Policy think-tank IMANI Center for Policy and Education has called for the immediate suspension of Ghana’s planned SIM card mass re-registration exercise, warning that the initiative risks repeating a cycle of policy failures that has persisted for more than a decade.
In a detailed analysis, IMANI argued that the country’s previous three re-registration efforts have been marked by consistent technical, operational, and governance shortcomings, raising serious concerns about the credibility of the 2026 exercise.
The think-tank maintains that without fundamental reforms, the latest attempt is unlikely to produce different results. The organisation emphasised that the issue is not simply the recurrence of the exercise but the apparent absence of institutional learning from past mistakes.
It noted that earlier registration drives were undermined by fragmented data systems, poor coordination between agencies, and unreliable registration platforms, all of which contributed to inefficiencies and public frustration.
A central concern raised by IMANI relates to the handling of sensitive personal data. The think-tank highlighted that previous exercises lacked clear frameworks for data custody, protection, and deletion, leaving uncertainty about how biometric information was stored and managed.
According to the analysis, the absence of effective oversight from the Data Protection Commission allowed telecom operators to collect and process user data without clearly defined legal responsibilities. This gap, IMANI warned, exposes citizens to potential misuse of their personal information.

The role of the National Communications Authority also came under scrutiny, with the think-tank noting that earlier exercises were conducted without adequate integration with the National Identification Authority.
This lack of coordination resulted in a system where collected data could not be effectively verified against national identity records. IMANI described this as a critical failure that undermined the purpose of the registration process, which is to ensure accurate identification and enhance security.
Technical Flaws Undermined Previous Exercises
The think-tank further pointed to significant technical shortcomings in the 2022 registration exercise, particularly the incompatibility of biometric systems. Telecom operators reportedly deployed contactless biometric devices, while the National Identification Authority relied on contact-based scanners.
This mismatch meant that biometric data collected during the exercise could not be authenticated within the national database. IMANI cited audit findings indicating that millions of records failed to produce successful biometric matches, even though facial recognition data showed higher verification rates.
The organisation stressed that this was not a minor oversight but a fundamental procurement failure that rendered large portions of the exercise ineffective. It argued that such disconnects between technical requirements and procurement decisions must be addressed before any new registration effort is undertaken.
IMANI also challenged the rationale for conducting a full-scale re-registration, pointing to existing data that suggests most subscribers have already been captured within the system.
Government figures indicate that approximately 30 million SIM cards have been linked to the Ghana Card, with around 80 percent of identities already cross-referenced.

Based on these figures, the think tank argued that the remaining challenge involves a smaller segment of unverified users rather than the entire subscriber base. It described the current plan as disproportionate and unnecessarily costly.
Instead of a blanket re-registration, IMANI proposed a targeted verification approach focused on resolving outstanding discrepancies. This, it said, would be more efficient and would avoid placing additional burdens on citizens and the state.
Concerns Over Procurement Driven Policy
A key theme in IMANI’s critique is what it describes as a procurement driven policy cycle, where repeated registration exercises create opportunities for contracts rather than solving underlying problems.
The think-tank referred to this phenomenon as “katanomics,” suggesting that the incentive structure behind such initiatives prioritises procurement over outcomes.
According to IMANI, this dynamic explains why failures in one exercise often become the justification for launching another, without addressing the root causes of the initial shortcomings.
The organisation warned that unless this pattern is disrupted, the 2026 exercise risks becoming another iteration of the same cycle, delivering limited benefits while consuming significant public resources.
The government has described the upcoming exercise as a final registration intended to resolve all outstanding issues. However, IMANI questioned this characterization, arguing that the necessary legal and technical foundations are not yet in place.
The think-tank pointed to unresolved issues such as unclear data governance frameworks, limited oversight mechanisms, and concerns about procurement transparency. Without addressing these gaps, it said, the claim of a final solution lacks credibility.
IMANI also raised concerns about proposed digital registration methods, including the use of USSD platforms. Experts have questioned whether such systems can meet the biometric verification standards required for integration with the National Identification Authority database.

Proposed Alternative Framework
As part of its recommendations, IMANI proposed a “verify and forget” model designed to streamline the process while enhancing data protection. Under this system, telecom operators would submit user details to the National Communications Authority, which would then verify identities through the National Identification Authority.
The authority would return a simple confirmation without sharing biometric data, ensuring that sensitive information remains securely stored within a single institution. This approach, IMANI argued, would reduce costs, improve efficiency, and strengthen privacy protections.
The think-tank also called for the introduction of strict safeguards, including clear data custody rules, audit trails, and user rights to access and control their personal information.
IMANI concluded that the planned mass re-registration should be halted until a comprehensive review is conducted. It urged the government to account for data collected in previous exercises, make procurement processes more transparent, and establish a robust legal framework to govern future operations.
The organisation stressed that effective reform requires more than repeating past strategies. It called for a shift toward evidence based policymaking, stronger institutional coordination, and a clear commitment to protecting citizens’ data.
As debate over the 2026 exercise intensifies, the think tank’s position adds to growing calls for a more measured and technically sound approach to SIM registration in Ghana.
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