The IMANI Centre for Policy and Education has filed a sweeping Right to Information (RTI) request demanding detailed documents, correspondence, and procurement records relating to the government’s planned nationwide SIM registration exercise scheduled for the first quarter of 2026.
The request, submitted to the Ministry of Communications, Digital Technology and Innovations, seeks to compel full transparency on the procurement processes, technical architecture, stakeholder engagements, and the role of private vendors—particularly a company known as Transactly Limited.
“Legal basis I make this application under Article 21(1)(f) of the 1992 Constitution and the Right to Information Act, 2019 (Act 989), which guarantees the right of access to information held by public institutions, subject to the limited exemptions set out in the Act.”
David Kukuia-Galley, IMANI’s Representative
The 37-page petition is one of the most extensive RTI filings by a civil society organisation in recent years, marking rising public concern over digital governance, citizen data protection, and the opaque management of past SIM registration exercises.
According to IMANI, the Ministry’s public announcements about a fresh round of SIM registration activities—expected to begin early 2026—raise critical questions that require immediate clarification.
The new exercise is expected to rely on biometric verification against the National Identification Authority (NIA) database and will be regulated by a new Legislative Instrument (L.I.) that the Ministry intends to lay before Parliament.
The Ministry has also revealed plans to procure a service provider to conduct the nationwide registration, with the associated cost billed to telecommunications operators.
Transactly Limited’s Engagement
IMANI argues that due to “whistleblower accounts” and emerging concerns about the Ministry’s engagements with Transactly Limited, full disclosure is necessary to ensure that the process is lawful, technically sound, and free from hidden contractual arrangements.
Transactly Limited, registered under ORC Number CS157791022, is at the centre of the civil society group’s inquiries about possible private involvement in biometric verification and digital platforms linked to the SIM registration process.
The request spans a wide timeframe—from January 1, 2023, to December 2025—and covers all records in the Ministry’s custody or control. This includes letters, emails, WhatsApp messages officially recorded, Cabinet and inter-ministerial briefs, minutes of meetings, policy papers, concept notes, technical designs, procurement documents, circulars, and instructions to agencies under the Ministry.
The scope extends to institutions such as the National Communications Authority (NCA), National Information Technology Agency (NITA), Ghana Digital Centres, GIFEC, Smart Infraco, the Cybersecurity Authority, the Data Protection Commission, and other agencies listed under the Ministry’s supervision.
IMANI is specifically requesting every draft and final version of the new Legislative Instrument on SIM registration, including explanatory memoranda and stakeholder consultation records.
The RTI filing highlights that civil society organisations, telecommunications companies, the NIA, NITA, Ghana.gov consortium members, K-Net, Ascend Digital, and Transactly should all have been part of the consultation process. IMANI seeks proof of these consultations and documentation of their outcomes.
Procurement Plans and Budget Funding Models
On procurement, the organisation is asking for internal procurement plans and budgets that explain the funding model for the new SIM registration exercise. It also requests all documents submitted to the Public Procurement Authority (PPA) seeking approval for a service provider—whether through open tender, restricted tender, or single-source procurement.
IMANI is calling for justification memos, PPA decisions, approvals, queries, responses, and briefing notes prepared for the Ministry’s leadership. Similar requests apply to any procurement activities carried out on the Ministry’s behalf by its agencies or special purpose vehicles.
In one of the most critical sections of the request, IMANI demands all records of interactions between the Ministry and Transactly. These include correspondence, proposals, meeting minutes, contracts, NDAs, memoranda of understanding, and pilot project files relating to SIM registration, digital identity verification, telecom fraud controls, and portals using the Ghana Coat of Arms or state agency logos.
IMANI is also demanding disclosure of any authorization the Ministry may have granted for Transactly’s use of official insignia, along with any internal complaints or concerns raised about this. The RTI request also focuses on the financial obligations of telecommunications operators.
IMANI is seeking documents that confirm whether the Ministry intends to “bill the telcos” for the upcoming exercise, compel them to adopt a designated platform or vendor, or impose new licensing or regulatory conditions tied to specific technical systems. Cost-sharing and levy arrangements, financial models, and cost-benefit analyses are all part of the items requested.
Additional requests include any Data Protection Impact Assessments conducted for the new registration system, records of data flow arrangements between telcos, NIA, Ghana.gov, Smart Infraco, and private vendors, and all correspondence with the Data Protection Commission on the legality of data sharing.
IMANI also asks for all agreements between the Ministry and the NIA relating to Ghana Card-based verification, API integrations, middleware, and the role of private vendors in that chain.
Public Interest Overrides Commercial Interest
Notably, IMANI pre-emptively addresses potential grounds for refusal under Section 10 of the RTI Act, which allows institutions to withhold information pertaining to commercial interests.
The organisation argues that the public interest override should apply, stating that “the integrity of the national biometric registry is a matter of paramount public interest” and that private technology vendors performing public functions must be held to transparency standards.
The request reminds the Ministry of its legal obligation to respond within 14 days and of the applicant’s right to seek an internal review or appeal to the RTI Commission should the Ministry refuse, delay, or fail to provide adequate disclosure.
With the government preparing to roll out a fresh SIM registration exercise in early 2026, possibly involving significant private-sector participation and compulsory links to the Ghana Card, IMANI’s RTI request represents a major push for transparency in an area where past controversies—such as system failures, long queues, data concerns, and disputes over timelines—still linger in public memory.
The Ministry of Communications, Innovation, and Digital Technology under Hon Samuel Nartey George’s response, or lack thereof, may shape public trust in the next national digital identification exercise.
READ ALSO: Ghana Heading for 14% Policy Rate by 2026 as Fitch Forecasts Big Shift Ahead
