With the January 31 regularisation deadline now behind us, attention in Zimbabwe has shifted from debate to enforcement, as the government begins implementing Statutory Instrument 215 of 2025 (SI 215) — the regulation restructuring participation in sectors reserved for Zimbabwean citizens.

Gazetted on December 11, 2025, SI 215 requires foreign-owned businesses operating in reserved sectors to submit regularisation plans and divest 75 percent of equity to locals over three years. The regulation also introduces strict beneficial ownership disclosure requirements and criminal penalties for false declarations.

The pressing question now is not whether the policy will be implemented, but how.

Enforcement Must Be Consistent and Transparent

Officials from the Ministry of Industry and Commerce have indicated that compliance verification is underway. Analysts, however, caution that credible enforcement will determine whether SI 215 strengthens local enterprise or unsettles investor confidence.

Clive Mawarire, Financial Inclusion Specialist, said the policy presents a strategic opportunity to anchor Zimbabwe’s economic growth in domestic participation but warned that success hinges on disciplined implementation.

“Ownership alone is not enough; empowerment must be linked to productive capacity, efficiency, and innovation,” Mawarire said. “We must ensure transparent enforcement, strict verification of beneficial ownership to prevent fronting, and coordinated institutional oversight. 

Productive capacity and competitiveness, not protection alone, will determine whether the policy delivers sustainable value creation.”

Analysts stress that cross-institutional data matching and routine audits are essential to prevent fronting, while uniform application across sectors and provinces is critical to avoid perceptions of arbitrariness.

Clear Operational Guidelines Urgently Needed

Business groups, including the Zimbabwe National Chamber of Commerce, have called for detailed sector-specific guidelines clarifying definitions, exemptions, and the treatment of integrated business models.

SI 215 reserves 13 sectors for Zimbabweans, including passenger transport, barber shops, bakeries, advertising agencies, estate agencies, and pharmaceutical retailing. It also sets high investment and employment thresholds for sectors where foreign participation is permitted.

“Gradualism is not a policy weakness,” said ZNCC President Tapiwa Karoro. “Businesses are requesting precise and practical guidance on how the policy will be interpreted and applied. 

"While SI 215 provides a schedule of reserved sectors and thresholds, members remain uncertain about definitions, sector boundaries, exemptions, and the treatment of integrated business models.”

Economists note that legal clarity reduces disputes and encourages voluntary compliance, while ambiguity increases litigation risks and administrative delays.

Transitional Management Must Balance Reform and Stability

With the deadline expired, the government faces the delicate task of managing non-compliant firms. Immediate closures could disrupt supply chains in retail, logistics, and grain milling, while indefinite leniency could weaken policy credibility.

Analysts suggest a sequenced enforcement approach: issuing compliance notices, setting structured divestment milestones, and publishing aggregate compliance data to demonstrate seriousness while maintaining economic stability.

Such measures would also reassure lenders and investors concerned about abrupt operational disruptions.

Empowerment Must Extend Beyond Ownership

Policy experts argue that ownership transfer alone does not guarantee productive empowerment. Local beneficiaries must gain access to finance, technical skills, management capacity, and market linkages.

“To deliver meaningful impact, SMEs must be supported with access to finance, technology, skills development, and market linkages,” Mawarire emphasised.

Coordination between the Ministry of Industry and Commerce, the Ministry of Women Affairs, Community, Small and Medium Enterprises Development, and financial institutions will determine whether local enterprises can absorb new opportunities sustainably.

Private Sector Voices

A foreign-owned transport logistics operator in Harare, speaking on condition of anonymity, said:

“We understand the objective of empowering local enterprises, and we are open to structured partnerships with Zimbabwean investors. However, logistics is capital-intensive and operates on long-term contracts. Sudden changes to ownership structures without clear transitional guidelines could disrupt supply chains and financing arrangements. 

"What we need now is transparent communication, practical timelines, and assurance that compliant businesses will be treated consistently.”

Protecting Investment Confidence

Private sector representatives maintain broad support for citizen empowerment but stress that execution is key. Clear communication on enforcement timelines, publication of compliance procedures, and harmonised interpretation across regulators will be central to preserving investment confidence.

Economic analysts note that empowerment policies succeed when they combine clarity, institutional discipline, and measurable productivity gains. They fail when characterised by policy uncertainty and administrative unpredictability.