- Ghana’s GH¢21.88bn Gold Debate Needs Accounting, Not Accusations
The GH¢21.88 billion figure associated with Ghana’s Domestic Gold Purchase Programme is understandably alarming. In a country still recovering from a severe economic crisis, any suggestion that billions of cedis have been “lost” by a public institution will provoke anger, suspicion and legitimate demands for accountability.
But numbers, particularly accounting numbers, must be understood before blame is assigned. In our view at NorvanReports, the current public discussion has moved too quickly from the appearance of a large charge in the accounts to the conclusion that the Bank of Ghana somehow took GH¢21.88 billion of public money, traded it away, gave it to private gold buyers or simply presided over an avoidable commercial disaster.
That conclusion is not supported by the mechanics of the transaction as we understand them. There are legitimate questions to ask about the Domestic Gold Purchase Programme, GoldBod, pricing, fees, foreign-exchange policy, transparency and ultimately whether the total economic benefits justify the costs. But there is an equally important obligation to distinguish an accounting loss or exchange-rate differential from an actual cash loss, because the two are not synonymous.
The largest component of the reported GH¢21.88 billion is understood to arise from an exchange-rate gap effect associated with the way gold is purchased locally and subsequently recorded for accounting purposes. Gold is acquired in Ghana at market-linked cedi prices, while the dollar proceeds associated with the gold are eventually translated into the central bank’s accounts using an official exchange rate.
That differential can become very large when three things happen simultaneously: the amount of gold being purchased rises sharply, the exchange rate moves significantly during the period, and the local purchasing mechanism uses a market rate different from the rate employed for financial reporting.
Gold purchases under the programme increased from 56.47 tonnes in 2024 to 110.99 tonnes in 2025, almost doubling the scale of the transactions passing through the system. At the same time, the cedi appreciated by approximately 40.70%, producing an unusually large exchange-rate movement within the accounting period.
The result was a substantial accounting charge. That is very different from saying somebody took GH¢21.88 billion from the Bank of Ghana and lost it.
Imagine that gold is acquired locally using a cedi price derived from the market value of the dollar because miners know what their gold is worth internationally. If the buyer attempted to purchase that gold using an artificial exchange rate that substantially undervalued what the miner could obtain elsewhere, the miner would have an obvious incentive not to sell through the official system.
He could sell to another buyer, divert the gold into informal channels or, in the worst case, participate in smuggling. The gold purchasing system therefore operates inside a real market.
The authorities cannot pretend that the official accounting exchange rate is necessarily the rate at which every physical gold transaction can be competitively sourced from miners and aggregators.
The pricing framework is understood to have sought to keep local purchase prices sufficiently close to prevailing market conditions to discourage gold from leaving Ghana through unofficial channels. That objective is also tied to the statutory role created for the formal gold purchasing architecture.
This means the exchange-rate differential is partly the accounting expression of two different realities colliding. The first is the commercial reality at which gold must be competitively purchased from the domestic market.
The second is the financial-reporting reality under which those transactions must ultimately be translated and recognised in the accounts. When the cedi moves sharply, the distance between those two realities can become enormous.
For this reason, we believe it is inaccurate to describe the entire GH¢21.88 billion as though it were equivalent to cash physically leaving the Bank of Ghana without receiving anything in return.
The accounting treatment itself identifies the exchange-rate gap as an adjustment arising from the conversion of dollar gold proceeds into cedis rather than a cash expense representing a direct disappearance of public funds.
They affect the financial statements of the institution. They can weaken reported profitability and capital. They can raise legitimate questions about programme design, risk allocation and whether the central bank should be carrying particular types of quasi-commercial exposure on its own balance sheet.
But those are very different questions from accusing the institution of losing GH¢21.88 billion through recklessness.
Ghana must be mature enough to hold both ideas simultaneously. A transaction can impose a substantial accounting cost and still produce broader economic benefits. It can also produce economic benefits while still requiring reform.
And a programme can be strategically useful without every cost within it being optimal. The debate therefore cannot end with the phrase “it is only an accounting loss” any more than it should begin and end with the accusation “the Bank of Ghana lost GH¢21.88 billion”.
The more serious question is: what did Ghana receive in exchange for carrying these costs, and was the economic return worth it? That is the conversation policymakers, economists and Parliament should be having.
The Domestic Gold Purchase Programme was built around a relatively straightforward idea: Ghana produces substantial quantities of gold, yet historically a large portion of that gold leaves the economy while the country continues to struggle with foreign-exchange shortages.
Converting a greater share of domestic gold production into official foreign-exchange flows and reserve accumulation therefore has obvious strategic appeal.
If gold can be bought locally, exported formally, converted into foreign exchange and used to strengthen the country’s reserve position, the programme can help address one of Ghana’s most persistent macroeconomic vulnerabilities.
But the programme cannot be evaluated intelligently without considering its costs.
Those costs include assaying, procurement, logistics, insurance, refining, shipment, guarantees, marketing and the discount required when doré gold rather than fully refined bullion is sold into international markets.
Doré is not the same thing as London Good Delivery bullion. It requires additional processing before it becomes a fully marketable refined product, and somebody must bear the cost of transporting, securing, assaying and refining it. The fact that a discount exists therefore does not, by itself, establish wrongdoing.
The relevant question is whether the discount is competitive.
The information before us indicates that the offtake discount stood as high as 2.00% before 2025, was reduced to 1.30% during 2025 and has subsequently been lowered further to 1.00%. The move from a single-offtaker structure towards multiple approved offtakers is also said to have strengthened competition and reduced concentration risk.
If Ghana was paying 2.00% and can now achieve 1.00%, then there was clearly room to improve the economics of the programme.
That should not be interpreted as proof that the original arrangement was corrupt or improper.
It should instead encourage a more useful policy question: how much further can transaction costs be reduced?
The GoldBod assay charge reportedly moved from 0.25% before 2025 to 0.20%, and subsequently to 0.15%, while the service fee for procuring gold fell from 0.50% to 0.40% during 2025 and later to 0.20%.
Again, those reductions are important. They show that the cost structure is not immutable.
The question should not merely be: “Who caused the GH¢21.88 billion loss?” It should also be: “Which elements of the cost were unavoidable, which were policy choices, which were accounting consequences, and which can be reduced going forward?” Those questions would produce far more value for Ghana than the current political temptation to identify a villain.
The Bank of Ghana should not automatically become that villain simply because the accounting effects eventually appear on its books.
The institution sits at the end of a chain involving miners, aggregators, GoldBod, assaying, transport, refining, international offtakers, foreign-exchange conversion and financial reporting.
Assigning the entire economic outcome to one institution ignores the structure of the transaction. Indeed, one of the most important issues arising from this debate is whether a central bank should carry all these commercial and exchange-rate exposures in the first place.
A central bank exists primarily to preserve monetary and financial stability. When it begins participating in large-scale commodity purchasing arrangements for broader national policy objectives, its balance sheet can become the place where the cost of those policies ultimately appears.
But it does mean Ghana must decide transparently who should bear the cost of national strategic interventions.
If government wants gold purchased at commercially competitive rates because doing so discourages smuggling, generates foreign exchange and strengthens reserves, then part of the resulting cost may properly be understood as a public-policy cost rather than simply a central-bank trading failure.
That distinction becomes particularly important when exchange-rate policy is involved.
Suppose the central bank uses its official reporting rate while the gold market effectively prices transactions closer to the prevailing market or forex-bureau rate.
The resulting accounting gap is not created because an official woke up one morning and decided to lose money. It emerges from the difference between the price required to secure the commodity and the rate required for accounting recognition. If the cedi then appreciates sharply, the effect can become magnified.
That is why the approximately 40.70% appreciation recorded during the period is so important to understanding the GH¢21.88 billion figure.
A currency appreciation is ordinarily something Ghana celebrates. It lowers the cedi cost of imports, eases inflationary pressure and can improve confidence.
Yet the same appreciation can generate adverse accounting consequences for an institution holding or converting foreign-currency assets.
That apparent contradiction demonstrates why central-bank financial statements cannot always be interpreted in the same way as the accounts of an ordinary commercial company.
A commercial bank exists principally to generate profits for shareholders. Its interventions may deliberately impose financial costs in order to achieve monetary, exchange-rate or financial-stability objectives. That does not grant it immunity from accountability.
If the central bank sells foreign currency during a crisis and subsequently the currency appreciates, accounting outcomes may emerge that look unattractive in isolation while the intervention itself helped prevent disorderly market conditions.
If it purchases gold to build reserves at a time when the domestic gold market is pricing off market exchange rates, it may similarly absorb accounting effects that reflect the mechanics of the policy. The correct question is whether the intervention achieved its intended objective at a reasonable cost.
This is where the current debate should now move.
- We should ask how much foreign exchange was generated by the programme.
- We should ask how much reserve accumulation resulted from it.
- We should ask whether gold smuggling was reduced.
- We should ask whether formal gold exports increased.
- We should ask whether the Bank of Ghana’s reserve position became stronger because of the gold programme.
And we should place those benefits alongside the complete cost. Only then can Ghana calculate the programme’s true economic return. A GH¢21.88 billion accounting charge viewed without those benefits tells only one side of the story.
Equally, billions of dollars in gold exports quoted without accounting for the costs of acquiring and monetising that gold would tell only the other side.
Gold offtakers are entities that purchase the exported doré under agreed commercial arrangements. The framework requires prospective buyers to undergo Know Your Customer procedures and enhanced due diligence before onboarding, although their identities are treated as commercially confidential.
This is an area where public confidence must be handled carefully. Commercial confidentiality is legitimate, particularly in commodity markets.
But confidentiality cannot become a substitute for accountability. Even if names cannot appropriately be broadcast publicly, the relevant oversight institutions should be able to establish that counterparties were competitively selected, properly vetted, commercially credible and operating on terms consistent with international markets.
The public does not necessarily need every commercial detail. It does need confidence that the system has been independently tested.
This is particularly important because large numbers naturally generate suspicion. If billions of cedis appear as costs while counterparties remain anonymous, it is entirely predictable that people will ask questions.
The solution is not to dismiss those questions. It is to strengthen assurance.
Audit institutions, Parliament and legally empowered oversight bodies should be able to scrutinise the processes without destroying commercially sensitive relationships.
That is what mature financial governance looks like. The same principle applies to the discount. The fact that transporting, refining and marketing doré involves costs is indisputable.
But Ghana should still benchmark those costs continuously against comparable international transactions.
A discount that was commercially reasonable yesterday may become excessive tomorrow if competition improves or domestic refining capacity changes.
Indeed, reducing the discount from 2.00% to 1.30% and eventually 1.00% suggests precisely why active renegotiation matters. Every fraction of a percentage point becomes significant when multiplied across billions of dollars of gold.
The next stage of reform should therefore focus aggressively on cost compression.
- Can more gold be refined domestically?
- Can freight and insurance costs be pooled or competitively tendered?
- Can settlement periods be shortened?
- Can technology reduce assaying costs?
- Can multiple offtakers compete more aggressively?
- Can domestic financing structures reduce the amount of central-bank balance-sheet exposure?
These are the questions capable of saving Ghana real money. There is another uncomfortable question. Should commercial banks eventually finance a larger portion of domestic gold purchases rather than relying heavily on the central bank?
If private financial institutions can provide the cedi liquidity required to purchase gold while the central bank concentrates on reserve management and settlement, some of the commercial exposure currently appearing on the central bank balance sheet could potentially be redistributed.
- Such a transition would require careful design.
- Commercial banks would demand returns.
- They would price risk.
- They would require security and predictable settlement.
- The structure could therefore become more expensive in some respects.
But the broader principle deserves examination: a national gold strategy does not automatically require the central bank to carry every financial risk associated with buying gold. This is where critics of the Bank of Ghana have a legitimate opening, but not necessarily the one currently dominating the debate.
The strongest criticism is not that the Bank “lost GH¢21.88 billion”. The stronger argument is that Ghana should continually ask whether the current institutional architecture places risks on the appropriate balance sheet. That is a much more sophisticated question.
Persistent losses can weaken institutional independence, create recapitalisation needs and eventually generate fiscal consequences.
Even accounting losses that do not represent immediate cash outflows should therefore not be casually dismissed.
The fact that a charge is non-cash does not mean policymakers should be indifferent to it.
But neither does a non-cash accounting charge justify accusations of theft, waste or commercial incompetence without evidence.
Ghana’s economic debate is too often damaged by our tendency to turn complex financial questions into binary political arguments.
Either the programme is presented as a miraculous success that saved the cedi, or it is presented as a GH¢21.88 billion scandal.
The gold programme can simultaneously have contributed to stronger foreign-exchange inflows and reserve accumulation while imposing substantial financial and accounting costs.
GoldBod can have improved formalisation and bargaining power while still requiring stronger transparency.
The Bank of Ghana can have implemented a legitimate macroeconomic strategy while still needing to reconsider how risks are structured. There is no contradiction in any of these positions. What Ghana needs is a consolidated economic assessment.
- We need to know the gross value of gold purchased.
- We need to know the foreign exchange realised.
- We need to know the full costs.
- We need to separate cash costs from accounting adjustments.
- We need to identify how much value was retained as reserves.
- We need to measure the effect on smuggling, official exports and foreign-exchange liquidity.
- And we need to examine what would have happened under the alternative.
- That final point is particularly important.
- Economic policy must be evaluated against a counterfactual.
- What would Ghana’s foreign-exchange position have looked like if the gold had not been formally purchased?
- Would miners have sold through official channels anyway?
- Would the dollars have entered the formal financial system?
- Would smuggling have been higher?
- Would reserves have been weaker?
- Would the cedi have faced greater pressure?
No honest analysis can answer those questions perfectly.
But they must at least be considered.
It is intellectually weak to count the cost of an intervention while assuming the alternative would have been free.
If refusing to pay a market-linked price for gold resulted in significant volumes leaving through informal channels, Ghana might have avoided an accounting exchange-rate differential while losing billions of dollars in potential foreign-exchange inflows.
Similarly, if the programme helped increase official gold flows but did so at unnecessarily high transaction costs, then the correct policy is not necessarily to abandon it. This is why NorvanReports believes the central bank cannot simply be blamed for the GH¢21.88 billion headline.
The structure of the programme, the exchange-rate mechanics and the distinction between accounting recognition and cash expenditure make that conclusion far too simplistic.
The biggest component appears to arise from an exchange-rate differential generated by the way gold is acquired and subsequently accounted for, amplified by an extraordinary appreciation of the cedi and the near doubling of programme volumes.
And policymakers should determine whether some commercial functions can eventually migrate to institutions better designed to carry them. The debate must therefore mature beyond blame. Ghana has built a potentially powerful mechanism for converting one of its greatest natural-resource advantages into foreign-exchange strength.
The task now is to make that mechanism cheaper, more transparent and more institutionally sustainable.
If the programme can generate billions of dollars in formal gold exports, strengthen reserves, reduce smuggling and improve foreign-exchange liquidity while progressively lowering its transaction costs, then a large accounting charge cannot be interpreted in isolation as proof of economic failure.
Conversely, if the costs persist, reserves do not improve sustainably and the programme depends permanently on the central bank absorbing large balance-sheet effects, then reform will become unavoidable.
That is the standard Ghana should apply, Not slogans, Not political convenience. Not the seductive simplicity of a single GH¢21.88 billion headline.
The debate should ultimately come down to one question: after separating accounting effects from real cash expenditure and measuring the foreign exchange, reserves and wider economic benefits generated, did Ghana obtain more value from the programme than it cost?
Until that full equation is answered, declaring that the Bank of Ghana simply “lost GH¢21.88 billion” is not analysis. It is an accounting number stripped of the economic story required to understand it.
