Gold Export Policies in Madagascar: Rules, Licenses, Procedures, and Investor Guidance

Gold Export Policies in Madagascar: Madagascar’s gold mining industry plays a significant but largely informal role in the economy, dominated by artisanal and small-scale mining (ASM).

With rich deposits across various regions, the country has potential as a gold producer, yet gold export policies in Madagascar emphasize strict regulation to combat smuggling, ensure traceability, and maximize state revenue.

Legal compliance is essential for exporters, investors, and international buyers to avoid severe penalties, shipment seizures, or legal issues.

This guide details Madagascar gold export regulations, licensing, procedures, taxes, challenges, and practical advice for compliant exporting.

It targets gold investors, mining companies, bullion buyers, and import/export agents seeking trustworthy information on exporting gold from Madagascar.

Overview of Madagascar’s Gold Industry

Madagascar’s gold sector is primarily artisanal. Thousands of small-scale miners operate in regions like the north (around Diego Suarez), central highlands, and areas near Antsirabe or Ilakaka.

Official production figures remain low (e.g., around 13 kg declared in recent periods), while actual output, including unreported artisanal activity, is substantially higher.

The mining sector contributes notably to exports (around 47% in some recent data) and GDP (about 5%), though gold’s formal share is modest compared to minerals like nickel, cobalt, and ilmenite. Artisanal miners use manual or lightly mechanized methods, often in designated corridors or under permits.

Government oversight has intensified through the 2023 Mining Code (Loi n° 2023-007), which establishes a dedicated framework for gold activities, including traceability via the Centrale de l’Or de Madagascar (COM). A 2020 export suspension aimed to curb smuggling was later lifted, with reforms introducing a one-stop shop (Single Window for Gold Exports) for permits.

As of early 2026, Madagascar lifted a long-standing moratorium on new mining permits for most minerals but maintained the suspension for gold due to regulatory challenges and discrepancies between official and actual production. Existing licensed operations and trading can continue under the formalized channels.

Madagascar gold trade balances economic potential with environmental, social, and governance (ESG) concerns, including child labor risks, deforestation, and illicit flows (estimated at several tonnes annually smuggled). Legal exporters benefit from structured channels but must navigate bureaucracy and compliance costs.

Authorities Regulating Gold Exports in Madagascar

Effective compliance requires engaging the right bodies:

• Ministry of Mines and Strategic Resources: Oversees policy, permit granting (via BCMM), and conformity controls for exports.
• Bureau du Cadastre Minier de Madagascar (BCMM): Manages the national mining cadastre and permit applications.
• Centrale de l’Or de Madagascar (COM): Key for gold-specific activities—melting, hallmarking, issuance of passes/identification sheets, and collector cards. It plays a central role in traceability.
• Customs Authorities (Direction Générale des Douanes): Handle customs declarations, clearance, and duties.
• One-Stop Shop / Single Window for Gold Exports: Facilitates coordinated approvals from multiple agencies.
• Other bodies: Tax authorities for fiscal compliance, environmental agencies for impact assessments, and the Central Bank for foreign exchange repatriation.

These authorities enforce the Mining Code, emphasizing formalization of ASM, hallmarking, and anti-smuggling measures.

Gold Export License Requirements (Madagascar Gold Export License)

Who can export gold from Madagascar? Only approved Gold Trading Centres (with valid approval) for commercial purposes. Artisanal miners, collectors, jewelers, and holders of relevant permits (e.g., PREA or PE where applicable) must channel through these licensed entities.

Key requirements include:

• Company Registration: Legal entity registered in Madagascar (or partnership with one). Foreign investors typically need local incorporation or joint ventures.
• Gold Trading Centre Approval: Specific authorization under the Mining Code terms of reference. Involves due diligence, anti-money laundering (AML) compliance, and financial capacity.
• Tax and Fiscal Compliance: Registration with tax authorities, TIN, and proof of good standing.
• Exporter Identification: Customs registration and EORI-like identifiers if applicable.
• Mining/Supply Documentation: Traceable sourcing from licensed miners or collectors, supported by COM passes and identification sheets.
• Environmental and Social Compliance: Relevant authorizations and CSR plans.

Licenses are not indefinite; renewals require ongoing compliance. Foreigners cannot directly hold certain artisanal permits but can invest in trading or larger operations (subject to restrictions).

Madagascar gold dealers must operate transparently to maintain licenses.

Required Export Documents for Exporting Gold from Madagascar

Robust documentation is non-negotiable for customs clearance and international acceptance. Core documents include:

1. Export Permit / Authorization from the Single Window/Gold Trading Centre approval.
2. Certificate of Conformity issued by the Ministry of Mines after inspection.
3. COM Pass and Identification Sheet — essential for gold traceability.
4. Assay Report / Purity Certificate — verifying fineness (e.g., for 24K gold or bullion).
5. Hallmarking Certificate — official COM hallmark on bars, jewellery, or works.
6. Commercial Invoice — detailing value, quantity, parties.
7. Certificate of Origin — proving Malagasy sourcing.
8. Packing List — weights, descriptions.
9. Customs Declaration — filed with customs.
10. Transport Documents — Air Waybill/Bill of Lading, insurance.
11. Proof of Tax/Royalty Payment and foreign exchange domiciliation commitment.

Additional: KYC documents, end-user certificates for some buyers, and refinery certificates if processed.

Table: Export Documents Checklist

Document	Issuing Body	Purpose	Critical For
Gold Trading Centre Approval	Ministry/COM	Legal export right	All commercial exports
COM Pass & ID Sheet	COM	Traceability	Mandatory
Certificate of Conformity	Ministry of Mines	Quality & origin verification	Customs
Assay Report	Approved Lab/COM	Purity (e.g., 99.9% for bullion)	Buyers & compliance
Commercial Invoice	Exporter	Transaction details	All
Certificate of Origin	Relevant Authority	Preferential trade (if any)	International buyers
Customs Declaration	Customs	Clearance	Shipment

Failure to provide complete documentation risks rejection or seizure.

Taxes and Royalties on Gold Exports

Costs impact profitability:

• Special Duties and Taxes on Mineral Products (DTSPM): Around 5% on FOB value (split between state and local communities). Reduced or zero for transformed/local value-added products.
• Excise Duty: 6% on gold exports (as of 2024 updates).
• Royalties/Redevances: Percentage-based on production or sales.
• VAT: Generally 20%, but 0% on exports.
• Other: Administrative fees, COM processing fees, customs handling.

Foreign exchange must be repatriated and sold via the interbank market. Non-compliance leads to export suspension.

Table: Approximate Taxes/Fees (Subject to Updates)

• DTSPM: ~5% FOB
• Excise: 6%
• VAT on Export: 0%
• Royalties: Variable per code
• Total effective burden: Often 8-12%+ depending on structure (consult professionals).

Buyers often cover some costs in contracts.

Gold Export Procedures Step-by-Step: How to Export Gold from Madagascar

1. Secure Sourcing and Mining Authorization: Source from licensed artisanal miners/collectors or permitted operations. Obtain necessary upstream permits.
2. Register/Partner as Gold Trading Centre: Ensure approval and compliance setup.
3. Assay, Refine, and Hallmark: Present gold to COM for weighing, analysis, melting (if needed), and official hallmarking. Receive Pass and ID Sheet.
4. Prepare Documentation: Compile full file including invoice, assay, etc.
5. Apply for Export Permit: Via Single Window; obtain conformity certificate.
6. Pay Taxes and Duties: Secure receipts.
7. Customs Clearance: Submit declaration; physical inspection and sealing in presence of officials.
8. Domicile Proceeds: Commit to bank for repatriation.
9. Shipment: Use secure, insured transport (often air for bullion). Comply with international carrier rules for precious metals.
10. Post-Export: Repatriate funds within timelines (e.g., 90 days) and report.

Timeline: 7-30+ days depending on preparedness. Use experienced agents.

Export Process Timeline Table (Approximate)

• Sourcing & Assay: 1-7 days
• Permit & Conformity: 2-10 days
• Clearance & Loading: 1-5 days
• Shipment: Varies

Challenges Facing Gold Exporters in Madagascar

• Illicit Trade and Smuggling: Black market persists despite reforms; creates unfair competition.
• Regulatory Uncertainty: Recent moratorium on new gold permits; frequent policy tweaks.
• Traceability Gaps: Discrepancies in data; enforcement varies.
• Bureaucracy and Infrastructure: Delays in approvals, limited facilities, logistics challenges (remote mines, port/airport security).
• AML/KYC and International Scrutiny: Buyers demand LBMA/OECD alignment; reputational risks.
• Environmental & Social Issues: Pressure for responsible sourcing.

Mitigate via strong local partners and due diligence.

How International Buyers Can Safely Source Gold from Madagascar

Verifying suppliers is crucial. Work only with licensed Madagascar gold dealers and approved Gold Trading Centres. Demand full documentation chains, third-party assays, and site visits where possible. Avoid cash deals or untraceable sources to prevent scams or tainted gold.

Experienced facilitators like us at Gold Bar Suppliers Africa Ltd operate as compliant African gold sourcing companies and international gold suppliers. We assist with verified suppliers, documentation, logistics, and adherence to Madagascar gold export regulations, helping navigate the Single Window and COM requirements for secure 24K gold or bullion transactions.

Practical Tips:

• Use letters of credit.
• Independent assay at destination.
• Blockchain/traceability tools if available.
• Legal counsel familiar with Malagasy law.

FAQ: Madagascar Gold Export Regulations

Is gold export legal in Madagascar?

Yes, through licensed Gold Trading Centres and the Single Window, subject to strict compliance.

Do you need a license to export gold from Madagascar?

Yes — Gold Trading Centre approval is mandatory for commercial exports.

What documents are required to export gold?

COM Pass/ID Sheet, conformity certificate, assay report, commercial invoice, certificate of origin, customs declaration, and more (see checklist above).

Can foreigners buy or export gold in Madagascar?

Foreigners can buy from licensed dealers and arrange exports via approved channels but typically partner locally for trading approvals.

How much tax is charged on gold exports?

Approximately 5% DTSPM + 6% excise + other fees; VAT 0% on exports. Confirm current rates.

Is Madagascar gold high quality?

Often high-purity alluvial gold suitable for 24K bullion when properly refined and hallmarked.

How do I verify a gold exporter in Madagascar?

Check Ministry/COM licensing, request full documentation chain, references, and use third-party verification.

Conclusion and Investor Guidance

Gold export policies in Madagascar prioritize formalization, traceability, and revenue while addressing artisanal realities. Success demands patience, local expertise, and unwavering compliance.

For mining companies and buyers, partnering with established compliant entities minimizes risks in this high-potential but complex market.

Always consult current official sources (Ministry of Mines, COM, BCMM) and legal/fiscal advisors, as regulations evolve. For professional assistance in sourcing or exporting compliant Madagascar gold, reach out to specialized African gold suppliers with proven track records.