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RBGLP SEPTEMBER - NOVEMBER 2025 NEWSLETTER

BLOG: MANAGING PARTNER’S DESK

The Crystallisation of a New Legal Order: Q4 2025

By Reagan Blankfein Gates | Managing Partner

Distinguished Clients and Colleagues,

The final quarter of 2025 was not merely a passage of time but a definitive inflection point in Zambia’s legal history—a season requiring deep analytical digestion rather than immediate reportage.

From discretion to mandate: We have witnessed the twilight of broad ministerial discretion and the dawn of rigid, autonomous regulation. Instruments like the Minerals Regulation Commission Act and SI 68 of 2025 signal a shift from soft policy to statutorily mandated resource nationalism. The state is no longer requesting local participation; it is enforcing it.

A hardening compliance environment: This 'hardening' extends across the economy. From the Supreme Court’s Nestlé judgment to the Bank of Zambia’s monetary directives, the message is singular: flexible discretion has been replaced by strict adherence. Whether through the digitisation of land titles or the strict jurisdictional enforcement seen in the Musukwa and Mataliro judgments, the system is modernising yet increasingly formalistic.

Our commitment: In this landscape, technical interpretation is merely the baseline; strategic foresight is the true differentiator. We present this digest not just as a record of the past, but as your roadmap for the strict compliance environment that defines 2026.

Yours in service,

Reagan Blankfein Gates Managing Partner