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The Verified Record · Issue 1

Four things that don't match the primary documents

August 2026 · Published fortnightly

Everything below comes from a named document with a date — a gazette, a board approval, a company filing. Where a figure isn't public, we say so rather than estimate it. Each item is checkable by any reader in about five minutes, which is the point.

1 · Ghana's lithium royalty. Two primary documents disagree.

The gazetted instrument — L.I. 2517, in force 10 March 2026 — sets four bands: 5% up to US$1,500/t; 7% to US$2,500; 10% to US$3,000; 12% above. Atlantic Lithium's own RNS of 20 March 2026, announcing parliamentary ratification of the Ewoyaa mining lease, prints the same four rates and attributes them to the same instrument — but with two breakpoints moved: 7% to US$2,300, 10% to US$3,200, 12% above US$3,200. Trade coverage over the following days carried the RNS figures.

So the rates agree and so does the first breakpoint. The tables give different rates in two bands only, and in opposite directions: between US$2,300 and US$2,500 the gazette gives 7% and the RNS 10%; between US$3,000 and US$3,200 the gazette gives 12% and the RNS 10%. This is not a press error. It is a company announcement and a gazette, each describing the same Legislative Instrument, printing different numbers. Which figures govern the Ewoyaa lease is not determined here; Ewoyaa is pre-production and no royalty has been payable under either table.

The larger point sits in the same schedule. It pegs gold to the London PM Fix. For lithium it provides that market value is determined by the parties on an arm's-length basis, having regard to prevailing international market price. No prescribed benchmark.

So the rate is fixed in law and the base it applies to is not observable from outside the transaction. Two countries could adopt identical bands and collect materially different revenue, and neither could audit the other. For anyone working on harmonising African mineral fiscal regimes, that gap is worth catching early.

Minerals and Mining (Royalties) Regulations 2025, L.I. 2517 — made 18 Dec 2025, gazetted 19 Dec 2025, in force 10 Mar 2026; Schedule read directly from the instrument. Atlantic Lithium Limited RNS, 20 Mar 2026 (ratification of the Ewoyaa mining lease), schedule as printed in that announcement. Trade coverage 20–24 Mar 2026 carried the RNS figures. Full side-by-side: Verified Drop 005.

Corrected 8 September 2026. As first published this item attributed the US$3,200 breakpoint to trade reporting and cited Mining.com and Northern Miner as the source, and said there were "four bands, not two". The US$3,200 and US$2,300 breakpoints are printed in Atlantic Lithium's own RNS; the trade press carried them downstream. The RNS also prints four bands, not two. Naming two publications as the source of a schedule the operator itself published was wrong to them and understated the finding: the divergence is between two primary documents, which is a stronger thing and the one this platform holds. Neither document's figures changed; our description of them did.

2 · Ownership records go stale faster than datasets update.

Ghana's first ratified lithium mine has moved twice in twelve months. Piedmont Lithium merged with Sayona to form Elevra in August 2025 — completed. In May 2026 China's Huayou Cobalt agreed to acquire the developer for about US$210m, and separately to buy the offtake interest for around US$71m — announced, not closed. Shareholder vote November, completion targeted December, subject to FIRB, PRC regulators, ECOWAS and a Ghana Revenue Authority ruling.

Both states matter. But a file still naming Piedmont is describing an owner that no longer exists, and one naming Elevra without the pending acquisition is a year behind on the counterparty.

Piedmont/Sayona merger completed 29 Aug 2025. Huayou Cobalt SSE announcement 2026-044, 7 May 2026. Elevra ASX/SEC 6-K, 11 May 2026. Timetable and conditions per Atlantic Lithium Scheme Implementation Deed and quarterly to 30 Jun 2026.

3 · Lobito: three different figures for the same lender.

The African Development Bank's board approved a US$255m loan plus a US$10m grant for Zambia's participation on 7 August 2026, described as a first tranche. Also in circulation as the AfDB figure: US$200m, and about US$500m.

Separately, the US$1.6bn widely attributed to the Bank is a programme figure it is helping mobilise, not a commitment — the Bank's own release says so. And on the greenfield Zambia–Lobito line, financial close is reported as Q1 2027 in some places and Q4 2027 in others, from the same reporting period.

None of this is the Bank's doing. It is what happens between a primary document and the market's version of it.

AfDB board approval release, 7 Aug 2026. AfDB 2023 release confirming US$1.6bn as a programme figure to be raised. Variants: April 2026 reporting (US$200m); May 2026 reporting (~US$500m). Close-date divergence: Q1 2027 vs Q4 2027, both April 2026.

4 · Kabanga's investment decision moved.

Now expected Q1 2027, against "late 2026" in the March filing. The operator attributes the change to slower-than-expected Framework Agreement amendment negotiations with the Tanzanian government, and states the date could move either way depending on lenders' assessment of the amended agreement.

Lifezone Metals H1 2026 interim results, 29 Jul 2026. Prior positions: Form 20-F, 19 Mar 2026 ("late 2026"); release 11 Dec 2025 ("2026").

None of these are market calls. They are the paperwork underneath the model, and it goes unchecked more often than it should.

A rating, a credit paper or a corridor case gets built on figures like these. The verified record on any asset mentioned here — every figure traced to a named document, method shown where derived, gaps marked rather than filled — is available on request.

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