IMANI Center for Policy and Education has filed what can be described as a comprehensive Right to Information (RTI) request to the Ministry of Communications and Digital Technologies, seeking to demand transparency in the new SIM Registration exercise.
The RTI request cited by The High Street Journal, among other things, seeks to expose alleged anti-competitive practices and questionable authorizations surrounding the planned nationwide SIM registration exercise.
Among the interesting requests, the policy think tank is focused heavily on the role of a specific private entity, Transactly Limited, and is forcing the Ministry to answer three highly contentious questions that strike at the heart of public trust, digital infrastructure, and national identity security.

The request seeks to uncover issues such as the following;
The Monopoly Threat: Are Telcos Being Forced to Contract?
Critical analysis of IMANI’s application highlights a major fear, which suggests that the government is paving the way for a monopoly in the crucial SIM registration ecosystem.
The organization is demanding all records detailing whether telecommunications operators (telcos) will be compelled to connect to, integrate with, or contract with a designated platform or vendor (including, but not limited to, Transactly).
Additionally, IMANI is looking for documents discussing whether any private party will be granted exclusive rights or de facto exclusivity concerning any part of the registration solution.

The Authorization: Who Approved the Biometric Vendor?
While the Ministry might claim that contracts for the new biometric verification systems are strictly between the telcos and the private vendor, IMANI has bypassed this potential defense.
The Center is specifically requesting the Ministry’s “No Objection” letter or policy document that authorized the selection of said vendor as an approved contractor or provider for national biometric verification.
This insightful demand suggests that even if the government is not signing the contract directly, it must have provided official authorization for the selection of any private entity dealing with Ghana Card-based identity verification.
The Weird Demand: Why is a Private Firm Using the Ghana Coat of Arms?
Perhaps the most unusual and striking demand relates to the use of national symbols by Transactly. IMANI is demanding all records relating to any authorization, approval, or correspondence concerning Transactly’s use of the Ghana Coat of Arms and of official Ministry, Department, or Agency (MDA) logos on any web portal or mobile application.
The think tank is specifically asking for the legal basis used to grant such authorization, and whether any internal complaints, queries, or concerns were raised about a private entity using official state insignia.
IMANI asserts that the need for transparency overrides commercial sensitivities because the integrity of the national biometric registry is a matter of paramount public interest, and any private entity performing functions mandated by state law should be subject to transparency obligations.

The Ministry now faces a statutory 14-day time limit to respond to these explosive demands.
Find the full details of the RTI Request below: