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The Ugandan government’s bid to entrench transparency in its extractive industries is facing its toughest test yet, as mining companies continue to resist participation in the Extractive Industries Transparency Initiative. The tension was unmistakable on 20 November when Gloria Mugambe, Head of the Uganda EITI Secretariat, delivered an unusually forthright assessment at the launch of the country’s Fourth EITI Report. Her remarks reflected growing frustration within an initiative that depends on voluntary disclosure in a sector where secrecy remains profitable.
Mugambe said, “Every time we approach companies, once the MSG has decided the companies that will be included in the scope of the report, and we start approaching these companies, many times we will get the same questions. What is this? Where is it from? Why do we have to do it? Is there a law? Am I compelled to do this?Also note the chronic delays, incomplete submissions and a persistent refusal to provide beneficial ownership data. Sometimes; by the time we get the data, we do not have the opportunity to cross check. So, we need that participation from the companies.”
Her candour underscored an uncomfortable reality of the mining sector’s reluctance to disclose is now undermining Uganda’s transparency commitments. A directive from the Minister of Energy urging companies to cooperate did little to shift behaviour. “By the time the Minister informs you that you must do something and you still don’t do it, I don’t know what other avenues are open to us for complying or ensuring compliance with this requirement,” noted Mugambe.
Uganda joined EITI in 2020 to align with global standards and support ambitions under Vision 2040. At the launch, Minister of State for Planning Amos Lugoloobi reiterated that “resource wealth does not become a curse but a driver of broad-based prosperity” and that transparency plays a central role in attracting credible investment. Yet the EITI process shows the governance reforms meant to accompany mineral expansion are lagging behind the sector’s rapid growth.
For the 2022/23 cycle, all mining companies paying more than Shs 750 million in taxes were included in the reporting scope. Only half submitted declarations. Two licence holders had left the country entirely, offering no data. Others ignored repeated requests or submitted incomplete, unsigned or unaudited information. The discrepancies were stark when compared with oil and gas companies, which provided fully audited figures, highlighting the regulatory gulf between the two sub-sectors.
Much of the opacity stems from companies whose operations extend beyond extraction, making it difficult to separate mineral revenues from broader business activities. But Uganda’s most persistent challenge remains the shadowy gold economy. Official production figures capture only a fraction of what is actually mined, while large volumes move through informal or illegal channels. Senior Inspector of Mines David Ssebagala provided the bluntest assessment: “Seventy to eighty percent of Uganda’s gold is illegal. A huge part of it bypasses DGSM completely”.
Unlicensed and artisanal operations dominate this shadow market, and the gold they produce cannot be formally reported. Civil society activists argue that companies benefiting from these opaque networks deliberately stay out of the EITI process. “Their absence from the reporting process is not accidental, it is strategic,” one participant said. The state’s own inconsistencies compound the problem. Key government agencies regularly produce conflicting figures for production, exports, and payments. Mugambe urged greater coherence, saying, “If DGSM says a figure, URA must reflect the same. At the moment, that is not happening.” These misalignments give companies room to challenge official data and weaken Uganda’s position ahead of its next EITI validation.
Beneficial ownership disclosure remains one of the weakest areas. Companies use complex foreign shareholding structures, shell firms or simply fail to comply. Because beneficial ownership reveals the individuals behind companies, including politically exposed persons, resistance remains strong. Mugambe described an exhausting cycle in which Secretariat staff must retrain new company representatives each year while also managing inconsistent government submissions and tight report deadlines.
Civil society voices argue that the voluntary nature of EITI is no longer adequate. “Voluntary reporting will never work for a sector where secrecy benefits the actors,” said Henry Bazira of the Water Governance Institute. Development Economist Fred Muhumuza echoed that regulators, not companies, should define the terms of disclosure. “It is not the companies’ discretion,” said Muhumuza. Artisanal miners face different barriers, with compliance often tied to cost. Kenneth Asiimwe of the Uganda Association of Artisanal Miners said companies will embrace transparency only if it brings tangible benefits such as access to financial support or government programmes. Meanwhile, communities remain disconnected from the royalties collected on their behalf. “People producing these extractives need to see something returned to them,” said Mugambe.
Uganda’s previous EITI validation score of 78.5 percent revealed significant weaknesses in beneficial ownership, data quality and artisanal mining oversight. With another validation due in June, hopes for improvement depend on cooperation from a mining sector that has shown little inclination to change. MSG Chair Moses Kaggwa believes Uganda can reach 90 or even 100 percent if contract transparency and ownership disclosure improve, but acknowledges that resistance from companies remains the biggest obstacle. Behind the technical debates lies a deeper political economy: a mineral sector expanding faster than its governance structures. Weak regulation, informal trade networks and links to politically connected actors create an environment where opacity is not an accident but an incentive. Without enforceable requirements, the risks range from revenue loss to money laundering and environmental harm.
The EITI was meant to provide a stabilising framework, but its success depends on cooperation. Mugambe’s final words captured the stakes, “Transparency is not optional. If Uganda is to benefit from its minerals, we must all be accountable; government, companies, and communities alike. The EITI process cannot work if mining companies continue to ignore it. Our validation depends on this. Our credibility depends on this.” The contrast with the oil and gas sector, where reporting obligations are clear and consistently enforced, highlights the broader truth. Uganda’s mining companies are not failing to report because they cannot; they are failing to report because the system allows it. Until that changes, Uganda’s transparency experiment will remain fragile.
