Africa Policy Lens (APL) has urged the government to amend Section 25 of the Ghana Gold Board (GoldBod) Act, warning that the current law could create conflicts among state institutions, weaken governance structures, and expose the country to financial risks.
In a statement issued on June 22, the policy think tank expressed concern about GoldBod’s growing involvement in activities linked to small-scale mining. According to APL, these activities go beyond the Board’s primary responsibilities.
The group’s concerns come after GoldBod signed an agreement with the Forestry Commission and the Ghana Armed Forces to restore parts of the Tano Nimiri Forest Reserve that illegal mining has severely damaged.
The reclamation project, valued at GH¢36.35 million, aims to rehabilitate 50 hectares of land affected by years of illegal mining operations.
Although APL supports efforts to restore degraded land, it believes existing institutions already have the legal authority and technical expertise to carry out such work.
“Reclamation of degraded mine sites has been undertaken by the Minerals Commission, NAELP, Forestry Commission and GLRSSMP, under the lead of the Ministry of Lands and Natural Resources, with mandates,” the statement noted.
APL argued that GoldBod’s participation in these projects could result in overlapping responsibilities and duplication of work within the country’s natural resource management sector.
“Although section 3(g) 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,” APL stated.
The think tank also pointed to GoldBod’s plans to work with the Ghana Geological Survey Authority (GGSA) and the Minerals Commission on geological exploration projects in areas designated for artisanal and small-scale mining.
To support its argument, APL cited a Right to Information response from the Minerals Commission dated May 18, 2026.
The response stated that the Commission “only provides the Ghana Geological Survey Authority (GGSA) with information on blocked out areas to enable the authorities’ geological investigations initiatives on behalf of the Ghana Gold Board.”
According to APL, this arrangement raises important questions about the responsibilities of institutions that already have direct legal authority over mining activities.
The organisation warned that GoldBod’s continued participation in upstream mining projects, even when presented as financial support, could gradually undermine the authority of the Ministry of Lands and Natural Resources and agencies such as the Minerals Commission, Forestry Commission and RCOMSDEP.
APL further cautioned that such developments could blur lines of accountability, weaken institutional independence, and create parallel governance systems within the mining sector.
The think tank also raised concerns about how funds allocated under Section 25 of the GoldBod Act are managed.
To address the issue, APL proposed an amendment to the law, stating: “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).”
The organisation maintained that GoldBod’s Board of Directors should approve funding but should not directly administer those funds.
It argued that allowing the Board to control both approval and implementation gives it excessive influence over activities that fall outside its core mandate.
APL also called for an immediate review of Section 25(3). It insisted that GoldBod should not have the power to issue guidelines on how funds for upstream small-scale mining activities are allocated, disbursed, or used.
“GoldBod must focus on its core mandate in line with section 2 of the Ghana Gold Board Act 2025, Act 1140, and the appropriate institutions with the mandate and capacity must be allowed to drive upstream activities,” the statement stressed.
