Ghana's gold debate is being forced into an unhelpful choice. One side treats the reported losses as proof that the entire programme failed. The other describes every cost as the unavoidable price of rescuing the cedi. Both positions are too easy.

But, in my view, these are not the questions that matter most. What did the Domestic Gold Purchase Programme achieve? What did it cost? Could Ghana have secured similar reserve, exchange-rate and inflation benefits at a lower price? After the Ghana Gold Board Act, 2025 (Act 1140), which institution carries the commercial and fiscal risk? Did the purchasing model strengthen or weaken environmental discipline? Who received the benefits, and who will eventually pay the bill?

These questions matter because the figures are enormous, unemployment remains high, and every avoidable public loss has consequences for households, businesses and future budgets. This is not an argument for abandoning gold. It is an argument for managing Ghana's gold with the same discipline we would demand of any valuable national asset.

*WHY THE POLICY WAS ADOPTED*

The programme responded to a real economic problem. Ghana needed foreign exchange, stronger reserves and a more effective way to bring artisanal and small-scale gold into official channels. The policy logic was to use cedis to purchase locally produced gold, convert that gold into reserve assets or foreign exchange, improve traceability and supply dollars to the market without first spending scarce foreign currency.

That rationale was practical, especially after severe exchange-rate, inflation and financing pressures. But a necessary objective does not automatically validate every price, contract or financing method used to pursue it. The relevant managerial test is whether the same public benefit could have been achieved with less loss, less concentration and clearer accountability.

*LET US START WITH WHAT THE RECORDS ACTUALLY SAY*

The Bank of Ghana's audited 2025 financial statements record a net loss of GH¢8.849740 billion under Gold for Reserves and GH¢203.034 million under Gold for Oil. Together, those two audited lines equal GH¢9.052774 billion.

The International Monetary Fund uses a broader method. Its August 2026 assessment estimates that the Domestic Gold Purchase Programme generated operational losses of more than US$1.7 billion in 2025 — about 1.5 per cent of Ghana's gross domestic product and roughly 17 per cent of the value of the doré transactions it matched.

These figures describe overlapping activity through different accounting and analytical lenses. They must not be added together. Nor should GoldBod's reported corporate surplus be used to cancel the Bank of Ghana's programme loss. GoldBod's accounts, the Bank's audited gold-deal lines and the IMF's economic reconstruction answer different questions.

This distinction is more than accounting. It tells us why Parliament, the Auditor-General, the Bank of Ghana, the Ministry of Finance and GoldBod should publish a joint reconciliation. Ghanaians should be able to follow the money from the purchase of each material gold lot to its assay, refining, sale, foreign-exchange conversion and final settlement.

*ACT 1140 CHANGED THE INSTITUTIONAL ARCHITECTURE*

Act 1140, assented to on 2 April 2025, did more than create another public agency. It made GoldBod the central institution for overseeing and undertaking gold buying, selling, assaying, refining and export. For gold produced outside large-scale mining, GoldBod became the sole authority to purchase, sell and export, while also controlling licensing across aggregation, buying, refining, storage, transport and related services. Its statutory purpose includes generating foreign exchange and supporting the Bank of Ghana's accumulation of gold reserves.

One legal distinction is essential. The Act transferred the rights, assets, liabilities, staff and existing contracts of the Precious Minerals Marketing Company to GoldBod. It did not transfer the Bank of Ghana's balance sheet, historical losses or reserve-management mandate. Large-scale mining also remains differently treated: GoldBod may purchase its gold where government exercises statutory pre-emption rights, but the Act's exclusive purchase-and-export powers are directed principally at gold outside the large-scale sector.

The law also did not move every operation on the day it was passed. The Bank of Ghana's 2025 accounts show that it continued to finance and account for important Domestic Gold Purchase Programme transactions, including artisanal and small-scale gold channelled through GoldBod. The IMF reports that doré purchases began to be conducted by GoldBod from 1 April 2026 under a memorandum formalising the transfer, while its July 2026 assessment still called for the transfer to be fully implemented and for central-bank quasi-fiscal activities to end. The 2025 losses therefore remain Bank of Ghana losses; they cannot be moved retroactively by changing the institutional operator.

That boundary should now be explicit. GoldBod should carry clearly limited commercial, procurement and operational risks. The Bank of Ghana should decide reserve adequacy, conduct monetary policy and manage foreign-exchange operations under a transparent framework. The Bank may purchase reserve assets on market-consistent terms, but it should not be the routine financier of a state trading operation or the place where an unbudgeted subsidy is hidden.

Political claims that the Bank of Ghana's loss was simply the 'capitalisation' of GoldBod are therefore too imprecise to settle the matter. Formal equity capital, working-capital advances, pre-financing, exchange-rate subsidies and the absorption of trading losses are different transactions. A surplus within GoldBod's own accounts does not erase a loss borne elsewhere in the public sector; equally, a central-bank loss does not prove that every cedi advanced was lost or diverted.

The remedy is not another partisan number. It is a consolidated, independently assured statement showing the legal basis, amount and terms of every advance; the gold and foreign exchange received; the identity and remuneration of aggregators, assayers, refiners and off-takers; the exchange rates applied; all outstanding balances; and which institution ultimately absorbed each cost.

*BOKPIN AND SARKODIE ARE RIGHT TO DEMAND A FULLER BILL*

Professor Godfred Bokpin has argued that the IMF's US$1.7 billion estimate does not capture Ghana's complete economic cost. His position is that the intervention must be examined across the entire value chain, including design defects, foregone revenue and the burden transferred to the central bank and ultimately the taxpayer.

That concern has a factual foundation: the IMF states that its estimate excludes sterilisation. When the Bank of Ghana creates cedis to purchase gold, it increases liquidity. If that liquidity threatens inflation or exchange-rate objectives, the Bank may have to withdraw it through open-market operations and pay interest. The monetary cost therefore does not necessarily end when the gold is sold.

Dr Adu Owusu Sarkodie has added another dimension. He estimates that abolishing the 1.5 per cent withholding tax on artisanal and small-scale gold may have cost Ghana roughly GH¢2 billion in forgone revenue. That estimate deserves official verification, including an assessment of how much tax would actually have been collected after allowing for changes in smuggling and seller behaviour.

But caution is essential. The GH¢2 billion estimate is a tax expenditure, not a trading loss. A future recapitalisation of the central bank would be a fiscal consequence or financing response; it cannot automatically be added in full to the original loss as though both were separate. Environmental and water costs must also be measured incrementally: Ghana should not blame GoldBod for damage that would have occurred without the programme, but it must not ignore damage that the purchasing model encouraged or failed to prevent.

The correct approach is a consolidated cost-benefit study that measures operational losses, incremental sterilisation and financing costs, verified tax expenditure, environmental damage and governance risks—then subtracts the additional benefits of formalisation, reserve insurance, reduced smuggling and greater stability. Every component must be measured against a credible "without-programme" baseline and checked for double-counting.

*GOLD PRICES WERE NOT THE MAIN CULPRIT*

The losses cannot credibly be blamed on depressed world gold prices. Gold reached record levels in 2025, and the World Bank estimated an annual price increase of roughly 41 per cent. Ghana benefited from an unusually favourable external environment.

The IMF identifies the central weakness elsewhere: the exchange-rate spread. Gold was purchased using a forex-bureau-linked cedi rate, while the resulting foreign exchange was accounted for or sold using a lower Bank of Ghana reference rate. Service and assay fees and discounts to private off-takers added to the cost.

The arithmetic is straightforward. If Ghana uses GH¢150 million to acquire, process and sell a gold batch that produces US$10 million net, the break-even exchange rate is GH¢15 to US$1. Recording or selling those dollars at GH¢12 produces a GH¢30 million shortfall before sterilisation. Gold prices can rise and the transaction can still lose money if the cedi-dollar conversion is mispriced.

*MANTEAW IS RIGHT THAT THE PROGRAMME PRODUCED REAL BENEFITS*

A fair assessment must recognise what worked. According to the IMF, the Bank of Ghana purchased and exported approximately 104 tonnes of artisanal and small-scale gold worth US$10.9 billion in 2025. The programme helped bring gold and foreign exchange into official channels, rebuild reserves and support foreign-exchange market liquidity.

The Bank sold about US$10.6 billion into the foreign-exchange market during the year. The cedi appreciated strongly, inflation declined and reserves improved. Formalisation also appears to have narrowed the gap between Ghana's recorded exports and the gold reported by importing countries. These are valuable achievements.

Dr Steve Manteaw therefore makes an important argument when he says the wider economic benefit may have exceeded the reported programme cost. Stable foreign exchange can help businesses plan, reduce imported-cost pressure and protect household incomes. He also argues that GoldBod entered a market where established foreign buyers were already financing miners and purchasing gold at discounts, making competitive local pricing necessary to draw gold into official channels.

That defence should be tested, not dismissed. But gross turnover is not net benefit. The US$10.9 billion export value is not automatically US$10.9 billion of new national wealth created by the programme. Much of that gold already existed and some would have been exported legally under a different arrangement. The relevant benefit is the additional official foreign exchange, reduced smuggling and lower volatility attributable to the programme.

*GOLD DID NOT STABILISE GHANA ON ITS OWN*

It is equally unsafe to credit the entire improvement in the cedi, inflation and debt sustainability to GoldBod or the gold-purchase programme. Fiscal consolidation, tighter monetary policy, improved food supply, historically high gold prices, debt restructuring and restored confidence all contributed.

Professor Bokpin is right to remind the country that pensioners, domestic bondholders and Eurobond holders absorbed part of the adjustment. The Domestic Debt Exchange Programme and external restructuring reduced financing and debt-service pressure. Gold was an important channel through which exceptional foreign-exchange flows reached the official market; it was not the only cause of stability.

This matters for policy. If officials mistake a commodity boom and debt-relief effect for a permanent improvement in productivity, Ghana may repeat an old cycle: celebrate temporary relief, increase commitments and then face painful adjustment when external conditions change.

*THE STRONGER CEDI ALSO EASED THE ENERGY-SECTOR BURDEN*

One benefit deserves more attention because it links exchange-rate stability directly to the budget. IMF Resident Representative Dr Adrian Alter has explained that many energy-sector obligations—including payments to independent power producers and fuel suppliers—are denominated in United States dollars. When the cedi appreciates, the same dollar bill requires fewer cedis, reducing pressure on government finances and the energy-sector shortfall.

But Dr Alter was equally clear that the exchange rate was only one part of the improvement. Better Electricity Company of Ghana collections, stronger implementation of the Cash Waterfall Mechanism, and greater use of domestic gas instead of more expensive imported liquid fuel also mattered. The IMF's energy-sector analysis adds the need for cost-reflective but socially protected tariffs, lower technical and commercial losses, payment enforcement, transparent procurement and stronger governance.

This is precisely why attribution matters. Gold-related foreign-exchange inflows may have supported the cedi, but fiscal consolidation, tight monetary policy, debt restructuring, cocoa receipts, IMF and other official inflows, high commodity prices and restored confidence were also at work. The programme should receive credit only for the incremental stability it produced relative to a credible alternative — not for every improvement that occurred at the same time.

Government can make this measurable. It should publish the dollar obligations and budget exchange rates used for the energy sector, the actual cedi cost, ECG collection rates, distribution losses, arrears, Cash Waterfall allocations, fuel mix and subsidies. That would show how much of the relief came from the exchange rate, how much from sector reforms, and whether the benefit reached households through reliable power, restrained tariffs or lower taxes rather than remaining an accounting gain.

*A PUBLIC PURPOSE DOES NOT REMOVE THE LEAST-COST TEST*

Exchange-rate and price stability have public-good characteristics because their benefits spread across the economy. But that does not mean every mechanism used to produce stability is itself a public good or that any price is acceptable.

Professor Festus Ebo Turkson of the University of Ghana, who serves as an external member of the Bank of Ghana's Monetary Policy Committee, offers the clearest public-good defence of the intervention. He describes the Domestic Gold Purchase Programme as an economic-policy intervention intended to build reserve buffers, reduce gold smuggling and support currency stability. In his view, a central bank's monetary-stability role provides benefits across the economy, so the programme's balance-sheet cost should be judged against the wider gains rather than treated like the loss of an ordinary private trader. He is also right to insist that the IMF's US$1.7 billion estimate is a cost recorded through the Bank of Ghana's programme, not proof that GoldBod's own corporate accounts show the same loss.

That argument deserves serious weight, but it does not end the inquiry. A road, vaccination programme or monetary intervention may produce a public good and still be overpriced, poorly procured or financed through the wrong institution. The IMF's assessment also goes beyond a harmless accounting translation: it identifies an exchange-rate mismatch, fees, discounts and financing arrangements that created a real economic cost. Professor Turkson's claims about reserve gains, debt-ratio improvement and debt-service savings should therefore be reconciled with official data and a credible counterfactual, because debt restructuring, fiscal consolidation, economic growth, high commodity prices and monetary policy also contributed. Public-good status strengthens the case for measuring the benefits; it does not remove the duty to obtain them at the lowest reasonable cost.

Foreign exchange is scarce and allocated to particular users. If the Bank effectively acquires dollars at a high cost and supplies them at a lower rate, the first-round benefit goes to the recipient of the foreign exchange. Some benefits may reach consumers through lower prices, but that cannot simply be assumed. The programme must disclose who received foreign exchange, at what rate, for what purpose and with what measurable pass-through to the economy.

The economic rule is simple: a legitimate public objective should be achieved through the least costly instrument capable of delivering it. If the same reserve and stability benefits could have been obtained through a transparent auction, market-consistent pricing, lower fees and better risk management, the excess cost was avoidable.

*THE LOSSES CARRY REAL OPPORTUNITY COSTS*

A GH¢9.053 billion accounting loss does not mean government held the same amount in cash and refused to build hospitals or create jobs. Opportunity cost is more subtle. Losses can reduce future central-bank income, create recapitalisation needs, add financing costs and narrow future fiscal choices.

The scale remains important. The audited loss is roughly 90 times the 2026 allocation for the National Coders Programme, more than 50 times the allocations for Adwumawura and the National Apprenticeship Programme, and over 22 times the stated capital allocation to the Women's Development Bank. These comparisons do not prove that the money could have been transferred immediately or spent perfectly. They show the magnitude of the trade-off.

That trade-off is especially serious when unemployment remains around 13 per cent and job quality is weak. The World Bank reports that only 13 per cent of Ghanaian workers held high-quality formal-wage or high-skilled jobs in 2023. Gold can finance development, but extraction is capital-intensive and cannot by itself employ Ghana's growing working-age population.

Ghana must therefore use the present gold windfall to diversify into reliable power, logistics, irrigation, agro-processing, light manufacturing, digital services, tourism and employer-linked skills. Otherwise, a gold-heavy external surplus may strengthen the cedi while weakening non-gold exporters and import-competing businesses— the familiar Dutch-disease problem.

*THE ENVIRONMENTAL BILL CANNOT REMAIN OUTSIDE THE ACCOUNTS*

The debate has largely measured gold in tonnes, dollars, reserves and trading losses. That is incomplete. If gold production leaves Ghana with polluted rivers, unusable farmland, damaged cocoa areas, abandoned pits, mercury exposure and higher water-treatment costs, part of the apparent gain is being financed by households, farmers, water utilities and future taxpayers.

The IMF's 2026 assessment describes environmental degradation from illegal mining as a persistent drag on agricultural productivity and long-term growth. World Bank work on Ghana's artisanal and small-scale mining sector identifies enduring damage to water, soil, forests, cocoa and food security. Ghana Water has also reported raw-water turbidity at the Sekyere Hemang treatment plant of about 14,000 NTU—seven times its stated design level of 2,000 NTU—because of illegal-mining activity along the Pra River. That translates into more chemicals, faster equipment deterioration, interrupted supply and the risk that some water sources become uneconomic to treat.

The rapid rise in official artisanal gold purchases does not, by itself, prove that GoldBod caused an increase in galamsey. Higher recorded volumes can result from formalisation, reduced smuggling, record world prices or genuinely higher legal production. Nor does the creation of a state buyer amount legally to state approval of illegal mining.

But the incentive risk is real. A powerful state-backed buyer offering competitive prices can increase the demand for extraction. If buyers cannot yet trace each lot to a licensed, environmentally compliant mine, legally and illegally produced gold can be mixed before it reaches the official channel. GoldBod rejects allegations that it supports galamsey and has announced a national mine-to-export traceability system. The fact that the system is still being procured while record volumes are already being purchased, however, leaves an accountability gap that should concern both government and the opposition.

This is where the language of "state backing" must be handled carefully. The evidence does not justify saying that the state has authorised illegal mining. The more defensible criticism is that a public purchasing system may unintentionally validate production, create a guaranteed market or weaken deterrence if environmental verification comes after purchase. A state institution must never become a laundering point through which illegally or destructively mined gold acquires official respectability.

Environmental damage should not simply be added wholesale to the IMF's US$1.7 billion estimate. Much of Ghana's galamsey crisis predates GoldBod, and the same loss must not be counted twice. The correct measure is the additional damage attributable to the programme relative to a credible "without-programme" baseline: changes in illegal mine footprints, river quality, cocoa and food-crop losses, water-treatment expenditure, mercury-related health burdens, land-reclamation liabilities and public enforcement costs.

The safeguards should be immediate. GoldBod should purchase only against a verified mining licence, EPA permit, geofenced production site and realistic production-capacity profile. Every lot should carry a digital chain-of-custody record from mine to assay, refinery and export. Buyers linked to unlicensed sites should be suspended; anomalous production should trigger investigation; beneficial owners and sourcing volumes should be disclosed; and an independent environmental and responsible-sourcing audit should be published annually.

Ghana should also apply the polluter-pays principle. A transparent environmental bond or levy should finance reclamation, water monitoring and community health surveillance without becoming another hidden margin. River-quality baselines, treatment costs and restored hectares should appear beside gold-export and reserve figures in the programme's performance report. Gold cannot be called a national success if the foreign exchange is public but the poisoned water is left to local communities.

*LOSS IS NOT PROOF OF CORRUPTION — BUT THE RISKS ARE REAL*

Neither the audited loss nor the IMF estimate proves theft, bribery or diversion. A responsible policy article must not turn an accounting result into a corruption allegation without evidence.

However, the structure contains recognisable integrity risks: a sole state buyer and seller, large cedi advances, private aggregators, purity and weight determinations, off-taker selection, cross-border settlements and exchange-rate conversions. The IMF reports that one aggregator supplied more than 60 per cent of artisanal gold exports in 2025 before a second was licensed. Such concentration increases dependence and integrity risk even when no wrongdoing has been established.

The safeguards are practical: publish licensing criteria and beneficial owners; use independent dual assays; apply one published LBMA-and-FX pricing formula; obtain multiple executable bids from prequalified refiners and off-takers; reconcile cash, gold and bank settlements daily; disclose lot-level first-trade information; and give Parliament, the Auditor-General and independent assurance providers access to transaction records.

*ACT 1140 REQUIRES REPORTING — BUT DISCLOSURE MUST GO FURTHER*

Act 1140 contains important accountability provisions. GoldBod must maintain an internal audit unit that reports every three months to its leadership. Its annual accounts are to be audited by the Auditor-General, and its annual report—covering performance, challenges and the audit—must pass through the responsible ministers to Parliament. The Act also identifies its funding sources, including budgetary resources, market and off-taker finance, fees, loans and grants, and subjects borrowing to public-finance rules and ministerial consent.

Those safeguards are necessary, but annual aggregate reporting is not enough for a fast-moving commodity business. GoldBod is simultaneously regulator, licensor, national assayer, dominant buyer, seller and exporter for the artisanal and small-scale segment. That concentration may reduce smuggling and improve bargaining power, but it also creates a structural conflict: the institution that sets the rules is deeply involved in the transactions governed by those rules.

A public monopoly therefore requires more disclosure than an ordinary company. GoldBod should publish a quarterly trade and fiscal-risk dashboard showing purchase and sale volumes, benchmark prices, exchange rates, fees and discounts, inventories, aged receivables, realised and unrealised gains or losses, borrowing, guarantees, counterparties, foreign-exchange proceeds and their destination. Contracts, tender results, aggregator volumes and beneficial owners should be disclosed, subject only to narrow and justified commercial redactions. Lot-level records should remain available to the Auditor-General, Parliament and independent investigators.

Moving the programme away from the central bank is good institutional policy, but it does not make public risk disappear. If GoldBod borrows with state consent, receives budgetary capital, uses off-taker advances or later requires government support, commercial losses can become fiscal or contingent liabilities. Ghana therefore needs one consolidated public-sector account covering GoldBod, the Bank of Ghana and the Ministry of Finance, with no double-counting and no cost left outside the reporting boundary.

*A BETTER MODEL IS AVAILABLE*

In my view, we do not need to choose between returning to uncontrolled gold exports and continuing a loss-making central-bank structure. The useful parts of the programme can be retained within a more disciplined model.

The distinction between legacy and continuing operations must also be maintained. The Bank of Ghana states that Gold for Oil was discontinued in March 2025. Its GH¢203.034 million loss remains part of the 2025 audited record, but the scheme should not be described as a continuing GoldBod operation or as though every former Bank of Ghana activity moved wholesale under Act 1140.

First, every purchase, accounting entry and foreign-exchange sale should use a single, transparent and market-consistent exchange-rate rule. GoldBod's reported move from the forex-bureau rate to an interbank-rate formula is a positive response, but the formula and its results should be independently verified and published.

Second, the Bank of Ghana should concentrate on monetary policy, reserve management and transparent foreign-exchange auctions. It should not remain the routine provider of open-ended working capital or absorb commercial gold-trading losses. GoldBod and licensed commercial participants should carry clearly limited trading risks on their own books.

Third, Ghana should sell doré through transparent electronic tenders among multiple prequalified, creditworthy refiners and bullion-market counterparties. Refined bullion can be sold through established over-the-counter markets using recognised benchmarks. Futures, options and currency forwards should be used carefully to hedge short settlement risks—not to speculate.

Fourth, reserve accumulation should follow a published adequacy range based on import cover, short-term external debt, market access and Ghana's exchange-rate regime. More reserves are valuable, but not without limit. The IMF estimates that about six months of import cover may be adequate and warns that pursuing a much larger target through continuous gold purchases could create very high sterilisation and opportunity costs.

Fifth, every subsidy should appear transparently in the national budget, carry a cost ceiling and expire unless Parliament renews it after an independent evaluation. A public subsidy should be voted and measured, not concealed in the central bank's balance sheet.

Sixth, the Ministry of Finance and GoldBod's board should impose hard risk limits: maximum inventory days, counterparty and aggregator concentration limits, open foreign-exchange limits, minimum collateral and settlement standards, a cumulative loss trigger, and a prohibition on unapproved Bank of Ghana overdrafts or implicit guarantees. GoldBod's regulatory, assaying, licensing and commercial teams should operate behind clear governance firewalls, with independent compliance, procurement and risk committees.

Finally, Ghana should establish a gold windfall and productive-transformation rule. After paying miners fairly, covering transparent operating costs and meeting a prudent reserve target, part of the remaining public mineral rent should finance environmental restoration, fiscal stabilisation and competitive investments in job-rich productive sectors.

*PRESERVE THE PURPOSE; REDESIGN THE INSTRUMENT*

The national debate should not become a partisan contest between celebration and scandal. The gold programme responded to a genuine crisis. It helped formalise trade, bring foreign exchange into official channels, rebuild reserves and — alongside other reforms — ease some exchange-rate pressure on the energy sector and the wider budget. Those achievements matter. So do the losses, the legal concentration created by Act 1140 and the public risks that remain after the programme changes institutions.

Professor Bokpin's warning about full cost and sustainability, Dr Sarkodie's questions about tax expenditure and institutional responsibility, Professor Turkson's public-good case and institutional-accounting distinction, Dr Manteaw's argument about economy-wide benefits, and GoldBod's defence of its corporate results all belong in the analysis. None should be accepted as the entire story on its own.

The humane objective is to protect households twice: first from inflation, exchange-rate disorder and reserve crises; and second from avoidable losses that crowd out jobs, water, health, skills and productive investment. Ghana can do both.

The standard should be straightforward. Every ounce purchased through a public programme must strengthen Ghana's reserves or public finances after all costs—not merely increase gross turnover. If GoldBod buys and sells at disciplined prices, publishes enough information to make corruption difficult, controls commercial and environmental risk, and leaves monetary financing to the Bank of Ghana, it can become a valuable national institution. If Ghana then uses the gold windfall to diversify rather than become more dependent on gold, today's stability can become tomorrow's resilience.

By Kwabena Nyantakyi; Economic policy Analyst