Licence Refusal or Revocation in Tanzania: Which Desk Hears It

This page is the licence-appeal operating file: who may reconsider a refused or revoked licence, on what grounds, and inside which window. It is not a substitute for the empowering Act, and not a pleading you can lodge.

• Before the certificate lapses: business licence renewal
• Which approvals an activity needs: sector-licence finder
• A licence carrying conditions of its own: tour operator licence
• Foreign money behind a hotel: ownership, land and licence

As at 15 September 2026. This file rests on Cap. 208, the Law Reform (Fatal Accidents and Miscellaneous Provisions) Act Cap. 310 and the sector statutes named below; confirm the live appeal clause with the authority that signed your letter.

Read the decision before you choose a forum

Four events reach this desk wearing one word. A refusal disposes of an application that never became a licence. A suspension keeps the licence alive but stops the activity. A revocation ends it. A lapse after non-renewal is no decision at all: the term ran out, and a fresh application follows. Only the first three carry a right of appeal.

Take three things off the paper: the date, the reference, the reasons. Article 13(6)(a) of the Constitution of the United Republic of Tanzania, 1977 gives a right to be heard and to a remedy against an administrative decision; a body that refuses without saying why has handed you a ground. Request reasons by letter, and diarise from the date the decision bears.

Restrictions no appeal will cure

Where a refusal rests on a bar rather than on discretion, the answer is a restructure. GN No. 487A of 2025 reserves a schedule of activities for citizens; a foreign-held company turned away from one of them is not the victim of an error, and no Minister can licence past the Notice.

The same holds for land. The Land Act Cap. 113 keeps a non-citizen out of a granted right of occupancy except for investment purposes, taken as a derivative right through the Tanzania Investment Centre under the Tanzania Investment Act, 2022. A licence conditional on lawful premises will not issue over a defective occupation.

Sector statutes add requirements of their own: minimum shareholding, a citizen director, professional registration of the signatory. An appeal against a condition you have not met spends the window you would use to meet it.

Who issues the licence, and who hears the appeal

On the Mainland the business licence sits under Cap. 208, which splits issue between two desks. Class A licences come from the Ministry responsible for trade, in practice through the Business Registrations and Licensing Agency; Class B licences come from the city, municipal, town or district council for the area. The Act then routes an aggrieved applicant or holder to the Minister, whose decision closes the administrative route.

Sector licences follow instead the Act that created the regulator, and the appeal clause in that Act is the only one that counts.

Zanzibar is a separate jurisdiction. Island business licensing runs through the Business and Property Registration Agency, tourism through the Zanzibar Commission for Tourism, revenue through the Zanzibar Revenue Authority. A decision there is contested within that administration and, on legality, before the island’s High Court.

The forum each instrument names

Confirm the row against the section that refused you. Regulators are reorganised by statute more often than their portals are rewritten, and a stale appeal address is still an out-of-time appeal.

The sequence the desks take

1. Collect the decision on paper: date, reference, signatory, reasons; a portal status line is not a reasoned decision.
2. Open the empowering Act at the section relied on: it names the appellate body and the period, and neither is negotiable.
3. Answer any show-cause notice first: representations go back to the authority that issued it, inside its stated period.
4. Pass a board resolution: authorising the appeal and naming the signatory, minuted before filing.
5. Lodge the statutory appeal in time: memorandum of grounds, the decision annexed, supporting affidavit, fee receipt, service on the authority.
6. Apply separately for a stay: lodging an appeal does not revive a revoked licence.
7. Keep everything else current: returns, payroll and levies do not pause with the licence.
8. Escalate once the statutory route closes: judicial review goes to the High Court on legality, inside the Cap. 310 window.

The papers the appeal carries

The decision letter and whatever dates its delivery; the application or the licence under attack, with its conditions; the show-cause notice and your reply; any inspection report or committee minute relied on; the certificate of incorporation and the TIN; the tax clearance current when the application went in; sector pre-approvals (fire, health, weights and measures, professional registration; proof of premises) lease or title, council permit; the board resolution; a memorandum setting out numbered grounds; an affidavit verifying the facts; the fee receipt. One set for the body that will hear it, one served, one kept.

Time, and the clocks that do not pause

Statutory windows run from the day the decision was made or communicated, in the words of the Act, not from the day the board met to discuss it. A letter collected late is still dated when it was signed.

Judicial review carries its own limit. Section 17(2) of Cap. 310 bars leave for certiorari more than six months after the decision, and leave must be granted before the substantive application is filed under the Judicial Review Procedure and Fees Rules, 2014. Extension of time under the Law of Limitation Act Cap. 89 needs good cause on affidavit; internal delay rarely qualifies.

Other clocks keep running. The annual return to the registrar under the Companies Act Cap. 212, provisional tax instalments on the last day of the third, sixth, ninth and twelfth months of the accounting year under the Income Tax Act Cap. 332, and monthly payroll remittances fall due whether or not the licence is alive.

What the High Court reviews, and why a stay is separate

Judicial review tests legality, procedure and reasonableness: whether the authority held the power, heard you, and weighed what it should have weighed. It does not ask whether a different officer would have granted the licence. The remedies under Cap. 310 are certiorari to quash, mandamus to compel a decision never made, and prohibition to stop one being made unlawfully. A successful applicant gets the decision removed and the file sent back, not the licence.

Neither route restores the licence by itself. A stay is asked for expressly, on affidavit, showing what closure is doing to the business and that the appeal is arguable. Until one is granted, carrying on the licensed activity is an offence under the licensing Act and hands the authority a fresh ground it did not have.

Illustrative arithmetic: ninety days off the register

Illustrative arithmetic, not a quotation. A Dar es Salaam contractor turning over TZS 1,800,000,000 a year has its Class A licence cancelled, and ninety days pass before the Minister rules.

A quarter of that turnover, TZS 450,000,000, never arises. Service levy under the Local Government Finance Act Cap. 290 runs at 0.3 per cent of turnover, so that line falls by TZS 1,350,000: the only cost that shrinks.

The payroll does not. On a quarterly wage bill of TZS 60,000,000, skills and development levy at 3.5 per cent for employers with ten or more employees (Vocational Education and Training Act Cap. 82) is TZS 2,100,000; Workers Compensation Fund contributions at 0.5 per cent of the private-sector wage bill (Cap. 263) are TZS 300,000; and social security at 20 per cent of gross pay, the employer bearing at least half (National Social Security Fund Act Cap. 50), is TZS 6,000,000. Statutory outflow for the quarter: TZS 8,400,000, against nothing earned. Confirm the live schedule on tra.go.tz.

Output tax at 18 per cent under the VAT Act Cap. 148 is no part of that loss. It was never the company’s money. Closure destroys margin, and the contract behind it.

Where this file stalls

• An oral refusal at a counter, never reduced to writing, so there is nothing to annex.
• The appeal addressed to the regulator that refused, instead of the body its statute names.
• A period counted from the day the managing director read the letter.
• Judicial review filed while the ministerial appeal was still open, and struck out for it.
• Trading through a revocation because the appeal felt like protection.
• Grounds drafted as complaint rather than as breaches of the section relied on.

What moved in 2025

GN No. 487A of 2025 settled which activities are reserved for citizens, and refusals now cite it directly. That is a legislative bar, so an appellate body has nothing to weigh; the file moves instead to ownership, or to an activity outside the schedule.

Lodgement has moved online, so an outcome often surfaces as a portal status against an application number. Ask for the signed letter regardless.

Mandate-holders this file does not replace

BRELA owns Class A issue and the companies register. Councils own Class B licences and the service levy. Sector regulators own their own instruments: the energy and water authority, the communications authority, the land transport authority, the medicines and medical devices authority, the bureau of standards, the Mining Commission, the Bank of Tanzania for banks and bureaux de change, the insurance regulator for insurers. Clearance and registration sit with the Tanzania Revenue Authority.

Outcomes belong to the Fair Competition Tribunal, the Appeals Board and the High Court. An advocate settles the grounds, argues leave and moves for a stay. Zatra prepares the bundle and coordinates the desks; it does not practise law, issue licences, or promise an outcome.

What to confirm before you act

• Which of refusal, suspension, revocation or lapse the letter actually records.
• The section relied on, and the appellate body and period that section names.
• Whether a show-cause notice was issued, and whether the reply period has closed.
• Whether the ground is a discretion or a bar under GN No. 487A of 2025.
• Whether a stay has been sought, and what the business may lawfully do meanwhile.
• The live fee, form and lodgement channel published by the body that will hear you.