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Energy, Extractives & Infrastructure 

Following the political transition after the 2024 general elections, 2025 was marked by the operationalisation of policy priorities and implementation of key reforms. As forecasted in our 2025 Outlook, the year saw significant fiscal, policy, legal and regulatory shifts across the energy, extractives and infrastructure sectors.

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Energy and Extractives

Consistent with our 2025 Outlook, the Ghana Gold Board (GoldBod) was established to regulate the gold trading and marketing, in relation to artisanal and small-scale mining (ASM). Further, the ownership dispute over the Bogoso/Prestea mine continued, with Blue Gold escalating the dispute against government to international arbitration. Several legacy initiatives were sustained, including the Scaling-Up Renewable Energy Programme (SREP), which aims to inject 100MW of renewable power into the national grid for small and medium-sized energy users and the Petroleum Hub project which aims to establish Ghana as a leading downstream petroleum and petrochemical hub. A number of decarbonisation projects also began, including the Jospong Group’s composting, landfill gas recovery and clean cooking initiatives which were integrated with the Ghana Carbon Registry, and UpEnergy’s rollout of modern cooking technologies across Ghana supported by the World Bank’s USD 200 million Clean Cooking Outcome Bond. The country reached a major milestone in the fight against climate change by transferring 11,733 tons of carbon credits to Switzerland, becoming the first African country to issue credits compliant with the Paris Agreement. However, some anticipated developments, such as the acquisition by the Minerals Income and Investment Fund (MIIF) of a stake in the operation of the Zijin Mining Group’s Akyem gold mine, and the development of the Pecan field, did not materialise. The realignment of the MIIF’s mandate and the reduction of its revenue stream largely contributed to the abandonment of the plans to acquire the interests in the Akyem mine. In the case of the Pecan field, the pending sanctions against Russia and, subsequently, Lukoil (among other factors) may have contributed to the inability of the joint venture partners to raise funding for the proposed development.

 

Key developments during the year included:

  • the respective conclusion of landmark agreements between the government and the Jubilee/Tweneboa, Enyenra, and Ntomme (TEN) partners, and the government and the Offshore Cape Three Points (OCTP) partners in connection with USD 2bn and USD 1.5 bn renewed investments and licence extensions;

  • the termination by the Bank of Ghana (BoG) of the Gold for Oil programme, which was on the back of its gold purchase programme introduced to provide foreign exchange financing for the importation of petroleum products;

  • the rebranding of the Bulk Energy Storage and Transportation Company Limited as BOST Energies, enabling expansion into renewable and alternative energy;

  • the disciplined implementation of the cash waterfall mechanism, renegotiation of all power purchase agreements with Independent Power Producers (IPPs) and improvement in payments to IPPs, alongside renewed efforts to restructure the electricity sector and increase private sector participation in power distribution;

  • the launch of the Responsible Cooperative Mining and Skills Development Programme (rCOMSDEP), a government initiative aimed at formalising and transitioning ASM operations into a transparent, mercury-free, responsible community-centred mining backed by a national network of centralized processing facilities. The rCOMSDEP replaces the Community Mining Scheme and the National Alternative Employment and Livelihood Programme introduced by the previous government;

  • an intensified crackdown on illegal mining, including the revocation of over 300 mining licences for regulatory non-compliance;

  • Newmont’s achievement of commercial production at its Ahafo North project, projected to produce between 275,000 and 325,000 ounces of gold annually over a 13-year mine life;

  • the acquisition of Azumah Resources’s Black Volta and Sankofa gold concessions by Engineers & Planners, marking the first indigenous Ghanaian-owned large-scale mine;

  • completion of the drilling phase of Ghana's first-ever Mineral Resource Estimation (MRE) for iron ore at the Gyamurume Iron Ore Block in the Oti Region by Africa Exploration and Minerals Group LTD, a wholly owned Ghanaian exploration company;

  • discovery of potentially mineable nickel deposits during iron ore exploration at Gyamurume by the Ghana Integrated Iron and Steel Development Corporation (GIISDEC) and the Ghana Geological Survey Authority; and

  • Ghana’s issuance of its first Forest Law Enforcement, Governance and Trade (FLEGT) licence, positioning the country as the first in Africa and second globally to export timber to the EU under strict legality standards.

 

Infrastructure sector

Developments in the infrastructure sector similarly reflected continuity of the government’s programmes and initiatives. As forecasted in our 2025 Outlook, the government’s “Big Push” infrastructure programme (the USD 10 billion national infrastructure development programme geared towards boosting economic growth and creating sustainable jobs) (the Big Push Infrastructure Programme), largely shaped developments in the sector in 2025 with a strong emphasis on road infrastructure. Work initially covering 33 road projects including the dualisation of the Winneba-Mankessim road and the Cape-Coast-Takoradi road, with the Accra-Kumasi Expressway and the Ekye Amanfrom-Adawso Bridge later added. In the 2026 State of the Nation Address (2026 SONA), the President disclosed that work had started on 50 major road projects covering over 1,100 km and that the government is completing 23 road projects inherited from the previous administration.

In October 2025, the President launched the Ghana Infrastructure Plan (the GIP), a comprehensive 30-year strategy designed to end the country's longstanding pattern of abandoned and politicised projects while establishing a coordinated framework for national development. The GIP, developed by the National Development Planning Commission, is built around 9 strategic pillars relating to energy, water, transport, human settlements and housing, and serves as the infrastructure arm of Ghana's 40-year national development plan. The Big Push Infrastructure Programme, serves as the first implementation phase of the GIP.

Also, some programmes initiated under the previous administration were sustained, with the government indicating its commitment to complete 10 abandoned Agenda 111 projects. The President also launched the Advance Passenger Information (API)/Passenger Name Record (PNR) System at international airports.

Other significant developments included:

  • budget allocation of GHS 13.85 billion for infrastructure development;

  • award of road contracts worth GHS 63 billion under the Big Push Infrastructure Programme;

  • commissioning of phases I and II of the USD 1.5 billion Tema Port Expansion Project;

  • securing of a 3 billion Japanese Yen (about USD 20 million) grant from the Japan International Cooperation Agency to upgrade the Inner Ring Road in Kumasi;

  • signing of memorandum of understanding between PKA Export and Import, a Ghanaian company, and two Chinese firms, Polyrocks and Sinovcle, to construct an electric vehicle assembly plant in Ghana;

  • securing of USD 1 billion by the Minister of Energy and Green Transition, for climate financing to be used for key projects, such as the SREP, the Forest Carbon Partnership Facility, as well as developing a project pipeline through the Green Climate Fund and the Ghana Climate Innovation Centre;

  • announcement of the government’s plans to construct a new gas processing facility to supplement the existing Atuabo Gas Processing Plant;

  • suspension by the President of Ghana of ongoing and pending State land transactions except searches and processing of applications relating to leases granted before 2017, which suspension has since been lifted;

  • commencement of plans to build a state-owned gold refinery at the Accra International Airport;

  • Cabinet approval of the reintroduction of road and bridge tolls with a modern electronic system without physical barriers on roads;

  • completion of Phase II of the Tamale Airport expansion, including new cargo and Hajj facilities, and Phase I of the Takoradi Dry Bulk Terminal; and

  • launching of the Methodology for Assessing Procurement Systems Assessment (MAPS) by the Public Procurement Authority in collaboration with the Ministry of Finance and the World Bank, to strengthen public procurement systems.

 

New Laws

As anticipated, the Environmental Protection (Mining in Forest Reserves) Regulations, 2022 (LI 2462), together with the Environmental Protection (Mining in Forest Reserves) (Amendment) Regulations, 2025 (LI 2501), were revoked by the Environmental Protection (Mining in Forest Reserves) (Revocation) Instrument, 2025 (LI 2515).

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In addition, the following sector-relevant laws came into force in 2025:

  • Environmental Protection Act, 2025 (Act 1124) (Environmental Protection Act) – amends and consolidates laws relating to environmental protection; establishes the Environmental Protection Authority (EPA) to regulate and protect the environment; provides for pesticide control and regulation; provides for the control, management and disposal of hazardous, electrical and electronic waste; provides for the co-ordination of climate change responses; and provides for related matters. The Environmental Protection Act also establishes the Ghana Carbon Registry and the Carbon Market Committee, tasked, among other responsibilities, to facilitate and oversee carbon market projects;

 

  • Growth and Sustainability Levy (Amendment) Act, 2025 (Act 1131) - amends the Growth and Sustainability Levy Act, 2023 (Act 1095) by extending the application period of the growth and sustainability levy (the GSL) to 2028, and increasing the GSL rate for mining companies and upstream oil and gas companies from 1% to 3% of gross production;

 

  • Energy Sector Levies Act 2025 (Act 1135) - consolidates existing energy sector levies to promote prudent and efficient utilisation of proceeds, addressing energy sector shortfall payments and legacy debts. The energy sector levies include the energy sector shortfall and debt repayment levy, road fund levy and the energy fund levy, which are imposed on certain petroleum products such as petrol and diesel;

 

  • Minerals Income Investment Fund (Amendment) Act, 2025 (Act 1137) - amends the Minerals Income Investment Fund Act, 2018 (Act 978) to provide for the transfer of minerals income to the Minerals Income Holding Account and related matters;

 

  • Petroleum Revenue Management (Amendment) Act, 2025 (Act 1138) - amends the Petroleum Revenue Management Act, 2011 (Act 815) (PRMA Act) to provide for the Annual Budget Funding Amount to be used for infrastructure development and provide for related matters;

 

  • Public Procurement (Amendment) Act, 2025 (Act 1139) - amends the Public Procurement Act, 2003 (Act 663) to require a commitment authorisation issued by the Minister of Finance to accompany a procurement funded by central government (aiming to prevent unauthorised spending and ensure budget compliance) and for related matters;

 

  • Ghana Gold Board Act, 2025 (Act 1140) - establishes the GoldBod to oversee, monitor, and undertake the buying, selling and export of gold (excluding gold produced by large scale mining companies); promote value addition to Ghana’s gold and other precious minerals; support responsible mining and the accumulation of gold reserves by the BoG; generate foreign exchange; and provide for related matters;

 

  • Energy Sector Levies (Amendment) Act, 2025 (Act 1141) - increases the energy sector shortfall and debt repayment levy rate to raise additional revenue, supporting payment of energy sector shortfalls, reducing energy sector legacy debts owed to independent power producers and other stakeholders, and stabilising power supply;

 

  • Fisheries and Aquaculture Act, 2025 (Act 1146) - reviews and consolidates the laws relating to the sustainable exploitation of fisheries resources, establishes the Fisheries Commission to ensure long-term conservation, development, management and utilisation of fisheries and aquaculture resources, contributes to the attainment of a sustainable blue economy, and provides for related matters. It provides for the requirement to notify the Fisheries Commission prior to commencement of activities which, though not directly related to fishing, may have a substantial impact on fishery resources;

 

  • Road Maintenance Trust Fund Act, 2025 (Act 1147)– establishes the Road Maintenance Trust Fund to provide sustainable financing for the maintenance and rehabilitation of public roads, bridges and related infrastructure in the country, provides for related matters;

 

  • Petroleum Revenue Management (Amendment) (No.2) Act, 2025 (Act 1155) - amends the PRMA Act to expand the definition of "qualifying instrument" in which the Ghana Petroleum Funds and subsequently the Ghana Petroleum Wealth Fund may be invested, to include other qualifying instruments prescribed by the Minister for Finance by Executive Instrument;

 

  • Environmental Protection (Environmental Assessment) Regulations, 2025 (LI 2504) – seeks to (a) protect the environment through the environmental assessment process; (b) promote sustainable development; (c) mainstream climate change and other emerging issues into the environmental assessment process; (d) promote and integrate public participation into the assessment process; and (e) facilitate sustainable decision-making process of the EPA;

 

  • Environmental Protection (Management of Ozone Depleting Substances, Halocarbons, Halocarbon Alternatives and Products) Regulations, 2025 (LI 2505) – seeks to amongst others, (a) manage ozone depleting substances, halocarbons, halocarbon alternatives, and the products of ozone depleting substances, halocarbons and halocarbon alternatives in the country; (b) provide relevant requirements and directions regarding amongst others, the production, release, servicing, and importing, of man-made chemicals that deplete the stratospheric ozone layer of the earth and cause changes in the climate including chlorofluorocarbon hydrochlorofluorocarbons, halons and hydrofluorocarbons (Controlled Substances) and products containing Controlled Substances (Controlled Products); and (e)  address issues related to the commercial use of Controlled Substances and Controlled Products and the maintenance, handling and disposal of appliances containing Controlled Substances by a person;

 

  • Environmental Protection (Effluent) Regulations, 2025 (LI 2506) – aims to (a) control effluent discharges into the environment to protect the environment and public health; (b) ensure that releases and discharges of harmful substances from an activity into the environment comply with the requirements specified in the Ghana Standards Authority’s Ghana Standard for Environmental Protection - Requirements for Effluent Discharge (GS 1212) as may be revised from time to time; and (c) enable the EPA to collaborate with key stakeholders in the control of effluent discharges into the environment in order to protect the environment and public health;

 

  • Environmental Protection (Air Quality Management) Regulations, 2025 (LI 2507)– seeks to improve air quality in the country by among others, ensuring compliance with the requirements for monitoring and reporting on air quality of an undertaking;

 

  • Public Private Partnership Regulations, 2025 (LI 2511)– seeks to provide for amongst others, (a) the obligations of contracting authorities; (b) the public private partnership process; (c) the procedures for the application of the margin of preference for domestic business; (d) the procedures for procurement through the Ghana Infrastructure Investment Fund; (e) the procedures for unsolicited proposals or private sector led proposals; (f) a complaints procedure; (g) the management of the Project Development Facility and Viability Gap Facility; (h)  the establishment and use of a special purpose entity for a public private partnership project; (i) contract management and amendment; (j) early termination payments; (k)  transparency, disclosure and reporting obligations and accountability mechanisms; (l) controls and limitations imposed on the regulated entity governed by the Act; and (m) guidance on provisions to mainstream climate considerations into the different phases of the public private partnership project cycle; and

 

  • Public Procurement (Thresholds for Approving Authorities and Procurement Methods) Regulations, 2025 (LI 2516) – aims to increase the thresholds in the Second, Third and Fifth Schedules of the Public Procurement Act 2003 (Act 663).

As Ghana enters 2026, the Big Push Infrastructure Programme, the discipline imposed by the ongoing IMF programme (notwithstanding the impending exit), the accelerating global energy transition, and the proposed programmes and projects in the 2026 Budget Statement and Economic Policy (the 2026 Budget) are set to redefine the trajectory of the energy, extractives and infrastructure sectors. The following outlook highlights where commercial opportunities are likely to emerge and the anticipated legal, regulatory and policy developments.

Contacts

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Managing Partner 

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