Strategic minerals and regional deals: the unused power to designate strategic minerals under Article 3(d) of Law N° 072/2024, State equity and free carried interest, lithium, tungsten and rare-earth targets, RMB's 2025 investment rounds, the Rwanda-DRC Regional Economic Integration Framework of 4 December 2025, the US-Rwanda economic framework and what each means for an investor

What 'strategic' means in Rwandan mining law

Rwandan law uses the word in one place. Article 3(d) of Law N° 072/2024 of 26/06/2024 on mining and quarry operations (the Mining Law) allows the competent organ, the Rwanda Mines, Petroleum and Gas Board (RMB), to 'designate certain strategic minerals for which the Government exercises exclusive rights in the public interest'; Article 3(e) gives a parallel power over quarries reserved for Government projects. The Law sets no procedure, criteria or compensation rule for a designation, and none had been made or published by 10 October 2026. The power nonetheless matters: a designation could reserve a mineral to the State after an investor has spent money exploring for it, and an exploration licence gives a 'primary right' to a mining licence only within the existing legal framework. Investors exploring for lithium, rare earths or other minerals with strategic value elsewhere should ask RMB in writing whether a designation is under consideration and seek protection in the agreement with RMB, discussed in Mining agreements, local content and community.

Outside the Mining Law, 'critical' and 'strategic' are policy labels. In its announcement of 2 December 2025 RMB described tin, tantalum, tungsten, lithium, beryllium, rare earth elements and gold as Rwanda's 'strategic minerals', a policy description rather than a designation under Article 3(d). No national critical-minerals strategy had been adopted by 10 October 2026, and commentators in Kigali called for one in December 2025. The practical consequence is that a mineral's strategic status changes the commercial and political context of a project, the buyers it attracts and the sanctions and due-diligence scrutiny it receives, but not, so far, the licence regime that applies to it.

State equity and free carried interest

Two provisions allow the State into a project. Article 48 provides that the Government may acquire shares in mining or quarry operations 'on such terms as agreed upon between the holder of a licence and the Government'; Article 15 of RMB's 2019 large-scale model agreement repeats the point. This is a negotiated stake, which the Government may pay for in cash or in kind. Article 49 goes further: the grant of a mining licence 'may entitle the government with free carried interest', and an Order of the Minister in charge of Government investment is to determine 'the number and modalities' of that interest. That Order had not been published by 10 October 2026, so no carried interest can yet be imposed by reference to it, but the statutory basis exists and a mining licence granted now could become subject to it once the Order is made.

Some secondary sources state that Rwanda takes no carried interest; that reflects current practice rather than the Law. Investors should model both cases: a negotiated equity stake under Article 48, which is the route used in recent ventures, and a possible free carried interest under Article 49, whose size is unknown. The September 2026 tungsten venture between Almonty Industries and the Government of Rwanda illustrates the first route: according to Almonty's announcement of 14 September 2026, filed with the United States Securities and Exchange Commission, Almonty holds 75% and the Government 25%, the Government contributing the Shyorongi exploration concession of about 32 km² and a licence to process tailings with mobile plant. Anyone acquiring an existing licence should check whether any State equity, option or carried interest has been promised, because a transfer needs RMB's prior approval under Articles 16 to 18 of the Mining Law.

Where the opportunities are: the 2025 investment rounds

RMB moved to competitive allocation in 2025 through its Rwanda Mining Investment Pitchbook. The first round, launched in May 2025, offered 10 blocks with a closing date of 16 August 2025 and drew 73 applications. The second, announced on 3 December 2025 during Rwanda Mining Week, offered another 10 blocks, 4 for mining, 4 for exploration and 2 for gemstones, with a closing date of 3 March 2026; RMB's instructions for that round state that applicants would be informed of the results within 90 days after the closing date. The December blocks cover lithium and beryllium as well as the traditional tin, tantalum, niobium, tungsten and gold and gemstones such as sapphire, ruby, amethyst and tourmaline, and the May 2025 pitchbook describes one block's surroundings as possibly hosting a rare earth element deposit. Applications follow the 2019 RMB regulations on applications and tenders, which RMB continues to apply, and require the full licence file described in Mining licences and quarry licences.

Exploration is at an early stage. RMB reports 52 target areas under exploration and more than 92,000 jobs in the sector, and the Rwanda Development Board (RDB) reports mineral exports of USD 1.1 billion in 2023, against USD 373.4 million in 2017. Lithium has attracted most attention: in July 2025 the press reported drilling results of 7 metres at 2.1% lithium from a project of Aterian with Rio Tinto, and secondary sources refer to a planned lithium refinery. These are company and press reports, not RMB findings. On processing, RMB stated on 2 December 2025 that refining of gold, tin and tantalum is already operational in Rwanda, and tungsten processing is the object of the Almonty venture.

Raw exports: taxed, not banned

Rwanda does not prohibit the export of unprocessed minerals. Its tools are fiscal. Under Law N° 056/2024 of 26/06/2024 establishing tax on minerals, in force since 5 July 2024, minerals 'exported in raw form' pay an export tax on top of the mining royalty tax: 2% of norm value for base metals (including tin, tungsten, tantalum and niobium), 3% for gemstones, 2% for platinum group metals, 1% for rare-earth elements, 2% for energy minerals such as lithium and cobalt, and 0.5% for gold (Article 5). Processed minerals and imported minerals for re-export, except gold, are exempt from tax on minerals at the export point (Article 7(2)), and neither tax is deductible for income tax (Article 6(3)). Separately, the Investment Code's 15% corporate income tax rate for exporters does not apply to exporters of unprocessed minerals, while 'processing and value addition in mining' is a priority activity. The rates and the collection rules are explained in Mineral tax, royalties and fiscal terms.

RDB's investment pages state that trading in minerals, 'including cassiterite, wolframite and niobium - tantalite, must contain at least 30% value added'. No legal instrument imposing that requirement was found: it does not appear in the Mining Law, in Law N° 056/2024 or in RMB's 2019 regulations on processing and trading licences. It should be treated as a policy statement until RMB confirms its legal basis, and any buyer or trader relying on a contrary position should obtain that confirmation in writing.

The Washington process and the Regional Economic Integration Framework

The Democratic Republic of the Congo (DRC) and Rwanda signed a Declaration of Principles on 25 April 2025 and a Peace Agreement on 27 June 2025, both with United States facilitation. Economic integration was negotiated in parallel: the Regional Economic Integration Framework (REIF) was agreed in November 2025 and signed at Washington on 4 December 2025 by the two Foreign Ministers, as part of the Washington Accords for Peace and Prosperity. The text released by the United States Department of State begins from the principle that 'each country has full, sovereign control over the exploitation, processing, and export of its natural resources' and that initiatives must comply with each country's laws.

On minerals the REIF commits the two governments to combat and progressively eliminate illicit extraction and trade; to 'progressively eliminate barriers' obstructing the direct and lawful export of minerals sourced in the region, notably tin, tantalum, tungsten, niobium and gold; to block the financing networks of armed groups; to formalise artisanal and small-scale mining, including through cooperatives and joint traceability; to build regional value chains with processing plants in both countries and value sharing through 'equity participation, royalties and revenue-sharing mechanisms'; to locate tolling centres in both countries, with unpaid tax and duty remitted automatically to the relevant jurisdiction; to endeavour to 'harmonize tax policies - including royalties, levies, and any other form of taxation or fees' and avoid harmful tax competition; to develop end-to-end digital traceability and publish mine, licensing and trade data; to mandate that minerals-related transactions occur through, or are documented by, formal financial institutions; and to explore joint cross-border special economic zones. On energy it prioritises financial close of the Ruzizi III hydropower project and the cooperative exploitation of Lake Kivu methane (Petroleum and Lake Kivu methane). On investment the parties commit to ratifying the Rwanda-DRC bilateral investment treaty.

Three features limit its legal effect. Its implementation measures are stated to be 'instructive and not prescriptive' and adjustable through its coordination mechanisms. It takes effect only 'upon satisfactory execution' of the Concept of Operations annexed to the Peace Agreement and of the related operation order, as determined by the Joint Oversight Committee; whether that determination had been made by 10 October 2026 could not be confirmed. And it changes no Rwandan law: harmonised royalties, tolling arrangements or payment rules would need Rwandan legislation or regulations. Its governance bodies are a Steering Committee due to meet within 30 days of signature, technical working groups due within 45 days, an annual high-level summit, the first within six months, and a Private Sector Input Mechanism through which investors may be consulted.

The United States-Rwanda framework and commercial deals

On the same day Rwanda and the United States signed a Framework Between the United States and Rwanda for Shared Economic Prosperity, reported to cover mining and mineral processing and energy. It is an economic framework, not a minerals treaty: its text had not been published in the sources reviewed, and in June 2026 the chairman of Trinity Metals was still publicly proposing a separate minerals strategic partnership agreement, which suggests none exists. Legally enforceable protection for United States investors continues to come from the United States-Rwanda bilateral investment treaty, in force since 1 January 2012, explained in Investment guarantees, treaties and reporting.

Commercial activity has followed. In May 2025 Trinity Metals signed a letter of intent with the United States tin trader Nathan Trotter; the press reported in June 2026 that more than 320 tonnes of tungsten concentrate had been shipped to Pennsylvania since August 2025; and Almonty described its September 2026 venture with the Government as 'aligned with' the United States framework. These are company and press statements and should be checked in each transaction.

Headwinds: sanctions and European scrutiny

The same period brought measures that a buyer, lender or partner must take into account. On 17 March 2025 the Council of the European Union listed Gasabo Gold Refinery, a Kigali refinery, and the then chief executive of RMB under its Democratic Republic of the Congo sanctions regime. On 2 March 2026 the United States Department of the Treasury designated the Rwanda Defence Force and four of its senior officers under Executive Order 13413, as amended, citing actions it said threatened the peace, security or stability of the DRC and material assistance to the M23 group. On 25 June 2026 the Treasury designated Gasabo Gold Refinery LTD, its chairman, its general manager and three Rwandan mining companies. The scope of these measures, what they require of buyers and how to screen counterparties are set out in Sanctions, due diligence and reforms.

Within Europe, the European Union and Rwanda signed a memorandum of understanding on sustainable raw materials value chains on 19 February 2024; members of the European Parliament asked in February 2025 for it to be suspended, and its status at 10 October 2026 could not be confirmed. Importers into the European Union of tin, tantalum, tungsten and gold remain subject to Regulation (EU) 2017/821, for whose review the European Commission published a prior information notice on 11 May 2026 and a call for tenders on 16 June 2026.