By Fanuel Chinowaita
Harare – The Climate Action Council of Zimbabwe (CACZ) has welcomed the passage of the Climate Change Management Bill (H.B. 5 of 2025) and Statutory Instrument 48 of 2025, describing the new framework as a “technically strong and internationally aligned” step towards implementing the Paris Agreement, but has cautioned that high fees, centralised powers and weakly enforceable participation rights could undermine inclusivity and local benefits.
In a detailed policy analysis authored by CACZ chief executive officer Anglistone T Sibanda and reviewed by climate governance expert Dr Keith Phiri, the Council says the Bill positions Zimbabwe as a continental leader in carbon markets, while at the same time raising “serious governance and equity concerns” that require urgent reform.
“Zimbabwe has put in place one of the most comprehensive climate governance and carbon market frameworks in Africa, with full Article 6 readiness and a technologically advanced national registry,” Sibanda said. “However, strong systems on paper do not automatically translate into fairness, inclusion and trust on the ground.”
According to the report, the Bill effectively domesticates Zimbabwe’s obligations under the Paris Agreement, including implementation of the country’s Third Nationally Determined Contribution (NDC 3.0), which targets a 40 percent reduction in per capita greenhouse gas emissions by 2035 compared to a business-as-usual scenario.
The legislation establishes a Climate Change Management Department, specialised technical units and the Zimbabwe Carbon Markets Authority (ZiCMA), which will regulate carbon trading and manage the Zimbabwe Carbon Credit Registry (ZCR).
“The Bill explicitly seeks to domesticate and implement international conventions on climate change, including the Paris Agreement, and it creates the legal backbone needed for credible participation in international carbon markets,” the report notes.
The Council also highlighted Zimbabwe’s recent milestone of completing the world’s first official corresponding adjustment and inter-registry transfer of carbon credits under Article 6, calling it “a significant achievement for environmental integrity and transparency”
While the law guarantees public participation, access to climate information and Free, Prior and Informed Consent (FPIC) for affected communities, CACZ warns that these rights risk remaining aspirational rather than enforceable.
“The law speaks strongly about participation and consultation, but in legal terms these are framed as guiding principles rather than hard rights,” Sibanda said. “That creates a real risk that communities, women and youth can still be sidelined in practice.”
The report points to past carbon projects, including forest-based initiatives, where communities were allegedly consulted late, excluded from decision-making, or unclear about how revenues were shared.
“Field evidence shows that top-down decision-making and elite capture are not theoretical risks – they have already happened in some projects,” the analysis states.
One of the strongest criticisms in the CACZ report relates to the fee structure under SI 48 of 2025, which it describes as “among the most onerous globally”.
Project developers face high upfront and annual costs, including registration fees of up to US$20 000, registry maintenance fees, and an auditor licensing fee of US$50 000. In addition, 30 percent of carbon credits are retained by the State as a share of proceeds, alongside other mandatory deductions.
“These costs create high entry barriers that effectively shut out community groups, small farmers, local NGOs and start-up developers,” Sibanda said. “Carbon markets will be dominated by large, well-capitalised players, mostly foreign, while local actors are reduced to spectators.”
CACZ argues that the 30 percent retention far exceeds international norms and contradicts the principle of a just transition.
“Under the Paris Agreement, the share of proceeds is around five percent for adaptation and two percent for administration. Zimbabwe’s 30 percent is simply too high,” the report states.
The Council also raised concerns about the concentration of authority in the hands of the Minister and ZiCMA, including powers to approve projects, manage the National Climate Fund, amend regulations and revoke project authorisations.
“When the Ministry becomes both referee and player, the risk of conflicts of interest is unavoidable,” Sibanda warned. “Centralisation can lead to political interference, slow decision-making and loss of investor confidence.”
The report cautions that such discretion could discourage investment and weaken accountability, particularly in the absence of independent oversight bodies.
Despite its criticisms, CACZ stressed that the Bill can still deliver inclusive climate action if reforms are implemented quickly.
Among its key recommendations are: reducing and tiering fees to accommodate community and small-scale projects; cutting or removing the 30 percent share of proceeds, especially for technology-based projects; establishing independent, multi-stakeholder oversight of the National Climate Fund; making FPIC and participation legally enforceable rights; and
restoring stronger roles for Rural District Councils and local monitoring committees.
“This law has the potential to support climate action, rural development and investment at the same time,” Sibanda said. “But without adjustments, it risks excluding the very people it is meant to protect.”
CACZ concluded that failure to address governance and cost barriers could erode public trust and undermine national development priorities.
“If communities lose access to land, if benefits do not reach local people, and if decision-making remains opaque, carbon markets will deepen inequality instead of reducing it,” the report warns.
The Council urged policymakers to act decisively, arguing that “fixing these weaknesses will help Zimbabwe meet its climate commitments while ensuring fairness, transparency and shared prosperity”.