Zimbabwe has commenced preparations for its third round Financial Action Task Force (FATF) Mutual Evaluation, scheduled for 2026–2027. The Mutual Evaluation will assess the country’s compliance with international standards on Anti-Money Laundering, Countering the Financing of Terrorism, and Countering Proliferation Financing (AML/CFT/CPF), including FATF Recommendation 8, which specifically relates to Non-Profit Organisations (NPOs). This process is highly consequential for civic space. Without proactive and informed civil society engagement, there is a risk that overly restrictive regulatory measures may be introduced under the banner of international compliance, further limiting the ability of CSOs to operate freely and legitimately. At the same time, the evaluation presents an important opportunity for civil society to influence risk assessments and policy responses to ensure that AML/CFT/CPF measures are proportionate, evidence-based, and consistent with international human rights standards.
As part of the preparatory phase, the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) convened a Pre-Mutual Evaluation Workshop from 12 – 16 January 2026 at Rainbow Towers Hotel in Harare. The workshop aimed to prepare key stakeholders who will be directly involved in Zimbabwe’s Mutual Evaluation, including officials working on AML/CFT/CPF matters and representatives expected to engage with FATF assessors during the evaluation process. Participation targeted institutions responsible for policy, regulation, and implementation within the national AML/CFT/CPF framework.
Civil society participation in the workshop was limited, reflecting the historically constrained involvement of NPOs in FATF-related processes. Through NANGO’s facilitation, representatives from the Zimbabwe Council of Churches (ZCC), the Alliance of Community-Based Organisations (ACBOs), and the Zimbabwe Human Rights NGO Forum attended the workshop, alongside the PVO Registrar and officers from the Ministry of Public Service, Labour and Social Welfare (MoPSLSW). In total, four representatives participated on behalf of the NPO constituency.
The workshop was particularly significant for civil society as it builds on ongoing advocacy around FATF Recommendation 8, which has frequently been misinterpreted and misapplied in ways that justify disproportionate regulation of NPOs. In Zimbabwe, such misapplication has contributed to restrictive legal and policy developments, including provisions within the Private Voluntary Organisation (PVO) Amendment Act of 2025. The limited representation of NPOs at the workshop further underscores the need for deliberate and coordinated engagement to ensure that civil society perspectives are adequately reflected throughout the Mutual Evaluation process.
Historically, Zimbabwean civil society has not meaningfully participated in previous FATF Mutual Evaluations and has largely been excluded from in-country AML/CFT/CPF processes. Many CSOs and CBOs have a limited understanding of how the Mutual Evaluation operates, the areas of focus for assessors, and the potential implications of the process for civic space and organisational operations. This knowledge gap heightens the risk of regulatory responses that may undermine legitimate civil society work.
In response, NANGO is prioritising a sector-wide sensitisation and awareness initiative aimed at strengthening CSO and CBO preparedness for Zimbabwe’s upcoming FATF Mutual Evaluation. The initiative will focus on demystifying the Mutual Evaluation process, clarifying the intent and scope of FATF Recommendation 8, and explaining the role of civil society in supporting compliance while safeguarding operational freedoms. It will also address in-country AML/CFT/CPF obligations, typical areas of assessor scrutiny, and practical measures organisations can adopt to identify compliance gaps and mitigate risk.
The overall objective of this initiative is to strengthen sectoral understanding of FATF Recommendation 8, empower organisations to engage meaningfully with the Mutual Evaluation exercise, and foster collective advocacy for risk-based, proportionate, and rights-respecting AML/CFT/CPF oversight. This is particularly important given that NPOs will be afforded an opportunity to engage directly with FATF assessors during the Mutual Evaluation process.
Based on key takeaways from the preparatory process and lessons from other jurisdictions, including Kenya, NANGO intends to establish a Zimbabwe NPO Technical Working Group (TWG) on FATF. The TWG will serve as a structured and coordinated platform to strengthen civil society engagement in FATF-related processes. It will facilitate engagement with regulators, policymakers, and other stakeholders on the implementation of a risk-based approach to AML/CFT/CPF oversight that is effective without undermining civic space.
The TWG will also monitor AML/CFT/CPF compliance trends, assess regulatory risks, and provide timely updates and technical guidance to CSOs. Through coordinated advocacy, peer learning, and capacity building, the group will support efforts to prevent the securitisation of civic space and ensure that compliance measures do not become tools for arbitrary or disproportionate restrictions on civil society. It will further enable CSOs to anticipate regulatory changes, provide informed input into the Mutual Evaluation, and contribute meaningfully to shaping national AML/CFT/CPF responses.
The Mutual Evaluation will assess both Zimbabwe’s technical compliance with the FATF 40 Recommendations and the effectiveness of its AML/CFT/CPF system. Mandatory Recommendations to be assessed include Recommendations 1, 2, 4, 8, 15, 24, 25, 30, 31, 38, and 40. The process will culminate in a single public Mutual Evaluation Report that provides an internationally agreed assessment of Zimbabwe’s compliance and effectiveness, alongside recommendations for strengthening the national AML/CFT/CPF framework.
Of particular relevance to civil society is Immediate Outcome 10, which examines the extent to which Zimbabwe has applied focused and proportionate mitigation measures to NPOs identified as vulnerable to terrorist financing abuse, without disrupting or discouraging legitimate NPO activities. FATF Recommendation 8 explicitly seeks to address the historical misapplication of counter-terrorism financing measures to the non-profit sector. It requires countries to identify relevant risks, apply proportionate and targeted measures, and remain mindful of the impact of regulation on legitimate NPO activities. Measures that are overly burdensome or restrictive, or that impose obligations such as due diligence on NPOs, are not consistent with the FATF standards.
During the 15th Edition of the NANGO Annual NGO Directors’ Summer Retreat, held in Masvingo, a dedicated session on the FATF Mutual Evaluation Overview was convened to further enhance civil society understanding of the process and its implications. A presentation was delivered by Mr. Tichafa Chigaba, Deputy Director at the Financial Intelligence Unit (FIU) Zimbabwe, who provided insights into the Mutual Evaluation framework, key assessment areas, and expectations for Zimbabwe ahead of the 2026–2027 evaluation cycle. The engagement formed part of NANGO’s ongoing efforts to promote informed, constructive dialogue between civil society and regulators on AML/CFT/CPF issues. For those who were unable to attend the session, the recording is available and can be accessed here:
The FATF Mutual Evaluation represents a critical moment for Zimbabwe’s civil society sector. The way AML/CFT/CPF standards are interpreted and implemented during this process will have lasting consequences for civic space, organisational autonomy, and democratic participation. Sustained, coordinated, and technically informed civil society engagement will be essential to ensure that international compliance obligations strengthen transparency and accountability without eroding the freedoms necessary for civil society to operate effectively.
On 11 April 2025, Zimbabwe officially gazetted the Private Voluntary Organisations (PVO) Amendment Bill into law. This marks a major shift in how Civil Society Organisations (CSOs) are regulated in the country. The Act, first reintroduced in Parliament on 1 March 2024, moved through all legislative stages despite ongoing concerns from CSOs about some of its provisions and their impact on civic space.
Throughout the process, CSOs engaged openly with the government, hoping to help shape a law that promotes both accountability and a supportive environment for civic work. CSOs have long been key partners in Zimbabwe’s development, contributing to governance, service delivery, and alignment with international standards. Contrary to popular belief, CSOs are not against regulation. They have always shown a willingness to cooperate with the government to ensure a clear and fair operational space.
As part of their engagement, CSOs submitted proposals to Parliament, met with the Minister of Justice, and responded to a call from the Attorney General to share feedback. At one point, the Attorney General even promised to arrange a meeting with the President to resolve outstanding concerns. However, the law was passed before these discussions could take place—disappointing many in the sector and undermining the spirit of inclusive dialogue.
Although the Act claims to promote a better working environment for PVOs, many of its provisions fall short. One major concern is the very short transition period. Section 14 of the schedule gives existing charitable organisations just 90 days to register under the new law. This is not enough time for most organisations, which often need to hold Annual General Meetings (AGMs), change their constitutions (with at least three months’ notice), complete audits, and consult with members and partners. Some may even need to dissolve or restructure existing trusts—steps that take time and legal support.
Initially, CSOs proposed a 12-month transition period. The Portfolio Committee on Public Service, Labour and Social Welfare recommended nine months. Yet, the final law set the deadline at only 90 days, without explaining why. This rushed process risks disrupting the sector, causing legal confusion and potential non-compliance. It also conflicts with Section 68 of Zimbabwe’s Constitution, which guarantees fair and lawful administrative action.
Another problem is the lack of clarity in the registration process. The law does not outline how applications will be processed, how long decisions will take, or what organisations should do if their applications are rejected or they choose not to re-register. The Registrar has wide powers to demand extra requirements at any time, which could lead to endless delays. Additionally, the new standard constitution model fails to reflect the diversity of CSOs, especially those that are not membership-based.
Public consultations on the Bill also raised concerns. Hearings held in May 2024 were disrupted in cities like Harare, Gweru, Masvingo, and Chinhoyi. Citizens were blocked from participating, and some hearings were abandoned. Still, the Portfolio Committee managed to compile a report with feedback from those who were able to take part.
The law-making process itself also faced issues. Changes made in the National Assembly were not included in the version passed by the Senate in October 2024. These were only partly fixed in February 2025, highlighting poor coordination and transparency in finalising the law.
Beyond legal issues, CSOs have played a vital role in Zimbabwe’s development. They have supported humanitarian efforts, promoted human rights, and worked with the government on health, education, economic development, and disaster response. As Zimbabwe moves from the National Development Strategy 1 (NDS1) to NDS2, strong partnerships with CSOs will remain critical.
CSOs have also supported international development goals and taken part in key reform processes, such as the Arrears Clearance and Debt Resolution initiative. Worryingly, the new law may affect Zimbabwe’s performance on global governance indicators. By April 2025, the country had already dropped in nine of sixteen indicators on the Mo Ibrahim Index—an outcome that could worsen if civic space continues to shrink.
Although the Act claims to support PVO operations, many of its provisions create legal confusion, administrative burdens, and restrictions that could prevent CSOs from carrying out their work effectively. If not improved during implementation, the Act could harm Zimbabwe’s democratic growth and development progress.
Zimbabwean CSOs remain committed to transparency, accountability, and national development. They call on the government to reopen inclusive dialogue to ensure that their work is not disrupted. As NANGO, we believe that a strong, independent, and empowered civil society is essential to Zimbabwe’s success—not only in delivering services but in building trust, encouraging innovation, and making sure no one is left behind.
The Summit of the Future 2024 is an essential event for tackling global issues and shaping international collaboration. Civil Society Organisations (CSOs) in Zimbabwe have a pivotal role in influencing the summit’s outcomes and advocating for a civic space where fundamental freedoms are upheld.
CSOs Advocate for a More Equitable Future
CSOs in Zimbabwe are calling for a future that is built on principles of human rights, social justice, and environmental sustainability. Their key messages for the Summit include:
Human Rights and Social Justice: We advocate for the inclusion of marginalized and vulnerable populations in all decision-making processes. Our emphasis is on the need for policies that address social inequities and promote justice. The Pact and Declarations should include strong commitments to protect human rights including freedom of expression, assembly, and protection from discrimination.
Climate Action and Environmental Sustainability: We urge the Summit to prioritise urgent climate action, with concrete commitments to reduce emissions, support renewable energy, and protect biodiversity. Emphasis is placed on Governments and the UN to prioritise environmental sustainability, poverty eradication, and sustainable cities and communities in their development trajectory.
Peace and Security: Conflict Prevention and Peacebuilding are paramount. We advocate for measures to prevent conflicts and support peacebuilding efforts, including addressing root causes such as inequality and lack of access to resources. The UN and its member states should promote initiatives aimed at disarmament, particularly the elimination of nuclear weapons, and support for international treaties and agreements on arms control.
Universal Health Access and Pandemic Preparedness: Declarations should be made for investments in public health systems to ensure they are resilient and capable of responding to pandemics and other health crises. We advocate for equitable access to vaccines, treatments, and healthcare services, especially for the poor and marginalized communities.
Economic Justice and Inclusive Growth: The UN and member states should promote fair trade practices and the protection of labour rights, ensuring decent work and economic opportunities for all. We call for policies that address economic inequality, including progressive taxation, social protection measures, and resolution of debt distress especially in many African countries.
Technology and Digital Inclusion: The digital divide must be bridged, ensuring access to digital technologies and the internet for all, particularly in remote areas. Ethical frameworks for emerging technologies like Artificial Intelligence (AI) are necessary to prevent exacerbating inequalities and ensure they benefit all societies.
Strengthening Multilateralism and Global Governance: The Summit should emphasise the need for inclusive multilateralism. There is a need for an inclusive and participatory approach to global governance, where CSOs and other non-state actors have a meaningful voice. This calls for reform of international institutions to make them more democratic, transparent, and responsive to global challenges.
Protection of Civic Space: There is a need for international resolutions that advocate for legal frameworks protecting the rights of civil society actors. This includes ensuring freedoms of association, expression, and peaceful assembly. The future we want should have established civil dialogue mechanisms that facilitate open communication between civil society, governments, partners, and international bodies.
The Summit is a high-level event, bringing world leaders together to forge a new international consensus on how we deliver a better present and safeguard the future.
This once-in-a-generation opportunity serves as a moment to mend eroded trust and demonstrate that international cooperation can effectively tackle current challenges as well as those that have emerged in recent years or may yet be over the horizon.
We already have the “what” in the form of many existing agreements and commitments, starting with the UN Charter and including the Universal Declaration of Human Rights, the 2030 Agenda, the Paris Agreement, the Addis Ababa Action Agenda, and many others.
The Summit of the Future will look at the “how” – how do we cooperate better to deliver on the above aspirations and goals? How do we better meet the needs of the present while also preparing for the challenges of the future?