With the Zimbabwe Climate Change Management Bill H.B. 5 of 2025 having reached the second reading stage in parliament, there is no better time for all who are likely to be required to comply with the stipulations of the upcoming law to get set and ready to take the needed action.
To be eventually known as the Climate Change Management Act of 2025, the published bill provides for the regulatory framework for enhanced climate change mitigation and adaptation actions, regulation of greenhouse gas emissions and measures to reduce the use of ozone depleting substances in Zimbabwe.
The crafting of the law is a similar act, among many, to that of South Africa’s Climate Change Act 22 of 2024, and the Zambian Green Economy and Climate Change Act of 2024. Climate Change Management Act of 2025 will stalwartly serve to facilitate the domestication of the implementation of provisions of international obligations related to climate change and ozone layer protection.
Globally, the nation is not only a party to the Montreal Protocol on Substances that Deplete the Ozone Layer and the Vienna Convention for the Protection of the Ozone Layer, but has also acceded the various amendments related to these global agreements, with the latest being the Kigali Amendments in October 2022. Zimbabwe is also a party to the United Nations Framework Convention on Climate Change (UNFCCC) and ratified the Paris Agreement in September 2017.
At regional level, the Act will back Article 12 of the Southern African Development Community’s Protocol on Environmental Management for Sustainable Development which mandates all member states to adopt the necessary legislative and administrative measures to enhance adaptation to the impacts of climate change and to take nationally appropriate voluntary climate change mitigation measures. The African Union’s Climate Change and Resilient Development Strategy and Action Plan also promotes the need for national climate laws – hence the new Act will be in tandem to this as well.
Section 73 of the current constitution of Zimbabwe embodies the foundation for the protection of the environment and it speaks to every person having a right to an environment that is not harmful to their health or wellbeing. In line with this, there already are in existence several policies in favor of environmental protection and having special emphasis on climate change management, such as the National Climate Policy, the Long-Term Low Greenhouse Gas Emission Development Strategy (LEDS), The National Adaptation Plan and the Zimbabwe National Response Strategy on Climate Change.
The legislation on the horizon will serve as the general framework within which plans, policies and strategies for climate change management will be formulated. Where any section of any other policy relating to climate change is in conflict or inconsistent with the Climate Change Management Act, the later shall prevail. The law will essentially replace the almost disjointed approach previously sprinkled across environmental statutes through a unified system aimed at building resilience and the transition into a low carbon economy. Through the Climate Change Management Act, Statutory Instrument 48 of 2025 will get a backbone to support it and Statutory Instrument 49 of 2023 will also find a “new home” to accommodate it.
The Ministry of Environment, Climate and Wildlife’s Climate Change Management Department (CCMD) will be responsible for the implementation and administration of the law under the guidance of a director who will be assisted by deputy directors. These deputy directors will each be in charge of the four units in which the department is subdivided into - Climate Transparency and Compliance Unit; National Ozone Unit; Loss and Damage Unit; and the Carbon Trading Unit. In addition to these four units, liaison committees will be created following the guided decision of the Minister in relation to who will be a member of the committees. It will be good to see civil society also taking space in these committees.
Currently the Climate Change Management Department only has its presence in Harare. Given the gravitas of the work at hand it will make business sense to decentralize to lower echelons such as provinces and districts. Doing so will no doubt come with a dent on the country’s already strained budget. This will nevertheless translate to money well spent if the core business at hand is rightfully executed as it should - Zimbabwe is one of the many country vulnerable to the vagaries of climate change and addressing the causes and effects of the global phenomenon is very detrimental to the progression of the teapot shaped country.
A quick scan of the bill can make one lead to the supposition that it’s key major focus points are carbon credit markets, the requirements for the provision of information related to greenhouse gas emissions and ozone depleting substances. One will easily be forgiven for jumping to conclude that the new law seems to be skewed more towards mitigation than adaptation. Focus on adaptation is partly catered through the planned formation of a National Climate Fund. A minimum of USD$ 19 billon is needed to rollout the ambition stated in Zimbabwe’s third Nationally Determined Contributions (NDC 3.0). The Minister will be a trustee of the fund and he or she, in consultation with CCMD, shall establish regulations and standard operating procedures outlining how the fund can be accessed.
The prospective legislation will strengthen the structured carbon market infrastructure the country has in place. Zimbabwe has made admirable trailblazing feats such as making history by establishing the first of its kind block chain based registry. In that vein, the first edition of the Africa Voluntary Carbon Credits Market Forum was held in Victoria Falls in 2023. The tourist town was the same location where the Southern African Alliance on Carbon Markets and Climate Finance was launched this year.
The launch subsequently led to the Government of Zimbabwe being appointed to chair and host the interim secretariat until final governance arrangements are finalized. Still on the trail of great moves in the carbon credits markets, through credits generated by a clean cook stove project led by a Cicada Carbon, Zimbabwe issued Article 6 carbon credits with Corresponding Adjustments through the Gold Standard registry. This was a big milestone for Africa in international carbon markets governed by the Paris Agreement.
The performance of the carbon credit market in Zimbabwe is currently behind compared to other countries in Africa and the world over. The Zimbabwe Carbon Registry website has no information on the amount of carbon credits sold. The statistics found there translate to a figure of about one percent for rate retirement of issued credits. According to data from the 2026 African Carbon Markets Initiative, the republic failed to find a spot in the top ten African countries for carbon credit retirements performance. Again, Zimbabwe failed to be rated within the top forty best performers with regards to the Abatable Voluntary Carbon Market Investment Attractiveness Index. There could be explainable reasons behind this. Some of them could probably be the Kariba Redd+ project phantom or junk credits scandal and the subsequent suspension of the carbon credit market in 2023. A Swedwatch investigation is said to have also unearthed how, under two cook stove projects, communities in Chimanimani were neither consulted nor given an opportunity to negotiate a fair and transparent benefit sharing agreement with the project developer.
It is imperative to have more confidence being put up around the carbon credits market in the country as there are opportunities to be reaped, especially opportunities to build the resilience and adaptive capacity of disadvantaged communities in the frontline of the effects of climate change. Project developers have to reign in all of the ten core carbon principles in their project design and implementation. Doing so will draw buyers.
CCMD together with the Environmental Management Agency (EMA) are expected to come up with greenhouse gas emissions thresholds that are not to be exceeded by emitters. Violations may result in fines or imprisonment. Going above the pegged caps would see entities either having to purchase carbon credits or pay a levy under the Finance Act. Entities will be obliged to submit verified data on emissions, adaptation, financing and carbon trading. In that vein, businesses will need to put in place assurance systems so as to avoid unnecessary litigation.
It goes without saying that the submission of the GHG emissions by those needed to supply the information is very detrimental to the compilation of the National GHG Inventory and the subsequent fulfillment of Zimbabwe’s reporting obligations such as the Bi Annual Transparency Report (BTR) and the National Communications to UNFCCC. Accurate and timely reports gives the country a good standing.
Who, every two years or as recommended, is to provide records of their greenhouse gas emissions is not fully unpacked by the bill. Neither is it spelt out the type of emissions to be recorded and subsequently reported. Looming questions could be will Scope 1 or direct emissions be the only type of emissions to be measured, reported and verified or Scope 2 and 3 emissions making form of indirect emissions also need to be covered by the data providers. Again, what will be the position of the regulation on emission measurements from the informal sector?
The country’s third Nationally Determined Contributions commits Zimbabwe to a forty percent per capita GHG reduction by 2030 across its focus sectors. These sectors are energy, industrial processes and product use (IPPU), waste, and agriculture, forestry and other land use (AFOLU). Could these ultimately be the sectors where data will be required to be drawn from? Whichever the verdict is, CCMD would need to come up with a comprehensive taxonomy of reportable activities against which data providers are required to report their GHG emissions on.
The date when the law will come in full force is not yet certain. What is certain is that prospective data providers can attune to the stipulations of the law particularly by taking stock of their carbon emissions. Businesses having experience with Environmental Social and Governance (ESG) frameworks such as the Green House Gas (GHG) Protocol, Carbon Disclosure Project (CDP), and Global Reporting Initiative (GRI) might have an advantage of acclimatizing quicker to the climate policy regulations on reporting and disclosure over those that do not have.
Greenhouse gas emission tracking might somewhat appear as a cumbersome task, especially tracking of Scope 3 emissions, but this exercise can actually be used as a forward looking strategic tool for enterprises. Through the lenses of emissions tracking, opportunities for efficiency can be identified. Business undertakings would definitely need to come up with internal carbon pricing (ICP) mechanisms and put a price on their carbon emissions. They would similarly have to build data sets that capture what they burn, buy and is beyond in terms of their carbon footprint.
The Minister, in consultation with Finance Ministry, may grant incentives to entities that reduce emissions, adopt renewable energy, implement adaptation measures or provide accredited climate training. It will be interesting to see if the regulations to establish the National Emissions Trading System will provide an option for companies that will be within the green in terms of their emissions to trade their excess carbon budget allowance. Again, would an entity facilitating an initiative that leads to carbon avoidance or reduction in a non- carbon credit project translate to an offset in their carbon emissions? For example, as part of its corporate social responsibility, could a mining company that donates fruit trees or cook stoves that will subsequently lead to remarkable and verifiable emission abatements elsewhere within Zimbabwe count as something to report against.
Zimbabwe is a highly fossil fuel intensive economy. The LEDS pointed to the energy sector as being the highest GHG emitter in the country. Businesses operating in energy intensive industries will need to strengthen monitoring systems and adjust operational strategies to avoid exposure to potentially costly enforcement measures related to the new law on the horizon.
The new law when enacted will potentially bring in great prospects for professionals in the environment and sustainability sector to thrive as their skills such as greenhouse gas accounting, sustainability training and advisory services provision are most likely to be on demand. As a matter of fact, private sector entities will be required to designate a climate change officer or an environmental or sustainability officer, who shall be responsible for submitting all reports as required in terms of the Act. However, professionals hoping to participate as independent auditors or set up verification and validation bodies referred to a Designated Operational Entities (DOEs) in the Act would need to part with a large considerable amount of money in the form of registration and licensing fees - values of which might be a barrier for those not financially stable to do so.
It will be wise for businesses to acquaint themselves with the bill and further have early knowledge of their GHG emissions. This will better place them in a position to quickly strategize and maneuver ways of getting below the threshold standards that EMA and CCMD are to prescribe. It will also be wise for them to gain knowledge through joining the various associations and bodies where matters to do with the law in the pipeline are most likely to be common banter.
Progressive as it is, Climate Change Management Act of 2025 is likely to be a complex policy to rollout. Comprehensive awareness campaigns will definitely be needed to foster smooth implementation. Within twelve months of it’s the enactment, the CCMD is to develop a stakeholder engagement strategy to raise awareness and encourage public participation. It will be over ambitious to foresee a seamless launch into operationalization. Many a times, legislation that warrants compliance especially by non-state actors is not tranquil. For example the European Commission had to come up with the Quick Fix and Stop the Clock Acts which postponed certain sustainability reporting requirements giving companies time to prepare. Possibly the CCMD can stagger the rolling out of some of the principles of the law and even provide leniency for entities that commit to transition to low carbon technology within a set agreed time period. Where possible, the levies for non-compliance can begin at a low rate and be later elevated to higher levels. In essence, after presidential accession some of the material sections might need to be suspended until the relevant regulations to operationalize them are put in place. Dialogue between government and business might be necessary for consensus to be reached on certain stipulations. In its entirety, the new law will go a long way in enabling Zimbabwe to adapt to and mitigate against climate change. It will greatly aid in advancing the country’s Vision 2030 development agenda.
As one of the key protagonists, business is at the center of the Act and thus like the Scouts motto should be preparing to take action even way before the accession into law by the President because after all, in the words of John Trusler, there is no better time than now!
Hazel Sethaunyane is a climate and resilience expert who writes here in her personal capacity. She can be contacted on 0772 578 400 and [email protected]
