ZIMBABWE Law and Practice Contributed by: Nellie Tiyago and Rudo Magundani, Scanlen & Holderness
• agriculture – land use permits, agro-processing licences and veterinary approvals. Whilst an investor is permitted to invest in any sector of the economy in Zimbabwe, certain sectors have been reserved for locals. To participate in those sectors, an investor would have to seek specific approval from the Zimbabwe Investment and Development Agency (ZIDA) and the minister responsible for indigenisation. The reserved sectors/enterprises in 2024 were agri - culture (primary production of food and cash crops); transportation (passenger buses, taxis and car hire services); retail and wholesale trade; barber shops; hairdressing and beauty salons; employment agen - cies; estate agencies; valet services; grain milling; bakeries; tobacco grading and packaging; tobacco processing; advertising agencies; milk processing; the provision, marketing and distribution of local arts and craft; and artisanal mining. In 2025, the following were added: haulage trucking, borehole drilling, customs clearing, shipping and for - warding, and pharmaceutical retailing. 2. Recent Developments and Market Trends 2.1 Current Economic, Political and Business Climate Exchange Control Guidelines to Authorised Dealers and their Clients on Foreign Exchange Transactions In August 2025, the RBZ issued the aforementioned guidelines, which consolidate all previous foreign exchange directives up to 22 April 2025. Of note with respect to FDI are the following provisions. • Supplier credit agreements: All credit-based supply contracts, arrangements or agreements entered into by corporate entities must be registered with the RBZ. A report detailing the goods or services received under such agreements must be submit - ted to the RBZ within 14 days of receipt. • Recurring service agreements: Where service provision (professional, technical, consultancy, management, administrative, software-related, or
involving royalties/franchises) entails recurring fees, the underlying agreement must be registered with the RBZ. Once registered, payments may be pro - cessed without further reference to the RBZ. • Import administration: All importers must be duly registered. Authorised dealers may process import-related transactions for both corporates and individuals without requiring prior approval from the RBZ. • Service payment thresholds: To mitigate risks associated with illicit financial flows (IFFs), the total value of service payments made by local compa - nies to both related and unrelated entities must not exceed 3% of the company’s audited or projected gross annual revenue. • Disinvestment proceeds: Foreign investors are permitted to remit disinvestment proceeds, includ - ing capital gains, subject to prior approval from the RBZ. • Restructuring involving foreign shareholders: Any corporate restructuring that alters the sharehold - ing structure of a local entity and involves a foreign shareholder requires prior RBZ approval. • Participation in local stock exchanges: Foreign investors and non-residents may invest in shares listed on local currency-denominated exchanges such as the Zimbabwe Stock Exchange (ZSE) and Financial Securities Exchange (FINSEC), provided the purchase is funded via inward transfer of for - eign currency through formal banking channels. No prior RBZ approval is required. However, foreign ownership is capped at 49% of total equity, with a single investor limited to a maximum of 15% of the shares on offer. • Bond subscriptions: Foreign investors may sub - scribe to up to 100% of primary bond issuances, provided the investment is financed through inward foreign currency transfers via normal banking channels. • Guarantees involving non-residents: Any guarantee where one or both parties are non-resident requires prior approval from the RBZ. • Non-equity capital contributions: Foreign investors may inject capital into local entities outside tradi - tional equity or debt structures, with the intention of participating in the company’s risk and return. Such arrangements require prior RBZ approval. Eligible sectors for profit-sharing structures include
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