82 Days Since Enactment of the PVO Act: Update, Challenges & Key Actions for a Smooth Transition

On 11 April 2024, the Private Voluntary Organisations (PVO) Amendment Act, 2025, was signed into law, closing a legislative journey that began on 5 November 2021, when the Bill was first gazetted. Now, 82 days later, Civil Society Organisations (CSOs), Trusts, and Community-Based Organisations (CBOs) across Zimbabwe are actively engaging with the transitional requirements and compliance measures introduced by the new law.

The transition period provides a crucial window for organisations—especially pre-existing Trusts and Common Law Universitas—to register as PVOs. However, several systemic, structural, and operational hurdles have emerged, complicating what should ideally be a straightforward compliance process.

This detailed update draws on data collected by NANGO through PVO Sensitisation and Outreach Blitz, which included workshops in Harare, Bulawayo, Gweru, Masvingo, and Mutare, reaching a total of 249 organisations. It captures lived realities on the ground, highlights key observations, and presents priority actions needed for a smooth, inclusive and efficient implementation of the PVO Act.

📊 Snapshot of the Registration Progress
Out of the 249 organisations engaged:

• 🏩️ 163 are pre-existing Trusts and universitas impacted directly by the new legal requirement to transition into registered PVOs.
• ✅ 29 of these have successfully submitted applications pending registration outcome.
• 🕐 130 are in various stages of compiling documents and making applications.
• ❌ 2 have indicated that they do not intend to register as PVOs.

If your organisation has not yet participated in our feedback process, we encourage you to contribute to our ongoing PVO registration tracking efforts by completing this short form:

👉 Click to Fill the Survey

📌 Contextual Realities: Implementation Challenges and Gaps
🧩 Challenges and Observations

From the Regulator’s Side (Supply Side):

1. ⚠️ Non-standardised Procedures: District Social Development Offices differ in application templates and requirements, including the use of specific newspapers for advert placements despite the clarification from the regulator that organisations are free to choose any press of their choice.
2. 🏛️ Difficulties in securing Letters of Intent from Local Authorities: CSOs face difficulties securing letters of intent due to confusion between MOUs, clearances, and actual recommendation letters. Some authorities are unaware of their role in the PVO registration process.
3. 🕓 Delayed Feedback: Several CSOs have gone over 2 months with no feedback after submission.
4. 👥 Understaffing: In some districts, untrained interns handle applications, resulting in miscommunication and delays.
5. 💰 Delayed Gazetting of Prescribed Fees: This continues to create uncertainty in budgeting and planning.
6. ⏳ Conflicting Timeframes: There is confusion between the 90-working-day window and the “3-month” timeframe stated in Section 14(1)(a).
7. 🧑🏽‍⚖️ Pending Reconstitution of the PVO Board: The delay in setting up the new Board is stalling processes.

From CSOs (Demand Side):

• 💸 Financial Barriers: CBOs cite high costs for printing, police clearance, adverts, and transport, especially for Board members based outside major cities.
• 🧠 Technical Gaps: Many need support in drafting constitutions, framing institutional objectives, and properly structuring Boards.
• ⏱️ Time Constraints: Organisations are racing to convene ad hoc Board Meetings, extraordinary AGMs, and constitute new boards compliant with the Act.

🧰 Resources and Support Offered by NANGO
Frequently Asked Questions (FAQ) Document: Aggregated from Registrar responses and field engagements. 🔗 Access FAQ Here

📝PVO Registration Advisory Note: Step-by-step guidance for CSOs navigating the registration process. 🔗 Download the Advisory Note

PVO Amendment Act, 2025, Fact Sheet: A summary of the key provisions for informational purposes. 🔗 Download the Fact Sheet

🤝 In-Person Support and Referrals:

Our Regional Coordinators are available across the five regions to assist in peer reviewing application documents, provide referrals to legal/technical advisors, and assist with form completion and submission.

🚨 Key Asks and Priority Actions Going Forward
To ensure smooth implementation of the PVO Amendment Act, NANGO recommends the following:

To the Regulator:

• Urgently standardize registration procedures and templates across all districts.
• Gazette and publicize prescribed fees to reduce uncertainty and foster compliance.
• Fast-track the reconstitution of the PVO Board to unlock full operationalization of the Act.
• Provide clear circulars to local authorities on their exact role in issuing letters of intent.
• Increase capacity-building for DSD frontline staff to handle applications competently.

To Development Partners:

• Support CBOs and grassroots organisations with flexible funding to cover compliance costs.
• Facilitate legal and technical advisory services for CSOs struggling to meet registration requirements.
• Continue supporting platforms that promote multi-stakeholder dialogue on civic space.

To Civil Society Organisations:

• Accelerate efforts to regularize your status in line with the PVO Act’s provisions.
• Leverage NANGO’s advisory support, FAQ, and registration guide, and any other credible source.
• Share your experiences and challenges through our survey link to help inform collective advocacy.