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SA Policy Space

Derelict and Ownerless Mines Rehabilitation Fund

OtherUnder reviewMedium TermRaised 3× in committeeMineral Resources and Energy

Theme: Mining rehabilitation / environment

First raisedFeb 2023Last discussedSept 2023No committee discussion in 12+ months3 meetings on the record ↓
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Reform at a glance

What changes
Derelict and Ownerless Mines Rehabilitation Fund
Responsible actor (recorded)
DMRE / DFFE / National Treasury
Recorded status
Under review — editorial assessment.
Milestone described by this status
Status scope has not yet been independently documented; it may cover only part of this reform.
Next documented milestone
Next milestone not yet documented
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Description

South Africa has approximately 6,000 derelict and ownerless mines (DOMs) from the gold and coal eras, posing acid mine drainage, sinkhole, and water pollution risks. The DMRE's DOM Unit faces a rehabilitation backlog requiring an estimated R50 billion. A dedicated fund—capitalised through mining royalty levies, the Mines and Minerals Development Bill, and potential green bond issuance—would address this fiscal liability systematically. Rand Water's AMD pumping operation costs R2 billion annually, a preventable outlay if upstream rehabilitation proceeds. Parliamentary BRRRs flagged the Western Basin AMD threat to Johannesburg's water security repeatedly from 2021 to 2024. International models (US Superfund, Canada's Abandoned Mines programme) inform the fund design.

Assessment

Growth Impact2/5
Feasibility3/5

Responsible: DMRE / DFFE / National Treasury

Feasibility Assessment

Medium. Funding mechanism is contentious—industry opposes retrospective levies. MMDB passage is a prerequisite. Environmental urgency provides political momentum.

Stakeholder Landscape

Who backs this reform, who needs convincing, and which interests or red lines shape political feasibility.

Backers

7

1 stakeholder

Negotiation weight

9

1 conditional actor

Opposition weight

0

0 opposing actors

Coalition Read

AI-drafted stances · 0 reviewed

2 of 38 actors mapped — not scored

A coalition score needs at least 3 mapped stances, or actors carrying 25% of the map's influence. The stances below are the evidence; the average over this few of them would not be.

Anchor: National Union of Mineworkers (NUM). Highest-leverage swing actor: National Treasury.

Political Tractability

—Needs reviewed signals

No reviewed signals · 0% of mapped influence has been reviewed.

Backers1 stakeholder
National Union of Mineworkers (NUM)Operational backerInfluence 7/10

NUM supports the derelict mines rehabilitation fund as it creates jobs in mine closure and addresses community health risks.

Interest: Mining employment security and worker safety; just transition pace that protects coal-dependent community livelihoods; collective bargaining rights in…

Concern: Accelerated coal phase-out without adequate income support, skills retraining, and community economic diversification; renewable energy job quality —…

Engagement path: Just transition fund with dedicated skills retraining and income support; coal community economic diversification plans with government commitments an…

Negotiation Priorities1 stakeholder
National TreasuryCritical swing actorInfluence 9/10

Treasury supports mine rehabilitation but insists the fund be structured so mining companies bear costs rather than the fiscus.

Interest: Fiscal consolidation with public debt stabilising below 75% of GDP; structural reforms that improve revenue without expanding contingent liabilities;…

Concern: Unfunded mandates in energy transition (JETP co-financing); Eskom's R400bn+ debt and how restructuring socialises costs; reform proposals that create…

Engagement path: Reforms must be fiscally neutral or revenue-positive over the MTEF window; SOE restructuring must demonstrably reduce contingent liabilities; credible…

OECD

Referenced in OECD Economic Surveys: South Africa

OECD SA Survey (2022, 2025). Environmental rehabilitation and resource governance recommended.

Implementation Roadmap

South Africa has approximately 6,000 derelict and ownerless mines generating acid mine drainage (AMD), sinkhole risk, and water pollution — a legacy of 130 years of gold, coal, and base metals mining. The DMRE DOM Unit manages rehabilitation with ~R700 million/year against an estimated R50 billion backlog; Rand Water spends R2 billion/year pumping Western Basin AMD to protect Johannesburg's water supply, a preventable recurring cost. A dedicated Rehabilitation Fund, capitalised through a mining royalties top-up levy, green bond issuance, and international climate finance under the Just Energy Transition framework, would systematically address this liability over 20 years. The Mines and Minerals Development Bill must include strengthened financial provision requirements to prevent the backlog from growing.

1

Gazette the Derelict and Ownerless Mines Rehabilitation Framework: funding model (annual levy on Minerals Council members of 0.5–1% of royalty payments), governance structure (independent fund board), procurement process for rehabilitation contractors, and 20-year rehabilitation schedule by priority site

Q2 2025DMRE / National Treasury
2

Establish the DOM Rehabilitation Fund as a Schedule 3B public entity under the PFMA: independent board with environmental engineering, finance, and community representation; dedicated accounting officer and audit committee

Q3 2025–Q1 2026DMRE / National Treasury
3

Issue the first tranches of DOM Rehabilitation Green Bonds: R5 billion in 5-year bonds under the National Treasury Green Bond Framework (2024), listed on the JSE and accessible to pension funds under Regulation 28 green infrastructure allocation

Q2–Q4 2026National Treasury / DOM Fund Board / JSE
4

Prioritise Western Basin and Eastern Basin AMD rehabilitation: contract AMD pumping and treatment infrastructure upgrades; coordinate with Rand Water, TCTA, and Department of Water and Sanitation on long-term water quality monitoring

Q3 2025 (ongoing)DMRE / TCTA / Department of Water and Sanitation
5

Strengthen financial provision enforcement for active mines: implement MMDB financial provision regulations requiring independent certification of rehabilitation funds, increasing currently underfunded provisions for the 1,500 active mines with rehabilitation liabilities

Q1–Q4 2026DMRE Mineral Regulation Division
6

Apply to JET-IP international partners (UK, EU, USA, France, Germany) for a DOM rehabilitation co-financing tranche as part of the Just Transition coal region component

Q2 2025–Q2 2026National Treasury / Presidency / DMRE
Timeline

Fund established Q1 2026; green bonds Q4 2026; AMD rehabilitation priority sites 2025 (ongoing); active mine financial provision reforms Q4 2026; 20-year rehabilitation programme 2026–2046

Estimated Cost

DOM Rehabilitation Fund capitalisation target: R20 billion over 10 years (levy contributions R1B/year + green bonds R5B + JET-IP climate finance R5B). Current annual rehabilitation budget: R700 million/year. TCTA AMD pumping costs of R2 billion/year become avoidable at scale. Total rehabilitation cost for full backlog: R50 billion over 20 years.

Required Legislation

Amendment to the MPRDA or new Mines and Minerals Development Bill: creates statutory basis for the DOM Rehabilitation Fund and mandatory levy mechanism. PFMA amendment or ministerial determination to list the Fund as a Schedule 3B public entity. National Treasury Green Bond Framework (2024) already provides the issuance framework.

Political Feasibility

Mining sector (Minerals Council SA) supports a well-governed fund as it provides certainty and limits retroactive liability claims. Environmental groups (groundWork, Centre for Environmental Rights) strongly support. Communities near DOMs are active advocates. National Treasury is cautious about a new public entity but supportive of the green bond model. ANC, DA, and EFF all have political reasons to support.

International Precedents

The US Superfund programme (CERCLA, 1980) is the global model for legacy mine rehabilitation funded by industry levies. Canada's National Orphaned and Abandoned Mines Initiative (NOAMI) provides a more applicable governance model for SA. Australia's Queensland Mine Rehabilitation Fund uses a financial assurance bond scheme that informs the active mine provision strengthening element. Chile's Cierre de Faenas fund provides a directly applicable Latin American precedent.

Evidence & Research

No linked research evidence yet. Coverage is incomplete.

Policy documents

No linked official-document evidence yet. Coverage is incomplete.

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Status History

tracked since Mar 2026
  1. Recorded as Under review when status tracking began — held since at least Mar 2026.
    Mar 2026

Data as of 2026-10-10 · latest PMG meeting 2026-10-02