ASM accounts for over 90% of Uganda’s gold production, supporting the livelihoods of 600,000 people directly and more than two million indirectly. In 2024 alone, the country earned more than 2.5 billion euros from gold exports, approximately 37% of total national export revenue.
Approximately 85% of artisanal gold miners continue to operate without licenses. This is largely due to a long-standing gap in the legal framework prior to the enactment of the Mining and Minerals Act (2022) and the Mining and Minerals (Licensing) Regulation (2023). This act formally recognized artisanal mining as a legal and licensable activity for the first time.
Despite the legal progress, formalization remains limited due to structural and financial barriers. In particular, high compliance costs, including unofficial fees and requirements imposed by sister agencies of the Ministry of Energy and Mineral Development, make the process expensive for ASMs. These compliance costs can reportedly amount to approximately EUR 2,810.89 (UGX 11,445,000).
The costs include statutory charges, namely, new or renewal application fees (UGX 10,000,000, ~ EUR 2,300), registration fees (UGX 1,000,000, ~ EUR 230), annual mineral rent per hectare (UGX 100,000, ~ EUR 23) or part thereof. Finally, they include gazetting fees for the grant of a Small-Scale Mining License, payable for a five-year period and renewable every three years (UGX 345,000, ~ EUR 81).
These barriers are also compounded by complex bureaucratic procedures and limited institutional support, collectively discouraging artisanal miners from transitioning into the formal licensing system. Previously, ASMs were not required to conduct an Environmental Impact Assessment (EIA). Today, however, they must do so at an estimated cost of about €30,000—a prohibitive sum for most artisanal mining associations.
In addition, NEMA, which is mandated by law to approve EIAs, adds further costs to the process. There is also a requirement from the tax authority, URA, for license applicants to obtain a tax clearance certificate before they can even apply for a license.
HIDDEN COSTS OF INFORMAL OPERATIONS
Artisanal and small-scale miners, as well as mining communities, continue to operate in a cycle of informality with social, environmental and economic consequences. Their operations are characterized by unsafe working conditions, limited legal protection, exploitative trading relationships and minimal access to finance or technology. The informality also perpetuates systemic risks, among them:
- Mercury pollution and toxic waste exposure, particularly affecting women and children heavily involved in gold processing and surrounding communities like Tiira Subcounty in Busia district. Here, several households have sluicing ponds in their backyards.
- Deforestation and land degradation, undermining safety, food security and community resilience
- Child labor and poor occupational safety, with minimal regulation oversight
- Limited access to capital, modern technology and technical training, stifling productivity, safe mining, innovation and overall profitability
- Trade imbalances, with miners earning as little as €0.92–4.60 per day, while intermediaries capture significantly higher profits
- Weak representation in policy and regulatory processes, limiting miners’ ability to influence reforms that directly affect their livelihoods and working conditions
- Systemic exclusion of women, resulting in lower representation in leadership roles and access to fair wages, coupled with heightened health risks related to mercury exposure
FORMALIZATION IN ACTION: MUMA SECURES UGANDA’S FIRST SMALL-SCALE MINING LICENSE
In 2025, the Mubende United Miners Assembly (MUMA), one of Solidaridad’s longstanding grassroots partners, secured Uganda’s first-ever small-scale mining license. Issued by the Ministry of Energy and Mineral Development, this license marked a milestone in the formalization of ASM in the country. It represents the culmination of multi-stakeholder policy advocacy efforts undertaken in collaboration with the RECLAIM Sustainability! Gold Project.
Since 2020, Solidaridad, through the RECLAIM Sustainability! Gold project has supported miner associations, influenced national policy and mobilized cross-sector collaboration to close the gap between legal reform and on-the-ground implementation.
“Our contribution focused on advocacy and civic education. We supported a technical working group comprising the ministries of Energy and Mineral Development; Justice and Constitutional Affairs; and Gender, Labour and Social Development, and together with the Uganda Association of Artisanal and Small-Scale Miners (UGAASM) to finalize the Uganda Mining (Licensing) and the Mining (Artisanal and Small-scale Mining) regulations for ministerial approval,” shared Rukundo Nduhuura Joshua, Senior Project Officer, Solidaridad East & Central Africa.
Through this collaborative engagement, UGAASM influenced approximately 60% of the provisions in the Mining and Minerals Act (2022) and the Artisanal and Small-Scale Mining Regulations (2025). UGAASM also secured a USD 15,000 (EUR ~13,000) grant from the Global Initiative (2024) to advance civic education on mining laws, further strengthening miners’ capacity to engage with regulatory processes.
John Bosico Bukya, the Chairperson of MUMA shared that “Our journey to formalization began in 2020, when we first partnered with Solidaridad East & Central Africa under the RECLAIM Sustainability! Gold Project. At the time, most of us operated informally, with limited knowledge of legal frameworks or safety standards. Through continuous advocacy, civic education and capacity-building, we learned how to engage with government institutions, organize ourselves as an association and meet the requirements for licensing.”
He goes on to say that “securing Uganda’s first small-scale mining license wasn’t easy; it required patience, investment and persistence, but it proved that with the right partnerships and community ownership, change is possible.
Finally, he added that “Formalization has given us dignity, security and a seat at the policy table. We can now sell our gold transparently, attract investment and ensure that our miners, especially women and youth, work safely and benefit fairly. This journey has taught us that transformation begins when communities take the lead. We are now more organized, environmentally conscious and committed to showing that artisanal mining can be both sustainable and profitable.”
This milestone is not just a legal license for MUMA but also a replicable roadmap for other ASM communities across the country. The legalization has opened doors to safer mining operations and potentially unlocked bottlenecks to access to finance and capacity building to improve the livelihoods of over 3,000 individuals directly and indirectly dependent on gold mining at the site.
THE WAY FORWARD
The licensing of MUMA is not the finish line; it is the starting point. Solidaridad East & Central Africa is now focused on:
- Scaling this legalization model to other mining communities
- Strengthening capacity for safe and environmentally responsible mining
- Deepening women’s and youth leadership
- Advancing ongoing regulatory reform and enforcement, with the goal of reaching 30,000 miners by 2030.
This milestone demonstrates the power of community-driven change supported by government and development partners. Solidaridad thanks the Embassy of the Kingdom of the Netherlands, MUMA and UGAASM for their unwavering collaboration.
Learn more about Solidaridad East & Central Africa’s ASM work and strategy