Uganda’s latest extractive-sector transparency report contains major contradictions in official mineral trade data, including a discrepancy of almost 11.7 trillion Shillings in reported mineral exports and conflicting records of the country’s gold imports and exports.
The findings raise questions about how Uganda accounts for gold from the point it is mined to when it is refined and exported, and whether government agencies have sufficient information to determine the source and value of the minerals passing through the country.
The fifth Uganda Extractive Industries Transparency Initiative (UGEITI) report, covering the financial year 2023/24, records total mineral exports at about 11.8 trillion Shillings in one section. But another table in the same report, based on data attributed to the Uganda Revenue Authority, puts total mineral exports at only 119.2 billion Shillings. The difference is almost 11.7 trillion Shillings.
The detailed mineral export table records 9.73 billion kilogrammes of minerals valued at 119.2 billion Shillings. Non-agglomerated iron ore accounts for 68.7 percent of the value, followed by vermiculite, perlite, and chlorites at 20.6 percent.
Yet a separate analysis of gold trade based on URA data records gold exports at 11.816 trillion Shillings and imports at 11.477 trillion Shillings.
Semi-manufactured gold alone is recorded at 11.363 trillion Shillings, equivalent to 1.631 billion US dollars. The gold export figure is therefore about 99 times the total mineral export value reported in the other table.
The report does not reconcile the conflicting figures. It instead describes Uganda as a regional gold refining and trading hub, noting that gold accounted for less than one percent of reported domestic mineral production while remaining the country’s most significant extractive export commodity.
The conflicting figures also affect how the report assesses the contribution of mining to Uganda’s economy. The report later uses about 119 million Shillings as the mining-sector export figure when calculating the sector’s contribution to Uganda’s total exports, resulting in an estimate of only 0.0004 percent. But the same report records gold exports of 11.816 trillion Shillings.
The two figures would produce radically different assessments of the importance of mining and gold to Uganda’s export economy.
The discrepancy becomes more significant when the export figures are compared with Uganda’s reported domestic gold production.
Data from the Directorate of Geological Survey and Mines show that gold production was valued at only 785.4 million Shillings in 2023/24, up from 702.1 million Shillings the previous year.
Gold therefore accounted for only 0.17 percent of the 464.7 billion Shillings worth of mineral production reported during the year.
The low domestic production figure does not necessarily mean that all gold exported through Uganda was mined locally. Uganda has increasingly become a regional refining and trading centre, meaning gold produced elsewhere can enter the country, be refined and subsequently exported.
But the scale of the difference creates a question: where does the gold exported through Uganda actually come from?
Lawrence Muwonge, the Uganda Revenue Authority manager responsible for extractives, says the problem begins at the mining sites, particularly among artisanal miners who operate outside formal production and record-keeping systems.
He says URA cannot reliably establish how much gold an artisanal miner produces, how much is sold or who buys it.
“Even just to know what he has sold in a day or what he has produced in a day, it is next to impossible,” Muwonge said.
Muwonge said continuously monitoring every mining operation would require URA officials to be present day and night, which he described as practically impossible.
The problem continues further up the supply chain. According to Muwonge, gold refiners provide a more visible point of the trade because they operate from identifiable premises and their exports can be tracked. But determining where refiners obtain their gold remains difficult.
“We can track their figures in exports. The Bank of Uganda can report them. But when it comes to a refiner telling you from whom they buy gold, it is next to impossible,” Muwonge said.
He cited transactions that, in his view, do not make commercial sense. “The refiner is one person who will tell you, I have bought gold for $10. I have sold gold for $10, which mathematically cannot work out,” he said.
Muwonge questioned how a refinery could buy and sell gold at the same value while still meeting the costs of workers, electricity, rent, and other operations.
“Giving you evidence on what they bought from who and to who they sold is definitely very, very difficult,” he said.
The UGEITI report itself provides further evidence of the difficulty in reconciling gold flows. Five major gold businesses reported imports of 11.477 trillion Shillings and exports of 11.816 trillion Shillings during the financial year.
Thaba Investments Limited recorded exports of 2.763 trillion Shillings, Bullion Refinery Limited 2.899 trillion Shillings, Simba Gold Refinery Limited 1.746 trillion Shillings, Metal Testing and Smelting Company Limited 1.568 trillion shillings, and Faru Trading Uganda Limited 1.178 trillion Shillings.
Overall, gold exports exceeded imports by about 339.4 billion Shillings. The report says differences between imports and exports can arise from timing, valuation, refining processes, stock movements, or reporting classifications.
But it does not establish which of these factors accounts for the differences in Uganda’s case. The quantities reported by individual companies also differ between imports and exports.
Thaba Investments, for example, reported imports of 12,377,803 kilogrammes and exports of 12,657,815 kilogrammes. Simba Gold Refinery reported imports of 7,619,029 kilogrammes against exports of 7,798,408 kilogrammes.
Metal Testing and Smelting reported imports of 6,454,565 kilogrammes and exports of 6,881,358 kilogrammes.
All five companies listed in the EITI table reported exports exceeding imports. The differences should not, on their own, be interpreted as proof of missing or illegally sourced gold because the report does not provide enough information to establish the underlying transactions, stock movements, timing, or reporting adjustments.
However, they reinforce the difficulty of tracing gold from its source through the formal trading system. The inconsistencies also extend to government agencies. URA records show about 46,263 kilogrammes of gold exports during the financial year, valued at approximately 2.98 billion US dollars. Bank of Uganda records put gold exports at about 48,620 kilogrammes, valued at approximately 3.09 billion US dollars.
That leaves a difference of about 2,357 kilogrammes between the two government records. The question is therefore not simply how much gold Uganda exports, but how consistently the country measures gold from production through trading, refining and export.
Muwonge says the informal nature of much of Uganda’s gold mining makes taxation particularly difficult. “Artisanal mining, as I said earlier, has improved the livelihoods of so many communities, but when it comes to taxation, we have got so many problems,” he said.
He also raised concerns about establishing who actually controls some mining operations. Muwonge said URA had encountered mines that appeared to be Ugandan-owned but where foreign nationals were operating behind the scenes.
He cited one mine in western Uganda where URA found more than 50 excavators and numerous Chinese expatriates, despite the operation appearing on the surface to be a Ugandan company.
In another operation in northern Uganda, he said officials found more than 60 Chinese nationals staying at a mining camp, although the company had told URA that only three expatriates were employed.
The issue of ownership matters because it affects the government’s ability to establish who is responsible for production, taxation and compliance.
Officials from the Uganda Registration Services Bureau told the same extractive-sector meeting that beneficial ownership information is mandatory when companies are registered.
The information is intended to identify the natural persons who ultimately control a company or hold ultimate voting rights.
But Muwonge said registration requirements do not necessarily resolve the problem at mining sites. He described cases in which people left mining operations after URA assessments and officials could not establish whether they had left Uganda or moved to neighbouring countries.
He also said the agencies involved in managing the mineral value chain do not always share information effectively. Uganda’s mineral sector involves several institutions, including the Directorate of Geological Survey and Mines, URA, Bank of Uganda and the Uganda Registration Services Bureau.
“In the past, the actors in managing or administering revenue collection in the mining sector, that is the ministry and the URA, you find each of them wants to shine at their own,” Muwonge said.
“The URA wants to shine. The DGSM wants to shine.” He argues that production, licensing and taxation cannot be treated as separate activities.
The Petroleum Authority of Uganda has similarly called for stronger collaboration between regulators, URA and URSB, including the use of common identifiers to establish beneficial ownership and improve compliance.
The gold-data problems are part of a wider challenge in reconciling information about Uganda’s extractive-sector revenues.
The UGEITI reconciliation exercise found that government agencies initially reported 911.115 billion Shillings in payments from extractive companies.
After an independent reconciliation process, 256.099 billion Shillings was removed because the payments related wholly or partly to activities outside the extractive sector. Tororo Cement accounted for the largest adjustment, at 225.061 billion Shillings, followed by Mota-Engil at 28.603 billion Shillings and MHK General Agencies at 2.435 billion Shillings.
The adjustment affected several tax streams, including customs payments, VAT, income tax, PAYE, and withholding tax. After the adjustment, reconciled company payments stood at 655.015 billion Shillings.
The final extractive-sector revenue figure reported by the EITI process was 663.283 billion Shillings, which includes additional unilateral disclosures, social and environmental expenditure and sub-national payments. The figure represents an increase of about 25 percent from the 530.174 billion Shillings reported in extractive-sector government revenues in 2022/23.
Mining contributed 336.191 billion Shillings, while oil and gas contributed 327.092 billion Shillings. The reconciliation shows why matching company declarations against government records is important in determining how much money actually comes from extractive activities.
The report also presents different figures for mineral royalties. URA reported collecting 19.686 billion Shillings in mineral royalties during 2023/24. Of this, 1.968 billion Shillings was transferred to local governments and 984.3 million Shillings to lawful or bona fide occupants of land where mining takes place.
However, the main revenue reconciliation table reports no royalties under the reconciled payment streams. A separate unilateral government disclosure lists only 143.1 million Shillings in royalties, while annual mineral rents are separately reported at 22.720 billion Shillings. The report does not clearly explain how the different royalty figures relate to one another. This creates another information gap around the public return from Uganda’s mineral resources.
The transparency report also raises questions about the management of petroleum revenues as Uganda prepares for full-scale oil production. Uganda’s Petroleum Revenue Investment Reserve was established to invest petroleum revenues for the benefit of current and future generations.
However, the UGEITI review of available Petroleum Fund financial statements found that significant investments required under the Public Finance Management framework had not been undertaken. The report records an investment of 108.8 million US dollars made in 2017, which generated about one million US dollars in interest.
But subsequent publicly available Petroleum Fund reports, including the 2023/24 report, do not show significant new investment activity. UGEITI says the absence of a fully approved and implemented comprehensive investment policy has hindered further investment. The issue has also been raised by the Auditor General.
The report records a similarly sharp change in spending by extractive companies on social and environmental activities. Such expenditure fell from 48.45 billion Shillings in 2022/23 to only 562 million Shillings in 2023/24, a decline of about 99 percent.
The report does not provide a detailed explanation for the dramatic reduction. It is therefore unclear whether the fall reflects an actual reduction in company spending, changes in the projects captured by the reporting exercise, or weaknesses in reporting.
Companies also reported 592.5 million Shillings in payments to sub-national authorities during the year.
Taken together, the findings reveal a common problem across Uganda’s extractive sector: several institutions collect information on production, ownership, taxation, imports, exports and company payments, but the information does not always produce one consistent picture.
The country recorded gold exports worth 11.816 trillion Shillings while domestic gold production was reported at only 785.4 million Shillings.
URA and the Bank of Uganda also reported different quantities and values of gold exports. At the same time, different tables within the UGEITI report give radically different values for Uganda’s total mineral exports.
The discrepancies do not by themselves establish that gold has been illegally sourced or that revenue has been lost. But they expose limitations in Uganda’s ability to trace the mineral from its source through the trading and refining chain and to reconcile the information held by different institutions.
That has implications for taxation, regulation and public accountability. For Uganda, which is moving towards full-scale oil production, the broader lesson from the UGEITI report is the importance of having reliable and reconciled information on the country’s natural resources.
The EITI process is intended to make financial flows around extractive resources easier for the public to understand and scrutinise. Yet the 2023/24 report leaves unresolved questions about the value of Uganda’s mineral exports, the origin of gold passing through the country, the reconciliation of mineral royalties, the accuracy of inter-agency trade records and the investment of petroleum revenues.
The question is whether the country can reliably account for its natural resources from the point of extraction to the point of export, and establish the public revenue that should accrue from that trade-URN. Give us feedback on this story through our email: kamwokyatimes@gmail.com
