How Zimbabwe Has Changed the Rules of Energy Investment

Instrument-by-instrument analysis of the ten energy statutory instruments in Government Gazette Vol. 55 (31 July 2026), what problem each one solves, the actual fees and numbers involved, and what it means for renewable energy uptake and Zimbabwe’s Just Energy Transition

1. What just happened, in plain terms

On 31 July 2026, Zimbabwe gazetted ten statutory instruments covering electricity and petroleum regulation.[1] Taken together, they amount to a restructuring of the energy market rather than a simple tweak to solar licences or tariffs. This note goes through the actual legal texts instrument by instrument, explains the problem each one was written to fix, sets out the real numbers involved, honestly assesses whether each instrument actually solves the problem it targets, and explains specifically what each one means for renewable energy investment and Zimbabwe’s Just Energy Transition.

In short, Zimbabwe has made it cheaper and faster to build small and mid-sized renewable generation, made energy efficiency a legal obligation for big energy users, upgraded net metering into a genuinely commercial tool, and opened the door for private companies to build electricity infrastructure and even run their own mini-grids in unserved areas. In exchange, businesses now face more reporting, more licensing, and more compliance. This is not deregulation without conditions, it is a shift from permission to performance.

2. The instruments:

S.I. 125 of 2026: Electricity (Licensing) (Amendment) Regulations, 2026 (No. 2)

The problem

Before this amendment, every generation project, whether it burned diesel or ran on solar panels, paid the same licensing fees. There was no financial incentive within the licensing system itself for an investor to choose renewable energy over fossil-fuel generation, which undermined Zimbabwe’s renewable energy and emissions goals.

What it does, and the numbers

The amendment rewrites the fee schedule for electricity licences and, for the first time, treats renewable and non-renewable generation differently. For renewable generation for own consumption, of any size, there is no licence fee at all. For commercial renewable projects up to 10 MW, there is also no licence fee, only the standard US$20 application fee. Above 10 MW, renewable commercial projects pay a fixed amount plus a variable charge for every extra 25 MW, and the amount differs by technology, as set out below.[2]

Renewable generation licence fees above 10 MW

By comparison, a non-renewable commercial plant above 10 MW pays a flat US$10,000 plus US$5,000 per 25 MW, roughly two to three times the fee a solar or wind project of the same size would pay. Transmission and distribution licences remain expensive regardless of technology. A primary transmission or distribution licence costs US$60,000, secondary transmission US$50,000, bulk supply US$50,000, and retail supply US$40,000.

Does it solve the problem?

Yes, clearly. Renewable energy now has a real, quantifiable cost advantage over fossil fuel generation within the licensing system itself, exactly the gap this instrument set out to close.

How this increases renewable uptake and supports the Just Energy Transition

This is one of the strongest direct financial incentives for renewable energy in the entire package. Removing licence fees altogether for renewable projects up to 10 MW, the size range covering most mines, factories, farms and commercial buildings likely to invest in solar or wind in the next few years, takes a real cost out of every project’s budget and makes renewable energy the cheaper regulatory choice, not just the cleaner one.

S.I. 126 of 2026: Electricity (Own Consumption Undertakings Licensing Capacity) Regulations, 2026

The problem

A business that wanted to generate its own electricity, for example, a mine installing solar panels purely to power its own operations, previously had to go through the same lengthy, expensive licensing process as a company building a power station to sell electricity to the public.[3] That process was designed for utility-scale generation and was a poor, slow fit for a factory or farm simply wanting to cut its own power costs.

What it does, and the numbers

Own-consumption generation above 10 MW still needs a full generation licence. But for anything between 100 kilowatts and 10 MW, generating power purely for the owner’s own use, the company now only needs to register, not obtain a full licence, before it starts building. Registration means filling in Form GFOC1, attaching a grid impact assessment report, company registration papers, proof of access to the land, and an environmental impact assessment or an exemption letter, and paying a registration fee of just US$10.[4] Once construction is finished, the company files Form GFOC2 with a commissioning certificate before switching on. ZERA then publishes a quarterly public notice listing all registered facilities.

Does it solve the problem?

Largely yes. A US$10 registration process that can be completed before construction begins is dramatically faster and cheaper than a full generation licence.  It is also worth flagging that, although Form GFOC1 collects site coordinates and evidence of land access, nothing in the regulation requires the applicant to consult the community on whose land the facility will sit, or to obtain their free, prior and informed consent, a gap that matters as these projects scale into communal and resettlement areas.[5]

How this increases renewable uptake and supports the Just Energy Transition

This is also a very important for driving renewable energy investment. Mines, factories, farms, hotels, schools and telecoms companies, exactly the energy-intensive users Zimbabwe most needs to shift onto cleaner power, can now install their own solar generation for a US$10 registration fee instead of a full licensing process. That is a genuine, practical unlock for the kind of decentralised, private-sector-led renewable investment the Just Energy Transition depends on. The reforms come as Zimbabwe continues pursuing greater private-sector participation in electricity generation to address persistent power shortages and support industrial growth.

S.I. 127 of 2026: Electricity (Net Metering) (Amendment) Regulations, 2026 (No. 2)

The problem

Under the old net metering rules, a company with solar panels could only offset its electricity bill at the exact site where the panels were installed. A retail chain, bank, or farming business with several branches or plots could not pool solar credits across sites, so unused generation at one branch was simply wasted rather than benefiting the business as a whole. There was also no clear, guaranteed right to be paid for genuinely surplus electricity left over at the end of the year.

What it does, and the numbers

The amendment introduces virtual net metering. Credits generated at one site can now be transferred to another site, or group of sites, even in a different area, as long as the applicant can prove ownership or lease of the sites, show a genuine commercial relationship between them, and hold a net metering certificate.[6] The distribution company must decide on such an application within 21 days. Whoever wants to link their sites this way pays the cost of connecting them into the system. At the end of every annual billing cycle, participants must now be paid for any left-over electricity they exported to the grid, though the actual rate per unit has not been fixed in the regulation itself; it will be set later by the Authority through the tariff code, and payments will be taxed and subject to other applicable levies.[7]

Does it solve the problem?

Partly. The multi-site pooling problem is genuinely solved. The right to be paid for surplus power is a real improvement, but because the actual rate has not yet been published, businesses cannot yet calculate how much extra income to expect, so the financial case is not fully provable until the Authority issues the tariff.

How this increases renewable uptake and supports the Just Energy Transition

For any organisation with solar across more than one site- banks, retail chains, farms, property portfolios- this turns previously wasted excess generation into a shared, and eventually paid-for, resource. That materially improves the return on investment for embedded solar at scale, once the payment rate is confirmed, and also the monetisation of excess energy moving from the credit system, boosting uptake of solar net metering.

S.I. 122 of 2026: Electricity (Energy Management) Regulations, 2026

The problem

Zimbabwe’s biggest electricity users, mines, factories, farms, and large commercial or institutional buildings, had no legal obligation to measure, manage, or reduce how much energy they used. This meant avoidable waste, unnecessary strain on an already stretched national grid, and no formal link between industrial energy efficiency and Zimbabwe’s carbon market and climate commitments.

What it does, and the numbers[8]

The regulation applies to any “designated facility”, meaning any site with installed capacity of at least 100 kVA, or classified by its electricity supplier as a maximum demand customer, which in practice covers most large mines, factories, farms and commercial buildings. These facilities must, within 12 months of the law taking effect, file an energy management policy (following the international ISO 50001 standard), appoint a licensed energy manager, and set up an internal energy management committee. Every three years, they must have an independent energy audit, then submit a three-year energy efficiency investment plan responding to that audit, and must implement enough measures to achieve at least 50 per cent of the identified savings within those three years. Annual implementation reports and quarterly and annual energy-use returns are compulsory.  An efficiency investment plan may also be considered for funding through a “revolving energy savings fund”, or registered under a carbon finance mechanism, meaning it could generate carbon credits.

Does it solve the problem?

Largely yes, on design. It is a comprehensive, binding regime with a real numerical target. At least half of identified savings must actually be delivered within three years, not just planned. The gap is in the capacity of the regulator to enforce and monitor the implementation. Another gap worth mentioning is the financing gap. The revolving fund and the carbon finance route are only mentioned in passing, with no detail yet on how either will be capitalised or accessed, so their real usefulness depends on guidelines ZERA has not yet published.

How this increases renewable uptake and supports the Just Energy Transition

Every unit of energy a mine or factory saves through this regime is a unit that does not need to come from new generation capacity, freeing up scarce grid headroom that can instead go to new renewable connections. The explicit link to carbon finance also connects this regulation directly to Zimbabwe’s Carbon Trading Regulations (S.I. 48 of 2025)[9], meaning efficiency compliance and carbon markets are now formally joined up, a genuinely useful structural building block for the transition.

S.I. 128 of 2026: Electricity (Provision of Backbone Infrastructure) Regulations, 2026

The problem

There was no clear rule on who should pay for and own the basic electricity infrastructure, power lines, transformers, and substations needed to connect a new housing estate, industrial park or commercial development to the grid. This created disputes between developers and the national utility and slowed down electrification of new developments. At the same time, there was no realistic legal route for a private company to build and run electricity infrastructure in areas that had no power at all.

What it does, and the numbers

Land developers must now finance and build all the backbone electricity infrastructure for their own developments entirely at their own cost, with no reimbursement from the utility.[10] Once inspected and certified, this infrastructure is handed over to the primary distribution licensee for free, and the developer must guarantee it for five years.[11] Separately, private companies can now bid competitively to become independent distribution licensees serving areas that currently have no electricity supply, on a renewable 25-year licence.[12] Bids are judged on cost (30 per cent of the score), technical capacity (40 per cent) and financial capacity (30 per cent), and the winning company’s prices to customers cannot exceed the standard national utility tariff.[13] Any person who contravenes the provisions of these shall be guilty of an offence.[14]

Does it solve the problem?

Partly. It clearly settles who pays for new development infrastructure- developers do- and creates a genuine new legal route for private companies, potentially running renewable mini-grids, to serve unserved communities over a bankable 25-year period. But capping their prices at the standard national tariff sits awkwardly against the reality that off-grid or mini-grid power, especially solar mini-grids in remote, low-density areas, usually costs more to deliver than grid power, which could discourage investment in exactly the hardest-to-reach communities this instrument is meant to help. As with S.I. 126, there is also no requirement for the affected community to be consulted, or for its consent to be obtained, before an independent distribution licensee is awarded a 25-year licence to serve its area.

How this increases renewable uptake and supports the Just Energy Transition

The independent distribution licensee model is potentially an important vehicle for rural electrification using solar mini-grids, directly relevant to community energy access goals under the Just Energy Transition. Whether it delivers on that promise will depend on whether the tariff cap is later adjusted, or paired with a subsidy, to make mini-grid economics work in the low-density, high-cost areas that most need power.

S.I. 118 of 2026: Electricity (Export Control) Regulations, 2026

The problem

Zimbabwe previously had no clear, time-bound legal process for electricity generators or suppliers wanting to sell power across the border, for example into the Southern African Power Pool. That uncertainty discouraged investors from planning export-oriented projects, and also raised the risk that scarce local supply could be exported without adequate protection for domestic consumers.

What it does, and the numbers

Any licensee wanting to export electricity must apply to ZERA, attaching a wheeling agreement, a use-of-system agreement, a local power purchase agreement, an off-take agreement with the foreign buyer, and, where relevant, proof of Southern African Power Pool membership.[15] ZERA must decide within 45 days. Exports are capped. A generation licensee can export no more than 30 per cent of its available capacity, and a retail supply licensee no more than 20 per cent of its contracted capacity. Export tariffs cannot be lower than what is charged to local customers. Breaking these rules is a criminal offence, carrying a fine of up to level five or up to six months in prison, or both.[16]

Does it solve the problem?

Largely yes. Investors now have a defined, 45-day approval process and clear limits, which is a real improvement in predictability. The trade-off is that the 30 and 20 per cent caps limit how much revenue an export-focused project can realistically expect to earn from cross-border sales, so large projects built primarily around export revenue will need to test their numbers carefully against these ceilings. The gap is the lack of criteria, cost components, or approval process the Authority will use to determine wheeling charges. Exporting licensees are therefore unable to establish, in advance, what a material component of the cost of exporting power will be. Another gap worthy noting is the absence of import regulations which like the export regulations set out the import cap of electricity.

How this increases renewable uptake and supports the Just Energy Transition

This gives utility-scale solar and wind developers a clear, bankable pathway to sell surplus power regionally, which supports larger renewable investments that blend domestic supply with export revenue. It does not, on its own, make export-only renewable projects more attractive, since the capacity caps limit how much of the plant’s output can be sold abroad.

S.I. 119 of 2026: Electricity (Minimum Energy Performance Standards for Appliances and Labelling) Regulations, 2026

The problem

Zimbabwe has for years imported and sold appliances, fridges, air conditioners, kettles, and washing machines, with no minimum efficiency requirement at all. Inefficient appliances quietly push up national electricity demand and household bills, adding pressure to the grid that could otherwise be avoided.

What it does, and the numbers

Anyone importing, manufacturing, distributing or selling any of 27 listed categories of appliances must register with ZERA, meet a minimum efficiency standard for that product referencing international and Zimbabwean standards (including IEC, SANS, AHRI and Zimbabwe Standards), obtain a conformity certificate from an accredited testing facility, and display a five-star or A-to-G colour-coded efficiency label. Products already in the country before the law took effect get a grace period of six months to one year to be sold off. Breaking the rules is a criminal offence carrying a fine of up to level five, or up to six months in prison, or both.[17]

Does it solve the problem?

In principle, yes, it should slow the growth of avoidable electricity demand. In practice, it depends entirely on how much of Zimbabwe’s accredited testing capacity actually exists for all 27 appliance categories; where local testing is thin, the law allows fallback certification from the country of origin, but enforcement strength will vary by product until local capacity is confirmed.

How this increases renewable uptake and supports the Just Energy Transition

Every unit of demand avoided through more efficient appliances is a unit that does not need to be generated at all, whether from renewable or fossil sources. That makes it easier for Zimbabwe’s growing renewable capacity to actually close the supply gap, rather than being outpaced by demand growth driven by inefficient equipment.

S.I. 121 of 2026: Electricity (Public Safety) (Amendment) Regulations, 2026 (No. 1)

The problem

The 2018 Public Safety Regulations did not formally recognise “renewable energy engineer” as its own professional category, leaving ambiguity about who is legally qualified to design, install or certify renewable energy systems in Zimbabwe.[18]

What it does, and the numbers

The amendment updates several definitions in the principal regulations, and, notably, adds “electrical or mechanical or renewable energy engineer” as a formally recognised professional category, defined as a person holding a relevant university or college qualification and relevant experience recognised by their professional body.[19] There are no fees attached to this instrument; it is purely a definitional update.

Does it solve the problem?

Partly. It gives renewable energy engineers formal legal recognition for the first time, which is an important first step, but it does not on its own create a dedicated licensing or accreditation system specifically for renewable energy installations, unlike the detailed licensing regime the energy management regulations create for auditors and energy managers.

How this increases renewable uptake and supports the Just Energy Transition

Formal professional recognition supports the growth of a skilled renewable energy workforce, one of the persistent bottlenecks that has slowed solar and wind project delivery in Zimbabwe, and gives renewable engineers clearer standing in future accreditation and regulatory processes.

S.I. 120 of 2026: Electricity (Electric Vehicle Charging Station Safety) Regulations, 2026

The problem

Electric vehicles are beginning to appear on Zimbabwean roads, but there were no safety rules covering the charging equipment that plugs them into the electricity grid, an obvious hazard given the variable quality of electrical installations in the country, and a barrier to public and investor confidence in electric mobility infrastructure.[20]

What it does, and the numbers

The regulations set detailed technical safety requirements. Charging stations must run on their own dedicated circuit, be protected by safety switches (residual current devices) able to detect earth faults, have correct earthing with a monitoring system that shuts off power if the earth connection fails, be protected against overloads, and have plug sockets mounted at least 800 millimetres above ground level. Charging equipment must carry a supplier declaration of conformity to IEC or UL international standards and undergo periodic safety assessment. There are no fees prescribed in this instrument; it is a technical and safety code.[21]

Does it solve the problem?

Yes, comprehensively, on the safety question it was written to address.

How this increases renewable uptake and supports the Just Energy Transition

The regulation is about electrical safety, not about where the electricity comes from, so its effect on renewable uptake is indirect. Safe, properly regulated EV charging infrastructure supports Zimbabwe’s shift toward electrified transport, which can in future be powered by solar. This links with Statutory Instrument 35 of 2025, the Customs and Excise (General) (Amendment) Regulations, which offers a rebate of duty on imported equipment and machinery for establishing solar-powered charging stations for electric vehicles (EVs).

S.I. 129 of 2026: Energy Regulatory (Designation of Energy Source) Notice, 2026

The problem

For ZERA to properly regulate every form of energy used in Zimbabwe, from solar panels to nuclear power, the law first needed a clear, formal list of exactly what counts as an “energy source” under the Energy Regulatory Act.

What it does, and the numbers

This short notice formally declares solar, wind, geothermal, biomass, biogas, water, nuclear, coal bed methane, coal, petroleum products, ethanol, and waste-to-energy as designated energy sources under ZERA’s jurisdiction.

Does it solve the problem?

Mostly, but it also opens up a new problem worth flagging. As a foundational designation, it does the job. But folding nuclear into the same generic list as solar, coal and biomass, to be regulated by ZERA, a body whose core mandate is licensing, tariff-setting and promoting investment, sits awkwardly next to Zimbabwe’s existing, separate nuclear and radiation safety regulator, the Radiation Protection Authority of Zimbabwe (RPAZ), established under the Radiation Protection Act [Chapter 15:15] of 2004. Since September 2023, Zimbabwe has been bound by the IAEA Convention on Nuclear Safety, which requires nuclear safety regulation to be kept institutionally separate from any body with a promotional or economic mandate over the same energy source, exactly the role ZERA plays. [22]S.I. 129 creates ambiguity as to which body is, for Convention purposes, the regulatory body for nuclear installations in Zimbabwe, a risk that will only grow as Zimbabwe’s interest in nuclear power, including potential small modular reactor deployment referenced in its National Development Strategy and Vision 2030^[23], develops.

How this increases renewable uptake and supports the Just Energy Transition

This instrument treats renewables, coal and nuclear as equals under the law and it does not itself favour renewable energy. The real renewable-friendly signals in this package come from the fee waivers and licensing shortcuts in S.I. 125 and S.I. 126, not from this designation.

Conclusion: Reading the package as a whole

Put together, the pattern is consistent. Zimbabwe has removed cost and process barriers at the point of entry, especially for renewable projects up to 10 MW, while adding new, ongoing obligations once a project or facility is operating, including energy audits, licensed professionals, reporting, export controls, and infrastructure financing responsibilities. None of the instruments sets a renewable energy target, quota, or mandate. The push toward renewables comes entirely through making renewable energy cheaper and easier to build than the alternative, not through requiring anyone to build it.

The strongest, most concrete wins for renewable uptake are the licence fee waiver for renewable projects up to 10 MW (S.I. 125) and the light-touch US$10 registration process for own-consumption generation in the same range (S.I. 126). The most important structural piece for the long-term transition is the energy management regime (S.I. 122), because it creates a mandatory link between industrial efficiency and carbon finance. The biggest unresolved questions sit in the instruments that promise the most but leave key numbers undecided, namely the net metering payment rate (S.I. 127) and the financing detail behind the revolving energy savings fund (S.I. 122), both of which will only become fully bankable once the Authority publishes the guidelines and rates it has not yet released.

Three gaps run across the whole package and are worth reading together rather than instrument by instrument. First, public participation is largely absent, not just for communities but for everyone. Nothing requires the Authority to consult the public before the promulgation of the SIs in the first place and also in setting the S.I. 127 net metering payment rate, designing the S.I. 122 revolving fund, or evaluating S.I. 128 independent distribution tenders, and nothing requires an own-consumption or backbone infrastructure project under S.I. 126 or S.I. 128 to consult the community whose land it will use, even though the forms involved already collect site coordinates and land access evidence. Second, the designation of nuclear as an energy source under S.I. 129 regulated by ZERA, an economic and promotional regulator, sits uneasily next to Zimbabwe’s existing nuclear safety regulator, the Radiation Protection Authority of Zimbabwe, and Zimbabwe’s 2023 accession to the IAEA Convention on Nuclear Safety, which requires nuclear safety regulation to stay institutionally separate from bodies with a promotional mandate.Third, the existence of an export cap warrants a corresponding import cap, which is currently absent from the regulations. Addressing these gaps improves and strengthens the enforceability of the regulatory framework .

[1] Government Gazette Extraordinary, Vol. 55 (31 July 2026).

[2] Electricity (Own Consumption Undertakings Licensing Capacity) Regulations, 2026, S.I. 126 of 2026, sections 3 to 5 (registration threshold of 100kW to 10MW, Form GFOC1/GFOC2, US$10 registration fee).

[3] Section 42 of the the Electricity Act

[4]  Section 4 of SI 126 of 2026;  https://thezimbabwemail.com/business/zimbabwe-cuts-licensing-costs-for-small-power-plants-in-major-boost-to-private-electricity-investment/

[5] Schedule Form GFOC2 of S.I. 126 of 2026

[6] SI 127 of 2026 insertion of section 10 of the principal Regulations

[7] SI 127 of 2026 section 11 amendment of the principal Regulations

[8] S.I. 122 of 2026: Electricity (Energy Management) Regulations, 2026

[9] Carbon Trading (General) Regulations, S.I. 48 of 2025.

[10] Section 5 of the Electricity (Provision of Backbone Infrastructure) Regulations, 2026, S.I. 128 of 2026,

[11] Section 6 of SI 128 of 2026

[12] Section 12 of SI 128 of 2026

[13] Section 14 of SI 128 of 2026

[14] Section 17 of SI 128 of 2026

[15] Section 4 of SI 118 of 2026

[16] Section 5 of SI 118 of 2026

[17] Electricity (Minimum Energy Performance Standards for Appliances and Labelling) Regulations, 2026, S.I. 119 of 2026, made under section 65 of the Electricity Act [Chapter 13:19]

[18]  Section 2 of the Electricity (Public Safety) 2018.

[19] Electricity (Public Safety) (Amendment) Regulations, 2026 (No. 1), S.I. 121 of 2026, section 2, amending the definitions in the Electricity (Public Safety) Regulations, 2018 (S.I. 177 of 2018).

[20] https://www.heraldonline.co.zw/zimbabwean-government-sets-regulations-on-use-of-electric-vehicles/

[21] Electricity (Electric Vehicle Charging Station Safety) Regulations, 2026, S.I. 120 of 2026 [CAP. 10:11], sections 5 to 8 (compliance with standards, charging station setup, periodic assessment, electrical safety).

[22] Convention on Nuclear Safety, 1994, art 8(2). Zimbabwe acceded to the Convention in September 2023.

^[23] Government of Zimbabwe, National Development Strategy 1, 2021 to 2025; Government of Zimbabwe, Vision 2030.