The Chamber of Oil Marketing Companies (COMAC) has given the Ministry of Finance 14 days to suspend Section 136 of the Customs Act, 2026 (Act 1179), escalating an industry dispute over how petroleum taxes are collected in Ghana.
The Chamber says the new provision could shift substantial financing obligations onto Bulk Import, Distribution and Export Companies (BIDECs), with possible consequences for fuel prices, tax collection and supply security.
COMAC has placed its members on alert and says it will convene an emergency general meeting if the Finance Ministry does not announce the suspension within the two-week period. The meeting, according to the Chamber, will determine the industry’s next administrative, regulatory and legal steps.
The dispute centres on Section 136, which changes the entity responsible for accounting for downstream petroleum taxes. Under the new arrangement, the obligation moves from Oil Marketing Companies (OMCs) and LPG Marketing Companies (LPGMCs) to BIDECs, with the tax accounted for when the bulk supplier sells the petroleum product.
The Commissioner-General of the Ghana Revenue Authority (GRA) may defer the payment for up to 21 days where the obligation is supported by a bank guarantee. COMAC, however, argues that the arrangement could leave BIDECs financing tax liabilities before they receive payment from their customers.
“COMAC considers Section 136 to be a transfer of risk, not reform,” the Chamber said.
Tax collection shift raises liquidity concerns
At the heart of COMAC’s objection is a question of when government receives its money and who carries the financing burden before that happens.
The Chamber says BIDECs told the Customs Division of the GRA during a September 18 meeting that they would require at least 45 days to settle their tax obligations. That compares with the 21-day period applicable to OMCs and LPGMCs under the existing arrangement.
COMAC therefore disputes the argument that moving the tax obligation upstream will necessarily accelerate government revenue collection.
“Today, 56 BDCs exist, and there’s no statutory cap, just as there’s no cap on OMCs,” COMAC said, arguing that simply reducing the immediate number of taxpayers does not resolve weaknesses in enforcement.
The issue is particularly important because the additional liability would arise before BIDECs necessarily receive payment for the products they supply. That could increase their reliance on bank facilities, guarantees and working capital.
In turn, higher financing costs could become part of the cost structure of petroleum distribution.
COMAC argues that those costs could eventually be reflected in pump prices, although the extent of any such pass-through would depend on financing terms, market competition and the pricing decisions of operators.
The concern comes at a time when the downstream market is already facing renewed price pressure. COMAC’s October 1 pricing outlook projected diesel could reach GH¢19.60 per litre, with the Chamber attributing the expected increase to higher international petroleum prices and depreciation of the cedi.
Revenue assurance remains central to dispute
COMAC’s opposition is not limited to the financing implications.
The Chamber maintains that Section 136 changes the location of tax collection without addressing what it considers the underlying enforcement problem.
According to COMAC, the existing Integrated Customs Management System (ICUMS) already provides mechanisms for controlling petroleum operators through credit limits and restrictions. The Chamber is seeking greater transparency over instances where such controls were allegedly overridden.
“The issue is enforcement, not the collection point,” COMAC CEO and Industry Coordinator Dr Riverson Oppong said. “Until existing controls and system overrides are properly enforced, changing the collection point does not address the underlying challenge.”
The Chamber has also linked the dispute to outstanding questions over petroleum revenue assurance.
It says its analysis of 2025 industry data identified an estimated 819.25 million litres of unaccounted-for petroleum products, with an associated revenue implication of approximately GH¢2.5 billion.
COMAC is seeking a formal response to the analysis, alongside information concerning 10 diesel tankers it says were impounded in October 2025 and clarification over the granting of non-bonded status to three operators. These are claims and requests made by the industry body and require responses from the relevant authorities.
The Chamber’s argument is that resolving such enforcement and accountability questions should precede any major restructuring of petroleum-tax collection.
Supply risk could move upstream
A separate concern is the potential concentration of risk at the bulk-supply level.
Under the existing arrangement, enforcement action against an individual OMC can be targeted at that operator. COMAC argues that the consequences could be wider if the tax obligation is concentrated among BIDECs, because one bulk supplier may serve several marketers and a large number of retail outlets.
A restriction on a single BIDEC could therefore affect multiple downstream businesses simultaneously.
The Chamber describes this as a potential “single point of failure” in the petroleum supply chain.
That creates a policy trade-off for government.
A centralised collection mechanism could, in principle, allow the GRA to supervise a smaller number of bulk suppliers. But if those suppliers require longer payment periods, face greater financing pressures or become more consequential to downstream supply, the system could also concentrate rather than eliminate risk.
COMAC is consequently asking government to retain the current structure, under which BIDECs account for import duties and port charges at importation while OMCs and LPGMCs remain responsible for downstream taxes and levies at the ex-pump stage.
Government faces test on revenue and regulation
The Finance Ministry and GRA have yet to publicly respond to COMAC’s latest 14-day demand.
The government’s policy rationale, however, is tied to revenue assurance: shifting the obligation to bulk suppliers could give the tax authority fewer entities to monitor and potentially reduce exposure to defaults by individual marketers.
COMAC is challenging whether that benefit has been demonstrated sufficiently, particularly given the industry’s concerns over payment timelines, financing costs and the absence of what it says was adequate consultation and impact assessment before implementation.
The Chamber has made clear that it is not calling for a disruption of petroleum supplies.
“COMAC has no interest in disruption, given the essential service its members provide to households and businesses,” the Chamber said, while arguing that operators cannot confidently work under a framework it considers insufficiently tested or justified.
The 14-day deadline therefore places the immediate focus on whether the government will suspend Section 136, defend its implementation or engage with the industry over modifications.
For the downstream petroleum sector, the broader issue extends beyond which company remits the tax.
It is whether Ghana can tighten petroleum revenue collection while ensuring that the financing burden does not translate into higher consumer prices, that enforcement action does not create avoidable supply disruptions, and that any new system is supported by clear evidence, transparent controls and predictable rules.
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