Mining 2026

NORTH MACEDONIA Law and Practice Contributed by: Ana Tosic Chubrinovski, Ivica Jevtic, Ljupka Naumoska Gjorgjievska and Marija Boceska, JPM Partners North Macedonia

JPM Partners North Macedonia Leninova Street 38/1-2 1000 Skopje North Macedonia Tel: +389 23 162 222 Email: office.mk@jpm.law Web: www.jpm.law

1. Mining Law: General Framework 1.1 Main Features of the Mining Industry The mining sector in the Republic of North Macedo - nia is centred on polymetallic deposits, including cop - per, lead, zinc, gold and silver, together with industrial minerals such as limestone, aggregates, gypsum and clay. Historically, lignite played a key role in energy generation, although current decarbonisation policies are gradually reducing coal’s importance. Mining activities are carried out exclusively under state-awarded concessions granted by the govern - ment of the Republic of North Macedonia as the con - cession authority. Concessions are available to any qualified legal entity, including foreign companies operating through locally registered branches or sub - sidiaries, on equal legal footing with domestic inves - tors. Several major projects involve international capi - tal participation, particularly in underground copper and base metal developments. One of the most recent publicly recorded underground mining concessions was awarded to the legal entity BULMAK in 2016, which continues to operate active mining projects. Geological prospectivity remains strong, with under - explored reserves increasingly relevant for European supply chains of critical and energy-transition miner - als. 1.2 Legal System and Sources of Mining Law The Republic of North Macedonia has a civil law sys - tem. The principal statute governing the mining sec - tor is the Law on Mineral Resources, which regulates geological exploration, exploitation, concessions, roy - alties, mine closure, supervision and environmental

obligations. Concessions are awarded according to the Law on Concessions and Public-Private Partner - ships. Environmental regulation is primarily governed by the Law on Protection of the Environment (including mandatory environmental impact assessment (EIA) procedures), complemented by the Law on Nature Protection and the Law on Waters. The government of the Republic of North Macedonia is currently preparing a new Law on Mining and a new Law on Geology, intended to align national legisla - tion with Regulation (EU) 2024/1252 – the Critical Raw Materials Act (CRMA). Policy direction is provided by the National Strategy for Geological Exploration and Sustainable Use of Mineral Resources 2025–45. 1.3 Ownership of Mineral Resources Mineral resources are state-owned public goods. Ownership of surface land does not include rights over underground mineral deposits. Exploration and exploitation rights may be obtained only through a concession granted by the state – ie, the government of the Republic of North Macedonia. Concessions provide exclusive rights to explore or exploit within a defined area but do not confer ownership of the mineral deposit. 1.4 Role of the State in Mining Law and Regulations The state is the sole owner of mineral resources, which are classified as goods of public interest under national law. The state acts exclusively as a grantor and regulator of mineral rights and does not partici - pate as an owner-operator in mining activities. No

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