A gold purchase can look commercially complete when the supplier presents a company certificate and a contract. It is not complete if the buyer lacks authority to trade the metal or cannot show its lawful source when an export consignment reaches Customs.

For businesses assessing a mineral trading permit Zambia application, the central point is simple: authority to buy and sell gold differs from authority to export it. As of October 2026, the Minerals Regulation Commission, or MRC, regulates both permissions under the Minerals Regulation Commission Act, 2024. Our mineral trading permit Zambia hub provides related guidance on mineral trading and import permits.

This guide sets out the practical sequence for a Zambian enterprise, an investor, or an international buyer planning to purchase and export gold from Zambia. It explains how the right regulatory preparation protects trading continuity, strengthens supplier confidence and reduces avoidable delays. Confirm current statutory forms and requirements with the MRC and ZRA before filing.

Start by separating trading authority from export authority

Gold is a precious metal under Zambia’s current framework. A person who buys or sells gold needs a Mineral Trading Permit from the MRC unless that person already holds a mining licence or mineral processing licence.

The distinction matters because a trading permit does not allow export. For every gold shipment, the exporter needs a separate Mineral Export Permit from the MRC, supported by shipment-specific analysis, valuation and tax-clearance documents.

The Minerals Regulation Commission Act, 2024 took effect on 13 June 2025 and replaced the Mines and Minerals Development Act, 2015. Use the MRC in current correspondence and applications, rather than the former Director of Mines, because applications framed around the repealed regime can create avoidable questions at the filing stage.

Trading without the required authority exposes a buyer or seller to a maximum penalty of 500,000 penalty units, imprisonment of up to five years, or both. That consequence reflects the regulator’s focus on traceable mineral supply chains, particularly for precious metals.

Decide which authority your business needs

Use this decision point before paying for stock or signing an offtake arrangement:

1.       Buying or selling gold in Zambia: Apply for a Mineral Trading Permit if your enterprise does not hold a mining licence or mineral processing licence. A supplier agreement alone does not create trading authority.

2.       Exporting a specific consignment: Apply separately for a Mineral Export Permit for that shipment. The MRC needs evidence that the gold came from a lawful mining or mineral-processing source.

3.       Mining or processing your own gold: Confirm whether your existing mining licence or mineral processing licence covers the proposed activity before treating it as an exemption from the trading-permit requirement. The exemption relates to the need for a trading permit, not to export approval.

If your turnover is still speculative and you have no documented source of supply, do not start with an export-permit application. First establish the lawful supplier chain and your trading authority. The export application requires records that a new business cannot reconstruct at the airport or border post.

Apply for the Mineral Trading Permit

The MRC requires an application in the prescribed form and payment of the prescribed fee. The Ministry of Mines and Minerals Development hosts the MRC application-form portal.

The Act states that the MRC shall issue the permit within seven days after receiving the application. Treat seven days as the statutory decision period after receipt, not as a promise that an incomplete file will be approved within a week.

A Mineral Trading Permit lasts for three years and is renewable every three years. Build renewal planning into your compliance calendar because an expired permit creates a break in your authority to trade.

Prepare the application file

The Ministry’s legacy published checklist identifies the following documents for a trading-permit application:

●        A completed application form.

●        A certified NRC or passport.

●        A bank statement or bank letter.

●        A business plan and capital outlay.

●        A valid Zambia Revenue Authority, or ZRA, tax clearance.

●        For a company, a certificate of incorporation and a list of directors and shareholders.

The checklist gives the MRC a view of identity, financial capacity, tax standing and corporate control. The business plan and capital-outlay documents matter because gold trading requires a credible funding source, secure procurement arrangements and a practical compliance process.

The Ministry’s legacy brochure identifies a prescribed application fee. Confirm the current fee and documentary checklist directly with the MRC before submitting, because the brochure predates the Act that commenced on 13 June 2025. A verified application helps avoid preventable rework and supports a smoother approval process.

PACRA incorporation and beneficial-ownership disclosure establish the legal company and its ownership record. They do not replace the MRC permit, even where the company has a valid certificate of incorporation and tax registrations.

Take an illustrative retailer, which we will call Copper Crest Metals. Its two directors incorporated a Zambian company, opened a bank account and negotiated to buy small gold lots from a licensed producer. They initially assumed the PACRA documents and supplier contract would satisfy the buyer’s due diligence.

Before making a purchase, Copper Crest should assemble the MRC application file, including its ZRA tax clearance, a capital-outlay schedule and a directors and shareholders list. It should confirm the current MRC checklist in writing rather than rely on a brochure issued under the earlier framework. This preparation helps protect stock purchases, supplier relationships and the company’s ability to trade lawfully.

Keep the corporate record consistent

The names on the MRC form, PACRA documents, bank evidence and tax clearance should match. Where a shareholder, director or company name has changed, resolve the PACRA record first because inconsistent documents invite queries about beneficial ownership and control.

ZDA investment incentives may be relevant to a wider mining or processing investment. They are optional and do not authorise gold trading. Do not use an investment approval as a substitute for an MRC permit.

NAPSA registration is also separate. An employer must register with NAPSA within one month of beginning to employ staff, but NAPSA registration is not a stated precondition for a Mineral Trading Permit. Address it once recruitment starts, because the obligation follows employment activity rather than mineral-trading status.

Build a lawful-source file before buying gold

The most common weakness is not the permit form. It is the inability to demonstrate where each lot of gold came from and whether the source held the right mining or mineral-processing authority.

For each proposed purchase, retain the supplier’s licence evidence, sale documentation, quantity records and payment trail. A contract says the parties intended to transact. It does not, by itself, prove that the gold came from a lawful source.

Trade returns deserve the same attention. A trader needs trade returns for the export-permit process, so record purchases and sales when they happen rather than preparing a narrative months later from bank statements.

Worked example: prepare for an export order

Take a Lusaka-based trader preparing a gold export consignment. The business has a Mineral Trading Permit, but it buys stock through several intermediaries and stores only scanned invoices in separate email accounts.

Before arranging transport, the trader should reconcile each lot to its lawful mining or processing source, compile its trade returns and obtain the required MRC certificates. If a supplier cannot provide licence evidence, the trader should exclude that material from the shipment rather than hope a general contract will satisfy the MRC. A disciplined lot register improves traceability, supports timely clearance and protects customer confidence.

The step businesses skip is matching the export consignment to the underlying purchase lots. We recommend a file for every shipment that identifies the source, supporting licence, invoice, payment reference, weight and the MRC documents obtained for that particular shipment.

Obtain a Mineral Export Permit for each shipment

An MRC Mineral Export Permit is required for each gold shipment. Do not describe the trading permit as a gold export licence in board papers, contracts or shipping instructions, because the two approvals answer different regulatory questions.

The export application must include:

●        MRC mineral analysis and valuation certificates.

●        ZRA mineral royalty clearance.

●        Zambia Police security clearance.

●        Trade returns for a trader.

●        Evidence of the mining licence or mineral-processing licence that confirms the lawful source of the gold.

MRC analysis and valuation give the regulator a formal basis to assess the mineral being exported. ZRA royalty clearance confirms the tax position required for the consignment, while Zambia Police security clearance addresses the security dimension of moving a high-value precious metal.

The validity period of an export permit is currently described as “as prescribed” under the current Act. Confirm the period with the MRC, especially before booking freight, because the former three-month assumption may no longer apply.

Deal with royalty and export duty correctly

Gold mineral royalty is 6% of norm value. The mining licence holder must submit the monthly royalty return and make payment within 14 days after month-end, which is why a purchaser should understand the royalty position before relying on a supplier’s gold for export.

Do not confuse mineral royalty with export duty. Zambia suspended the 2025 export duty on precious stones and metals in February 2025, but the 6% royalty requirement continued. A suspended duty does not remove the need for royalty clearance or the MRC export permit.

Responsibility can depend on the commercial structure and the licence holder involved. Confirm the allocation of royalty reporting, payment evidence and export documentation in the supply agreement, then test it against the MRC and ZRA requirements before shipment.

Lodge the Customs export declaration with ZRA

After securing the MRC export approval, the exporter must have a ZRA TPIN and lodge a Customs export declaration. ZRA normally expects support such as a commercial invoice, cargo manifest, permit, packing list and transport document.

These documents need to tell the same story. The quantity, consignee, shipment details and commercial value should align with the MRC approval and valuation material, because conflicting descriptions can hold up Customs processing.

Prepare the Customs pack before the planned export date. A mineral export permit alone does not complete the Customs declaration, and a complete invoice does not replace the mineral permit.

A practical pre-shipment review

We advise a document review in this order:

4.       Confirm the trader’s Mineral Trading Permit or the applicable mining or mineral-processing licence. This establishes the authority to deal in the gold.

5.       Match the consignment to lawful-source evidence and trade returns. This supports the MRC’s assessment of the shipment.

6.       Obtain MRC analysis and valuation, ZRA royalty clearance and Zambia Police security clearance. These are stated requirements for the export-permit application.

7.       Obtain the MRC Mineral Export Permit for the particular consignment. Do this before treating the shipment as export-ready.

8.       Reconcile the permit, commercial invoice, packing list, manifest and transport document before lodging the ZRA Customs export declaration. This reduces inconsistencies across the records Customs will review.

Frequently Asked Questions

Do I need a Mineral Trading Permit to buy gold in Zambia?

Yes, if you buy or sell gold and do not already hold a mining licence or mineral processing licence. Gold is a precious metal, and the MRC regulates trading under the Minerals Regulation Commission Act, 2024.

Does a Mineral Trading Permit allow me to export gold?

No. Each shipment requires a separate Mineral Export Permit from the MRC. The export process also requires MRC analysis and valuation certificates, ZRA mineral royalty clearance, Zambia Police security clearance and lawful-source evidence.

How long does a Mineral Trading Permit last?

The permit lasts three years and is renewable every three years. The Act states that the MRC shall issue it within seven days after receiving the application, subject to a properly received application.

Is PACRA registration enough to start gold trading?

No. PACRA registration and beneficial-ownership disclosure create the company record, but they do not substitute for an MRC Mineral Trading Permit. A ZDA approval and NAPSA registration also serve separate purposes.

Gold trading compliance brings corporate governance, tax evidence and mineral regulation into one reliable transaction file. M&J Consultants Zambia helps businesses assess permit requirements, organise supporting documents and prepare for compliant gold trading and exports. Visit our mineral trading and import permits hub for guidance, or contact our team to discuss your needs and request a tailored quote.