Ghana’s plans to place the country’s gas aggregation business under the Ghana National Gas Limited Company (GNGLC) continue to face scrutiny, with the Ghana Extractive Industries Transparency Initiative (GHEITI) calling for the arrangement to be reconsidered.
GHEITI says the 2020 government directive that gave GNGLC the national gas aggregator role has never been fully implemented, while the legal framework and existing commercial agreements still leave the Ghana National Petroleum Corporation (GNPC) with the formal mandate.
The issue goes beyond which state-owned company should sell Ghana’s gas. It touches on who carries the financial and contractual risks of securing gas supplies, developing infrastructure and maintaining confidence among upstream investors and power-sector users.
In its 2023 Oil and Gas Report, GHEITI recommended that the government withdraw the directive. If it still wants GNGLC, or another institution, to take over the role, it says the relevant legislation should first be amended.
The disagreement is not new. It dates back to an earlier attempt to reorganise Ghana’s gas industry and determine where responsibility for aggregating and commercialising the country’s gas should sit.
A policy decision that never fully took shape
On May 11, 2020, Cabinet directed that GNGLC be assigned the national gas aggregator role, expanding its responsibilities beyond gas processing and positioning the company to aggregate, market and sell natural gas.
But the change was never fully operationalised.
According to GHEITI, GNGLC became involved in negotiations for the Jubilee Post-Foundation Gas Sales Agreement with Tullow Ghana and other Jubilee partners. However, the existing Gas Sales Agreements remained with GNPC.
Those agreements were signed before the 2020 Cabinet decision and have not been transferred to GNGLC.
As a result, GNPC continues to perform important gas marketing and sales functions, leaving the institutional arrangement between the two state entities incomplete.
For GHEITI, this creates more than an administrative problem.
The existing legal framework gives GNPC the gas aggregation mandate. Assigning that responsibility to another entity through a Cabinet directive, without amending the relevant legislation, effectively leaves policy and law pointing in different directions.
GHEITI therefore wants the government either to withdraw the directive or formally amend the law if it remains committed to changing the aggregator.
The debate goes back years
The institutional question has been part of Ghana’s gas-sector development almost from the beginning of commercial oil production.
Ghana’s initial approach was for GNPC to play a leading role in commercialising the country’s associated gas. That direction changed after the establishment of the Ghana Gas Company, which was expected to take a more prominent role in processing and commercialising gas.
The change, however, brought its own challenges, particularly around financing and infrastructure development.
In 2015, the government approved the takeover of Ghana Gas by GNPC as a subsidiary, partly to strengthen coordination and financing across the petroleum value chain.
The arrangement was subsequently implemented in July 2016, but lasted only about five months before it was abandoned following a change of government.
The institutional question therefore remained unresolved.
The Gas Master Plan had also recommended a structure in which Ghana Gas would operate as a subsidiary of GNPC, with GNPC retaining the aggregator function. The idea was to improve coordination and provide a stronger institutional platform for investment in gas infrastructure.
ACEP raised similar concerns in 2020
When the issue resurfaced in 2020, the Africa Centre for Energy Policy (ACEP) questioned the decision to move the aggregator role from GNPC to Ghana Gas.
ACEP argued at the time that becoming the national aggregator would expose Ghana Gas to significant financial and contractual obligations at a point when its balance sheet and financing capacity were already concerns.
The aggregator role is not simply about buying and selling gas. It can involve entering long-term supply agreements, guaranteeing payments, financing infrastructure and absorbing risks when gas producers or downstream buyers are unable to meet their obligations.
ACEP pointed to the Sankofa-Gye Nyame and Offshore Cape Three Points (OCTP) development as an example of the financial pressures that can arise.
GNPC had initially been expected to provide financial backing for aspects of the project, but changing conditions affected its ability to access planned financing. Project partners eventually provided financing on GNPC’s behalf, with the exposure recovered through GNPC’s oil liftings.
ACEP’s argument was that placing a similar level of exposure on a financially weaker entity could create wider risks for gas supply and the power sector.
That concern was particularly significant because gas from OCTP has become an important source of fuel for Ghana’s power generation.
Financial pressure adds another layer
The financial position of GNGLC has since made the question of institutional responsibility even more consequential.
The Public Interest and Accountability Committee (PIAC), while it has not specifically taken a position against GNGLC becoming the national gas aggregator, has observed the company’s debt exposure as a risk to the wider energy sector.
PIAC’s 2025 Annual Report put GNGLC’s outstanding debt at about US$620.54 million, although this represented a marginal reduction. The committee also identified tariff distortions and weak pricing structures as continuing risks to revenue recovery and stability across the gas-to-power value chain.
The debt problem is not entirely new. PIAC’s 2023 report showed that GNGLC’s indebtedness to GNPC had risen to about US$604.05 million at the end of 2023 and warned that continued growth could pose a serious risk to the energy sector.
By June 2024, the debt had climbed further to about US$626.74 million, according to PIAC’s 2024 semi-annual report, with the committee attributing much of the increase to challenges in payments for gas supplied to the power sector.
The figures do not by themselves settle the question of who should be Ghana’s gas aggregator. But they underline the financial weight of the role and the risks that could arise if additional contractual and commercial responsibilities are transferred to an entity already carrying substantial obligations.
Why the aggregator role matters
At the centre of the debate is the structure through which Ghana moves gas from producers to the companies and institutions that need it.
The aggregator sits between upstream gas producers and downstream users, making decisions that affect supply security, pricing, contracts and payments.
That makes the institutional choice important not only for the companies involved but also for electricity generation and industrial users that depend on reliable gas supplies.
A weak aggregator could struggle to honour contracts or finance infrastructure. A poorly designed arrangement could also complicate relationships with upstream investors, particularly where existing agreements require the consent of producers before contracts can be transferred.
This was one of ACEP’s concerns when the 2020 directive was announced. It argued that existing gas contracts could not simply be moved from GNPC to Ghana Gas through an administrative decision because contractual novation would require the agreement of the affected parties.
The bigger question for government
The latest GHEITI recommendation therefore reopens an institutional debate that Ghana has been unable to settle for more than a decade.
The question is no longer simply whether GNGLC should become the national gas aggregator. It is whether Ghana has the legal framework, financial capacity and commercial arrangements needed to make whichever model it chooses work.
For GHEITI, the starting point is clear: government must bring the law into line with its policy.
If GNPC is to remain the aggregator, the 2020 directive should be withdrawn. If GNGLC or another institution is to take over, Parliament should amend the relevant legislation and the necessary commercial and contractual arrangements should follow.
Until then, Ghana’s gas sector will continue to operate with an unresolved divide between the institution that the law recognises as aggregator and the institution government has sought to give that responsibility.
That gap, GHEITI’s findings suggest, is becoming increasingly difficult to ignore as Ghana confronts the financial, infrastructure and supply challenges running through its gas-to-power value chain.
