By ZBT analyst
The continued delay by Madison Financial Services to trigger a mandatory offer by ZFI holdings in 2019 is raising fears that the Lusaka Securities Exchange – LuSE is simply unable to police the firm.
The delays in this case bear resemblance to the LuSE’s findings in Feb 2023 that Madison breached many provisions of the Harmonised Listings Requirements of the Lusaka Stock Exchange. In that matter, which looks set to repeat itself regarding this unexplained delay of the ZFI mandatory offer, raises questions regarding remedies to harmed shareholders and penalties for perpetrators.
According to an expert who spoke to the Zambian Business Times – ZBT on condition of anonymity, Madison on 13 August 2025, announced that ZFI Holdings Limited, a large shareholder, triggered a mandatory offer in 2019, but it did not extend the mandatory offer to other shareholders for reasons not disclosed. Madison proposed that shareholders waive the mandatory offer.
Later on 22 August 2025, shareholders deferred waiving the mandatory offer, and then on 12 January 2026, Madison announced that ZFI will be belatedly making a mandatory offer to shareholders, and that the terms of the offer will be announced in future announcements. As at end of February 2026, Madison has not made any further announcements about the mandatory offer.
The financial expert told ZBT that if Zambia wants to continue developing its capital market, such lapses should not be allowed. This situation now raises more questions than answers.
Questions such as why did ZFI not make a mandatory offer in 2019 when it triggered the obligation? What consequences will ZFI face for making a mandatory offer over 6 years late? How will it compensate shareholders for being deprived of a mandatory offer for over 6 years?
As at the time of going to press, efforts to get a comment from Madison or LuSE were still underway, and Madison had not made further announcements about the mandatory offer since 12 January 2026. More details to follow.
