Mining 2026 Comparisons

Last Updated January 27, 2026

Contributed By Project Lawyers

Law and Practice

Author



Project Lawyers is a successful, independent and leading Gabonese law firm established by Jean-Pierre Bozec. The firm is dedicated to projects and financings in Gabon, with a four-member team located in Libreville with more than 70 years of accumulated experience in Gabon business law. Project Lawyers is a niche premium law firm with a strong commitment to independence, integrity and confidentiality that aims to provide high-quality and innovative legal services to major corporations, financial institutions and international law firms, especially those involved in energy, mineral resources and infrastructure projects, and project financing. Project Lawyers is an active member of the Employers' Union in Gabon (Fédérations des Entreprises du Gabon; FEG ) and has a seat on the Legal, Tax and Ethics Commissions. The firm has been ranked by Chambers and Partners as a Band 1 business law firm for 12 consecutive years.

The mining industry in Gabon is an important pillar of the national economy and is dominated by the extraction of manganese. Gabon is one of the world’s leading producers of manganese, particularly in the Moanda region. This mineral is central to the national strategy, which is aimed at increasing local processing and value addition. During the Council of Ministers on 30 May 2025, the Gabonese government announced its intention to ban the export of raw manganese, starting on 1 January 2029, in order to stimulate local industrial processing and employment.

Alongside manganese, Gabon also holds significant but still underexploited reserves of iron ore, gold, niobium, rare earth and other minerals, although the development of these resources has been slowed by infrastructure and investment constraints. In addition, the law allows certain substances to be classified as “strategic” by the state, with their management regulated by decree, and the list of strategic substances could also be extended by decree.

The mining sector contributes substantially to export revenues and supports employment and regional development, especially in mining towns, by imposing obligations on operators regarding local and social development to support communities and promote territorial development.

In recent years, the government has introduced reforms to attract foreign investment, improve transparency and promote economic diversification beyond oil. At the same time, the industry faces environmental and social challenges due to its impact on forests, water resources and biodiversity, prompting growing expectations for stricter environmental standards. Transport infrastructure, such as the Transgabonais railway, remains essential for exporting minerals and plays a central role in supporting future mining projects.

In Gabon, the legal system is civil law as per most of the francophone countries. Mining activities are regulated mainly through written legislation, supplemented by regulatory instruments and, where applicable, international treaties ratified by Gabon.

The main source of mining law and regulation in Gabon is Law No 037/2018 (the Mining Code), dated 11 June 2019. The Constitution establishes the fundamental principles governing the ownership and management of natural resources, which are vested in the state. The Mining Code, the central legal text for the mining sector, sets out the rules applicable to mineral exploration, exploitation, licensing procedures, the rights and obligations of operators, and the state’s role in regulating mining activities.

The Mining Code is complemented by a series of implementing decrees that provide the detailed administrative and technical regulations needed for its practical enforcement. Although there is a real problem in Gabon with the slowness with which decrees implementing laws are issued, several such decrees have nonetheless been issued. For example, Decree No 0023/PR/MPGM of 22 January 2021 sets the rules governing the contribution of mining activities to local development, including the financing of social projects and the allocation of a portion of mining revenues to local development funds. More recently, Decree No 0276/PR/MM of 2 July 2024 established a special legal regime applicable to so-called sovereign substances, reflecting Gabon’s evolving strategic priorities in managing specific mineral resources.

Additionally, mining conventions concluded between the state and private operators serve as contractual instruments that define project-specific rights, fiscal regimes and operational obligations. Other relevant legislation, including environmental, land and tax laws, also forms an integral part of the regulatory framework governing mineral activities in Gabon.

According to Article 7 of the Mining Code, naturals resources, in particular all mineral substances contained in the soil and the subsoil, continental waters and the marine domain, remain the property of the state.

Under the Mining Code, the state may act either as a grantor-regulator or as an owner-operator, or can assume both roles concurrently. As a grantor-regulator, the state authorises mining activities by issuing various mining titles, such as the exploration permit (granted by ministerial order), and it defines the legal and regulatory framework applicable to the sector. It also supervises compliance and ensures that governance, environmental, fiscal and social obligations are respected. The state may also act as an owner-operator, since mineral resources are the property of the state, and it may participate in mining operations through equity interests held directly or through the state-owned company Société Équatoriale des Mines (SEM).

The 2019 Mining Code requires a mandatory free-carried interest of 10% in the share capital of any company holding an exploitation permit. In addition to this non-dilutable interest, the state has the option to acquire up to 25% additional paid interest at market value. The Code also grants the state a pre-emptive right in the event of a transfer of mining titles to non-affiliated third parties. Therefore, there is a form of mandatory state participation. Moreover, Decree No 0276/PR/MM of 2 July 2024, establishing the Sovereign Substances Regime, provides the state with a systematic 35% non-dilutable free participation in companies operating large-scale mines of sovereign substances, further strengthening the state’s role as both regulator and participant in mining projects.

In Gabon, mineral rights have a constitutional and legal foundation. Indeed, the Constitution of the Gabonese Republic, adopted in 2024, affirms the state’s sovereignty over all natural resources in its soil and subsoil, including mineral substances, which is the constitutional basis for mining rights.

The rights to explore and exploit minerals do not arise from private property rights over land, but from legislation, namely the Mining Code. Under the Code, all mineral substances contained in the soil and subsoil belong to the state, which may grant mining titles to operators. Anyone wishing to carry out mining activities must obtain a mining title (exploration permit or exploitation permit), which is granted by the state under the rules defined by the law.

Once granted, these titles are often formalised by a mining convention between the state and the mining company, which sets out the specific rights and technical, fiscal, environmental and social obligations. Thus, mineral rights in Gabon derive primarily from law, but their detailed conditions and exercise are governed by mining conventions (conventions minières) concluded with the state. These titles grant holders an exclusive right of use and exploitation, and transfer private ownership only of extracted mineral ore. The Mining Code clearly distinguishes the mineral resources in the soil and sub-soil (which remains the property of the state) from the right to exploit the extracted minerals – which, once extracted, become the property of the operator under the terms of the mining convention.

In Gabon, the authority responsible for granting mineral rights is exclusively national. The granting process begins with an administrative act, such as a ministerial order or, in the case of large-scale operating permits or a permanent quarry-operating permit, a decree from the President of the Republic. The detailed conditions of exploitation are then governed by a mining convention, which establishes a contractual relationship between the state and the holder of the permit or mining title, in accordance with the provisions of the Mining Code. Depending on the type of mining right, the granting authority may be either the Ministry responsible for Mines or the head of state.

The Mining Code governs mining tenure in Gabon, establishing clear rules for the granting, duration, renewal, progression and transfer of mining titles. For reconnaissance (prospection) activities, a prospection permit is required. It is granted by the Minister responsible for Geological Resources and Mining for a non-renewable one-year period and covers a limited area. Foreign companies may obtain this permit only if they maintain a registered branch in Gabon.

To conduct exploration, an exploration permit is necessary. Initially granted for three years, it may be renewed twice for additional three-year periods. Permit holders are subject to limits on the number and size of permits depending on the mineral type. Within one year of issuance, a mining convention must be signed, outlining technical, legal, fiscal, economic, environmental and financial obligations, ensuring compliance with the Mining Code.

For mining operations, a mining title is required. Small-scale permits, reserved for companies with at least 35% Gabonese ownership, are granted by ministerial order for five years, renewable in three-year increments. Large-scale permits are granted by presidential decree to public limited companies registered in Gabon, with a duration of 10–20 years, renewable for 5–10-year periods depending on investment. These titles must also be accompanied by a mining convention detailing operational, environmental and financial obligations.

The Code allows for the progression of titles, enabling holders to move from a prospection permit to an exploitation permit subject to the submission of a technical and financial programme validated by the administration and to compliance with legal obligations.

Regarding transferability, mining titles may be assigned, leased or transferred only with the prior approval of the Minister, ensuring operational control and regulatory compliance. Titles are considered secure as long as the holder fulfils fiscal, environmental, social and technical obligations, including site rehabilitation (see Articles 20–23 of the Mining Code).

Finally, revocation or suspension of a title is possible only in cases of non-compliance with legal obligations, following formal notification and a period to remedy deficiencies (see Article 48 of the Mining Code).

In Gabon, mining projects are regulated by the 2019 Mining Code and Law No 007/2014 of 2014 (the “Environmental Protection Law”). Holders of mining permits and titles must conduct all operations sustainably and responsibly, and develop and regularly update environmental and social management plans, as well as risk prevention and emergency response plans, which are submitted to the Ministry of Mines, the Ministry of Environment and local authorities for monitoring (Articles 162–164 of the Mining Code). Operators are also required to rehabilitate mining sites progressively during exploration and exploitation activities.

Before any mining or exploration permit is granted, an environmental impact assessment (EIA) must be conducted and approved, ensuring that potential environmental and social impacts are identified and mitigated. Environmental licensing is managed at the national level, with the Ministry of Environment co-ordinating oversight and compliance throughout the project life cycle.

Gabon has significant protected areas, governed by the Environmental Protection Law. This law establishes the principles of sustainable management and conservation mechanisms that strictly regulate the use of natural spaces.

Law No 003/2007 on the creation, organisation and management of national parks, which prohibits industrial activities in classified areas, governs national parks. When mining activity is planned in the vicinity of these spaces, it is subject to a prior environmental assessment obligation in accordance with Articles 17–27 of the Environmental Protection Law, necessitating an environmental impact study (EIA). The Mining Code reinforces this constraint by requiring the development of an environmental and social management plan (see Article 164 of the Mining Code) and a rehabilitation and closure plan (see Articles 153–156 of the Mining Code). The existence of protected areas can therefore lead to formal bans on exploitation or impose strengthened constraints on exploration and development in order to ensure the preservation of sensitive ecosystems.

In Gabon, relations between mining operators and local communities are governed by the Mining Code as well as by Decree No 0023/PR/MPGM, which sets the rules regarding the contribution of mining activity to local development in the Gabonese Republic. Articles 173–180 of the Mining Code specify the obligations of operators with regard to taking populations into account, particularly in terms of compensation, protection of rights of use and social participation.

Decree No 0023/PR/MPGM institutionalises the relationship between operators and communities by requiring the establishment of a corporate social responsibility programme (CSR) and the creation of consultative bodies, such as the Operational Management Committee and the Partnership Management Committee. These bodies bring together the state, local authorities, community representatives and the mining operator to define social projects, monitor their implementation and ensure their transparency.

Prior and informed consultation are legally mandatory in Gabon, under both the Environmental Protection Law and Decree No 0023/PR/MPGM. The environmental law requires, in Articles 17–27, public participation and the publication of an EIA before beginning any project likely to have significant effects on the environment, including mining projects.

The 2021 Decree strengthens this mechanism by providing a specific procedure for community consultation prior to the adoption of the CSR programme. The consultation is not left to the initiative of the investor alone; it is organised and supervised by the Operational Management Committee, a body legally established by the state comprising representatives of communities and the operator. The conclusions must then be validated by the Partnership Management Committee, which places the state at the heart of the mechanism. Prior and informed consultation are therefore mandatory and formalised, conducted under state supervision and legally enforceable.

Gabon is home to traditional forest-dwelling communities. While they do not have a distinct legal status as “indigenous peoples”, the law ensures their participation in projects affecting their environment; these communities are protected through a formalised and enforceable consultation mechanism, as mentioned in the foregoing.

In Gabon, community development agreements are not only usual, they are made mandatory under Decree No 0023/PR/MPGM (see 2.4 Prior and Informed Consultation on Mining Projects).

Gabon has integrated ESG principles into its mining convention and environmental legislation. The Mining Code establishes, in particular in its Articles 150–171, a comprehensive framework for health, safety, environment, risk management, site rehabilitation and operational standards in line with international best practices. The Environmental Protection Law strengthens the environmental pillar of the ESG scheme by imposing EIA, public participation, risk prevention and sustainable resource management requirements.

The adoption of Decree No 0332/PR/MM of 15 August 2024, establishing the National Observatory on Mining Risks, completes the governance pillar by establishing a body responsible for monitoring, preventing and evaluating risks related to mining activity. Finally, Decree No 0023/PR/MPGM specifies the obligation of societal responsibility, consolidating the social pillar. Together, these texts form a complete, modern and integrated ESG framework for the Gabonese mining regulations.

Illegal mining is a real problem in Gabon. Very recently, a vast network of illegal gold mining was dismantled in Ndjolé (in the centre of Gabon): the Directorate-General for Research (DGR) arrested 16 people and seized about XAF170 million. From a legal point of view, the Mining Code provides for very strict penalties for untitled exploitation. For example, Article 259 allows a fine of 150% of the commercial value of illegally exploited substances, while Article 260 penalises non-compliance with hygiene, safety and environmental rules through fines of up to XAF15 million.

When illegal exploitation is established, the minister in charge of mines may order the immediate suspension of activities (if the perpetrator holds a title) and refer the matter to the public prosecutor if the offender does not guarantee compensation for the damage (Article 259 of the Mining Code). Furthermore, the recent Decree No 0098 (Article 49) provides for specific sanctions for the illegal possession of gold. It provides that any person holding gold without a document detailing its origin may be fined, with the seized gold being forfeited to the state. In practice, faced with this scourge, the government combines repressive efforts (under the DGR) with administrative and criminal sanctions, and also tries to formalise certain artisanal operators to reduce illegality.

The uranium mining operations formerly carried out in Mounana by Compagnie des Mines d’Uranium de Franceville (COMUF) represent an example of negative community and environmental relations. COMUF, a subsidiary of the French nuclear industry, operated uranium mines in Mounana from the early 1960s until the closure of the sites in 1999. Local populations were exposed to radioactive contamination for years, with limited information, inadequate consultation and delayed mitigation measures. The relocation of affected residents only occurred long after the impacts were identified (almost 20 years later), undermining trust and highlighting failures in community engagement and environmental responsibility.

Also, during the 2010s in the Moanda manganese mining area, the operations of Comilog were criticised by local people and civil society for their environmental and social impacts, including river pollution and challenges accessing clean water, which affected traditional livelihoods and raised health concerns. Comilog has since put in place a strong CSR programme, with the development and rehabilitation of certain infrastructure and significantly improved relations with local communities.

Climate change initiatives influence the mining industry in Gabon mainly through general environmental and national climate commitments rather than sector-specific rules. Gabon is a Party to the Paris Agreement and has submitted an Intended Nationally Determined Contribution, now its Nationally Determined Contribution, which outlines national objectives for emissions reduction and the preservation of carbon-rich ecosystems, particularly forests.

While Law No 018/2022 of 22 December 2022, ratifying Ordinance No 019/PR/2021 of 13 September 2021, relating to climate change does not contain mining-specific provisions, it establishes a national framework for low-carbon development and for the protection of natural capital.

Mining projects are therefore indirectly affected by the Environmental Protection Law, which requires EIAs and environmental and social management plans that address impacts on ecosystems, forests and natural resources that are central to Gabon’s climate commitments.

As the Mining Code does not expressly regulate climate change, the influence of climate initiatives on the mining sector comes primarily from these broader environmental and international commitments, which reinforce scrutiny of forest impacts and require operators to align with national sustainability objectives.

Gabon has its own climate change law but not a law specifically related to mining (see 3.1 Climate Change Effects). Also, although the Mining Code does not contain provisions explicitly devoted to climate change, its stipulations concerning impact studies, environmental management, site rehabilitation and ecosystem preservation fit within the general framework established by the climate and environmental laws.

As previously mentioned, the Gabonese legal framework integrates sustainable development principles across the mining sector, notably through Law No 002/2014 on sustainable development, the Environmental Protection Law and Law No 018/2022 on climate change, whose provisions were detailed earlier. The Mining Code complements these texts by imposing environmental, social and local development obligations on operators (see the earlier discussion on environmental and climate obligations).

Beyond this regulatory framework, the Gabonese government wants to strengthen sustainability in the mining sector and has recently announced concrete initiatives. At the Council of Ministers meeting on 30 May 2025, a strategic plan was presented aiming to encourage local mineral processing, promote renewable energy use in mining operations and establish a dedicated fund for sustainable development in mining areas. These measures demonstrate a commitment to go beyond mere regulatory compliance and foster more integrated and responsible development.

Gabon does not have a law specifically for energy-transition minerals such as lithium, cobalt or copper.

However, the 2019 Mining Code provides for “strategic substances”, including minerals of economic or geostrategic interest. It classifies uranium, thorium and their derivatives as strategic substances by nature, and the 2024 Decree on Sovereign Substances classifies gold, silver, uranium, diamonds, gems and rare earth elements strategic substances by context (sovereign) – although this list could be extended. This triggers mandatory state involvement, including a 35% free, non-dilutable participation in large-scale mining operations, priority for local processing and strict control over exploitation, marketing and exportation.

In Gabon, mining companies are typically subject to the general tax regime, which includes corporate income tax, withholding taxes, dividend distribution tax, value added tax (VAT), land contributions, payroll taxes, stamp duties, registration fees and port fees.

In addition to these general taxes, specific mining operations such as the allocation, renewal, transfer, leasing or modification of mining authorisations or titles are subject to fixed fees and royalties. Depending on the stage of activity and the type of mineral resource, mining companies must pay specific royalties, including a proportional mining royalty, which is an annual tax on exploitation titles (products resulting from local processing are exempt), and a surface area royalty, calculated annually based on the area covered by the mining authorisation or title.

The export, import (excluding inputs used exclusively for local processing, which are exempt from customs duties), collection and marketing of precious substances, as well as the manufacture and processing of precious metal products, are also subject to taxes, with rates defined under the Mining Code.

Local processing of mineral resources benefits from an incentive regime, access to which requires approval from the Ministry responsible for Mines, Economy and Industry, based on an economic model, processing project or development plan.

Furthermore, the 2019 Mining Code establishes social responsibility and local content requirements that mandate contributions from mining titleholders to specific funds. These include funds supporting mining development, local communities and the rehabilitation of mining sites (to be deposited in a local bank account), as well as a 1% contribution of net profit for industrial liability provisions if appropriate insurance is not available. The tax and royalty framework in Gabon does not generally distinguish between national and foreign investors, meaning that the obligations apply equally to all mining companies operating in the country.

To encourage local content and domestic processing of mineral resources, the Gabonese Mining Code provides that the export of certain processed minerals is exempt from proportional mining royalties. Mining conventions may also include additional tax incentives, such as reductions in export duties, which in any case are capped at 1%.

Tax stabilisation agreements are available under these mining conventions. Except for small-scale mining operations, these stabilisation agreements are initially granted for a period of ten years. For ongoing operations, the duration of the tax stability guarantee is aligned with the remaining term of the permit upon renewal, ensuring predictable fiscal conditions for investors over the life of their projects.

Also, additional tax incentives for “critical mining projects” can be subject to negotiation under mining conventions, but require approval by Parliament.

Gabon does not impose a mining-specific capital gains tax separate from the general corporate tax regime; all transfers and assignments of mining titles are strictly governed by the Mining Code and the General Tax Code. In Gabon, the transfer or sale of a mining project is governed by the Mining Code (particularly Articles 193–195), which provides that any allocation, renewal, transformation, lease, transfer or assignment of mining authorisations and titles is subject to the payment of fixed fees.

These fees must be paid in a single instalment prior to the issuance of the relevant administrative act, and their amount is determined according to the title category and the nature of the act (allocation, renewal or transfer). For example, the transfer of a large- or small-scale mining exploitation permit is subject to a fee equal to 15% of the transaction value according to Article 195 of the Mining Code. Furthermore, pursuant to Article 23, paragraph 6 of the General Tax Code, the selling company is liable for a withholding tax of 20% on the capital gain realised from the sale.

Additionally, the transfer of shares in a company that holds a mining project must be registered with the Gabonese tax authorities, in accordance with Article 583 of the General Tax Code, and is subject to a proportional tax of 3% of the sale price. These provisions apply regardless of the mode of transfer, including when the transaction is conducted through companies or structures located outside Gabon, provided that the mining titles or underlying assets are located in the country.

The competent mining authority must also approve the transfer, in accordance with legal procedures, ensuring state oversight and the collection of the fixed fees and taxes associated with the transfer.

See 4.2 Tax Incentives for Mining Investors and Projects.

Under Regulation No 2/18/CEMAC/UMAC/CM of 2018, governing foreign exchange in the Central African Economic and Monetary Community (CEMAC), foreign direct investment must be declared to both the Central Bank and the minister in charge of currency and credit at least 30 days before the realisation of the investment.

In addition, when a non-Gabonese company, a foreign individual or a Gabonese national residing abroad acquires, directly or indirectly, control over a company registered in Gabon, or when it acquires all or part of a branch of activity of such a company, prior authorisation from the minister responsible for the economy is required pursuant to Decree No 0673/PR/MECIT of 15 May 2011, which implements the Investment Charter on Foreign Direct Investment in Gabon, in accordance with Articles 174 and 175 of the Organisation for the Harmonization of Business Law in (OHADA) Uniform Act on Commercial Companies and Economic Interest Groups (Acte Uniforme OHADA relatif au Droit des sociétés commerciales et du groupement d’intérêt¬économique; GIE).

Furthermore, the Mining Code treats any change of control over a company holding a mining authorisation or permit as a transfer of rights, which must receive approval from the Minister of Geological Resources and Mining to be valid. The only exception applies to affiliated companies that have been in existence for at least five years. All such transactions are subject to the state’s pre-emptive rights, which must be exercised within a 60-day calendar period; if the state does not act within this timeframe, the transaction may proceed.

There is no specific multilateral or bilateral treaty related directly to exploration and mining. However, the Gabonese Republic is a party to several multilateral and bilateral treaties that aim to promote and protect foreign investments, and these frameworks can apply to investments in the mining sector.

In particular, Decree No 0673/PR/MECIT, dated 15 May 2011 – which implements the Investment Charter – establishes Gabon’s adherence to key international investment protection mechanisms, including membership with the Multilateral Investment Guarantee Agency (MIGA) to cover political risks and affiliation with the International Centre for Settlement of Investment Disputes (ICSID) for dispute resolution. Gabon has also ratified the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, allowing foreign investors to enforce arbitral decisions in the country.

Under the Mining Code, the state recognises, in case of dispute, arbitral awards made under bilateral agreements and multilateral treaties on investment, notably those of MIGA and ICSID, and arbitral awards made pursuant to the New York Convention on the Recognition and Enforcement of International Arbitral Awards (concluded in 1958) under the auspices of the United Nations – as well as decisions rendered pursuant to the OHADA Uniform Act on Arbitration.

In Gabon, financing for mining activities – ie, exploration, development or production – mainly comes from private sources. Mining companies typically rely on equity financing from shareholders and debt financing from local or international banks to fund exploration and development.

In Gabon, the domestic and regional securities markets are not yet the standard route for financing mining and exploration, although exceptions exist, notably with respect to Comilog.

In March 2025, Comilog issued bonds on the regional securities market via the Central African stock exchange (Bourse des Valeurs Mobilières de l’Afrique Centrale; BVMAC), raising XAF80,065 billion (approximately USD133 million) through a multi‑tranche issuance. That issuance shows that, for at least some large‑scale mining companies with established operations, debt via securities markets can serve as a viable source of financing. Nevertheless, this remains the exception; for most operations, traditional financing routes – equity, reinvested profits or private loans – continue to dominate. However, international securities markets are indirectly involved through the listing of certain companies with head offices aborad, notably in Europe (Eramet for Comilog) or Australia (Fortescue for Ivindo Iron and Genmin for Reminac).

Under Gabonese law, mining titles may be used as security when financing is required for exploration, project development or mining operations. The Mining Code grants large-scale exploitation permits the legal status of real property, which allows them to be encumbered as collateral, including through mortgages, for the benefit of lenders or investors. Other mining-related assets such as equipment, extracted ore, commercial receivables or shares in the company holding the mining title may also be pledged or otherwise used as security in accordance with Gabonese civil and commercial law.

Creating a security interest requires a formal agreement between the holder of the title or asset and the secured creditor. To ensure enforceability against third parties, the security must then be registered with the tax administration and, for most types of movable security, recorded in the Commercial and Movable Credit Register maintained by Gabonese court registries. This publicity requirement is essential, as it determines the creditor’s priority ranking and its ability to enforce rights in the event of default.

The 2025 Finance Act has standardised the cost of these formalities by introducing a fixed registration fee of XAF20,000 for most of the security instruments within the tax administration. This fixed fee applies to a broad range of guarantees commonly used in mining finance, including pledges over business assets, mortgages, first-demand guarantees, charges and pledges over professional equipment or receivables. A stamp duty of XAF500 per page remains payable on documents submitted for registration.

The outlook for the mining sector in Gabon over the next two years appears cautiously optimistic, driven by strong government support and a desire to diversify the sector.

For 2026, the government has proposed a mining budget of XAF68.12 billion, a significant increase from XAF4.56 billion in 2025 (according to a proposal presented on 21 October before the Transitional National Assembly’s Finance Committee by Gilles Nembe, the Minister of Mines and Geological Resources). This unprecedented boost demonstrates the state’s commitment to revitalising the sector through funding exploration activities, regulatory reforms and infrastructure development, as well as by promoting the exploitation of new mineral deposits beyond the traditional focus on manganese.

While manganese remains a cornerstone of Gabonese mining, other minerals, including iron from the Belinga or Bamiaka deposits, rare earth elements, potash mine in Mayumba and precious metals, are attracting attention. Recent initiatives, such as the commissioning of a local gold refinery, reflect the government’s emphasis on value addition and local processing rather than the simple export of raw materials. These developments indicate that the country may see new exploration and development projects, and associated infrastructure and mining plants, come online over the next two years.

The regulatory framework is also evolving. The government plans to publish several implementing decrees for the 2019 Mining Code in 2026, which will clarify procedures for strategic or sovereign substances, environmental obligations, local processing incentives and investor rights. If implemented effectively, these measures could reduce legal uncertainties, attract new investors and accelerate project development.

However, the sector remains exposed to global market fluctuations. The demand for manganese, for example, has been volatile, impacting production forecasts for operators such as Comilog. Prices for iron, rare earths and other strategic minerals are also sensitive to international market conditions and industrial demand, which could affect the economic viability of projects in the short term. Gabon is also improving its commitment to the Extractive Industries Transparency Initiative (EITI).

Project Lawyers

Batterie IV
BP 11656
Libreville
Gabon

+241 11 44 25 32

jpbozec@gmail.com www.project-lawyers.com
Author Business Card

Law and Practice in Gabon

Author



Project Lawyers is a successful, independent and leading Gabonese law firm established by Jean-Pierre Bozec. The firm is dedicated to projects and financings in Gabon, with a four-member team located in Libreville with more than 70 years of accumulated experience in Gabon business law. Project Lawyers is a niche premium law firm with a strong commitment to independence, integrity and confidentiality that aims to provide high-quality and innovative legal services to major corporations, financial institutions and international law firms, especially those involved in energy, mineral resources and infrastructure projects, and project financing. Project Lawyers is an active member of the Employers' Union in Gabon (Fédérations des Entreprises du Gabon; FEG ) and has a seat on the Legal, Tax and Ethics Commissions. The firm has been ranked by Chambers and Partners as a Band 1 business law firm for 12 consecutive years.