Zambia

Two forward-looking, unenacted signals round out the module. The Ministry of Technology and Science has stated intent to run simulated real-world crypto-usage tests to inform future regulation, reported by CoinDesk in April 2023, but no comprehensive licensing legislation has resulted from that exploration as of the most recently verifiable status (CLM-ZM-b2c3d4e5); this is a low-tier, speculative-confidence signal about policy direction rather than an enacted instrument. Separately, the Ministry of Finance and National Planning has periodically referenced intent to develop a crypto or free-zone regulatory framework, but this cycle's research pass could not independently verify any specific proposal content on the Ministry's own site, leaving the claim at proposal-stage, speculative confidence (CLM-ZM-c3d4e5f6).

Taken together, the module's traffic light is set to amber rather than red: BOZ's explicit disclaimer of supervisory responsibility is real, but SEC Zambia's active, currently-enforced registration requirement means market entrants dealing in security-like crypto products face at least one binding compliance touchpoint in Zambia today. That distinction -- a fragmented regime versus a total gap -- is the material change this cycle, and it was only surfaced through Challenger-driven backfill against the original BOZ-only baseline.

Outlook

The near-term posture to watch is less about new legislation than about how actively SEC Zambia continues to exercise its existing securities-law nexus over crypto products. The 2026 civil-penalty actions referenced this cycle suggest an enforcement posture that is live rather than dormant, and any further public notices, warnings, or penalty actions from SEC Zambia would be the clearest forward indicator of how far that nexus reaches into token sales, exchange platforms, or investment-product wrappers marketed to Zambian residents. On the central-bank side, BOZ's own-risk framing has been stable and there is no indication in current sourcing that BOZ intends to establish a dedicated crypto-licensing regime in the near term. The two unenacted policy threads -- the Ministry of Technology and Science's regulatory-sandbox-style testing and the Ministry of Finance's free-zone/framework references -- remain worth tracking but should not be read as imminent legislative outcomes; both rest on thin, dated, or unverifiable sourcing. A useful next step flagged in this cycle's gaps register is a systematic sweep of capital-markets regulators, not just central banks, across comparable under-indexed African jurisdictions, since the SEC Zambia discovery suggests other jurisdictions may carry an analogous, previously-missed securities-law nexus around crypto assets that a central-bank-only research pass would not surface.

The module's traffic light is amber for the same structural reason as crypto_licensing: BOZ's non-engagement on classification is real and confirmed, but it coexists with an active securities-law classification pathway operated by a different regulator, so the module is not a total taxonomy vacuum. The legal-tender question, by contrast, is the most settled fact in this module -- it rests on a specific statutory provision (BOZ Act Section 30) rather than an inference from regulatory silence, and its is_binding status is set to true, distinguishing it from the softer market-access and taxonomy-gap findings elsewhere in the module.

Outlook

The forward-looking question for this module is whether SEC Zambia's case-by-case security test evolves into anything closer to a published, general-application taxonomy, or remains a purely discretionary, product-by-product determination. Nothing in current sourcing points to an imminent shift in either direction. Because the SEC's classification test has apparently operated quietly since 2018 without prompting a comprehensive statutory update, the more probable trajectory is continued reliance on ad hoc security-versus-non-security determinations rather than a codified multi-category framework covering stablecoins, utility tokens, or NFTs specifically. The legal-tender position anchored in the Bank of Zambia Act is the most stable element of this module and is not expected to change absent a fundamental statutory amendment. Analysts should treat the SEC's classification activity as the leading indicator here: any future public notice applying the security test to a named platform or token would be the clearest sign of the classification regime's practical reach, in the same way the 2026 civil-penalty actions did for the licensing module.

The module's amber traffic light reflects a deliberate distinction from a fully static regulatory gap: while no in-force regime exists for any on-chain activity category, the ongoing (if unconfirmed) government policy discussion around a hydropower-linked mining pilot means this is an area of live, if inconclusive, policy attention rather than pure silence.

Outlook

The mining/free-zone pilot is the one thread in this module worth active monitoring, given Zambia's genuine hydropower surplus and the plausible economic logic of attracting mining operations on that basis; however, its status could not be confirmed this cycle beyond a general ministerial reference, and the underlying press source (the Bank of Zambia's own "Press Release on Cryptocurrencies" PDF) returned no fetchable content in this pass, leaving its relationship to the FAQ-page warning language unconfirmed. Absent primary-source verification directly from the Ministry of Finance and National Planning, this claim should be treated as unresolved rather than progressing. Staking, DeFi, DEX, and validator activity show no comparable policy signal at all and should be expected to remain in a pure regulatory vacuum unless and until BOZ or another regulator addresses digital-asset activity categories beyond the securities-law nexus already identified in the licensing and classification modules.

Outlook

Because Zambia's stablecoin gap is a genuine full vacuum rather than a fragmented regime, the more likely trigger for change here is exogenous: either a future BOZ policy statement addressing stablecoins directly, or spillover from SEC Zambia's securities-law classification test if a stablecoin-adjacent product were ever marketed in a form that met the statutory security definition already being applied to other crypto products. No such development has occurred as of this research pass, and there is no indication in current sourcing that stablecoin-specific rulemaking is imminent. This module should be treated as stable and structurally under-addressed rather than actively changing.

The module sits at amber rather than red because a general risk-warning position does exist and is publicly communicated by the regulator, even though it confers no operative protection -- no custody standards, no complaint-handling channel, no marketing restrictions, and no suitability test apply to crypto-asset dealings in Zambia specifically.

Outlook

Absent a shift in BOZ's posture or a consumer-protection-specific intervention from another regulator, this module is likely to remain static: a disclaimed-risk environment with no substantive protective architecture. Any future consumer-harm event involving a Zambian crypto platform would be the most likely catalyst for regulatory attention here, particularly given SEC Zambia's demonstrated willingness to issue warnings and civil penalties in the licensing and classification context; whether that enforcement posture extends to consumer-protection-style remedies (as opposed to purely securities-law registration and penalty actions) is not yet confirmed and should be watched.

Outlook

This module is consistent with a fleet-wide pattern of thin tax-treatment coverage across jurisdictions, and Zambia adds to that structurally under-indexed vector rather than representing an outlier gap. Absent a ZRA-issued ruling or public guidance note, the presumptive-general-law position should be treated as an analytical inference rather than a confirmed compliance baseline. Any future ZRA publication addressing crypto-asset income or capital-gains treatment directly would materially upgrade this module's confidence and is the clearest signal to watch for.

Outlook

This module remains one of the fleet's structurally under-indexed vectors, and Zambia's position here is consistent with that broader pattern rather than a distinct local anomaly. The open question -- whether BOZ's exchange-control directives under the Bank of Zambia Act have been applied in practice to crypto-asset flows -- would require direct confirmation from BOZ's exchange-control publications rather than the FAQ page currently anchoring this finding. Until that confirmation exists, cross-border crypto transfers in Zambia should be treated as falling into a genuine supervisory gap rather than an unconfirmed-but-likely-covered activity.