Legislative Analysis: Implications of the Revised Fee Structure Under the ZIDA (General Investments) (Amendment) Regulations, 2026 (No. 1)

Executive Summary

On February 6, 2026, the Government of Zimbabwe, through His Excellency the President and in terms of the Zimbabwe Investment and Development Agency Act [Chapter 14:38], promulgated Statutory Instrument (S.I.) 17 of 2026. This instrument introduces significant amendments to the existing fee structure governing investment licensure and administration handled by the Zimbabwe Investment and Development Agency (ZIDA).

The primary effect of S.I. 17 of 2026 is the complete repeal and substitution of the Second Schedule of the 2023 Regulations (S.I. 227 of 2023). The new schedule establishes a fee regime denominated explicitly in United States Dollars (US$), pegging administrative costs for both local and foreign investors to hard currency value, albeit with different payment mechanisms for local entities.

1. Introduction and Legal Context

The Zimbabwe Investment and Development Agency (ZIDA) serves as the country’s primary investment promotion body, tasked with streamlining business entry and facilitating both domestic and foreign direct investment. The agency operates under the ZIDA Act [Chapter 14:38].

Section 46 of this Act empowers the President to make regulations necessary for the administration of the agency and the implementation of the Act’s provisions. S.I. 17 of 2026 serves as the first amendment in 2026 to the “General Investments” regulations initially established in S.I. 227 of 2023. The focus of this amendment is entirely fiscal, specifically targeting the administrative fees charged for processing investment licenses and maintaining the investment register.

2. Key Provisions: The New Second Schedule

S.I. 17 of 2026 replaces the previous fee schedule with a revised structure. The most critical aspect of this revision is the denomination of all approved fees in United States Dollars (US$).

The new fee structure is broken down as follows:

A. Investment License Lifecycle Costs

The instrument bifurcates the initial licensing process into two stages: application and issuance.

• Application for Investment Licence: A non-refundable fee required to commence the evaluation process.

  • Foreign Investor: US$500

  • Local Investor: The equivalent of US$500 paid in Zimbabwe Gold (ZWG/ZWL) at the prevailing Interbank rate of Exchange.

• Issuance of Investment Licence (Upon Approval): A fee payable only after the investment proposal has been successfully vetted and approved.

  • Foreign Investor: US$4,000

  • Local Investor: The equivalent of US$4,000 paid in local currency at the prevailing Interbank rate of Exchange.

Therefore, the total initial administrative cost to secure a ZIDA license is effectively pegged at US$4,500 for both categories of investors.

B. Ongoing Compliance and Administrative Fees

The new schedule establishes flat-rate fees for post-licensing administrative actions, applicable to all investors regardless of origin:

• Renewal of Investment Licence: US$3,000

• Alteration or Amendment of Licence: US$3,000

• Replacement of Lost Licence: US$3,000

C. Information Access

• Request for Information/Inspection of Investment Register: US$100

3. Analysis and Implications

The promulgation of S.I. 17 of 2026 highlights several key policy trends and practical implications for the business community in Zimbabwe.

3.1. Hard Currency Pegging and Revenue Protection

The explicit denomination of all fees in US Dollars is the most significant feature of this S.I. In an economic environment characterised by currency volatility, pegging government administrative fees to the USD is a mechanism to protect the real value of ZIDA’s revenue streams against inflation. It ensures the agency maintains the financial resources necessary to carry out its mandate efficiently.

3.2. The Mechanism of Differential Treatment

While the value of the fees is uniform for local and foreign investors, the S.I. mandates differential payment mechanisms.

• Foreign Investors: Must pay in foreign currency (USD). This ensures a direct inflow of forex into the agency.

• Local Investors: Are mandated to pay the equivalent in local currency at the official Interbank rate.

This distinction is crucial. It acknowledges that local investors may not have immediate access to USD cash for administrative tasks, allowing them to use the domestic currency. However, by tying the amount to the Interbank USD rate, the cost burden remains equal in real terms to that of a foreign investor.

3.3. The High Cost of Maintenance and Compliance

Investors should note the significant costs associated with maintaining a license. While the initial application fee is relatively low ($500), the issuance fee is substantial ($4,000).

Furthermore, the fees for renewal, amendment, or replacement of a license are set at a flat rate of US$3,000. This is a high administrative bar. It suggests a policy directive aimed at ensuring only serious, capitalized entities maintain active ZIDA registration. It also places a premium on administrative diligence; losing a physical license certificate now carries a $3,000 replacement penalty.

4. Conclusion

Statutory Instrument 17 of 2026 provides clarity and certainty regarding the cost of engaging with Zimbabwe’s primary investment authority. By standardizing fees against the US Dollar, the government has signaled a preference for hard currency value in administrative dealings.

Prospective and current investors, both local and international, must update their financial projections to account for these USD-pegged costs, particularly the $4,500 initial licensing requirement and the substantial $3,000 fees for any subsequent amendments or renewals.