Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

Zambia enacted the Income Tax (Amendment) (No. 2) Act No. 17 of 2025, assented to 23 December 2025 and effective 1 January 2026, introducing two mining-specific fiscal provisions. First, interest deductibility is capped at 30% of tax EBITDA for all companies, with unrelieved interest carry-forwardable for up to five years (general) or ten years for entities in mining and electricity generation. Second, mining companies deriving at least 75% of gross income in foreign exchange from outside Zambia may maintain their books of accounts in US dollars, reducing FX translation risk for dollar-denominated operators. Both measures are structurally distinct from the concurrent Act No. 10 of 2025 (Minimum Alternative Tax and loss carry-forward cap).

Zambia's Statutory Instrument No. 68 of 2025 under the Geological and Minerals Development Act 2022 establishes the first binding procurement-quota local-content regime in the Zambian copper-cobalt mining sector, entering into force 1 January 2026. Mining and mining-related companies must reserve a minimum 20% of their annual procurement budget for Zambian-owned or citizen-empowered suppliers of core mining goods and services, escalating to 25% in year two and 35% in year three, targeting 40% within five years. All non-core ancillary services (catering, security, haulage, cleaning, gardening) are reserved exclusively for Zambian-owned companies. The instrument operationalises the Minerals Regulation Commission created under the 2024 MRC Act and completes the ZM resource-nationalism statute stack.

On 8 October 2025 South Africa's Public Investment Corporation (PIC) — the state-owned asset manager that invests the Government Employees Pension Fund and other public-sector funds — announced it has set aside ZAR 1.35 billion (~USD 78.7 million) to fund early-stage mining projects, from post-scoping through bankable-feasibility-study stage. Capital is deployed indirectly via private equity, venture capital, specialist mining funds and joint ventures, in tickets of ZAR 100-400 million per project. At least 50% of funded projects must be in South Africa, with the remainder earmarked for copper/cobalt in Zambia and the DRC, rare earths in Malawi, and graphite in Tanzania and Madagascar. The fund explicitly targets minerals aligned with South Africa's Just Energy Transition (JET) and carries BEE Level 2 / Historically Disadvantaged Individuals preference criteria for South African applicants.

The Bank of Zambia formally accepted Chinese renminbi (RMB/CNY) for copper and cobalt mining royalty and tax payments starting October 2025, making Zambia the first African country to establish an official RMB settlement channel for mining fiscal flows. In December 2025 the BoZ began publishing an official RMB-kwacha exchange rate to enable precise royalty and corporate tax calculations. The central bank cited efficiency grounds: Chinese mining companies operating Zambia's largest copper producers already receive export revenues in yuan from Chinese off-takers, making yuan-denominated tax settlement a natural extension that also reduces Zambia's Chinese-debt servicing friction. The policy embeds Chinese currency infrastructure into the sovereign fiscal architecture governing Zambia's copper and cobalt supply chain, deepening structural alignment between Zambia's resource sector and China's commodity-import ecosystem.

Japan Bank for International Cooperation (JBIC) signed a loan agreement, announced 2025-08-21 (signed 2025-08-20), providing up to USD 14 million (JBIC's portion) toward a USD 24 million total co-financing package with Sumitomo Mitsui Banking Corporation for ETC Group Limited, a Mauritius-based company backed by Mitsui & Co., Ltd. The loan funds liquefied petroleum gas (LPG) operations conducted through ETG Energy, ETC Group's wholly owned subsidiary, across Zambia, South Africa, Mozambique, and Uganda. JBIC explicitly framed the financing as supporting Japanese overseas business expansion and enabling a household-fuel transition from charcoal to LPG aligned with the recipient countries' Paris Agreement emissions commitments.

Zambia enacted the Income Tax (Amendment) Act No. 10 of 2025 on 8 August 2025, gazetted 19 August 2025, introducing three interlocking fiscal measures. First, a 1% Minimum Alternative Tax (MAT) on annual turnover applies to all companies and partnerships, creditable against standard income tax with a five-year carry-forward — directly raising the floor tax burden on large copper and cobalt mining groups that have historically reported low taxable profits. Second, the 50% annual loss carry-forward cap (previously mining-sector-specific) is universalised, reducing the tax-shelter advantage for capital-intensive mining projects with front-loaded losses. Third, withholding tax on government-securities interest is raised from 15% to 20%.

At its 34th session in Harare on 5 June 2025, the SADC Committee of Ministers of Trade formally endorsed Angola's accession to the SADC Free Trade Area after Angola submitted its final tariff offer covering 90% of tariff lines — surpassing the SADC standard threshold of 85%. Angola becomes the 14th SADC member state to join the FTA, with implementation targeted for January 2026. The accession ends Angola's longstanding outlier status as the region's second-largest economy operating outside the bloc's duty-free zone, and opens tariff-free corridors between Angola and FTA members including South Africa, Zambia, DRC, Zimbabwe, and Mozambique.

Zambia's Geological and Minerals Development Act, 2025 (Act No. 2 of 2025) was assented to on 8 April 2025, gazetted 15 April 2025, and entered into force 13 June 2025 via a dedicated Commencement Order. The Act reorganises the Ministry of Mines and Minerals Development's executive capacity by establishing three statutory directorates — Geological Survey; Artisanal, Small-Scale Mining and Value Addition; and Large-Scale Mining and Mineral Investment Promotion — and creates a dedicated Artisanal and Small-Scale Mining Fund providing grants and capacity-building loans to the informal sector. It functions as a sibling statute to the Minerals Regulation Commission Act, 2024 (No. 14/2024) and is the enabling parent Act for the Local Content Regulations (SI No. 68/2025), completing Zambia's post-2024 three-Act resource-nationalism legislative stack.

On 25 March 2025 the European Commission adopted the first list of 47 Strategic Projects inside the EU under Article 7 of the Critical Raw Materials Act (Regulation (EU) 2024/1252), followed on 4 June 2025 by 13 Strategic Projects located in third countries — 60 designations in total. The 47 EU projects span 13 Member States and 14 strategic raw materials, with an expected EUR 22.5bn capital-investment envelope; the 13 third-country projects require a further EUR 5.5bn. Designation triggers fast-track permitting (max 27 months for extraction, 15 months for processing/recycling), preferential access to EU/EIB/EBRD finance, and Member State priority status, operationalising the CRMA's 2030 benchmarks (≥10% extraction, ≥40% processing, ≥25% recycling, ≤65% single-country dependence).