INTRODUCTION
On 31 July 2026, the Government of Zimbabwe gazetted the Electricity (Energy Management) Regulations, 2026 (Statutory Instrument 122 of 2026). The Regulations were promulgated by the Minister of Energy and Power Development, after consultation with the Zimbabwe Energy Regulatory Authority (ZERA), in terms of section 65 of the Electricity Act [Chapter 13:19]. A compulsory regulatory framework governing energy efficiency, facility ratings, mandatory energy audits, equipment performance standards and the licensing of energy practitioners in Zimbabwe is introduced by this Statutory Instrument.
Among its key reforms, SI 122 of 2026 introduces statutory energy consumption ratings, mandates formal energy management policies and energy efficiency investment plans for designated facilities, sets minimum energy performance standards (MEPS) for industrial equipment, and codifies the licensing requirements for energy auditors, energy managers, measurement and verification (M&V) professionals, and Energy Service Companies (ESCOs).
This article examines the key statutory mechanisms introduced by SI 122 of 2026 and considers their implications for facility owners, occupiers, energy equipment importers, and energy professionals across Zimbabwe.
New Definitions
Section 2 of the Regulations expands the statutory vocabulary to define the scope and technical application of the new energy regime:
(i) Carbon finance means a mechanism that facilitates the financial reward through carbon credits for the reduction of greenhouse gas emissions by emitters in developing countries;
(ii) Designated Facility is defined as any facility with an installed capacity of at least 100 kVA or a maximum demand customer of a distribution licensee. The term facility encompasses factories, industries, mines, farms, commercial buildings, institutional buildings, and plants,
(iii) Energy Audit refers to an inspection, survey, and analysis of energy flows for energy conservation in a building, process, or system to reduce energy input without negatively affecting output
(iv) Energy Manager means a person licensed by ZERA who carries out and optimizes the energy performance of a facility, building, or industrial plant.
(v) An Energy Service Company (ESCO)is defined as a company or business registered with ZERA to provide energy solutions and services, including project design, implementation, and management.
(vi) A Measurement and Verification (M&V) Professional is defined as a licensed person who manages or performs internationally recognized methods of quantifying the energy usage impacts of energy management activities.
Scope, Facility Ratings, and Energy Management Policies
In terms of Section 3, the Regulations apply universally to all designated facilities.
Rating and Classification of Facilities (Section 4)
ZERA is mandated to carry out energy consumption and facility ratings. Designated facilities are classified under the First Schedule according to their Energy Performance (EP):
ClassRating DescriptionEnergy Performance Metric (EP)A
High energy performanceEP > 1.3BEnergy efficient1.0 < EP < 1.3CNational benchmarkEP = 1.0DNot energy efficient0.5 < EP < 1.0ELeast energy performanceEP < 0.5
Mandatory Energy Management Policy & Records (Section 6)
(i) Owners or occupiers of designated facilities must formulate an energy management policy in accordance with the Third Schedule and the Zimbabwe Standard (ZWS) ISO 50001 series for energy management systems.
(ii) Pursuant to the Third Schedule, the policy must be formally endorsed by senior executive leadership and articulate explicit commitments to compliance, resource provision, strategic planning for energy efficiency, staff training, and transparent stakeholder communication.
(iii) Existing facilities must file their policy with ZERA for approval within twelve (12) months of promulgation of the regulations; new facilities must do so prior to receiving an electricity connection.
(iv) Facilities must appoint a ZERA-licensed Energy Manager and establish an internal Energy Management Committee representing all organizational hierarchy levels.
(v) Section 6 (7) mandates that designated facilities maintain records of daily, weekly, monthly and annual energy/fuel/water consumption, production data, and floor drawings for a minimum period of five years.
Mandatory Energy Audits and Investment Plans
Sections 7, 8, and 9 establish a triennial (3-year) compliance cycle designed to convert energy insights into verifiable savings.
- In terms of Section 7, facility owners must cause an energy audit to be conducted by a licensed energy auditor at least once every three years. Audits must adhere to ZWS ISO 50002 (Fourth Schedule) and report formats in the Fifth Schedule. Audit reports must be submitted to ZERA within 30 days of completion.
- Within three months of the audit, the facility must submit a three-year investment plan detailing proposed energy saving measures, as mandated by Section 8. Plans reviewed by ZERA may be considered for funding under the revolving energy savings fund.
- The Regulations impose a mandatory Implementation Threshold in Section 9. According to this provision, facilities are legally required to implement measures to realize at least 50% of the identified energy savings opportunities within three years of submitting the investment plan. Facilities may also register relevant components under an active carbon finance mechanism.
- Sections 10 & 11 introduce Reporting & Use Returns for facilities. Annual implementation reports (Seventh Schedule) must be filed within 30 days of year-end, while energy use returns (Eighth Schedule) must be submitted quarterly and annually within 14 days of the reporting period.
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Minimum Energy Performance Standards (MEPS) for Industrial Equipment
Section 5 introduces strict product stewardship obligations regarding industrial equipment manufactured or imported into Zimbabwe.
No person may import, sell, lease or use industrial equipment unless:
(i) The equipment complies with the applicable standards set out in Part A of the Second Schedule (incorporating international standards such as IEC 60034 for rotating electrical machines and IEC 60534 for process control valves); and
(ii) The manufacturer or importer presents a certificate of conformity issued by an authorized testing centre.
Equipment covered under MEPS in Part B of the Second Schedule includes air conditioners, commercial chillers, distribution transformers, three-phase electric motors, compressed air systems, boilers, pumps and industrial ovens.
Licensing of Professionals, ESCO Accreditation and Oversight
Sections 15 to 19 transform energy management from an unregulated advisory space into a licensed statutory practice.
- Firstly, in terms of Section 15, no person may conduct an energy audit, energy management, or M&V activities without a valid licence issued by ZERA. Audit firms must be registered in Zimbabwe and employ at least one licensed professional. Foreign firms must show proof of registration and employ at least one licensed auditor.
- The Ninth Schedule provides Licensing Categories wherein licences are divided into Category A (authorized for all audits, including investment-grade audits) and Category B (limited up to Level III audits). Licences are valid for three years in terms of Section 16(2). In addition, licence renewal and replacement is provided for in Section 17, which further states that a public register of licensed energy auditors shall be maintained by the Authority.
- ZERA is given inquiry and cancellation powers, in terms of Section 18,which provides that the regulator may initiate inquiries into any licensee. In doing so, the Authority possesses the powers, rights, and privileges of a commissioner under the Commissions of Inquiry Act [Chapter 10:07].
- According to Section 19 and the Eleventh Schedule of the Regulations, ZERA shall maintain a public register of accredited Energy Service Companies and evaluate their expertise in energy performance contracting.
Dispute Resolution and Offence Mechanisms
(a) Dispute Resolution (Section 14)
In disputes arising between facility owners, energy auditors, ESCOs, or M&V professionals, parties are required to attempt an initial informal resolution. If unsuccessful, any party may petition ZERA, which will hold a hearing and issue a binding determination.
(b) Offences and Penalties (Section 20)
The Regulations establish strict criminal sanctions. Any person who:
(i) Carries out an energy audit, M&V, or energy management activities without a valid ZERA licence; or
(ii) Being an owner/occupier of a designated facility, fails to submit an audit report or denies ZERA access to the facility for inspection or statutory auditing (under Section 13),
…shall be guilty of an offence and liable to a fine not exceeding Level 5, imprisonment for a period not exceeding six months, or both.
Statutory Instrument 122 of 2026 marks a structural shift in Zimbabwe’s energy legal framework. By moving away from voluntary conservation and introducing mandatory facility ratings, 50% minimum savings implementation targets, MEPS equipment compliance, and a strict licensing regime for energy professionals, the Regulations introduce clear regulatory accountability across commercial and industrial sectors. For designated facilities and energy practitioners, securing early ZERA licensing, auditing compliance, and establishing structured energy management policies will be vital for avoiding statutory default.
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