03/02/2026
Our General view on Zema
1. Risk of Weakened Environmental Protection
The shortened review timelines (20–30 calendar days) may not give ZEMA enough time to thoroughly assess complex or sensitive projects. This could lead to important environmental or social risks being overlooked, especially in mining, energy, agriculture, and infrastructure projects.
2. Reduced Fees May Limit ZEMA’s Capacity
While lower fees help investors, they may reduce ZEMA’s revenue, which is crucial for:
Hiring and retaining technical experts
Conducting site inspections
Monitoring project compliance
This could weaken enforcement and follow-up, especially in rural and remote areas.
3. Exemptions for “Low-Impact” Projects Can Be Abused
The risk based exemption system may be exploited if:
Project impacts are underestimated by developers
Cumulative impacts of many “small” projects are ignored
Over time, multiple exempted projects could cause serious environmental degradation.
4. Limited Public Participation
Shorter review periods may reduce meaningful community consultation, especially for:
Rural communities
Indigenous or vulnerable groups
This can lead to projects being approved without adequate local input, increasing conflict and resistance later.
5. Social Issues May Be Overshadowed
Although social impacts are now integrated, there is a risk that:
Social issues (land rights, livelihoods, displacement) receive less focus than environmental ones
Weak social data leads to poor mitigation measures
Integration is good, but only if capacity and expertise are strong.
6. Implementation Challenges
New regulations require:
Training of ZEMA staff
Awareness among consultants, developers, and communities
Without strong sensitization, there may be confusion, inconsistent application, and legal disputes.
7. Investor Bias Concerns
The reforms strongly favor ease of doing business, which may raise concerns that economic interests are prioritized over environmental justice, especially in resource-rich but environmentally sensitive areas.
8. Weak Post-Approval Monitoring
The regulations focus heavily on approval speed, but Zambia already struggles with monitoring and compliance enforcement. Faster approvals without stronger monitoring could increase:
Environmental pollution
Community harm
Non-compliance by developers
Conclusion (Balanced View)
While the regulations improve efficiency and reduce costs, without strong enforcement, transparency, and community engagement, they risk undermining Zambia’s long-term environmental sustainability.
