Navigating the Costs of Expansion: An Analysis of S.I. 18 of 2026
The Zimbabwean investment landscape has undergone a significant regulatory shift with the gazetting of Statutory Instrument (S.I.) 18 of 2026. Issued under the Zimbabwe Investment and Development Agency (ZIDA) Act, these regulations repeal the 2023 fee schedule and introduce a more structured—albeit more demanding—fiscal framework for Special Economic Zones (SEZs).
The timing of this S.I. aligns with the 2026 National Budget theme of “Enhancing Drivers of Economic Growth,” signaling a move toward higher accountability and the “weeding out” of speculative investors who hold land without development.
1. Breakdown of the New Fee Structure
The amendment replaces the First Schedule of the 2023 regulations. The costs are now clearly delineated across three roles: Developers, Operators, and Investors.
High-Entry Barriers for Zone Designation
The most striking change is the cost of designating a new SEZ. While the application remains a modest US$1,000, the SEZ Designation Certificate Fee is now set at US$25,000.
Comparative Fee Table
All fees are quoted in US Dollars, reflecting the government’s drive for stable, hard-currency revenue from large-scale investments.
| Category | Application Fee | Permit/Licence Fee | Annual Fee |
| SEZ Developer | US$1,000 | — | US$1,000 |
| SEZ Operator | US$1,000 | US$10,000 | US$1,000 |
| SEZ Investor | US$1,000 | US$4,000 | US$3,000 (Renewal every 3 yrs) |
Note: All Licences and Permits are valid for 10 years, subject to conditions.
2. Analysis of Impact: The “Quality over Quantity” Approach
The 2026 regulations represent a strategic pivot by ZIDA. By increasing the upfront and administrative costs, the agency is likely targeting two outcomes:
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Discouraging “Land Banking”: In the past, entities would apply for SEZ status to benefit from tax holidays without actually commencing operations. The US$25,000 certificate fee and US$5,000 resizing fee ensure that only well-capitalized entities apply.
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Administrative Sustainability: The introduction of high fees for replacing lost documents (US$3,000) and altering permits (US$3,000) reflects a push for greater corporate responsibility and administrative cost-recovery.
3. The Price of Delay: New Penalty Regime
A critical addition in S.I. 18 is the standardized penalty section. Previously, grace periods were often negotiated; now, they are strictly defined:
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Permit Renewals (Developers/Operators): Must be done within 6 months.
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Licence Renewals (Investors): Must be done within 3 months.
Failure to meet these deadlines, or a delay in paying the US$1,000 annual fee, results in a flat penalty of US$2,500. This “one-size-fits-all” penalty represents a significant risk for smaller investors within a zone.
4. Strategic Implications for Investors
While the fees have increased, the 10-year validity provides a decade of policy certainty. Investors should view these fees not just as costs, but as the “entry price” for the massive incentives SEZs offer, such as:
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Zero-rated Corporate Income Tax for the first 5 years.
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Duty-free importation of capital equipment and raw materials.
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Exemption from Non-resident Withholding Tax on dividends and fees.
Expert Insight: The US$25,000 designation fee is a clear signal that the government views SEZs as “Industrial Cities” rather than just business parks. Projects like the Manhize Integrated Industrial City set the tone for the scale of investment ZIDA is now looking for.
Summary Checklist for SEZ Compliance
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[ ] Budgeting: Ensure US$1,000 is set aside for the annual fee due each year.
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[ ] Renewal Tracking: Set a reminder for the 3-year Investor Licence renewal (US$3,000).
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[ ] Documentation: Keep digital copies of all permits; a physical replacement now costs US$3,000.
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[ ] Timeline: Review the 10-year permit expiration date to start the renewal process at least 6 months in advance.
