The Africa Policy Lens (APL) has raised a red flag over the systemic vulnerabilities in Ghana’s resource governance, cautioning that overlapping statutory frameworks among key natural resource institutions are severely undermining sector accountability and regulatory performance.
According to a press release, the policy think tank expressed grave concerns about the expanding administrative footprint of the Ghana Gold Board (GoldBod).
APL contends that the current wording of the Ghana Gold Board Act, 2025 (Act 1140), particularly sections 3 and 25, enables an unintended expansion of GoldBod’s influence into upstream activities.
This legislative ambiguity allows the agency to climb upstream into the small-scale mining value chain under the guise of project funding, effectively triggering structural tensions and duplication of efforts with established mining regulators.
“While Goldbod steps in to support reclamation activities, the Africa Policy Lens holds the view that, although section 3g of the Act may be used by Goldbod as a justification for the reclamation exercise, the breadth of these provisions creates significant risks of mandate duplication, institutional overlap, and the gradual evolution of Goldbod into a de facto upstream small-scale mining regulator. It doesn’t fall within the mandate of the Goldbod to veer off its objects under section 2 of the Goldbod Act to lead and manage upstream allied mining activities. These continuous actions by the GoldBod, climbing upstream of the small-scale mining chain under the guise of funding, seek to undermine the mandate of the Ministry of Lands & Natural Resources and related agencies.”
Africa Policy Lens (APL)
This policy alert follows a recent reclamation agreement signed on Tuesday, 16 June 2026, where GoldBod partnered with the Forestry Commission and the Ghana Armed Forces to reclaim sections of the Tano Nimiri Forest Reserve degraded by years of illicit mining operations.
The initiative, budgeted at GH¢36.35 million, targets the ecological restoration of 50 hectares of land.
While the effort appears progressive, APL notes that it directly intersects with the statutory functions of the Ministry of Lands and Natural Resources and its specialised arms, including the Minerals Commission, the National Artisanal and Small-Scale Mining Awareness and Enforcement Committee (NAELP), and the Ghana Landscape Restoration and Small-Scale Mining Project (GLRSSMP).
Furthermore, an Right to Information (RTI) response dated May 18, 2026, revealed that the Minerals Commission only provides the Ghana Geological Survey Authority (GGSA) with blocked-out area data to facilitate geological investigations on behalf of GoldBod, highlighting a deep-seated institutional friction where downstream entities fund and drive primary upstream exploration.
Institutional Mandate Duplication and Weakened Accountability
By expanding its scope into active exploration and land reclamation, GoldBod creates a parallel administrative track that clashes with the core objectives of the Minerals Commission.
This institutional entanglement blurs the lines of state accountability. When multiple public entities hold overlapping responsibilities over the same geographical and legal jurisdictions such as the Tano Nimiri Forest Reserve it becomes difficult to monitor performance or isolate regulatory failures.
APL warns that this dynamic “could weaken institutional independence, distort accountability frameworks and create parallel governance structures within the mineral sector,” reducing the overall efficiency of resource management.
Threat of Financial Losses and Ineffective Oversight
A major concern raised by the think tank is the high risk of state financial loss resulting from these structural overlaps. Because GoldBod lacks direct statutory oversight or structural capacity to manage technical mining operations, its involvement in funding large-scale upstream projects creates fiscal vulnerabilities.
The organisation may face severe challenges in tracking, evaluating, and ensuring value for money in complex field operations like the GH¢36.35 million reclamation project. Without specialized technical oversight, millions of public funds risk misallocation.
To prevent these fiscal loopholes, APL insists that regulatory power must be properly separated from financial administration, ensuring that entities without core technical mandates do not manage large-scale field budgets.
The Path to Legislative Reform: Amending Act 1140
To resolve these structural vulnerabilities, APL is calling for immediate legislative intervention to amend Section 25 of the Ghana Gold Board Act, 2025 (Act 1140).
The policy think tank argues that the current legal framework gives GoldBod excessive control by allowing it to administer the very funds its Board allocates.
APL proposes redrafting Section 25(1) so that all earmarked funds are legally transferred to, and managed by, the relevant public institutions and agencies mandated to support small-scale mining.
Additionally, amending Section 25(3) is crucial to strip GoldBod of its power to issue standalone guidelines on the disbursement and use of these funds.
Correcting these legislative ambiguities will ensure GoldBod focuses strictly on its downstream mandate under Section 2, leaving upstream operations to the proper regulatory authorities.
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