• Ghana has introduced a sliding-scale gold royalty regime, increasing the rate from 5% to 12% as gold prices rise, with the top rate kicking in at $4,500/oz
• Zimbabwe is already operating a tiered gold royalty structure
• The new regime has sparked debate on resource nationalism vs. investment deterrence

Harare- Ghana has pressed ahead with a new sliding-scale gold royalty regime that links state revenues to rising bullion prices, the head of its mining regulator confirmed to Reuters, defying a rare joint diplomatic effort by the United States, China, and several other Western governments who had lobbied Accra to halt the policy.

The decision places Ghana at the forefront of a continental push by African governments to capture more value from surging commodity prices, and its reverberations are already being felt in mining capitals from Harare to Lusaka. Gold is currently trading above US$5,000 per ounce, a level none of Africa's mining royalty frameworks were designed to anticipate, and the question every resource-rich African government now faces is the same: how much of this extraordinary windfall belongs to the state, and how much to the companies extracting it?

This comes as Zimbabwe, which operates its own tiered gold royalty structure and holds world-class assets in gold, platinum, and lithium, finds itself in an analytically interesting position relative to the Ghana benchmark, closer than most commentary acknowledges on gold, but critically exposed on lithium, where the royalty framework governing one of the world's potentially largest deposits remains far below what the current price environment justifies and far below what Ghana has just established as the new continental standard.

Examining Ghana's model, surveying what other African nations are doing, and assessing Zimbabwe's framework honestly reveals a picture that is more nuanced than either the resource nationalism advocates or the investment deterrence critics tend to acknowledge, but one with clear and urgent policy implications for Harare.

Ghana's new royalty framework replaces a flat 5% rate that applied regardless of gold price movements. Under the sliding scale, royalty rates increase in steps linked to published price thresholds, reaching the maximum 12% when gold exceeds US$4,500 per ounce. With gold now trading above US$5,000, Ghana is immediately operating at the maximum rate. At 3.5 to 4 million ounces of annual production, the revenue difference between the old 5% flat rate and the new 12% rate at current gold prices is in excess of US$1.2 billion per year, a figure that compresses Ghana's persistent fiscal deficit in a single policy instrument.

The lithium sliding scale, linking royalties of 5% to 12% to prices between US$1,500 and US$3,200 per metric tonne, is in some respects more strategically significant than the gold revision. African nations hold some of the world's largest lithium deposits, and the global energy transition's battery supply chains are structurally dependent on African lithium supply.

Ghana is establishing a price-linked framework for that mineral before the market reaches full scale, capturing the template-setting advantage that goes to the jurisdiction that moves first.

Source: Reuters royalty framework review, Equity Axis analysis

Ghana's Minerals Commission CEO Isaac Tandoh confirmed that the United States, China, and several other diplomatic missions had met with Ghanaian authorities to raise concerns, though he noted they did not oppose the principle of a sliding scale, only the bracket design.

The objecting governments proposed that the 12% top rate be triggered only above US$5,000 per ounce rather than US$4,500,  a shift that, at current gold prices, would have kept Ghana at a lower rate and significantly reduced the immediate revenue impact. Accra rejected the proposal.

The joint US-China opposition is diplomatically extraordinary, two governments that compete fiercely for African mineral access and routinely take opposing positions on African policy questions aligned on this one because both calculated independently that allowing Ghana's precedent to stand would raise the cost of extracting African minerals across the continent.

If Ghana gets 12% at US$5,000 gold, every other African producer begins renegotiating from a higher floor. The resistance was never primarily about Ghana. It was about the continental template.

Tandoh dismissed the investment deterrence argument directly, telling Reuters that his modelling showed the sliding scale struck the right balance between state revenue and industry margins, and that investors care more about regulatory stability than marginal cost shifts.

What Other African Nations Are Doing

Sources: national mining codes, Chamber of Mines disclosures, IMF country reports, Equity Axis compilation

Botswana's diamond governance model is the benchmark for African resource revenue capture, and it is worth examining closely because it demonstrates that the most effective form of resource nationalism is not a royalty rate at all, it is equity participation. Rather than extracting revenue through a passive fiscal instrument, Botswana negotiated a 50% stake in Debswana, the joint venture with De Beers that mines the country's diamonds, giving the state direct participation in profits, production decisions, marketing strategy, and pricing.

The 2023 Debswana renegotiation, which extended the joint venture to 2054, increased the Okavango Diamond Company's allocation of rough diamonds to 30% of production for direct sale, giving the state not just royalty and dividend revenue but direct market access and price-setting influence over one of the world's most valuable commodity flows.

Botswana's model works because it aligns incentives, the state as equity partner wants the mine profitable, efficiently operated, and sustainably produced. It does not want to extract maximum royalty revenue in the short term at the cost of mine viability. The Pula Fund, accumulated from diamond revenues over decades, provides fiscal buffer against price cycles. Botswana's per capita income, credit rating, and social outcomes are the direct consequence of this model applied consistently.

No African jurisdiction operating a royalty-only framework has matched Botswana's long-term outcomes from mining, which is the most important observation in any honest assessment of what the options actually deliver.

Tanzania's resource nationalism programme under the late President Magufuli,  a new mining act requiring 16% free carried interest for the state, a ban on unprocessed mineral exports, cancelled export permits for Acacia Mining over a disputed US$190 billion tax bill, produced real revenue gains in the short term and real investment damage in the medium term.

Barrick eventually settled by merging Acacia into the Twiga joint venture on terms that included US$300 million in immediate payments but suspended new capital expenditure for several years. Mining FDI fell sharply. Several marginal projects that would have been developed under the old regime never reached financial close. The lesson is not that resource nationalism fails but that the form and predictability of resource nationalism determines whether it captures windfall revenue or repels the investment that would generate that revenue. Tanzania's approach was retroactive, confrontational, and unpredictable. Ghana's is prospective, rule-based, and transparently linked to a published price framework. These are fundamentally different instruments.

Zambia's windfall copper tax, introduced in 2008 and reversed in 2009, remains the most cited cautionary example in African mining policy and for good reason. Mining companies responded to the windfall tax by suspending investment decisions, announcing layoffs, and threatening to exit. Zambia later attempted further royalty reforms in 2019, increasing rates to 5.5–10% in a graduated scale, only to face renewed industry pressure that forced a partial retreat. The pattern of advance and retreat has itself become the most damaging feature of Zambia's mining policy environment, independent of any specific rate level.

The Democratic Republic of Congo holds the world's largest cobalt reserves, enormous copper deposits, and significant gold resources. Its 2018 mining code revision increased strategic mineral royalties from 2% to 3.5%, introduced a super-profits tax concept, and raised free carried state interest to 10%. The revenue impact has been positive in absolute terms as cobalt and copper prices surged.

But the DRC's challenge is not royalty rate design, it is governance. Gécamines, the state mining company holding DRC's equity stakes, has been persistently accused of diverting revenue away from public accounts. The DRC demonstrates that well-designed royalty frameworks capture limited value for citizens when state institutions cannot translate mining revenue into public investment. Guinea's 2023 mining code revision, introducing profit-sharing on top of existing royalties for bauxite, faces the same governance test: the written code is ambitious, but Guinea's post-coup political environment creates implementation uncertainty that the published framework cannot resolve on its own.

Zimbabwe's Position: What It Has and What It Is Missing

Zimbabwe's gold royalty structure is tiered and price-linked, not a flat rate  rising to 10% when gold exceeds US$5,000 per ounce. This is a meaningful distinction that positions Zimbabwe ahead of most of its regional peers on gold royalty design. At current gold prices above US$5,000, Zimbabwe is already operating at its highest royalty tier, and the gap between Zimbabwe's 10% and Ghana's newly established 12% at the same price level is 2 percentage points, significant in revenue terms given Zimbabwe's annual gold output, but not the fundamental structural gulf that exists between a flat-rate jurisdiction and a sliding-scale one.

Zimbabwe moved in the right direction on gold royalty design before Ghana's announcement formalised the continental shift. The analytical question is not whether Zimbabwe needs to adopt the principle, it already has it, but whether its current bracket design and rate ceilings are calibrated correctly for a world where gold trades above US$5,000 and platinum trades at US$2,000.

Beyond the royalty structure, Zimbabwe has pursued resource value capture through mechanisms that most regional peers do not operate. The VFEX listing requirement compels major mining companies to list a portion of their shares on the Victoria Falls Stock Exchange, theoretically bringing domestic capital market participation in mining sector profits. Community share ownership trusts give local communities equity stakes in mining operations, distributing a form of dividend income to affected populations that a royalty payment to central government does not.

The beneficiation mandate, most developed in platinum, where the Zimplats smelter expansion is the direct consequence of a regulatory requirement for in-country processing, represents the most sophisticated element of Zimbabwe's resource governance architecture and the one that most clearly differentiates the country's approach from Ghana's royalty-only model.

Where Zimbabwe Leads: The Beneficiation Model

Zimbabwe's platinum beneficiation policy is the most developed in southern Africa and represents a form of resource value capture that a royalty rate alone cannot replicate. A royalty captures a percentage of the value of raw ore leaving the mine gate. Beneficiation captures a percentage of the value of a refined product, and the difference between platinum concentrate and refined platinum metal represents approximately 30 to 40% of final product value. By requiring Zimplats to build a smelter, Zimbabwe has captured that processing margin domestically rather than allowing it to accrue in South African or European refining operations.

WPIC's Platinum Quarterly Q4 2025 confirms that Zimbabwe's strongest quarterly output in Q4 2025, up 8% year on year  was driven by the Zimplats smelter ramp-up, the direct consequence of the beneficiation mandate being implemented. When Zimbabwe's platinum is processed domestically, the country retains the refining margin, the employment in refining operations, and the infrastructure that makes future downstream processing viable. That is a meaningfully different and more durable form of resource capture than a higher flat royalty rate would deliver.

Ghana has not built a comparable beneficiation architecture. Its gold leaves the country as refined bullion, not as gold-containing manufactured products. Ghana's royalty reform is stronger on revenue capture at current prices, Zimbabwe's beneficiation framework is stronger on long-term structural value retention. The ideal framework combines both, and no African jurisdiction has yet fully achieved that combination.

If Zimbabwe's gold framework is more advanced than commonly acknowledged and its platinum beneficiation model is genuinely sophisticated, its lithium royalty framework is the most significant unreformed gap in the country's resource governance architecture, and given the pace of Chinese acquisition of Zimbabwe's lithium assets, it is the gap with the most urgent policy timeline. Zimbabwe holds what may be among the world's largest lithium deposits, with Arcadia, Bikita, and other sites attracting rapid investment from Chinese companies including Zhejiang Huayou Cobalt.

Ghana has just established a 5% to 12% sliding-scale lithium royalty framework tied to prices between US$1,500 and US$3,200 per metric tonne, becoming the first African country to formally price-link its lithium royalty. Zimbabwe's lithium royalty remains at the low end of the rate scale, not price-linked, and not designed for a world where lithium is the most geopolitically contested mineral on the planet. The investment in Zimbabwe's lithium sector is proceeding rapidly under the current framework, which tells you that the royalty rate is not deterring investment, it is simply undertaxing it.

That is the precise scenario in which a sliding-scale adjustment is most economically rational and least investment-distorting: companies are already committed, the resource has been de-risked, and capturing a larger share of the windfall at elevated prices does not change the original investment decision. Zimbabwe's window to establish a Ghana-equivalent lithium royalty framework before the sector's production ramp-up is narrow, and it is closing.

At current gold prices above US$5,000 per ounce, Zimbabwe's 10% tier generates approximately US$350 million annually on estimated gold export receipts of over US$3.5 billion, assuming 2025 output of approximately 46 700 kilograms . Zimbabwe captures 10% across the range US$5,000 and above; Ghana captures 12% across the same range. Adjusting the trigger threshold and the ceiling rate for both gold and platinum would deliver incremental but meaningful revenue gains without requiring a wholesale framework redesign.

For platinum, the 5% flat rate needs to be examined against the extraordinary price environment of 2025 and 2026. With platinum at US$2,000 per ounce, more than double the 2024 average of US$960, a static 5% rate captures the same percentage of a price that has doubled. The case for a price-linked mechanism in platinum is structurally identical to the gold case. The investment decisions were made at lower price assumptions, the windfall above those assumptions was not anticipated by investors, and capturing a portion of it through a higher rate at elevated prices does not disturb the original investment economics.

The Ghana Chamber of Mines CEO's warning that the sliding scale will dry up new projects deserves engagement rather than dismissal. The Zambia experience demonstrates that the investment deterrence concern is not theoretical. However, the evidence on when royalty increases deter investment and when they do not produces a consistent pattern, deterrence is highest when changes are retroactive, applied to existing projects, introduced without advance notice, and set at levels that eliminate rather than reduce project profitability.

Deterrence is lowest when changes are prospective, rule-based, published in advance, and calibrated to preserve viability at mid-cycle prices while capturing a larger share at elevated ones. Ghana's framework meets all four criteria for low deterrence. Zambia's windfall tax met none of them. Tanzania's approach under Magufuli met none. Zimbabwe's tiered gold framework was introduced through a consultative statutory instrument process and is prospective in its application, which is why it has not generated the investment exit pressure that Zambia and Tanzania experienced.

Botswana charges more in total economic terms through its equity model than any flat royalty rate implies, but it has never experienced meaningful investment deterrence because the framework is stable and the state behaves as a partner rather than a predator.

There is a legitimate structural risk in price-linked royalty regimes that Ghana's framework must navigate and that Zimbabwe shares: the commodity cycle. Gold above US$5,000 generates extraordinary royalty revenues that fund state services, but it also incentivises new project development that will produce gold in five to ten years when prices may be materially lower. If fiscal frameworks built on high-price royalty revenues are not insulated against price normalisation, the result is pro-cyclical public finance: abundant in commodity upcycles, constrained in downturns, with the contraction in downturns falling hardest on the public services built during the boom.

The solution, well-established in theory and rarely implemented in Africa, is a sovereign wealth or fiscal stabilisation mechanism that accumulates windfall royalty revenues during upcycles and deploys them during downturns. Norway's oil fund is the archetype. Botswana's Pula Fund is the African example. Zimbabwe has neither, and without one, even a well-designed sliding-scale royalty reform risks delivering windfall revenue directly into current expenditure rather than long-term public wealth.

However, Revenue capture without institutional capacity to deploy that revenue productively replicates the DRC failure rather than the Botswana success. Zimbabwe needs, at minimum, a ring-fenced mineral revenue account separating royalty receipts from general consolidated revenue, a multi-year capital investment plan designating a portion of mineral royalty income for productive public investment, and an independent audit mechanism reporting publicly on mineral royalty receipts and their deployment annually. Without these structures, a royalty rate increase is a transfer from mining company shareholders to the Zimbabwean state's general account, better than the alternative, but far short of what Botswana has achieved by treating mineral revenue as the seed capital for a diversified national economy rather than as a recurrent budget line.

The beneficiation model must be protected and extended rather than traded away for a higher flat royalty rate. A government that accepts a higher royalty in lieu of a processing mandate is capturing more revenue today at the cost of less industrial development over the next thirty years. The optimal framework, which Zimbabwe is closer to than most of its peers, combines dynamic price-linked royalty rates with mandatory processing requirements, community equity participation, and a sovereign savings mechanism. No African jurisdiction has yet fully assembled all four pillars simultaneously. Zimbabwe has more of them in place than the commentary typically acknowledges. The task is completing the architecture, not rebuilding it.

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