Permits & People

Work Permit Succession Plan Tanzania: Understudies, the Eight-Year Cap and the 1:10 Ratio

Cover: work permit succession plan in Tanzania under section 7 of the Non-Citizens (Employment Regulation) Act Cap. 436 and regulation 16 of GN 331 of 2016
Section 7 of Cap. 436 and regulation 16 of GN 331 of 2016 tie every foreign permit to a named Tanzanian understudy. As at 27 October 2026.
Direct answer

What is a work permit succession plan in Tanzania? It is the employer's written plan, required by section 7 of Cap. 436, to pass a foreign employee's knowledge to a named Tanzanian understudy through a training programme. It goes in with the first application, or within three months for a new business, and each renewal needs a progress report. Permits run 24 months, capped at eight years in total.

This guide treats the work permit succession plan Tanzania employers file as a planning tool, not a form. It covers the classes that need one, its contents, how it is assessed, the cap, the ratio, sector rules, fees, penalties and Zanzibar, with a three-expatriate worked example.

Who should read this

For filing mechanics, read our guide to work permit renewal in Tanzania. This page covers the plan and the cap.

What the law says

The Non-Citizens (Employment Regulation) Act, Cap. 436, in TanzLII's consolidation of 14 March 2025, governs foreign employment on the Mainland. Section 2 limits it to Mainland Tanzania. The Non-Citizens (Employment Regulation) Regulations, 2016, GN 331 of 2016 fill in the procedure.

RuleProvisionWhat it says, in short
Duty to planCap. 436 s.7(1)Anyone who intends to employ or engage a non-citizen prepares a succession plan for passing the non-citizen's knowledge or expertise to citizens during the tenure
Duty to trainCap. 436 s.7(2)The employer establishes an effective training programme to produce local employees
Plan filed with the applicationCap. 436 Second Schedule item 14"Succession plan, in the case of employment" is a listed document
Named understudyGN 331 reg. 16(1) and (2)Tanzanian employees are designated to understudy the non-citizen; a new business files within 3 months of the permit
Progress report on renewalGN 331 reg. 16(3)Every renewal is accompanied by a progress report against the plan
Local search firstCap. 436 s.11(2); GN 331 reg. 6(1)(d)The Commissioner must be satisfied that all possible efforts were made to obtain a local expert
Validity and capCap. 436 s.12(4) and (5)24 months per permit; eight years in total; an investor of great value may exceed ten years
RatioCap. 436 s.19(2) and (3)One non-citizen to ten local employees, subject to the nature of the business

What is a work permit succession plan?

It is a written commitment, filed with the Labour Commissioner, showing how a role held by a non-citizen will pass to a Tanzanian. Section 7(1)(a) asks for "a well-articulated plan for succession of the non-citizen's knowledge or expertise to the citizens". Section 7(1)(b) adds any other information the Commissioner directs.

Regulation 16 turns that into a person. For an existing business, the plan must show that Tanzanian employees "have been designated to understudy the non citizen for the purpose of skills transfer". For a new business, a citizen is appointed to undergo on-the-job training under the non-citizen.

The plan therefore has three testable parts: the role, the understudy, and the training that closes the gap.

Which work permit classes need a succession plan?

Section 13 of Cap. 436 sets five classes. Section 7 applies to any person who employs or engages a non-citizen. The Second Schedule lists the plan "in the case of employment", and regulation 4(2)(b) lists "a succession plan (for renewals)" among the documents for Classes B, C and D.

ClassWho it coversSuccession planGovernment feeRegister ID
AInvestors and self-employedNot in the reg. 4(2) Class A list; confirm if the holder is also employedUSD 1,000F0413
BPrescribed professions: medical and health, oil and gas experts, science and mathematics teachersYes, at grant and with a progress report at renewalUSD 500F0414
COther professionsYes, at grant and with a progress report at renewalUSD 1,000F0415
DApproved religious and charitable activitiesYes, listed for renewalsUSD 500F0416
ERefugeesNot listedGratisF0417

Class A is the grey area. An investor working for their own company is not an employee in the ordinary sense, and the Class A document list omits the plan. Where a Class A holder also draws a salary as an executive, ask the Labour Commissioner in writing whether a plan is expected. Our guide to Class A permits for investors covers that route.

What must a succession plan contain?

The regulations refer to a plan "as set out in the Schedule" to GN 331. The published TanzLII copy notes that the forms have not been reproduced, so we cannot quote the official template. The OWAIS guidelines do not describe the plan either. Download the current form from the system when you file.

Until then, the statute and the closest official model give a reliable shape. The Mining Commission's 2018 guideline for local content plans (GN 305 of 2018) asks, for each position held by a foreigner, for the fields below.

FieldWhat to writeSource of the field
Position and departmentJob title, grade and reporting lineGN 305 of 2018 Part V
Current expatriateName, permit class, first grant date and years used against the capGN 305 Part V; Cap. 436 s.12(4)
Tanzanian successorNamed understudy, current role and qualificationsGN 331 reg. 16; GN 305 Part V
Training neededSkills gap, courses, certification, on-the-job rotationCap. 436 s.7(2); GN 305 Part V
DurationStart date and handover date, within the permit capCap. 436 s.7(1)(a); GN 305 Part V
Performance indicatorHow readiness is measured: sign-offs, acting periods, resultsGN 305 Part V
Budget and evidenceTraining spend, attendance records, certificatesGood practice for the reg. 16(3) progress report

Copied plans and understudies who are not on the payroll are visible in an interview, and section 20 makes false information an offence.

How does the Labour Commissioner assess the plan at grant and renewal?

No published scoring rubric exists that we could find. The tests come from the statute and regulations, and they differ at each stage.

At first grant. Section 11(2) requires the Commissioner to be satisfied that all possible efforts were explored to obtain a local expert. Regulation 6(1)(d) asks for evidence from a recognised job search mechanism that the post could not be filled locally. The plan then shows how the dependence on a foreigner will end. Regulation 5 lets the Commissioner approve or reject within fourteen days.

At renewal. Section 12(8) applies sections 9 and 10 to a renewal, so the full document set returns. Regulation 16(3) adds the progress report. An officer will compare it with the plan filed two years earlier. Training promised and not delivered is the obvious gap.

Near the cap. Section 12(9) lets the Commissioner attach a finality condition where the non-citizen is close to the end of the permitted period. A permit marked final signals that the next step is the understudy, not another renewal.

An appeal against refusal lies to the Minister within thirty days under section 18, and an advocate should prepare it.

Is the work permit cap five years or eight?

Eight. Section 12(4) states that a work permit is valid for 24 months from issue and that "the total period of validity of the first grant and its renewals shall not, in any case, exceed eight years". The Act as passed in 2015 set five years. Cymbell Attorneys' note of 3 November 2021 records the change made by the Written Laws (Miscellaneous Amendments) (No. 4) Act, 2021.

Older guides and some regulation text still reflect the five-year era. Regulation 12(2) of GN 331 refers to permits under section 12(5) being valid for "not less than five years". That provision concerns the investor exception, not the general cap.

The eight years run from the first grant. In practice that means four 24-month permits.

Can the eight-year cap be lifted or avoided?

Three routes exist in the law. None of them is a reward for a good succession plan.

RouteProvisionWho it suitsGovernment fee
Investor of great valueCap. 436 s.12(5); GN 331 reg. 12(2)An investor whose contribution to the economy or the wellbeing of Tanzanians is of great value; total may exceed ten yearsClass fee on each permit (F0413)
Certificate of exemptionCap. 436 s.4(4) to (6); GN 331 reg. 13Posts that cannot be filled locally, investments of great value, or marriage to a Tanzanian of at least three yearsNil (F0420)
Finality condition avoidedCap. 436 s.12(9)Not a lift; plan so the role is localised before the capNot applicable

Under regulation 13, the Minister decides an exemption after consulting the Labour Commissioner, within fourteen days. FB Attorneys' update of 15 March 2017 summarises the same grounds.

We found no provision that extends the cap for an ordinary employee because the understudy is not ready. A failed plan does not buy time. It ends the role for the foreign holder.

Is there a local-to-foreign ratio in Tanzania?

Yes. Section 19(3) of Cap. 436 requires an applicant not registered with the investment authorities to create employment "at a ratio of one non-citizen to ten local employees". The exception is where the nature of the business does not permit employment of local employees. Section 19(2) applies the same ratio when a registered investor hires beyond its quota.

Regulation 9 of GN 331 has a separate rule for bulk recruitment. The employer asks the Commissioner in writing, the Commissioner inspects, and permits "may be granted at a ratio of ten local employees to one non-citizen employee".

The ratio is a floor for headcount, not a substitute for the plan. A company with 100 Tanzanian staff and 3 foreigners still needs a named understudy for each foreign role. Our note on the foreign employee ratio covers localisation more broadly.

How many expatriates can a TISEZA-registered investor employ?

Section 19(1) of Cap. 436 lets an applicant registered with the Tanzania Investment Centre and the Export Processing Zones Authority "employ up to ten non-citizens without being subjected to the conditions prescribed under this Act". Only the prescribed fee remains payable. That is the immigrant quota.

The Investment and Special Economic Zones Act, 2025 replaced both bodies with TISEZA. Its section 36, headed immigrant quota, allows an investor to employ foreign workers "subject to the number limits specified under the law governing employment of foreigners". The 2025 Act sets no number of its own. UNCTAD's summary of the 2025 regulations says the certificate allows foreign experts, subject to immigration laws, and gives no figure either.

Our reading: the number is ten, under section 19(1), applied to TISEZA-registered investors. Section 19 still names the old bodies, so confirm the current practice with TISEZA and the Labour Commissioner. Our guide to the 2025 investment Act explains the repeal.

Inside the quota, each person still needs a permit. Files lodged through TISEZA's work permit desk pay a USD 100 facilitation fee (F0418) on top of the class fee. We advise a plan for every quota role.

Do mining and petroleum add their own succession plans?

Yes, and they run in parallel with the work permit plan, before a different regulator.

Mining. The Mining (Local Content) Regulations, 2018, GN 3 of 2018 require an employment and training sub-plan within the local content plan filed with the Mining Commission. Breakthrough Attorneys' note of 28 February 2019 places the succession plan "for any employment position that is occupied by a foreigner" in regulations 20 and 21, with quarterly employment reports. The GN 305 guideline sets the fields in the table above, with projections up to five years.

Petroleum. The Petroleum (Local Content) Regulations, 2017, GN 197 of 2017 require an employment and training sub-plan under regulation 12. Regulation 13 requires "a detailed succession plan for any employment position, that is occupied by a non-Tanzanian". Regulation 14 reserves semi-skilled and unskilled jobs to Tanzanians, with written approval needed for exceptions.

Petroleum First Schedule, Tanzanian share of management staffAt startAfter 5 yearsAfter 10 years
Upstream10%15%25%
Midstream and downstream15%30%50%

Clyde & Co's note of 9 April 2024 sets out the other bands, rising to 100% for unskilled roles. Suppliers should read our guide to local content for oil, gas and mining suppliers. File both plans and keep them consistent.

What does it cost in government fees?

The succession plan itself carries no fee. The costs sit on the permits it supports. All figures below come from the Zatra fee register at 26 September 2026; the full schedule is in our government fees handbook.

ItemGovernment feeRegister IDLegal basis
Work permit Class CUSD 1,000F0415Cap. 436 s.10(2)(a), Fifth Schedule
Renewal or change of classFull class fee againNEW-04-36Cap. 436 s.12
TISEZA facilitation fee on a work permitUSD 100F0418TISEZA one-stop centre
Work Permit Register inspectionUSD 50NEW-04-37Cap. 436 s.8(2), Fifth Schedule
Certificate of exemption, and appealsNilF0420Cap. 436 s.4(4) to (6)
Residence permit Class B-1, directUSD 2,000, plus USD 50 re-entry passF0406; NEW-04-21Immigration Act Cap. 54 s.50(1)(j)

The register inspection fee lets an employer check a candidate's years already used against the cap before making an offer.

What are the penalties?

The succession duty has no fine of its own in section 7. The risk comes through the permit. A permit that is refused or not renewed leaves the employee without authority to work, and section 9 then applies. Our guide to working without a permit covers enforcement.

BreachPenalty as set by lawRegister IDLaw
Employing or engaging a non-citizen without a valid permit or exemptionFine not less than TZS 10,000,000, or imprisonment not less than 2 years, or bothF0422Cap. 436 s.9
False information, forged documents, breach of permit conditionsFine not less than TZS 10,000,000, or imprisonment not less than 12 months, or bothF0423Cap. 436 s.20
Failure to surrender a permit within 14 days before departureFine not less than TZS 10,000,000, or imprisonment not less than 12 months, or bothF0424Cap. 436 s.17
Failure to produce a permit to an authorised officerFine not less than TZS 5,000,000, or imprisonment not less than 6 months, or bothF0425Cap. 436 s.6
Late half-yearly return on non-citizen employeesTZS 500,000 for each month or part of a monthNEW-04-39Cap. 436 s.16

Regulation 24 of GN 331 adds a general penalty for breaches of the regulations where no other penalty applies: a fine of not less than TZS 5,000,000, six months' imprisonment, or both. That line is not in our fee register, so confirm it before relying on it. A fabricated understudy or training record falls under section 20. If an inspection or a prosecution is in view, instruct an advocate before responding.

How does Zanzibar handle succession and caps?

Cap. 436 does not apply in Zanzibar. Foreign employment there falls under the Zanzibar Employment Act No. 11 of 2005, and permits are issued by the Labour Commissioner in Zanzibar. A Mainland permit does not authorise work on the islands.

PointMainland TanzaniaZanzibar
LawCap. 436 and GN 331 of 2016Employment Act No. 11 of 2005; Zanzibar Investment Act No. 10 of 2023
Local search tests.11(2): all possible efforts to obtain a local experts.36(1)(a): no Tanzanian with the required qualification available
Statutory succession planYes, s.7 and reg. 16None found in either Act; ask the authority
Permit length and cap24 months; eight years totalLong-term permits 6 to 12 months; four-year total with stated exceptions (s.37)
Investor expatriate limitTen under s.19(1); otherwise 1:10Up to 10% of total employees for eight years, ZIPA may extend (s.38)
Penalty for unpermitted workNot less than TZS 10,000,000 (F0422)Not less than TZS 500,000 or 3 months (s.42)

Section 38 of the Zanzibar Investment Act, 2023 bars hiring an expatriate where a qualified Tanzanian or Zanzibari is available. Section 32(c) imposes a training duty without a named-understudy form. Our Zanzibar work permit guide covers the island process. Zanzibar fees are not in our Mainland register, so confirm them with ZIPA or the Labour Commissioner in Zanzibar.

Worked example: three expatriates and a two-year renewal budget

Mfano Foods Limited is a hypothetical food processor in Dar es Salaam, not registered with TISEZA. It employs 64 Tanzanians and 3 foreigners, all on Class C permits with Class B-1 residence permits. The ratio is roughly 1 to 21, inside the 1:10 floor in section 19(3).

RoleFirst grantCurrent permit endsRenewal filed byEight-year cap endsUnderstudy
Plant manager1 Mar 202128 Feb 202728 Dec 202628 Feb 2029Production supervisor, 6 years' service
Process engineer1 Jul 202530 Jun 202730 Apr 202730 Jun 2033Graduate engineer, ERB-registered
Maintenance lead1 Oct 202630 Sep 202830 Jul 202830 Sep 2034Senior technician

The filing dates use the earlier of the two rules: two months under regulation 17, and sixty days under section 12(7). The plant manager is the priority. His February 2027 renewal will be his last, and the Commissioner may mark it final under section 12(9). His plan must show the supervisor acting as plant manager for set periods during 2027 and taking the role by early 2029.

Government fees over the two years, direct route, from the register:

The total is USD 9,150 in government fees. At an illustrative rate of TZS 2,500 to USD 1, that is about TZS 22,875,000; the amount on each control number governs. Filing through TISEZA would add USD 100 per work permit (F0418) and change the residence permit line to F0404, but Mfano is not registered.

The plan's own budget is the company's cost, not a government charge. Mfano sets aside an illustrative TZS 24,000,000 over two years: TZS 14,000,000 for the supervisor's management course and rotations, TZS 6,000,000 for the engineer's certification and TZS 4,000,000 for the technician. Each spend is evidenced for the progress reports.

What to do now

  1. Map the cap. List every non-citizen, permit class, first grant date and the date eight years ends.
  2. Name an understudy for each role. Record the person, current role, qualifications and the skills gap, as regulation 16 requires.
  3. Write the training programme. Set courses, rotations, acting periods and a handover date that falls before the cap.
  4. Keep evidence as you go. File attendance records, certificates and supervisor sign-offs each quarter for the progress report.
  5. Check the ratio and quota. Confirm local headcount meets section 19, and confirm any TISEZA quota position in writing.
  6. Align sector plans. Where you supply mining or petroleum, make the local content succession plan match the permit plan.
  7. Budget the renewals. Put class fees, residence permits and re-entry passes in the budget by currency, using register IDs.
  8. Prepare for the last permit. For anyone in years six to eight, plan the exit, a Class A route or an exemption application early.

Key dates

WhenWhatBasis
With the first applicationSuccession plan filed (existing business)Cap. 436 Second Schedule item 14; GN 331 reg. 16(1)
Within 3 months of the permitSuccession plan filed (new business)GN 331 reg. 16(2)
Within 14 days of filingCommissioner may approve or rejectGN 331 reg. 5
Two months, and at least 60 days, before expiryRenewal lodged with the progress reportGN 331 reg. 17; Cap. 436 s.12(7)
30 June and 31 DecemberHalf-yearly return on non-citizen employeesCap. 436 s.16
Within 14 days of the job endingReport cessation to the CommissionerGN 331 reg. 18
Within 30 days of a refusalAppeal to the MinisterCap. 436 s.18
Eight years from first grantPermit cap reached, save the s.12(5) investor exceptionCap. 436 s.12(4)

How Zatra helps

Zatra's work and residence permits service builds the permit calendar, drafts each succession plan and progress report, and lodges renewals on OWAIS and the Immigration e-Permit system. Our HR consulting team designs the training programme and the evidence file. For employee residence permits, see our Class B residence permit guide.

Costs come in two separate buckets. Government fees are paid by the client to the Labour Commissioner, Immigration or TISEZA at the official amount, against each authority's control number. Zatra's professional fee is quoted on its own line and never mixed with them.

The Labour Commissioner and the Commissioner General of Immigration decide every application. Zatra prepares and coordinates, but does not decide or guarantee any authority's outcome. Appeals, exemption hearings, inspections that may lead to prosecution, and legal opinions go to an advocate.

Sources and status

Accurate as at 27 October 2026.

Figures to confirm before you act

This article is general information based on official sources available at the date of publication. It is not legal, tax or financial advice. Laws and notices change. Verify with the issuing authority or consult Zatra before acting.

Frequently asked questions

Can the understudy be a contractor rather than an employee?

Regulation 16 speaks of Tanzanian employees designated to understudy the non-citizen. A contractor on a short engagement is a weak fit and may draw a query. Put the understudy on the payroll, with NSSF and WCF registration, so the progress report rests on records the Commissioner can check.

What happens if the understudy resigns halfway through the plan?

Name a replacement at once and record the reason in the next progress report. Explain the training already given and the revised handover date. A plan that adapts to a resignation reads better than one that stays silent until renewal.

Does a foreign employee who changes employer start a new eight-year count?

Section 12(4) counts the first grant and its renewals, and we found no rule that resets the count with a new employer. Treat the years already used as continuing. Check the Work Permit Register (USD 50, NEW-04-37) before making an offer.

Is a succession plan needed for a short project assignment?

Section 7 applies to anyone who employs or engages a non-citizen. For a short assignment, the plan can focus on knowledge transfer during the project. The Commissioner may issue a shorter permit under regulation 12(1) and may attach a finality condition under section 12(9).

Can a company ask for fewer than 24 months to fit the plan?

Yes. Regulation 12(1) lets the Commissioner issue a permit for a lesser period, including one the applicant requested. Section 12(9) then allows a finality condition where the employer asked for a limited duration.

Does the 1:10 ratio count part-time and casual Tanzanian staff?

Section 19 speaks of local employees without defining full-time status. Casual and part-time workers may be counted differently in practice. Use payroll and NSSF records as the evidence, and confirm the counting rule with the Labour Commissioner before relying on casual headcount.

Can the foreign employee switch to a Class A permit after eight years?

Only if they become a genuine investor or self-employed person who meets the Class A conditions. A paper shareholding to extend an employee's stay invites refusal and a section 20 risk. The Class A route has its own documents, fee (F0413) and residence permit.

Who signs the succession plan?

The employer, through an authorised officer such as the managing director or HR head. Many employers also have the foreign holder and the understudy sign, which helps show the plan is real. Keep the signed copy with the training records for the next renewal.

Sources & regulators

Verify before filing: Rates, forms and thresholds move by Finance Act, Government Notice and portal revision. Confirm the live schedule on the mandate-holder portal before you budget or submit. Law-firm alerts and Big Four notes are discovery only.

Brief the desk

This Insights page is orientation. Work and residence permits is the commercial desk for the same facts. Zatra’s fee stays on its own line, separate from government, bank and regulator charges. Approvals are not guaranteed.

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Disclaimer

This article is informational orientation. It is not legal, tax or investment advice and not a government decision. Tanzanian instruments move by Act, Government Notice, Finance Act and portal revision. If a sentence here disagrees with the live mandate-holder, the mandate-holder wins. Zatra Consultants Limited does not issue licences, permits, tax clearances or approvals, and gives no assurance of any regulatory or banking outcome. Professional fees are published only on /pricing/.

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