A national pilot mapped Zambia's laws, institutions and data systems against the United Nations Resource Management System (UNRMS), turning fragmented evidence and stakeholder experience into a sequenced agenda for more adaptive, integrated and accountable critical-minerals governance, underpinned by an agile regulatory framework.

The dilemma

Zambia's mineral endowment places the country at the centre of rising demand for copper and other materials used in the energy transition. That demand can support public revenue, employment, economic diversification and local industrial development. At the same time, it can intensify familiar pressures, including environmental impacts, uneven benefit sharing, weak links between extraction and the wider economy, and gaps in the governance of artisanal and small-scale mining.

The policy challenge was not simply a lack of rules. Zambia already had laws, strategies, regulators, environmental procedures and digital reporting systems. The question was whether these elements functioned as a single resource-management system across the mineral life cycle. Responsibilities were distributed among several authorities. Technical services were not equally accessible across provinces. Evidence was held in separate systems. Implementation capacity varied sharply between large mines and artisanal and small-scale operations. A static review of legislation would have shown the formal architecture. It would not have revealed how that architecture performed in practice or where its handovers were failing.

The regulatory need was therefore adaptive. Zambia required a credible means of comparing its existing arrangements with an integrated international framework, learning from regulators, operators, communities and technical institutions, and turning that evidence into a sequence of nationally owned reforms.

The regulatory gap

Existing tools tended to examine individual laws, institutions, projects or environmental requirements. None provided a single national lens covering aspects such as sovereignty, environmental stewardship, social engagement, comprehensive recovery, value addition, circularity, innovation, transparency, health and safety, and institutional capability.

This fragmentation mattered most where mandates and evidence had to cross institutional boundaries. Geological and production data might be available yet difficult to combine or use consistently. Environmental rules existed, but stakeholders reported weak enforcement in water, tailings and some artisanal and small-scale mining activities. Digital platforms supported licensing, production, exports and beneficial ownership, though coverage, interoperability and accessibility remained uneven. Innovation and formal safety systems were stronger in large operations than in smaller ones. Zambia also lacked a formal design-for-circularity framework, and technical services were concentrated in Lusaka.

The stakeholders most exposed to these gaps included mine workers, communities in mining areas, artisanal and small-scale operators, local authorities, regulators and businesses seeking predictable rules. Inaction risked allowing rapid sector growth to reinforce institutional silos, environmental liabilities and limited domestic value capture.

The approach

The Ministry of Mines and Minerals Development, the University of Zambia, Copperbelt University and the University of Exeter formed a government-academia partnership, supported by the United Kingdom Foreign, Commonwealth and Development Office. The pilot used the 12 principles and 55 requirements of the United Nations Resource Management System (UNRMS) as structured prompts rather than as a pass-or-fail scorecard.

The work combined five elements:

1.    System mapping: The team mapped institutions, policies, laws, regulatory practices, technical services and data arrangements against the UNRMS principles and requirements.

2.    Evidence gathering: More than 200 questionnaires were distributed among government, industry, artisanal and small-scale mining, traditional authorities, civil society, academia and development partners. Interviews provided qualitative and operational detail. As a pilot initiative, the survey should not be read as a statistically representative national sample.

3.    Provincial learning: Workshops in Lusaka, Kitwe and Solwezi tested the initial mapping against three distinct settings: the national policy centre, the established Copperbelt and the rapidly expanding North-Western mining region. Reported attendance across the three workshops exceeded 350.

4.    Iterative validation: Follow-up meetings, virtual consultations and bilateral exchanges continued through 2025. Knowledge exchange with the earlier Cornwall UNRMS application helped the team distinguish transferable practice from Zambia-specific adaptation.

5.    Translation into reform options: The team converted the findings into proposals covering policy integration, a permanent multi-stakeholder platform, capacity building, circularity, formalization of artisanal and small-scale mining, digital services, monitoring and further pilots.

The design rationale was to begin with evidence and relationships, then move towards regulatory change. It created a learning loop between national policy, provincial experience and international practice, while leaving decisions on adoption and implementation with Zambia.

Results achieved

The pilot produced Zambia's first national UNRMS baseline and the first national-level study in Africa examining the adoption or adaptation of UNRMS. It achieved several concrete milestones:

•    A national mapping of the 12 UNRMS principles and 55 requirements against Zambia's mineral-governance arrangements;

•    Stakeholder mapping, with more than 200 questionnaires distributed, interviews, and three provincial workshops;

•    Combined workshop attendance reported at more than 350, with broad participation from public authorities, companies, artisanal and small-scale miners, communities, academia, and civil society;

•    Presentation of preliminary findings at the fifteenth session of the UNECE Expert Group on Resource Management in Geneva in April 2024; and

•    A set of recommendations for national policy, institutional coordination, digital services, capacity building, circularity, monitoring, and follow-up pilots.

The assessment found that Zambia had a substantial foundation for integrated resource management. Relevant strategies and institutions were in place; digital systems supported licensing, production, trade and beneficial-ownership information; environmental assessment processes were in place; and large operations demonstrated established practices in safety, reporting and innovation.

The same exercise made implementation gaps more visible. The most material concerns were artisanal and small-scale mining safety and labour practices, access to technical services, enforcement of water and tailings requirements, transparency coverage, design for circularity, innovation uptake and reskilling for a just transition. The report therefore recommended formally adopting or adapting UNRMS in national policy, establishing a permanent multi-stakeholder platform, creating a national mining circularity framework, expanding access to digital and technical services, and strengthening independent monitoring.

The pilot laid a national foundation for adaptive mineral regulation: a shared baseline, an evidence base, a stakeholder network and a prioritised reform map. Work continued through 2025 and into 2026, moving from baseline assessment towards testing and advancing implementation of UNRMS principles in Zambia, aligned with the United Nations Guidance for Action on Critical Energy Transition Minerals (CETM), including its seven Guiding Principles and five Actionable Recommendations. Zambia is participating as a pilot country in an ongoing regulatory-learning process intended to translate shared principles into national policy, administrative practice and, where approved, formal regulatory measures. 

The transferable lesson

The central lesson is that adaptive mineral governance can begin before a comprehensive legislative rewrite. A country can first make the system visible: who holds each mandate, what evidence is available, where services are inaccessible, which handovers fail, and which gaps require policy, capacity, coordination or enforcement. That approach turns an international framework into a disciplined national conversation rather than an imported checklist.

Three features are especially transferable:

•    Adaptation is more credible than mechanical adoption. The framework was tested against Zambia's legal, institutional and provincial realities, thereby preserving national discretion and revealing the practical work required for implementation.

•    Regulatory learning requires more than consultation. Surveys and workshops generated evidence, while provincial comparisons and follow-up exchanges helped test it. The next step is to link each priority to a responsible institution, an evidence requirement, a review date and a corrective route.

•    Shared data and technical capacity are integral to regulation. Rules cannot perform as intended when evidence is fragmented, services are geographically dispersed, or smaller operators cannot participate. Digital infrastructure and institutional capability are therefore regulatory design choices, not secondary administrative matters.

The caution is equally important. Pilots can accumulate recommendations without changing practice. Zambia's model will become a full adaptive governance cycle only when implementation yields traceable decisions, periodic review, and evidence of correction. Open questions include which recommendations will be formally adopted, how the proposed multi-stakeholder platform will be mandated, how artisanal and small-scale operators will participate, and which indicators will show improvement beyond the baseline.