Togo Government: Draft Decree for National Commission Against Illegal Mining

• Togo's government is still considering a draft decree to establish a national commission against illegal mining, with its first reading on November 6, 2026.
• The commission aims to coordinate efforts against clandestine gold mining and other unlicensed operations, citing environmental, economic, public health, and security risks.
• Artisanal gold mining is prevalent in the Plateaux, Kara, and Centrale regions, with some production evading official reporting due to cross-border smuggling.
• This unofficial activity complicates authorities' efforts to track output and collect revenue.
• Togo's mining sector generated CFAF 119.4 billion in reported revenue in 2023, with Société Nouvelle des Phosphates du Togo (SNPT) contributing nearly 89.5%.

The establishment of the national commission is therefore a critical step towards enhancing oversight, improving revenue collection from all mining activities, and mitigating the risks associated with unregulated operations, ultimately aiming to ensure that the full economic benefits of Togo's mineral wealth are realized by the state.

The Togolese government is still in the process of establishing a dedicated national commission to combat illegal mining, with a draft decree having its first reading on November 6, 2026. This body is intended to spearhead the fight against illegal mining activities across the nation. The primary objective of this proposed commission is to centralize and coordinate governmental responses to the pervasive issue of clandestine gold mining and other forms of unlicensed operations within the country's mineral-rich regions.

Officials have underscored the multifaceted dangers posed by these unregulated activities, citing substantial environmental degradation, adverse economic impacts, severe public health concerns, and heightened security risks. While the government has clearly articulated the necessity for such a commission, specific details regarding its composition, including membership, and the financial or logistical resources it will be allocated, have not yet been made public. These crucial arrangements are anticipated to be fully delineated within the final version of the decree.

Togo's mining industry is characterized by a diverse range of operations, encompassing large-scale industrial ventures, quarrying activities, and a significant presence of artisanal mining. A particular focus of concern for authorities is artisanal gold mining, which is predominantly concentrated in the Plateaux, Kara, and Centrale regions of the country. These smaller-scale operations, while providing livelihoods, often operate outside formal regulatory frameworks.

A persistent challenge for the government involves the considerable portion of mining production that bypasses official reporting channels. This unofficial output is partly attributed to the prevalence of cross-border smuggling, which allows minerals to exit the country without proper documentation or oversight. Consequently, this makes it exceedingly difficult for governmental bodies to accurately track the total output from the mining sector and, crucially, to collect the appropriate revenues due to the state. The proposed commission seeks to address these systemic issues by bringing greater order and accountability to the sector.

The economic contribution of Togo's mining sector is substantial, as evidenced by recent financial disclosures. According to figures compiled by the Extractive Industries Transparency Initiative (EITI) and reported by Togo First, the nation's mining activities generated a reported revenue of CFAF 119.4 billion during 2023. This figure highlights the sector's importance to the national economy, even with the acknowledged challenges in tracking all production.

A significant portion of this reported revenue was attributed to a single entity: Société Nouvelle des Phosphates du Togo (SNPT), which accounted for nearly 89.5% of the total. This concentration underscores the reliance on a few major players for official revenue generation, while the informal sector, particularly clandestine gold mining, continues to operate with less transparency. The establishment of the national commission is therefore a critical step towards enhancing oversight, improving revenue collection from all mining activities, and mitigating the risks associated with unregulated operations, ultimately aiming to ensure that the full economic benefits of Togo's mineral wealth are realized by the state.

Lawyers advising mining companies in Togo should closely monitor the final decree establishing this national commission, as it will likely introduce new compliance requirements, increased enforcement scrutiny, and potential liabilities for operations deemed illegal or unlicensed, particularly concerning artisanal mining and revenue reporting.

Source: Original reporting via Togo First and Ayi Renaud Dossavi.