Policy think tank Africa Policy Lens (APL) is calling for an urgent amendment of Section 25 of the Ghana Gold Board Act, 2025 (Act 1140) to protect the mandates of mining sector institutions and prevent financial losses from duplicated functions.
On Tuesday, June 16, the Ghana Gold Board (GoldBod) signed an agreement with the Forestry Commission and Ghana Armed Forces to reclaim 50 hectares of the degraded Tano Nimiri Forest Reserve.
The project, costing GH₵36.35 million, targets land damaged by decades of illegal mining.
But in a statement issued Friday, June 19, APL warned that GoldBod is encroaching on mandates already assigned to other state institutions by law.
“Reclamation of degraded mine sites has long been undertaken by the Minerals Commission, NAELP, Forestry Commission and GLRSSMP, under the leadership of the Ministry of Lands & Natural Resources, with clear legal mandates,” APL stated, urging GoldBod to stay within its remit to preserve the independence of agencies like the Forestry Commission.
While Section 3(g) of the Act may be cited to justify reclamation, APL argued that the broad wording creates “significant risks of mandate duplication, institutional overlap, and the gradual evolution of GoldBod into a de facto upstream small-scale mining regulator”.
“Reclamation does not fall within GoldBod’s core objects under Section 2 of the Act. It is not mandated to lead or manage upstream mining activities,” APL said.
This follows GoldBod’s earlier announcement that its Mining Support Unit would partner with the Ghana Geological Survey Authority and Minerals Commission to conduct geological exploration for ASM.
However, the Minerals Commission, in an RTI response dated 18 May 2026 to APL, clarified: “the Commission only provides GGSA with information on blocked-out areas to enable the Authority’s geological investigations on behalf of the Ghana Gold Board.”
APL said the trend raises “serious governance concerns about the roles of natural resource institutions with direct mandates,” adding that GoldBod’s upstream expansion under the guise of funding “undermines the Ministry of Lands & Natural Resources and agencies such as the Minerals Commission, Forestry Commission and RCOMSDEP, which are legally mandated to lead reclamation.”
The think tank cautioned that GoldBod’s actions could “weaken institutional independence, distort accountability, and create parallel governance structures.”
It also warned of financial risk, stating “without direct oversight responsibility, GoldBod may struggle to track, evaluate, and ensure value for money in such initiatives, leading to loss to the State.”
Following its review, APL concluded that the current wording of Sections 3 and 25 of Act 1140 “may intentionally or unintentionally expand GoldBod’s influence into areas already covered by existing institutions.”
Proposed fix
APL is calling for an immediate amendment of Section 25 to ensure funds earmarked by the GoldBod Board are not administered by GoldBod itself under 25(1) and 25(3).
It proposed that the amendment should read: amendment: ”the funds earmarked under section 25(1) shall be transferred to the relevant public institutions, agencies and programmes established under law and mandated to support the activities of small-scale miners in accordance with section 25(2).”
“GoldBod must focus on its core mandate under Section 2. Institutions with the legal mandate and capacity must drive upstream activities,” APL recommended.
It also flagged GoldBod’s power to issue guidelines on fund use, allocation and disbursement as “excessive control over upstream ASM activities that fall outside its mandate”.