"Environmental governance is not a luxury to be pursued after economic recovery."

Ghana's landmark Environmental Protection Act, 2025 (Act 1124), risks becoming merely a "law on paper" unless the NDC administration urgently operationalizes its key institutions, according to Dr John Kingsley Krugu, former Chief Executive Officer of the Environmental Protection Authority (EPA) and spokesperson for the NPP Environment and Natural Resources Sector Policy Committee for Election 2028.

In a new assessment of the 2026 Mid-Year Fiscal Policy Review, Dr Krugu argues that while the government deserves credit for macroeconomic stabilization and renewed enforcement against illegal mining, there is "comparatively limited evidence" that the broader institutional reforms envisioned under Act 1124 are being implemented.

"Legislation, however ambitious, does not transform institutions on its own. Its success depends on sustained political commitment, adequate financing, institutional capacity, effective regulations and consistent administrative leadership," Dr Krugu stated.

Act 1124: From Environmental Regulation to a National Development Pillar

Assented to on January 6, 2025, by then-President Nana Addo Dankwa Akufo-Addo, Act 1124 was presented as Ghana's most comprehensive environmental governance reform since the Environmental Protection Agency Act, 1994 (Act 490).

Dr Krugu, who led the EPA during the final stages of the Act's development, said Parliament designed the legislation to move beyond pollution control and environmental permitting by establishing four key pillars:

A stronger institutional framework, replacing the Environmental Protection Agency with an expanded Environmental Protection Authority to coordinate environmental governance across government.

Climate governance as national policy, establishing the Ghana Carbon Registry, Carbon Market Committee, and Mitigation Fund to embed climate action into national development.

Sustainable environmental financing, creating the National Environment Fund and Mitigation Fund to provide predictable funding for environmental initiatives.
Accountability and evidence-based governance — strengthening environmental monitoring, audits, and public reporting.

"Parliament's vision for Act 1124 extended well beyond enforcement. The Act envisaged a comprehensive governance framework that would strengthen institutions, mobilize sustainable financing, mainstream climate considerations across government, improve environmental accountability, and position Ghana as a regional leader in environmental governance and green economic transformation," he said.

What the 2026 Mid-Year Review Shows — and What It Misses

Dr Krugu acknowledged that the Mid-Year Fiscal Policy Review highlights notable achievements, including fiscal consolidation, arrests and equipment seizures linked to illegal mining, and the registration of small-scale miners.

"Efforts to restore macroeconomic stability and strengthen enforcement against environmental crime deserve recognition," he said.

However, he contended that the review provides little information on the implementation of the transformative provisions of Act 1124. Specifically, he noted the limited mention of the Environmental Protection Authority's expanded mandate, the National Environment Fund, the Ghana Carbon Registry, the Carbon Market Committee, and integrated environmental information systems.

"This observation should not be interpreted as a dismissal of the progress reported by Government. The distinction is significant.

Effective enforcement addresses immediate environmental harm, while effective governance builds the institutions needed to prevent future harm, attract investment, manage environmental risks and support sustainable development," Dr Krugu explained.

He further warned that as international carbon markets continue to evolve under Article 6 of the Paris Agreement, delays in establishing the Ghana Carbon Registry and Carbon Market Committee could cause Ghana to miss valuable investment and climate finance opportunities.

"The Environmental Sector Operated Without Dedicated Ministerial Leadership"

A major concern raised in the paper is the issue of political leadership. According to Dr Krugu, the environmental sector operated for much of the current administration's first year without a dedicated minister.

"Whether intentional or circumstantial, such an extended leadership gap may have contributed to the slow pace of implementation and diminished policy attention to one of Ghana's most important governance reforms. Environmental institutions require sustained political direction if ambitious legislative reforms are to translate into measurable outcomes," he said.

Call to Action: Strategy, Budget, and Leadership

Dr Krugu urged President John Dramani Mahama to take three immediate actions:

Publish a comprehensive implementation strategy for Act 1124 with clear timelines.

Provide dedicated budgetary allocations and capitalize the National Environment Fund and Mitigation Fund.

Appoint a dedicated Minister for Environment to provide oversight and political direction.

He also called on development partners to support institutional capacity-building for the Environmental Protection Authority.

"This is not a criticism for its own sake, nor is it a partisan argument. Environmental degradation does not distinguish between political parties. Climate change does not recognize electoral cycles.

Polluted rivers do not discriminate between governments. The Environmental Protection Act, 2025, belongs to Ghana, not to any political administration. Its successful implementation should therefore become a shared national project," Dr Krugu stressed.

Implementation Is the Real Test

Dr Krugu concluded that while Ghana has succeeded in passing the legislation, the greater challenge now lies in implementing it effectively.

"The enduring success of Act 1124 will not be judged by its enactment, but by the strength of the institutions it builds, the environmental outcomes it delivers, and the confidence it inspires among citizens, investors and development partners," he said.

He added, "Environmental governance is not a luxury to be pursued after economic recovery. Above all, Government must treat environmental governance as a national development priority rather than a peripheral administrative function."

With Ghana facing increasing pressures from illegal mining, flooding, drought, and the global transition to green investment, Dr Krugu argued that how Act 1124 is implemented over the next 12 months will determine whether the country leads or lags in Africa's green transition.

Dr John Kingsley Krugu is the former Chief Executive Officer of the Environmental Protection Authority (EPA), Ghana, and spokesperson for the NPP Environment and Natural Resources Sector Policy Committee for Election 2028.