Two negotiations now under way will shape African public finance for a generation. Both will be won or lost in clauses that read like housekeeping. Movements need to be in those rooms before November.

The Cost of the Current Rules

UNCTAD’s A World of Debt 2025 records that between 2021 and 2023, forty-five countries spent more on interest payments than on health. Africa carries the sharpest version of this. UNCTAD puts the continental figure at 751 million people, roughly 57% of Africa’s population, living in countries that pay creditors more than they spend on the sectors that keep people alive.

Zimbabwe sits inside that statistic. Treasury’s own public debt report puts total public and publicly guaranteed debt at US$23.4 billion as at 30 September 2025. External debt accounts for US$13.6 billion of that. External arrears alone stand at US$7.7 billion, roughly 57% of the external stock. Paris Club creditors are owed US$4.2 billion. The World Bank is owed US$1.6 billion, Afreximbank US$1.2 billion and the African Development Bank US$768 million. Treasury states in the same report that the country remains in debt distress.

The arithmetic traps us. Arrears block concessional finance. Blocked concessional finance forces expensive borrowing. Expensive borrowing deepens the arrears. Zimbabwe entered a ten-month IMF Staff-Monitored Programme in April 2026 and completed its first review on 27 July. An SMP is a monitoring arrangement with no financing attached. It exists to build a track record, and that track record is the price of admission to a conversation about arrears clearance we have been deferring for more than two decades.

Now hold that picture, because the rules that produce it are being rewritten this year.

The Two Negotiations That Matter

The first room is the Intergovernmental Negotiating Committee on the UN Framework Convention on International Tax Cooperation. This is the process the Africa Group forced onto the UN agenda in 2022, over the objections of the OECD bloc. The fifth negotiating session closed in New York on 13 August 2026, nine days ago. The sixth session runs in Nairobi from 30 November to 10 December 2026. The final convention text and two protocols go to the General Assembly in the first quarter of its eighty-second session, in late 2027.

The second room is the Borrowers’ Platform, launched on 15 April 2026 in Washington during the IMF and World Bank Spring Meetings. Its founding working group is Colombia, Egypt, Honduras, the Maldives, Nepal, Pakistan and Zambia. UNCTAD holds the secretariat. Egypt chairs the process and Pakistan is vice-chair, while membership and modalities are finalised.

One process is drafting binding text. The other is building a debtor caucus that has never existed. Both trace back to the Compromiso de Sevilla, the outcome document of the Fourth Financing for Development Conference, held in Sevilla from 30 June to 3 July 2025.

Where the Africa Group Held the Line in August

The August session moved from scoping into line-by-line drafting. Seven fights defined it, and every one of them determines whether the convention has teeth.

Arbitration. The sharpest split came over Protocol 2, on dispute resolution. Switzerland, France, the UK and Japan backed arbitration as a last resort. The Africa Group opposed mandatory arbitration outright, warning that it hands fiscal decisions to external tribunals. We have watched this film before in investor-state dispute settlement. A revenue authority wins an assessment against a multinational, and a panel sitting elsewhere overturns it.

Reservations. Article 25 governs whether states can sign the convention and then carve out the parts they dislike. The Africa Group defended a flat prohibition. Malaysia, the UAE, Austria and China argued for flexibility. A reservations clause turns a treaty into a menu.

Voting. Germany, the UK and Austria want the Conference of the Parties to decide by consensus. The Africa Group, backed by Nigeria, Senegal, Ghana and Tanzania, wants a simple majority. Consensus sounds inclusive. In practice it gives every single party a permanent veto over implementation.

What counts as illicit. Article 7 covers illicit financial flows. Germany, the UK and others pushed to restrict “illicit” to conduct that is already unlawful. The Africa Group, Nigeria and India defended the broader UN definition, which captures aggressive tax avoidance. Narrow that definition and the largest channel of loss falls outside the convention on a technicality.

Existing treaties. Article 21 asks whether the convention overrides the thousands of bilateral tax treaties already in force. Alternative B, backed by the Africa Group and Brazil, aligns them automatically. Alternative A, preferred by OECD states, requires each pair of countries to renegotiate. Under Alternative A, a country with limited negotiating capacity faces the same asymmetry it faces today, just with new paperwork.

Gross versus net. Under Protocol 1 on cross-border services, Nigeria and Zambia argued for gross-basis withholding tax. The UK, France, Germany and Italy opposed it. This is technical and it matters enormously. Taxing gross payments means a source country collects on the money leaving its borders. Taxing net profit means it collects on a figure the taxpayer calculates, after deductions the revenue authority may lack the capacity to audit.

Who pays for implementation. Brazil, Nigeria and the Africa Group asked for financed implementation. Germany and France offered voluntary assistance. An unfunded obligation on an under-resourced revenue authority is a dead letter.

Look at What They Were Actually Arguing About

Read that list again. Only two of those seven fights concern tax rates or taxing rights. The rest are about arbitration, reservations, voting thresholds, treaty conflict rules and budgets.

This is how architecture actually gets built. The political battle over principle was won in 2022, when the General Assembly voted to start this process. The battle now is over whether the text that emerges can be enforced. A convention with strong obligations, a reservations clause, consensus voting and optional arbitration will produce headlines and no revenue.

Our sector has a habit of mobilising around preambles and going quiet during drafting. That habit is expensive.

The Debt Side Is Further Behind

Sevilla opened a pathway towards a UN Framework Convention on Sovereign Debt. It stopped short of mandating one. Global North negotiators blocked binding language on debt cancellation and on intergovernmental debt negotiations, keeping restructuring inside creditor-controlled forums. The United States, the United Kingdom, Switzerland, Canada, Japan, Korea and Saudi Arabia formally dissociated from the tax paragraph. A comparable group dissociated from paragraph 50(f), which points towards a UN-led intergovernmental process on the debt architecture. What Sevilla left us is the possibility of a General Assembly resolution to launch negotiations. Possibility requires pressure to become process.

The Borrowers’ Platform deserves an honest reading. Its own framework states that it is not intended to serve as a collective bargaining platform. It shares information, coordinates approaches and builds capacity. Those are real functions. Creditors have coordinated through the Paris Club since 1956 while debtors negotiated one by one, and even a modest debtor caucus narrows that gap. The limitation is worth naming plainly, because overselling it invites the disappointment that follows.

Four Things That Follow

Nairobi at the end of November is a continental venue for a continental fight, and proximity is an organising asset we should use.

Get technical. Movements need people who can read Article 21 and explain what Alternative A costs a revenue authority in Harare or Lusaka. Moral clarity without drafting literacy loses in a negotiating room.

Hold our own governments to their stated positions. Nigeria, Ghana, Kenya, Senegal, Tanzania and Zambia all took strong lines in August. Positions taken in New York can soften under bilateral pressure between sessions. Publishing what our delegations said, and asking them to confirm it, is cheap and effective accountability work.

Link the two files. The countries losing revenue to tax abuse are the countries borrowing to fill the hole. Debt campaigns and tax justice campaigns still largely run on separate tracks, with separate coalitions and separate donors. That separation serves no one on our side.

Keep the calendar public. 30 November to 10 December 2026 in Nairobi. Late 2027 at the General Assembly. Deadlines organise people in a way that analysis alone does not.

Both Things Are True

UNCTAD estimated that US$88.6 billion leaves Africa every year as illicit capital flight. The figure dates to 2020 and is almost certainly conservative now. Set it beside the debt service numbers and the shape of the problem is clear. We are a net creditor to the world, and we borrow expensively to fund what we have already lost.

Both things are true at once. The architecture is rigged, and our own fiscal governance is often opaque, captured and unaccountable. Public contracts are inflated at home while profits are shifted abroad. Neither fact cancels the other, and treating African debt as purely a governance failure lets the architects off the hook just as surely as treating it as purely a structural problem lets our own elites off.

The rules are open for editing. That happens rarely. It closes in 2027.