A lender can have capital, a signed lease and a growing loan book, yet still face disruption because its licence covers only an existing office or because renewal was overlooked. For directors, the real question is not only whether the enterprise secured money-lending authorisation in Zambia, but whether every location, borrower document and statutory obligation remains compliant.

As stated in the source article on 21 October 2026, the Money-lenders Act (Cap. 398) remained the operative framework for licensed money lenders. The Banking and Financial Services Act of 2026 had been enacted, but the source did not confirm a commencement instrument that would bring its repeal of Cap. 398 into effect. Confirm the live commencement and licensing position with the responsible authorities before relying on this guidance.

This guide outlines an ongoing compliance routine for lenders, directors and investors. An organised approach helps protect operations, support responsible lending, build customer trust and keep the enterprise prepared for regulatory change. M&J Consultants can help businesses review their obligations and establish practical controls suited to their operations.

Start with the licence, address and renewal date

Under Cap. 398, a money lender must hold an annual licence for every business address. The Permanent Secretary at the Ministry of Finance issues the licence after the lender obtains a money-lender’s certificate from the subordinate court with jurisdiction over the intended location.

This sequence matters because a company cannot treat one licence as a national operating authority. A Lusaka licence does not automatically cover a branch in Kitwe, Ndola or Livingstone. Before opening a customer-facing office, confirm whether the location needs its own court certificate and annual licence.

Both the certificate and licence expire on 31 December. Build the renewal process around that fixed date, rather than around the anniversary of incorporation or the date the company began lending. A December expiry creates a year-end pressure point, when directors also manage budgets, payroll and tax filings.

Step 1: Keep an address register

Maintain a register showing every place where the enterprise conducts money-lending business, the licence number attached to that location, the issuing date and the 31 December expiry. Include temporary premises and any site where staff meet borrowers, take applications or receive repayments.

The mistake we see most often is treating a new branch as an operational decision only. It is also a licensing decision, and the business should resolve it before it displays signage, receives customers or deploys staff.

Step 2: Confirm current licensing charges before applying

The applicable licence charge may depend on when the licence is obtained in relation to its year-end expiry. Rather than budgeting from an outdated published fee or fee-unit conversion, obtain the current schedule and payment instructions from the responsible authority before submitting the application.

Include licensing, document preparation and branch-readiness work in the launch plan. A current quotation and an early check of application requirements give management greater confidence about resources and timing. Request a tailored assessment where multiple premises or a new branch are involved.

Run lending operations within the Act

A licence is only the start. Cap. 398 controls how a lender presents itself to the public, documents lending transactions and receives payments from borrowers.

Use the authorised name everywhere

Loan agreements, receipts, notices and business documents must state the lender’s authorised name. This rule lets a borrower, regulator or court identify the party that actually made the loan.

Check the name on the licence against the name on the loan contract, receipt book, SMS template, demand notice and branch signage. Do not let trading names, group-company names and legacy templates create uncertainty about the legal lender.

Keep written contracts and complete borrower records

Maintain written loan contracts and provide borrower information and copies of loan documents when the Act requires them. The records should show the agreed principal, interest terms, repayment treatment and the documents given to the borrower.

The source article describes restrictions on compounding interest and rules for applying borrower payments between principal and interest under Cap. 398. Review those provisions against the current law and ensure repayment schedules reflect the legally permitted treatment. Unclear or incorrectly structured repayments can damage customer trust and create disputes.

Courts may review harsh or unconscionable lending arrangements. Directors should assess proposed products before launch, especially short-term facilities, rollover arrangements and charges that may make the true borrower obligation difficult to understand. Transparent terms and fair treatment support a more sustainable loan book.

Treat advertising as a controlled activity

The source article identifies restrictions on unsolicited circulars, specified advertising formats and agents who solicit borrowers under the Money-lenders Act. It also notes that advertising which states interest must state the annual percentage rate. Have legal advisers check current requirements before using social, print or third-party lead-generation campaigns.

This is where social-media campaigns need executive oversight. A lead generator paid per approved borrower may function as a prohibited soliciting agent, even if the marketing team calls the arrangement an affiliate programme. Pause that model until legal advisers assess the actual scripts, payment structure and borrower journey.

Do not assume that a Zambia Development Agency investment registration replaces money-lending authorisation. An investment licence is not a universal lender licence. The licensing question remains tied to the Money-lenders Act until the 2026 banking legislation formally commences.

Keep PACRA corporate records current

A company that lends money must meet its company-law duties separately from its lending licence. The Patents and Companies Registration Agency, PACRA, requires annual returns within three months after the company’s financial year-end.

A director or company secretary must sign the annual return, and the filing must include updated beneficial-ownership information. This requirement matters for lender groups because changes in shareholding, control or nominee arrangements can affect the accuracy of the record even when day-to-day lending continues unchanged.

Failure to maintain PACRA filings or beneficial-ownership disclosures can result in enforcement action and disruption to the company’s standing. Treat these filings as board-level controls and obtain current advice on the applicable consequences rather than relying on an illustrative penalty figure.

Practical example: branch expansion without a compliance plan

Consider a Lusaka lender preparing to open an additional office in Ndola. The directors approve premises, recruitment and marketing, assuming that the existing licence automatically covers the new location. They also postpone PACRA filings while the team concentrates on the launch. The result can be a delayed opening, avoidable rework and uncertainty about corporate standing.

A better sequence is to confirm address-specific authorisation before committing to the opening, obtain the necessary certificate and licence, and prepare PACRA returns with accurate beneficial-ownership information. This reduces interruption and makes expansion easier to manage. A compliance review should precede signage, customer onboarding and the start of lending.

Put ZRA and NAPSA dates into the operating calendar

A licensed lender still carries the ordinary obligations of a Zambian employer and company taxpayer. The Zambia Revenue Authority, ZRA, and the National Pension Scheme Authority, NAPSA, operate separate monthly and annual schedules.

Company income tax and provisional tax

ZRA company income tax and provisional-tax requirements need their own timetable. Under the dates described in the source article, the provisional income-tax return is due by 31 March, with instalments due on 10 April, 10 July, 10 October and 10 January. The final return and any balance payment are due by 21 June. Confirm applicable tax treatment and the live filing calendar with ZRA before acting.

A lender may receive repayments throughout the year but still face concentrated tax payment dates. The finance team should forecast taxable income using relevant records and allowable deductions, rather than treating total borrower repayments as taxable profit. This improves budgeting, protects working capital and reduces avoidable surprises.

PAYE and VAT

For employees, the source article identifies PAYE Form ITF/P16 and payment as due to ZRA by the 10th of the following month. Use the current ZRA PAYE schedule for each payroll period, since thresholds and tax bands can change. Ensure payroll systems reflect the current rules rather than relying on an older example.

Use the current table for each payroll period. The rate matters because an outdated payroll setup can under-deduct tax even when salary payments themselves are accurate. Teams can run the figures through a PAYE calculator before closing payroll, then retain the calculation support with the payroll file.

Where the lender registers for VAT, the VAT return and payment are due by the 18th of the following month. Do not assume that lending income, fees or ancillary charges receive the same treatment without transaction-specific tax advice. Product design and invoicing language can change the tax analysis.

NAPSA contributions and returns

NAPSA contributions must be calculated and remitted under the current statutory rules. Employers should submit the relevant monthly return and pay within 10 days after month-end, as described in the source article. Keep evidence of payroll calculations, employee deductions and remittances for audit and internal review.

Late or inaccurate statutory payroll remittances can attract penalties and damage employee confidence. Build a clear monthly payroll close, assign an owner for each submission, and review unresolved differences before they develop into compliance problems.

Practical example: payroll compliance after recruitment

Consider a lending business that recruits new employees to support a larger customer portfolio. If management budgets only for take-home pay and neglects statutory deductions, contributions and reporting, its payroll process can become strained from the first month. The right approach is to set up accurate PAYE and NAPSA calculations during onboarding and include all obligations in the operating cash forecast.

The finance manager should close payroll in time to review PAYE, prepare Form ITF/P16, complete the NAPSA return and fund both remittances. Directors should give statutory obligations clear priority in the cash plan. Consistent payroll administration protects staff records, strengthens governance and allows the business to focus on responsible lending.

Prepare for the regulatory transition without guessing

The Banking and Financial Services Act of 2026 is intended to move money-lending regulation to the Bank of Zambia when the relevant commencement provisions take effect. The source describes a broader framework covering licensing, governance, consumer protection, reporting and anti-money-laundering supervision. Verify the present commencement position before treating future requirements as already operative.

That future framework matters for strategy, especially for lenders planning external investment, digital origination or multi-branch growth. It does not remove the current duties under Cap. 398 before commencement.

We recommend a transition file now: board resolutions, ownership records, product terms, complaints records, lending policies, current licences and tax-clearance evidence. A lender with these records in order will be better placed to respond when the commencement position and Bank of Zambia requirements become clear.

A lender with a stable business should first ensure that its existing licences, PACRA filings, ZRA obligations and NAPSA processes are accurate. Lenders planning investment, digital channels or multi-branch growth may benefit from an early governance review, without assuming that an uncommenced regime already applies.

The business value of a disciplined compliance programme

Protect business continuity. A clear branch-licensing and renewal process reduces avoidable interruptions when you expand or relocate.

Strengthen customer confidence. Consistent borrower documentation, responsible product design and compliant marketing help lenders establish trust.

Improve financial control. Coordinating ZRA, NAPSA and PACRA dates supports cash-flow forecasting and reliable management reporting.

Support sustainable expansion. A clear evidence file helps directors, financiers and advisers understand the organisation’s licensing, governance and operational readiness.

A practical monthly and annual checklist

Each month, reconcile loans issued, repayments received, interest applied and borrower receipts against signed contracts. Check that every customer-facing document carries the authorised lender name and that no campaign uses prohibited solicitation methods.

Complete PAYE Form ITF/P16 and payment by the 10th of the following month, and complete NAPSA returns and contributions within 10 days after month-end. Where VAT registration applies, the source article identifies the 18th as the following-month filing and payment date. Check the latest official deadlines before filing.

Each quarter, review branch addresses against licences, test advertising approvals and check whether directors or beneficial owners have changed. This review prevents a routine expansion or share transfer from becoming a missed compliance event.

Each year, prepare for the 31 December expiry of certificates and licences, then file PACRA annual returns within three months after the company’s financial year-end. Submit the provisional income-tax return by 31 March, pay instalments on ZRA’s four dates and finalise the annual income-tax position by 21 June.

Frequently Asked Questions

Does one money-lending licence cover every branch in Zambia?

No. Under the Money-lenders Act, Cap. 398, a lender needs an annual licence for every business address. Confirm the requirement before opening or relocating a branch because the licence follows the business location.

Has the Banking and Financial Services Act replaced the Money-lenders Act?

The source article states that, as of 21 October 2026, commencement of the Banking and Financial Services Act of 2026 had not been confirmed from a primary source. Its anticipated repeal of the Money-lenders Act requires verification against the current official position. Obtain legal advice before making a licensing decision based on the transition.

When does a lender file annual returns with PACRA?

A company files annual returns within three months after its financial year-end. The return requires a director’s or company secretary’s signature and updated beneficial-ownership information.

What are the key monthly deadlines for an employing lender?

PAYE Form ITF/P16 and payment are due to ZRA by the 10th of the following month. NAPSA returns and contributions are due within 10 days after month-end, while VAT returns and payments are due by the 18th where the business is VAT registered.

An effective lending compliance programme should make it easier to grow responsibly, not simply create more paperwork. M&J Consultants can help review your branch authorisation, borrower documents, marketing controls and statutory calendar, then recommend practical improvements based on your operating model. Contact our team through the money lending licence Zambia hub to request a tailored consultation and quotation.