Private Voluntary Organisations Amendment Act, 2025

The Private Voluntary Organisations Amendment Act overhauls the PVO Act and also amends the Money Laundering and Proceeds of Crime Act, the Criminal Matters (Mutual Assistance) Act, the Criminal Law (Codification and Reform) Act and the National Social Security Authority Act. Its stated purpose, set out in a new preamble, is to create an enabling environment for PVOs by improving the regulatory and institutional framework — while the operative provisions substantially tighten control.

The registration net widens. A new section 6 catches any trust, body, association or institution whose objects fall within the definition of a private voluntary organisation and which does not fund itself exclusively from its own investments or activities — so a trust registered under the Deeds Registries Act, or one that took any funds from inside or outside Zimbabwe, must register. "Pre-existing charitable entities" had three months from commencement to lodge an application with the Registrar, with the constitution, the prescribed fee, particulars of when and how they began operating, their objects, service areas and funding sources. Where a beneficial owner or controller exerts a significant or preponderant voice in the organisation's affairs, the secretary or a governing body member must swear an affidavit naming them and describing the extent of that control; the clock on the application only starts when that affidavit arrives. Trusts suspected of operating in breach become "sanctionable trusts" the Registrar may act against.

Institutionally, the Act replaces the PVO Board arrangements and creates an Office of the Registrar of Private Voluntary Organisations in the Ministry responsible for social welfare, headed by a Registrar with Assistant Registrars and inspectors — public offices in the Public Service — with the Director of Social Welfare acting as Registrar until an appointment is made. The Registrar decides applications, cancellations and amendments, hears representations, advises the Minister, promotes coordination between organisations with similar objects, reports annually, and keeps the Register.

A new Part imports the Financial Action Task Force framework: risks of money laundering, terrorist financing and proliferation financing must be identified, appreciated and assessed in relation to PVOs, with defined terms drawn from the FATF standards and the Financial Intelligence Unit given a role. Civil penalties are payable to the Registrar and form part of the Consolidated Revenue Fund or a retention fund, recoverable as a debt in the magistrates court regardless of its usual monetary jurisdiction, with default carrying a fine up to level 6 or a year's imprisonment — and for a corporate defaulter, every officer liable to imprisonment.

Political activity is squarely prohibited. A PVO that supports or opposes a political party or candidate, or acts by political affiliation, commits an offence carrying a fine up to level 12; if the organisation does not pay within 14 days of conviction (or of an appeal being dismissed or abandoned), its national-level office-bearers become jointly liable in equal shares, and an office-bearer who does not pay their share faces 30 days' imprisonment. The one carve-out is assistance to members of disadvantaged groups seeking election to Parliament or a local authority, which must be strictly non-partisan.

The Minister's regulation-making powers are widened to cover registration requirements, increased monitoring of high-risk organisations, self-regulation measures, disclosure of foreign funding in applications and audit reports, and any further measures to combat money laundering, terrorist financing and proliferation financing or to promote accountability in the sector.