A buyer has identified a parcel of gold, agreed a price and arranged transport. Then a basic question stops the transaction: does the business hold authority to buy the gold, export it, or both?

A gold trading licence Zambia search often produces outdated references to the repealed mining law. Since 13 June 2025, the Minerals Regulation Commission Act No. 14 of 2024 has governed mineral trade oversight. For the wider permit framework, our mineral trading permit Zambia guidance sets out the related mineral trading and import permits businesses should consider before committing capital.

For a business that buys and exports gold, one permit does not cover the entire transaction. Gold is a precious metal. A Mineral Trading Permit governs buying and selling, while a separate Mineral Export Permit is required for each export consignment.

Start with the activity you will undertake

The first decision is commercial, not administrative. Will the company buy gold in Zambia, sell it locally, export it, or undertake more than one of these activities? Each answer changes the compliance file.

Under the Minerals Regulation Commission Act No. 14 of 2024, a person who buys or sells gold needs a Mineral Trading Permit from the Minerals Regulation Commission, unless that person holds a mining licence or mineral processing licence. The exemption matters because a mine selling its own production occupies a different position from an independent trader buying material from third parties.

Do not call a Mineral Trading Permit a gold export licence. It does not authorise export. The law requires a Mineral Export Permit for every export of gold, ore or mineral product, even where the exporter already holds a valid trading permit.

A practical judgement call

If your business will only source gold for a licensed miner or processor and will not take title, buy, sell or export in its own name, obtain legal advice before applying for a trading permit. The contracts, invoices and custody arrangements will determine the real activity.

If your company will pay suppliers, issue purchase records and resell or export the gold, treat it as mineral trading. Trying to describe a trading operation as brokerage creates a weak audit trail when the Commission asks for source evidence and trade returns.

Step 1: Establish a compliant Zambian entity

Start with company registration through the Patents and Companies Registration Agency, PACRA. Incorporation establishes the legal vehicle, but it does not authorise mineral dealing.

Keep the company’s annual returns and beneficial ownership information current. Under the Companies Act, annual returns fall due within 90 days after the company’s financial year-end. PACRA may impose prescribed penalties for late filing, and continued non-compliance can lead to striking off.

This timing deserves board attention. A trading permit application can lose momentum where the applicant cannot demonstrate that the company remains in good standing.

We also advise investors to settle ownership, director authority and funding arrangements before the permit application reaches the Commission. The prescribed application form is not the place to resolve an uncertain shareholder structure.

The Zambia Development Agency, ZDA, may form part of a wider investment-entry conversation for qualifying investors. Its role does not replace PACRA registration, a ZRA tax clearance certificate or the mineral permits required for a gold-trading operation.

Step 2: Obtain and maintain ZRA tax compliance

Register for a ZRA Taxpayer Identification Number, TPIN, and maintain a valid ZRA Tax Clearance Certificate. Zambian law requires production of a tax clearance certificate before the issue of a mineral trading, import or export permit, effective 1 January 2025.

Tax clearance is not an administrative attachment added at the end of the process. It is a gatekeeper document. A company that leaves tax registration, returns or outstanding tax matters until its buyer requests export documents can miss a shipment window.

For gold exports, the exporter also needs a ZRA mineral royalty clearance certificate. This is separate from the general tax clearance certificate. The export file therefore needs both documents where the statutory requirements apply.

Illustrative example: a new gold trader

Take a Lusaka company that plans to buy gold from licensed suppliers and export one consignment valued at US$250,000. It incorporates with PACRA, opens its operational account and applies for a Mineral Trading Permit, but delays its ZRA tax clearance because it has not yet made a sale.

When the first buyer asks for shipping documents, the company still lacks the tax clearance required for the mineral permits. The transaction does not fail because the buyer disappeared. It stalls because the compliance sequence started too late.

We would advise that business to build its ZRA registration and clearance work into the first month of setup, not the week before export. The cost of a delayed consignment can exceed the cost of putting a proper compliance calendar in place.

Step 3: Apply for the Mineral Trading Permit

A business buying or selling gold should apply to the Minerals Regulation Commission for a Mineral Trading Permit in the prescribed form and pay the prescribed fee. The Commission must issue the permit within seven days after receiving the application.

The permit remains valid for three years and is renewable every three years. That is useful planning certainty, but it does not remove the need to maintain tax compliance, company records and reliable source documentation throughout the permit term.

As of 15 October 2026, the Ministry download portal lists a Mineral Trading Permit application form updated on 14 July 2025. Confirm the current filing office with the Minerals Regulation Commission before submission, because the Commission took over licensing and mineral-trade oversight when the 2024 Act commenced on 13 June 2025.

Do not rely on a brochure issued under the repealed Mines and Minerals Development Act of 2015 for fees, validity or documentary requirements. Existing permits issued under the former Act remain valid until expiry, revocation or surrender, but new applications operate under the current regime.

Trading without the required permit is an offence. On conviction, the penalty can reach 500,000 penalty units, imprisonment for up to five years, or both.

Step 4: Build proof of source before buying gold

The most important file in a gold business is the source file. Before purchasing, establish how the gold links to a mining licence or mineral processing licence and retain records that allow that link to be tested later.

For an export application, the Commission requires evidence of the mining licence or mineral processing licence that forms the source of the mineral. A trader seeking to export must also provide trade returns.

That requirement changes how a buyer should operate on day one. Do not buy gold merely because a seller can produce metal and a price. Buy only where the source documentation can support the later export application.

Illustrative example: a trader with incomplete source records

Consider a trader purchasing several small lots over two months for a combined US$180,000. The trader records supplier names and weights, but does not collect evidence of the underlying mining or processing licence for each purchase.

At export stage, the trader can show invoices but cannot connect the gold clearly to licensed production. The Commission’s export requirements still call for source-licence evidence and trade returns. An invoice alone does not cure that gap.

We would advise this trader to create a purchase pack for every lot before payment: supplier identity, transaction record, source-licence evidence and the records needed for its trade return. Retrospective reconstruction is slow and often incomplete.

Step 5: Apply separately for each gold export

Apply to the Minerals Regulation Commission for a Mineral Export Permit in the prescribed form and pay the prescribed fee. Obtain this permit for every gold export, not once for the life of the trading business.

The export application requires Commission mineral analysis and valuation certificates, a ZRA mineral royalty clearance certificate, Zambia Police security clearance, and evidence of the mining or processing licence that is the mineral source. A Mineral Trading Permit holder must also submit trade returns.

The current statute leaves the validity period of the export permit to regulations. Do not rely on old guidance that describes a three-month validity period without obtaining current confirmation from the Commission.

This is a material risk for sales contracts. Do not promise a shipment date based on an assumed permit validity period, particularly where valuation, police clearance or royalty clearance remains outstanding.

Step 6: Complete ZRA customs export clearance

A Mineral Export Permit does not replace customs clearance. For export through ZRA Customs, the exporter must register for a TPIN, declare the goods directly or through a clearing agent, and present the commercial invoice, manifest, packing list, transport documents and mineral export permit.

The customs documentation should match the export-permit file. Differences in consignor details, weights, transport arrangements or invoice descriptions can create questions that delay release.

If the business uses a clearing agent, retain internal ownership of the process. The agent can lodge a customs declaration, but the exporter remains responsible for the accuracy of its commercial and regulatory records.

Step 7: Register with NAPSA where you employ staff

Where the business employs eligible workers, register with the National Pension Scheme Authority, NAPSA, within one month of commencing business or employing an eligible worker. NAPSA’s employer-registration requirements include PACRA documentation, a tax clearance certificate, a bank statement and the NAPSA registration form.

This requirement often arrives later than the mineral permits because a founder begins with consultants or directors. It becomes urgent when the company hires a buyer, accountant, security coordinator or logistics employee.

Treat employment compliance as part of the operating model. A gold business needs more than licences. It needs documented authority, controlled purchasing and staff records that withstand scrutiny.

A working compliance sequence for 2026

1.       Register the entity with PACRA and confirm that beneficial ownership information and annual-return obligations are controlled.

2.       Obtain a ZRA TPIN and maintain a ZRA Tax Clearance Certificate. Do this before the mineral-permit application, because tax clearance is required for permit issue.

3.       Apply to the Minerals Regulation Commission for a Mineral Trading Permit if the company will buy or sell gold and does not hold its own mining or mineral processing licence.

4.       Create a source-documentation process before the first purchase. Retain evidence that links each lot to licensed mining or mineral processing activity.

5.       Prepare trade returns as transactions occur. Do not wait until the export application, because a trader must provide trade returns when seeking to export.

6.       Obtain the analysis, valuation, royalty clearance and Zambia Police security clearance required for the specific export.

7.       Apply for the Mineral Export Permit, then complete ZRA Customs clearance with the invoice, manifest, packing list, transport documents and permit.

8.       Register with NAPSA within one month where the company commences business or employs an eligible worker.

Frequently Asked Questions

Do I need a gold trading licence to buy gold in Zambia?

A business buying or selling gold needs a Mineral Trading Permit from the Minerals Regulation Commission, unless it holds a mining licence or mineral processing licence. Gold is treated as a precious metal under the current framework.

Can I export gold using only a Mineral Trading Permit?

No. A Mineral Export Permit is required for every export of gold, ore or mineral product. The trading permit and export permit regulate different activities.

How long does a Mineral Trading Permit last?

The Mineral Trading Permit is valid for three years and is renewable every three years. The Commission must issue it within seven days after receiving the application, subject to the statutory process and prescribed requirements.

What documents do I need to export gold from Zambia?

The export application requires Commission mineral analysis and valuation certificates, a ZRA mineral royalty clearance certificate, Zambia Police security clearance, source-licence evidence and, for a trading-permit holder, trade returns. ZRA Customs also requires the relevant commercial and transport documents, including the mineral export permit.

Gold trading carries commercial opportunity, but the authorisation chain must hold from the first purchase through to customs clearance. Speak With Our Team, or visit our mineral trading and import permits guide, before you commit to a gold purchase or export contract.