The newly gazetted Climate Change Management Bill, H.B. 5 of 2025, introduces a comprehensive legal framework to strengthen Zimbabwe’s national response to climate change. It seeks to mainstream adaptation and mitigation into all sectors, establish institutional and financial mechanisms to coordinate action, and domesticate international obligations. This Bill replaces the fragmented approach previously scattered across environmental statutes with a unified system aimed at building resilience and transitioning towards a low-carbon economy. This article provides a structured overview of the Bill’s key provisions and the framework it establishes for climate governance in Zimbabwe.
Objectives of the Bill
The objectives of the Bill, as outlined in Clause 3, provide the foundation for Zimbabwe’s climate policy. The objectives are provided for as follows:
(a) establishing an institutional framework to coordinate, regulate and mainstream climate action across all sectors and levels of government;
(b) enhancing resilience through measures that manage climate impacts and strengthen emergency response capacity;
(c) ensuring programmes for long-term climate mitigation and adaptation are developed and implemented;
(d) creating a regulatory framework for monitoring, reporting and verifying climate change impacts and responses;
(e) promoting adaptation, resilience, and mechanisms for low greenhouse gas emissions;
(f) mobilising finance, including a carbon trading system, to support market-based responses;
(g) reducing the use of ozone-depleting substances;
(h) contributing fairly to global efforts to stabilise greenhouse gas concentrations and limit temperature increases;
(i) protecting the climate and environment for present and future generations;
(j) ensuring compliance by public and private entities with climate strategies and targets;
(k) promoting a just transition to a low-carbon, climate-resilient society;
(l) advancing measures to reduce greenhouse gas emissions; and
(m) domesticating and implementing international climate and ozone agreements in line with Zimbabwe’s sovereign interests.
PART II – RIGHTS, VALUES, AND PRINCIPLES
- This Part enshrines rights and guiding principles that underpin climate governance. Citizens are guaranteed access to climate information and participation in policymaking, while state and non-state actors are bound by principles such as intergenerational equity, precaution, accountability, and climate justice.
- Section 5 of the Bill affirms that every person has the right to access climate change information, participate in policymaking, and benefit from sustainable development programmes. It sets out guiding principles that require the protection of the climate system for present and future generations, mainstreaming of climate action into all sectors, and recognition of shared but differentiated responsibilities.
- Key values include equity, climate justice, precaution, transparency, accountability, and special attention to vulnerable groups and ecosystems. These rights and principles provide the framework for formulating policies, exercising functions, and interpreting laws related to climate change management.
PART III – ADMINISTRATIVE PROVISIONS
- Section 7 – Climate Change Management Department – The Bill formalises the Climate Change Management Department within the responsible Ministry as the lead body for implementing the Act. It will coordinate national climate policies, decentralise operations to provincial and district levels, and be headed by a Director supported by Deputy Directors in adaptation, mitigation, carbon trading, and other specialised areas.
- Section 8 – Functions and Powers of the Department – The Department will develop and implement climate policies, coordinate with ministries and local authorities, manage the national greenhouse gas inventory, and enforce emission standards. It will also regulate ozone-depleting substances, mobilise climate finance, promote low-carbon technologies, oversee carbon markets, and ensure compliance with international obligations.
- Section 9 – Climate Transparency and Compliance Unit – This Unit will manage data collection and archiving, develop and operate the Climate Transparency Portal, and oversee national greenhouse gas inventories. It is responsible for harmonising methodologies, implementing monitoring and verification systems, and ensuring compliance with emission standards through inspectors and officers.
- Section 10 – National Ozone Unit – The Ozone Unit will implement regulations to phase down ozone-depleting substances, build national capacity on ozone protection, and manage Zimbabwe’s international reporting obligations in this area.
- Section 11 – Loss and Damage Unit – This Unit will collect and share data on climate-related losses and damages, prepare anticipatory frameworks, and mobilise domestic and international resources to address such impacts.
- Section 12 – Carbon Trading Unit (Zimbabwe Carbon Markets Authority) – The Carbon Trading Unit will regulate carbon credit trading, maintain the Zimbabwe Carbon Credit Registry, and ensure projects comply with environmental integrity standards. It will also raise awareness, build capacity, oversee benefit-sharing arrangements, and link Zimbabwe’s registry with international systems.
PART IV – OPERATIONS OF THE DEPARTMENT
- Section 15 – National Reporting – The Department is responsible for preparing national climate reports and ensuring Zimbabwe complies with its regional and international reporting obligations on climate change and ozone layer protection.
- Section 16 – Public and Stakeholder Engagement – Within twelve months, the Department must develop a stakeholder engagement strategy to raise awareness, encourage public participation, and outline actions citizens can take towards climate objectives. The strategy will be reviewed periodically.
- Section 17 – Register of Licences or Permits – The Department must maintain a public register of all licences, permits, and authorisations related to greenhouse gas emissions, ozone management, and carbon trading, accessible at its offices or online.
- Section 18 – Greenhouse Gas Data Collection – Entities must submit verified data on emissions, adaptation, financing, and carbon trading. The Minister may require individuals or organisations to provide such data in prescribed formats to meet national and international reporting standards.
- Section 19 – Measurement of Emissions – Greenhouse gas emissions and removals will be measured in tonnes of carbon dioxide equivalent, updated every two years (or as prescribed) for the National GHG Inventory.
- Section 20 – Data Sharing Agreements – The Department may enter into data-sharing agreements with public and private entities. Regulations may guide data collection, frequency, security, and confidentiality, with each entity required to appoint a contact person.
- Section 21 – National Emissions Trading System and Levy – The Department, with the Environmental Management Agency, will set greenhouse gas emission thresholds. Entities exceeding limits must either purchase carbon credits or pay a levy under the Finance Act. Violations may result in fines or imprisonment.
- Section 22 – Technology Development and Transfer – The Department may facilitate the adoption and diffusion of low-carbon and climate-resilient technologies in collaboration with government, private sector, research institutions, and international partners.
- Section 23 – Liaison Committees – The Minister may form liaison committees with agencies such as EMA, Forestry Commission, ZERA, and others to coordinate climate action. Their mandate and procedures will be prescribed by directive.
- Section 24 – Control of Ozone-Depleting Substances and Gases – Regulations will prohibit or control the import, export, and use of listed ozone-depleting substances, greenhouse gases, and related equipment. Offences attract penalties of fines or imprisonment.
PART V – NATIONAL CLIMATE FUND
A major innovation in the Bill is the establishment of the National Climate Fund. Vested in the Minister as trustee, the Fund will mobilise resources from levies, carbon trading proceeds, taxes, and donor support to finance adaptation, mitigation, loss and damage, and capacity-building projects. Transparency is emphasised through mandatory publication of projects financed.
- Section 25 – Establishment and Vesting – The Bill establishes the National Climate Fund, which vests in the Minister as trustee and is administered by the Accounting Officer of the Ministry responsible for climate change.
- Section 26 – Objects of the Fund – The Fund will finance mitigation and adaptation projects, provide co-financing and project preparation support, and issue grants to local authorities and public entities. It will also support climate impact assessments, gender mainstreaming, equity, and inclusion of vulnerable groups. Other functions include promoting awareness, capacity building, and technology transfer; incentivising clean energy and emission reductions; financing loss and damage responses; and catering for unforeseen climate emergencies. Activities will be guided by an annual implementation plan developed by the Department in consultation with the Minister.
PART VI – CLIMATE CHANGE OBLIGATIONS AND DUTIES
Part VI imposes binding climate obligations on public institutions, local authorities, and private entities. Ministries and agencies are required to appoint climate focal officers, integrate climate action into planning and budgeting, and adhere to sectoral targets. Private entities must reduce emissions, appoint sustainability officers, and report on compliance.
- Section 31 – Mainstreaming of Climate Change – All public and private institutions must integrate climate change considerations into their policies, plans, budgets, and decisions. The Department will support this process by ensuring that climate risk and vulnerability assessments are incorporated into Environmental Impact Assessments and related processes.
- Section 32 – Public Sector Duties – Government ministries, departments, agencies, and local authorities are required to establish climate desks or focal officers to integrate climate programmes into their core work. They must budget for climate activities, support emission reduction targets, and report on sectoral greenhouse gas emissions. Data-sharing agreements with the Department will strengthen the national inventory system.
- Section 33 – Climate Change Focal Officers
Every ministry, department, and local authority must appoint a focal officer within six months of the Act’s commencement. These officers will serve as the primary liaison with the Department, facilitate mainstreaming of climate change in institutional plans and budgets, and oversee the implementation of adaptation and mitigation recommendations. - Section 34 – Duties of Provincial, Metropolitan, and Local Authorities – Sub-national authorities are required to assess climate risks, develop and implement climate response plans, and integrate them into budgets and planning instruments. They must report annually to the Department, support carbon credit projects, promote citizen participation, and may enact by-laws to advance local climate governance.
- Section 35 – Duties of Private Entities – Private entities may be assigned obligations by the Minister, including meeting annual emission reduction targets, appointing climate or sustainability officers, conducting compliance audits, and reporting on their climate performance. They are also expected to cooperate in adopting and applying climate-friendly technologies, subject to monitoring and regulation.
PART VII – GENERAL PROVISIONS
The final Part covers offences, penalties, regulations, incentives, international commitments, and public participation. Notably, exceeding prescribed emission thresholds constitutes an offence. The Minister is empowered to incentivise climate-friendly initiatives and ensure alignment with Zimbabwe’s international obligations under treaties such as the Paris Agreement and Montreal Protocol.
- Section 36 – Offences and Penalties – It is an offence to obstruct the Department, ignore its instructions, submit false information, or exceed prescribed emission thresholds. Offenders face fines, with penalties scaled to the severity and benefits gained from the offence. Corporate directors and partners may be held personally liable, with penalties of up to level 14 fines or five years’ imprisonment.
- Section 37 – Regulations – The Minister is empowered to make regulations necessary for implementing the Act. These may cover emissions targets, financial levies, penalties, carbon trading schemes, data sharing, reporting obligations, and the fulfilment of international commitments. Transitional periods of six months to five years may be given for compliance where new technologies are required.
- Section 38 – Incentives for Climate Change Initiatives – The Minister, in consultation with the Finance Ministry, may grant incentives to entities that reduce emissions, adopt renewable energy, implement adaptation measures, or provide accredited climate training. Incentives will follow international standards and best practice.
- Section 39 – International Obligations and Commitments – The Minister must ensure Zimbabwe meets its international climate and ozone commitments. Where the country is not yet party to an instrument, the Minister may recommend ratification or accession to Parliament, guided by the International Treaties Act and advice from the Attorney-General.
- Section 40 – Public Participation – Public participation is central to climate governance. All government entities must consult citizens, stakeholders, and communities when developing policies, plans, and regulations, with forums organised to ensure open representation and dialogue.
FIRST SCHEDULE – CONTROL OF OZONE DEPLETING SUBSTANCES
- The First Schedule of the Bill provides detailed measures for the regulation of ozone-depleting substances (ODS) and equipment that relies on them. It empowers the Minister, in consultation with relevant authorities, to specify prohibited substances, controlled substances, and restricted equipment, ensuring alignment with Zimbabwe’s international obligations under the Montreal Protocol.
- To enforce compliance, the Schedule requires importers, exporters, and consumers of listed substances or equipment to obtain licences, with provisions for application, suspension, cancellation, or amendment of those licences. It also mandates the creation of an official register of licensed operators and requires regular returns to be furnished by licence holders.
- Further, the Schedule prescribes standards for labelling, packaging, and record-keeping, while prohibiting the importation of banned substances or equipment. Violations attract penalties including substantial fines or imprisonment, underlining the seriousness of ozone protection in national environmental law.
SECOND SCHEDULE – CARBON TRADING FRAMEWORK
- The Second Schedule outlines the framework for carbon trading in Zimbabwe, providing rules for the regulation, monitoring, and oversight of carbon credit projects. In this regard, the Carbon Trading (General) Regulations, S.I. 48 of 2025, should be read alongside the Climate Change Management Bill as complementary instruments governing carbon trading in the country.
- This Schedule affirms the role of the Carbon Trading Unit—formally known as the Zimbabwe Carbon Markets Authority—in administering carbon markets in line with international best practice.
- It requires all carbon trading projects to be registered with the Authority and recorded in a national Carbon Credit Registry, which will be linked to international registries. This ensures transparency, traceability, and environmental integrity of credits generated within Zimbabwe.
- The Schedule also introduces compliance mechanisms, including monitoring, reporting, and verification requirements, and empowers the Authority to develop standardised baselines and methodologies for project approval. In addition, it provides for equitable benefit-sharing, mandating that proceeds from carbon trading contribute to sustainable development and community welfare.
Conclusion
The Climate Change Management Bill represents a landmark in Zimbabwe’s legislative evolution, embedding climate action into governance structures, economic planning, and community participation. By establishing institutions, financial mechanisms, and accountability frameworks, the Bill lays a foundation for resilience and a just transition.
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