustained compliance.
Many laws guiding mining operations, including Statutory Instruments 109 of 1990 and 72 of 1989, are outdated and misaligned with modern practices. Labour inspectors, for example, lack the authority to issue fines, and small-scale miners often rely on handwritten receipts rather than formal certificates.
Closely linked to these legal gaps are weaknesses in governance. ENM highlights that the RMA does not systematically assess principles-based oversight, including ethical leadership, anti-corruption safeguards or conflict-of-interest measures. Without these mechanisms, even technically compliant operations remain vulnerable to breaches that can undermine enforcement and erode public trust.
These legal and governance deficiencies directly affect enforcement. The report warns that while hundreds of violations were documented in the 2023 and 2024 audits, there is no structured follow-up, performance tracking or escalation process for repeat offenders.
Mines found in breach often return to non-compliant operations, reducing audits to snapshots rather than continuous standards of accountability.
Institutional fragmentation compounds the problem. Oversight agencies responsible for mine safety, environmental compliance, labour standards and licensing operate in silos, with no shared database or integrated ICT system to coordinate enforcement or track compliance across the sector.
ENM cautions that without stronger inter-agency coordination, systemic risks are likely to persist unchecked.
Taken together, the 2025 gap analysis paints a stark picture. Zimbabwe’s mining audits, while improving in scope and data quality, remain constrained by outdated legislation, weak governance and enforcement gaps.
The report concludes that urgent reforms are needed to modernise laws, embed ethical oversight, strengthen coordination and implement robust follow-up mechanisms, ensuring audits can drive lasting compliance, safety and accountability across the sector.
