Strengthening gold sector governance through institutional separation: Reforming GoldBod in line with modern extractive sector principles

By Nii Ayitey ARMAH

This article evaluates the existing institutional framework of the Ghana Gold Board (GoldBod) in view of the notable achievements made in 2025 and suggests reforms aimed at ensuring the sustainability of these accomplishments within a contemporary governance structure for the extractive sector. Although GoldBod has significantly aided in boosting gold exports, enhancing foreign exchange inflows, improving traceability, and formalizing artisanal and small-scale mining (ASM), its current arrangement merges regulatory responsibilities with commercial activities, leading to medium- to long-term concerns regarding conflicts of interest, diminished competition, lack of transparency, and insufficient checks and balances. Drawing on Ghana’s petroleum and power sub-sector governance models and international best practice from Botswana, Canada, South Africa, and Norway, this article recommends a clear separation of functions whereby regulatory authority is vested in the Minerals Commission or a new independent gold regulator, while GoldBod is restructured to operate strictly as a commercial off-taker and exporter of gold.

Gold continues to be Ghana’s most vital mineral export, serving as a key source of foreign exchange, government revenue, and job opportunities. In light of ongoing issues such as gold smuggling, loss of revenue, inadequate traceability, and fragmentation in the artisanal and small-scale mining (ASM) sector, the government created GoldBod to centralize gold aggregation, enhance price realization for miners, and bolster state involvement in gold marketing and exports.

In the reviewed year, GoldBod’s activities led to increased gold exports, improved foreign exchange inflows, greater participation of miners in formal markets, and enhanced oversight of gold production and export processes, thus aiding macroeconomic stabilization efforts. Nevertheless, as the organization shifts from short-term corrective measures to long-term governance of the sector, it is essential to evaluate whether the current institutional framework meets modern governance standards.

Assessment of current structure

The current responsibilities of GoldBod include licensing market participants, enforcing compliance, purchasing gold, aggregating it, and exporting, which effectively merges regulatory oversight with commercial activities within one organization. This consolidation of roles leads to inherent conflicts of interest, as GoldBod must regulate and discipline entities in the same market where it acts as a major buyer and exporter, thereby compromising regulatory impartiality and diminishing market trust.

Additionally, this structure poses a risk to competition, as private buyers, aggregators, refiners, and exporters may be deterred from investing or expanding in a market dominated by a state-supported entity that manages market access and enforcement while also pursuing its own business goals. Furthermore, transparency and accountability are limited because the mechanisms for pricing, off-take agreements, export volumes, and enforcement decisions are integrated.

Comparative international experience

Global examples show that nations that have effectively optimized long-term value from extractive resources have embraced governance frameworks that distinctly differentiate policy development, regulation, and business activities.

In Botswana, the government institutions are responsible for regulatory oversight of the diamond industry, while Debswana, a profit-driven joint venture, functions under company law free from regulatory control, promoting transparency, accountability, and ongoing value retention.

In Canada, robust independent provincial authorities manage licensing, environmental adherence, and enforcement, while private or state-associated entities conduct commercial mining and trading activities solely under commercial conditions.

In South Africa, the Department of Mineral Resources and Energy oversees mineral regulation, while both state-owned and private mining and trading companies function independently within the regulatory system, enhancing role clarity and institutional responsibility.

In Norway, governance of extractive resources is organized with distinct roles, where policy is managed by the Ministry, regulation is overseen by the Norwegian Petroleum Directorate, and commercial involvement is conducted by Equinor, the state-owned enterprise functioning purely as a business entity, a framework commonly viewed as a global best practice.

Ghana has implemented this governance framework in the petroleum sector, with the Petroleum Commission acting as the independent regulator and GNPC functioning as the state’s commercial entity, and similarly in the power sector, where regulation is distinct from commercial activities

 Suggested policy strategy

Distinction between Regulatory and Commercial Roles

The government must implement a contemporary governance model for the gold industry that distinctly differentiates regulatory supervision from commercial activities, in line with global best practices and Ghana’s past experiences in other critical sectors.

Oversight by the Minerals Commission or Autonomous Authority

The authority for gold regulation should either be granted to the Minerals Commission, according to its constitutional mandate or to a newly created independent regulatory body specifically for gold, solely tasked with licensing, compliance oversight, enforcement, and traceability throughout the gold value chain.

GoldBod as an Exclusively Commercial Off-Taker

GoldBod must be maintained and enhanced as a state-owned commercial off-taker and exporter of gold, prioritizing aggregation, value addition, transparent pricing, and international marketing, without any licensing, regulatory, or enforcement authority

Anticipated policy results

Preserve and consolidate the economic gains achieved by GoldBod

Separating roles safeguards the financial and macroeconomic gains already realized by GoldBod by preventing distortions that arise when a single institution both regulates and trades. With GoldBod’s commercial arm focused purely on efficient gold aggregation, value maximization, and export performance while an independent regulator ensures fair rules, the system becomes more resilient, predictable, and scalable. This separation reduces operational inefficiencies, revenue leakages, and policy reversals, thereby consolidating fiscal revenues, foreign exchange inflows, and benefits to small-scale producers.

Eliminate conflicts of interest and restore regulatory neutrality

Clear institutional separation removes the inherent conflict where GoldBod would otherwise regulate competitors while simultaneously operating as a market participant. An independent regulator can enforce licensing, pricing, compliance, and export rules impartially, without incentives to favor GoldBod’s trading interests. This restores regulatory neutrality, strengthens rule enforcement, and ensures that all actors including state-linked or private operate on equal terms.

Promote competition and private sector participation

When regulatory power is detached from off-taking and exporting, private firms gain confidence that market access, licensing, and compliance decisions will not be biased. This opens space for qualified private aggregators, refiners, logistics providers, and exporters to enter or expand within the gold value chain. Increased competition drives efficiency, innovation, better pricing for producers (especially ASM operators), and reduced dependence on a single buyer or exporter.

Strengthen transparency, accountability, and oversight

Distinct mandates make it easier to track performance, financial flows, and compliance outcomes. Regulators can be held accountable for enforcement quality and sector governance, while GoldBod’s commercial arm can be audited strictly on trading efficiency, pricing, and export revenues. This clarity strengthens parliamentary oversight, audit processes, and public reporting, reducing opportunities for rent-seeking, opaque pricing, or preferential treatment.

Enhance investor confidence and international credibility

Investors, development partners, and international bullion markets place high value on institutional clarity and regulatory independence. Separating GoldBod’s commercial and regulatory roles signals commitment to best practice, reduces perceived political and operational risk, and improves confidence in Ghana’s gold governance framework. This can lower transaction risk premiums, improve access to international markets and financing, and strengthen partnerships with refiners, buyers, and multilateral institutions.

Align gold sector governance with modern extractive-sector standards

The separation aligns the gold sector with global norms applied in oil, gas, and mining jurisdictions, where regulators set and enforce rules while state-owned or private entities operate commercially. This alignment supports compliance with international transparency and governance standards (e.g., EITI principles, OECD guidance), facilitates benchmarking against peer countries, and modernizes Ghana’s gold sector architecture for long-term sustainability.

 Legal and execution factors

Executing the suggested policy direction will necessitate modifications to the GoldBod Act to distinctly outline regulatory and commercial responsibilities, along with transitional measures to guarantee operational continuity and safeguard recent economic advancements

Concluding remarks and policy suggestions

This article finds that although GoldBod’s existing framework has successfully achieved short-term economic stabilization and sectoral formalization, maintaining these benefits and setting Ghana’s gold sector up for long-term prosperity demands adherence to contemporary extractive-sector governance standards.

It is thus suggested that the Government modifies the GoldBod Act to distinguish regulatory from commercial roles, assign regulatory power to an independent entity, and reestablish GoldBod as solely a commercial off-taker and exporter, aligning with Ghana’s governance frameworks in the petroleum and power sectors and adhering to global best practices.

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