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Madagascar's 2011 mining-permit moratorium was imposed by Decree No. 2011-074 of 8 February 2011 during the post-2009-constitutional-crisis Transitional Authority period, originally as a temporary measure to clean up the cadastre and audit pending applications. The suspension outlasted its intended timeline by over a decade. Successive attempts to lift it — including partial administrative reforms in 2016-2019 — stalled due to governance and transparency concerns within the Bureau Central des Mines de Madagascar (BCMM) cadastral office.
The January 2026 lift is the operational unlock that finally activates the architecture assembled by Loi n° 2023-007 (the July 2023 Mining Code overhaul). The new Code introduced a 2% royalty earmarked for local communities, a 3% state royalty with 30-year fiscal stability, a modernised environmental/health-and-safety chapter, and strengthened permit procedures — but none of these provisions could take practical effect while permit issuance was frozen.
The BCMM cadastre now holds approximately 1,650 applications (per ITIE Madagascar's 2025 EITI Report) to 3,000+ total files to process, covering graphite (Molo/Green Giant projects — Triton Minerals), nickel-cobalt (pipeline additions to the Ambatovy complex operated by the Sumitomo-led consortium), rare-earth elements (Tantalus REE deposit), iron ore (Soalala), and mineral-sand ilmenite/zircon deposits (neighbouring QMM-operator Rio Tinto territory at Fort-Dauphin).
Gold remains excluded. Minister Andriamparany cited the government's inability to establish rigorous monitoring, noting only ~13 kg of gold was officially declared despite extensive artisanal-mining activity nationwide — a gap that exposes the state to royalty leakage and formalisation failure.
Madagascar is the world's #3 graphite producer (alongside China and Mozambique), contributing approximately 5.5% of global supply from flake-graphite deposits in the northeast. The permit freeze had materially constrained exploration and development of new graphite projects over the period 2011–2025. The moratorium lift creates direct exploration opportunity for anode-precursor supply chains servicing lithium-ion battery gigafactories in Europe and the US (relevant to EU CRMA graphite-sourcing requirements and US IRA FEOC-clean anode-supply diversification ambitions).
Madagascar is also the world's 4th-largest nickel producer via the Ambatovy laterite nickel-cobalt complex (capacity ~60,000 t Ni/year). New permits could enable pipeline laterite development adjacent to Ambatovy's existing HPAL processing infrastructure.
This action is the functional equivalent of 2024-10-23-ecuador-decreto-435-catastro-minero-conim, in which Ecuador's CONIM commission reopened the mining cadastre following a 2018 freeze. Both are jurisdiction-level cadastre-reopening instruments with critical-minerals-supply-chain implications; both operationalise a recently passed Mining Code overhaul that had remained inactive on the permit-issuance side.
The decision also inserts Madagascar into the broader African mining jurisdiction regulatory-restoration cluster alongside filed Tanzania Mining Act amendments (2025), Zambia Critical Minerals Strategy (2024), Zimbabwe Statutory Instrument 162/2025 raw-platinum export ban, and the pending Uganda Mining Act 2022 — Madagascar joining as a top-tier graphite + nickel-laterite + REE jurisdiction.