Finance Minister Cassiel Ato Forson has directed the Ghana Revenue Authority and the Bank of Ghana to enforce Section 222 of the Insurance Act 2021, which requires imports into the country to carry locally issued cargo insurance.

The section has been part of the law since 2021. It has not been actively enforced. The directive this week is the operational moment at which a dormant legal obligation becomes a live compliance requirement.

The scale of the gap the enforcement is meant to close is the headline number. Only about 6 percent of imports into Ghana are currently insured by domestic underwriters. The remaining 94 percent are insured through the foreign seller, the freight forwarder, or the shipping line, with the premiums flowing to underwriters outside the country.

On typical Cost-Insurance-Freight import terms, the insurance leg of the quoted price pays a foreign carrier. The Minister's framing, via the Ghana Shippers' Authority leadership, is that those premiums should be retained inside the national economy.

Prof. Ransford Gyampo, the CEO of the Ghana Shippers' Authority, made the public case for the enforcement at a sensitisation seminar in Accra.

His argument has two legs. The first being economic; retaining cargo insurance premiums inside the country builds the balance sheets of the domestic insurance industry, which in turn supports its ability to underwrite other types of risk and generate investment income that stays in the local capital market.

The second is operational. Between 1,500 and 2,000 containers are lost at sea annually, with further exposure from piracy and Middle East-linked shipping disruption. A local insurer has a more direct incentive to engage with a Ghanaian shipper on a claim than a foreign underwriter has, and the claim settlement process itself can move faster.

The legal architecture is the part of the directive most worth reading carefully.

Section 222 of the Insurance Act 2021 is an existing provision. It does not require new legislation to activate so what the Minister's directive does is instruct the two regulators most relevant to cross-border trade, the Revenue Authority and the central bank, to incorporate Section 222 compliance into their respective processes.

The Revenue Authority assesses customs duties at port. The Bank of Ghana processes the foreign exchange that imports require. Both of them touch the import transaction at a chokepoint where compliance with the Insurance Act can be verified before clearance or settlement completes.

Several movings parts that are yet to be fully clarified by any involved party includes;

One: what constitutes verifiable compliance. The typical audit trail would be a cargo insurance certificate issued by a licensed Ghanaian insurer, attached to the import documentation at clearance.

The directive has not yet specified whether a simple certificate will be sufficient or whether the Revenue Authority will cross-check against a National Insurance Commission registry.

The enforcement is workable either way; the friction level for importers will depend on which path gets chosen.

Two: the cost passthrough. If the local underwriting market charges premiums above what the foreign insurer currently charges, the cost difference will be passed through to importers and eventually to end consumers.

The domestic insurance sector has the technical capacity to underwrite most marine cargo risks, but pricing will be tested by the sudden jump from 6 percent penetration to whatever share the enforcement actually achieves.

If local premiums clear the market close to international rates, the passthrough will be small. If they clear higher, the political economy of the directive gets more complicated at a moment when the country has spent three quarters walking inflation down.

Three: the domestic underwriting capacity test. The Ghana insurance sector has grown meaningfully over the past five years, but the marine cargo niche specifically is thinly served.

A shift from 6 percent local underwriting to anything close to majority coverage would require the handful of insurers that currently write marine cargo to scale capacity quickly or to reinsure the risk out to international reinsurers.

Reinsurance moves the money out again, which partly defeats the "keep it in Ghana" framing of the directive.


The political read is straightforward.

The Ministry of Finance has spent the past eighteen months making structural moves designed to strengthen domestic revenue mobilisation and reduce foreign-currency leakage.

Enforcing Section 222 fits into the same frame as the currency-related measures and the broader protectionist tilt the Ministry has been signalling.

It also fits into Ato Forson's public positioning as the finance minister who collected four out of fifteen ECOWAS member states' EBID capital commitments and used the high ground to lecture the eleven that did not pay.

What to watch: the first public enforcement action against a non-compliant import, the response from the Ghana Union of Traders' Association, any indicative pricing data on local marine cargo premiums once the directive is live, and whether the Ministry of Trade and Industry issues its own implementation guidance or defers to the Revenue Authority's clearance procedures.