What is S.I. 215 of 2025?

Statutory Instrument 215 of 2025 is a regulation made under Zimbabwe’s Indigenisation and Economic Empowerment Act. Its purpose is to clarify and enforce limits on foreign participation in specific “reserved sectors” of the economy. It does not apply to the whole economy and does not ban foreign investment in general.

Which sectors are considered “reserved”?

Reserved sectors are activities that government has decided should be primarily owned and controlled by Zimbabwean citizens. Some sectors are fully reserved, while others allow foreign participation only if very high investment and employment thresholds are met and a permit is granted.

Examples include retail trade, transport services, estate agencies, advertising agencies, bakeries, tobacco grading, artisanal mining and certain logistics activities .

Are restaurants specifically listed as a reserved sector?

No. Restaurants are not explicitly named in the Schedule to S.I. 215 of 2025.

So does that mean foreign-owned restaurants are automatically allowed?

In practice, many restaurants are treated as part of retail trade, because they involve the sale of food and beverages directly to the public. Retail trade is a reserved sector, with foreign participation allowed only at very high thresholds.

This means the treatment of a restaurant depends on how it is classified, not just what it is called.

What kind of restaurants are most affected?

Small and medium restaurants, including most family-run Chinese restaurants, typically:

• employ far fewer than 200 people, and
• have investments far below US$20 million.

If such a restaurant is classified as retail trade, it does not meet the threshold required for foreign participation and would therefore be affected by the regulation going forward.

What about large hotels and hotel restaurants?

Restaurants that are part of large hotels, lodges or resorts are generally treated as part of the hospitality and tourism sector, which is not listed as a reserved sector under S.I. 215 of 2025. These are usually unaffected, subject to other sector-specific laws.

Does permanent residency exempt a foreigner from S.I. 215?

No. Permanent residency does not equal citizenship under the regulations. S.I. 215 of 2025 applies to “foreign nationals”, which means anyone who is not a Zimbabwean citizen, regardless of how long they have lived in the country or whether they hold permanent residence.

Why does the law not distinguish permanent residents?

The indigenisation framework is based on citizenship, not residency status. From a policy perspective, the objective is to ensure that ownership in reserved sectors accrues to Zimbabwean citizens specifically.

As a result, a foreign national who has lived in Zimbabwe for 20 years and holds permanent residence is treated the same as any other foreign national for the purposes of reserved sectors.

Can a permanent resident apply for exemptions or permits?

Only where the sector allows foreign participation at all. If a sector is marked “exclusively for Zimbabweans,” permanent residency does not create an exception. If a sector allows foreign participation subject to thresholds and permits, a permanent resident may apply in the same way as any other foreign national.

What about foreigners married to Zimbabweans?

Marriage does not change nationality. Unless the individual has acquired Zimbabwean citizenship, they remain a foreign national under the regulations and are affected in the same way.

Is this regulation targeting foreigners unfairly?

The regulation is sector-specific, not nationality-hostile. Zimbabwe continues to encourage foreign investment in mining, manufacturing, energy, tourism and export-oriented industries.

What S.I. 215 of 2025 does is draw firmer boundaries around small-scale and service-level sectors that government believes should be dominated by local ownership.

What happens to foreigners already operating in reserved sectors?

Foreign businesses operating before the SI was gazetted are given:

• 30 days to submit a regularisation plan, and
• up to three years to comply, including divesting at least 75% equity to Zimbabwean citizens where applicable.

The intention is transition, not sudden closure.

What is the deadline for submitting regularisation proposals under S.I. 215 of 2025?

The deadline is 10 January 2026. Statutory Instrument 215 of 2025 was gazetted on 11 December 2025.
Section 6(1) of the SI grants 30 days from the date of gazetting for foreign businesses already operating in reserved sectors to submit their regularisation plans. Counting 30 calendar days from 11 December 2025 brings the deadline to: Saturday, 10 January 2026. This effectively means companies must submit plans by Friday January 9, 2026.

What happens if a company does not submit a regularisation plan by 10 January 2026?

If a company does not submit a regularisation plan by 10 January 2026, it loses the protection of the transition period under S.I. 215 of 2025. Continued operation in a reserved sector may then be treated as non-compliance, exposing the business to license suspension or cancellation, penalties, and enforcement action.