Critical Minerals in Cameroon: The 2023 Mining Code in Practice

Cameroon is not a mining country yet, but it has stopped being a theoretical one. Under the mining code that took effect on 19 December 2023, five projects have entered production or commissioning, and the first iron ore left the country in February 2026.

At the same time, the most commercially important fact about mining in Cameroon sits in a different piece of legislation entirely — and it is one investors routinely discover too late. Mining is excluded from the investment incentive regime that came into force in 2026. That single provision changes which mining projects in Cameroon are worth structuring.

This article covers both.

The 2023 code is the one that applies

The governing instrument is Loi n°2023/014 of 19 December 2023, the Code minier. It replaced the 2016 code. Any advisory material still citing the 2016 law is out of date, and a document that quotes the wrong code is a warning sign about the rest of the file.

Three terms matter most:

• The State holds at least 10% equity in industrial mining projects. This is not a royalty or a carried interest available at election — it is a participation requirement built into the code.
• SONAMINES holds exclusive rights to purchase and market gold and diamonds. If your project produces either, you are not selling into the market; you are selling to a single counterparty. That concentration should be priced into any gold or diamond economics before the resource is drilled.
• Companies must prioritise recruitment of Cameroonian nationals. A workforce plan built on expatriate-heavy staffing needs to be reconciled with the code from the start.

What is actually producing

The Minister has stated that five projects have entered production or commissioning. Three are iron ore and form the strategic core:

• Mbalam-Nabeba — first exports shipped in February 2026, with a stockpile above 600,000 tonnes and a stated revenue target of XAF 747 billion.
• Bipindi-Grand Zambi — target XAF 570 billion.
• Kribi-Lobé — target XAF 431 billion.

The remaining three in production or commissioning are Minim-Martap (bauxite, Canyon Resources), Bidzar (marble) and Colomine (gold).

The strategic framing is overt. Government targets mining revenue above XAF 1 trillion — roughly US$1.75 billion — per year, on the stated logic that mining should overtake oil. The three iron-ore projects are expected to absorb US$3.1 billion by 2030. SONAMINES, the state mining company, posted its first profit since launch — XAF 724.7 million — in FY2025.

For scale, mining is currently roughly 1% of GDP. Oil is 2.2% of GDP and 18.4% of fiscal revenue. Extractives overall were 4.9% of GDP, 11.9% of government revenue and 31.3% of exports in 2024. The gap between ambition and current contribution is the whole investment case, in both directions.

Mining gets no incentives under the 2025 regime

Ordonnance n°2025/002 of 18 July 2025 rebuilt Cameroon's investment incentive framework, repealing the 2013 and 2017 laws. It was ratified later in 2025 and operationalised in March 2026.

Article 3 lists eight eligible sectors:

1. Agriculture
2. Heavy, automotive and manufacturing industry
3. Water and energy
4. Education and health
5. Air, rail and maritime transport
6. Tourism
7. Large-distribution infrastructure
8. Digital infrastructure for storage and processing

And it excludes, explicitly: petroleum upstream, mining, gas, and commerce and distribution.

For an energy investor the reading is precise — energy is eligible except gas and upstream petroleum. For a mining investor the reading is absolute. There is no relief available under this regime. Clients with existing mining or oil exposure get nothing from the 2025 framework.

This is easy to miss, because the incentive mechanics are genuinely attractive and widely publicised. Installation-phase relief runs up to five years of full exemption from customs duty, VAT and registration duty, plus patent exemption. Exploitation-phase relief adds a corporate income tax credit of 25% for investment under XAF 1 billion, 50% for XAF 1–5 billion, and 75% above XAF 5 billion, rising further inside a Development Priority Zone to 30%, 55% and 80%. Credits are capped at 50% of declared profit and carry forward five years. PPP co-contractors get a five-point reduction in the corporate income tax rate for five years — the only headline rate reduction in the ordinance, and it does not apply to ordinary investors.

None of that is available to a mine.

Two conditions also govern who qualifies. An applicant must satisfy at least two of five tests: one job per XAF 50,000,000 invested; at least 50% of inputs from Cameroonian natural resources; at least 40% Cameroonian goods in turnover for large-distribution activities; at least 30% value added over the standard; or exports of at least 25% of turnover excluding taxes. And applications are adjudicated within ten working days through a Guichet Unique single window inside the investment-promotion agency.

The agency is the API — Agence de Promotion des Investissements. If you have been told to deal with an agency called "ARS-ACE", check that independently: we could not find any trace of that body, and the API is the functioning institution.

Use the conversion ratio, not the projections

The most useful dataset for modelling is the API's own mid-term assessment of the 2014–2024 programme:

• 453 companies approved.
• About XAF 8 trillion of projected investment.
• About 180,000 projected jobs.

Against which, for the 156-company subset actually assessed:

• About XAF 1.9 trillion of investment actually made.
• More than 16,000 jobs actually created.

That is roughly a quarter of projected capital and a ninth of projected jobs realised. The 2025 regime tightens eligibility further, so the ratio will not improve. Older figures still circulating — "127 projects, about US$2.3 billion committed" — understate the ambition and are superseded by this assessment.

For a live example of the new regime operating: Kam Plaza Hotel in Douala, XAF 2.811 billion and 82 direct jobs, tourism sector, agreement signed on 25 September 2026.

Two risks that belong in the model

Contract risk is live. An ICC arbitral award of approximately US$616 million was issued against Cameroon in the Mbalam-Nabeba matter in July 2026. That is not background colour; it is a counterparty-risk input.

The gold sector is being formalised, which cuts both ways. An estimated 80–90% of semi-mechanised gold production previously bypassed state collection channels. Over 200 illegal operators have been identified and 137 referred to court, with expected recoveries of approximately US$692 million. That improves formal supply and governance. It also means a newly formal gold sector competing against operators with no cost structure worth modelling.

Dispute resolution is the wider frame. In the World Bank's B-READY 2025 assessment, Cameroon scores 35% on Dispute Resolution — the weakest pillar, against an overall Business Entry score of 43.01. For a contract-heavy or litigation-sensitive exposure, that is the number to raise early.

What to do with this

• Cite Loi n°2023/014, never the 2016 code.
• Model the 10% state equity and SONAMINES marketing obligation as structural, not negotiable.
• Assume no incentive relief for a mining project under the 2025 regime, and check whether the project can be structured to qualify under a different eligible heading rather than assuming.
• Underwrite delivery, not endowment. The iron-ore projects are rail-and-port stories. The CAR–Kribi corridor has US$6 billion of Exim Bank of India financing for roughly 1,350 km, but port infrastructure at Kribi remains undefined and the two states do not jointly control the corridor. First exports shipping and a US$616 million award in the same year is what that risk looks like in practice.

If you are weighing a specific project or need the incentive position checked against your own structure, our investment advisory services cover this, and critical minerals and mining sets out the wider sector view. Start a conversation if you would prefer to work through it directly.