Zambia National Critical Minerals Strategy 2024-2028

Mechanism

The strategy is a five-year framework document — not a regulation in itself — that sets the direction of travel for downstream legislation, licensing and state-equity practice. Its operative force comes through four companion vehicles:

1. Pillar 1 — Geological knowledge & resource management. The 2025 national budget raised the allocation for aerial geological and geophysical mapping to ZMW 364m (from ZMW 160m in 2024); a Geological Mapping and Development Fund was created to support nationwide mapping covering southern, north- western, western and central provinces with a two-year expansion target. 2. Pillar 2 — Value addition and local processing. The strategy commits to reviewing the policy framework to limit raw-mineral exports and to extending tax incentives for local processing — paving the way for the country's first cobalt-sulfate refinery (announced for end-2025, billed as Africa's first). Investors are also expected to allocate ≥35% of procurement spending to local suppliers. 3. Pillar 3 — Government participation via a special-purpose vehicle. The strategy authorises the creation of a state investment vehicle (a Zambia Minerals Investment Corporation-style SPV) that will hold a minimum 30% equity stake in new strategic critical-minerals mining projects under a "production-sharing mechanism." This is the operational core of the resource-nationalism pivot. 4. Pillar 4 — Regulatory and institutional reform. Paired with the Minerals Regulation Commission Act No. 14 of 2024 (passed by Parliament and assented to in late 2024) which will repeal the 2015 Mines and Minerals Development Act once the commencement order is issued, and the Green Economy and Climate Change Act No. 18 of 2024.

Strategic context

The strategy underpins the parallel National Three Million Metric Tonnes Copper Production Strategy by 2031 — a target of roughly 4× current output (approximately 700kt in 2024). It is the first sub-Saharan-African horizontal critical-minerals strategy to be issued alongside South Africa's CMM (2025-05-20-south-africa-critical-minerals-metals-strategy) and the DRC ARECOMS cobalt regime (2025-02-22-drc-arecoms-cobalt-export-ban-quota- system). Zambia is also a signatory to the Lobito Corridor MoU (US-EU- Angola-DRC-Zambia, 2024) and the strategy is the policy precondition that positions ZM as a Critical Raw Materials Act / Minerals Security Partnership counterparty.

Downstream implications

• First-mover M&A pressure on existing copper-cobalt assets. Foreign

operators (First Quantum, Barrick Lumwana, Vedanta KCM, Glencore Mopani, IRH at Mopani) face a clear policy signal that any new expansion or greenfield licensing under the MRC Act will likely carry a 30% state- equity carve-out and a 35% local-procurement floor.

• Cobalt-sulfate refinery optionality. The strategy explicitly enables

the long-discussed end-2025 cobalt-sulfate refinery as Africa's first battery-grade processing facility — material for any FEOC-clean supply- chain narrative pulling cobalt processing out of China.

• Lithium licensing. KoBold Metals' Mingomba copper project and several

exploration-stage lithium plays sit under the new framework — investor conditions will be set by the MRC Act once commencement issues.

• Geological data step-up. ZMW 364m FY2025 mapping is large by Zambian

standards (>2× FY2024) and creates measurable first-pass exploration acreage that will feed exploration-licensing rounds in 2026-2027.

Open questions

• Final design of the state investment SPV — capital structure, governance,

whether ZCCM-IH plays the role or a new vehicle is incorporated.

• When the Minerals Regulation Commission Act commencement order is issued

and which provisions take effect first (licensing, royalties, local-content).

• Whether the 30% state-equity rule applies retroactively to expansions of

existing mining rights or only to greenfield grants.

• Tax-incentive design for local processing — whether headline corporate

rates are reduced or whether incentives flow through capital-allowances / VAT-deferral mechanisms.

• Timing of the first ZM-EU CRMA Strategic Partnership and ZM-US Minerals

Security Partnership MoU off the back of the strategy.