Policy think tank IMANI Africa has expressed profound concerns regarding the recent changes in state insurance placements within Ghana, asserting that the ongoing shift may constitute an allocation of business rather than a legitimate procurement process, thereby potentially violating the nation's public procurement laws. In an in-depth analysis from its "Insurance Question" series, IMANI associate Kay Codjoe highlighted that the legal framework governing insurance placements for State-Owned Enterprises (SOEs) and specified entities, specifically the Public Procurement Act, 2003 (Act 663) as amended by Act 914, is not being adequately followed. This legislation mandates competitive tendering, transparency in evaluation, demonstrable value for money, and non-discriminatory practices among qualified providers. While exceptions exist, such as sole sourcing, IMANI emphasizes that these are narrow and require stringent justification, conditions which they believe are not currently being met.

The immediate catalyst for these concerns was a December 2025 communication from the State Interests and Governance Authority (SIGA) which directed state entities to prioritize SIC Insurance PLC and SIC Life for their insurance needs. IMANI reports that this directive has led to a noticeable shift in insurance renewals, a narrowing of participation by private insurers, and in some instances, the premature disruption of existing insurance placements before their natural contractual cycles conclude. The think tank critically questions the absence of clear tendering processes, transparent evaluation mechanisms, and documented justifications, stating, "Because without those, the process is no longer procurement. It is an allocation. And allocation without process is precisely what Act 663 was designed to prevent."

IMANI further challenges any argument that such preferential treatment for SIC could be justified as an internal governmental allocation. They point out that SIC Insurance PLC is a publicly listed commercial entity where the government holds only a minority stake, with private investors holding the majority. Consequently, SIC operates in the open market, competing directly with other major private insurers like Enterprise Insurance, GLICO, Hollard, and Star Assurance. Thus, IMANI concludes that any preferential placement must adhere to the same competitive and legal standards applicable to any other insurer in the market.

The think tank warns that the emerging pattern in the insurance sector establishes a dangerous precedent, signaling a preferred policy direction that could adjust market behavior and shift contracts, potentially spreading beyond insurance to other critical sectors. "Today, it is insurance. Tomorrow it could be energy procurement, infrastructure contracts, or financial service mandates," IMANI cautions. They stress that the fundamental issue is not whether state-linked insurers should participate in public sector business, but rather whether they secure such business through genuine competition or through administrative direction. This distinction, IMANI argues, is the difference between a functioning market and a managed one.

In a direct appeal to President John Dramani Mahama, IMANI Africa is urging a formal reaffirmation of a 2014 position from his first administration. This earlier stance granted public institutions the autonomy to place insurance based on merit, value for money, and competitive capacity. This call, articulated in the third installment of the "Insurance Question" series, argues that a clear directive from the Presidency could resolve the escalating controversy surrounding alleged political interference in Ghana's insurance landscape. The current situation, IMANI suggests, is characterized by an ambiguity that undermines legal frameworks.

Historical documents provide a crucial context to the current debate. On December 9, 2013, President Mahama’s office issued a directive, signed by then-Executive Secretary Dr. Raymond A. Atuguba, instructing all Ministries, Departments, and Agencies (MDAs) to procure or renew insurance solely from state-owned or partially state-owned insurance companies, with exceptions requiring presidential approval. SIC Insurance swiftly acted on this, requesting insurance details from institutions for an audit and renewal schedules. However, the Ghana Insurers Association (GIA) vigorously opposed this, petitioning President Mahama on January 24, 2014. The GIA argued that the directive would foster unfair competition, stifle innovation, harm private investment, and potentially usurp the regulatory functions of the National Insurance Commission (NIC). They specifically warned of SIC charging unfair premiums due to a lack of competition, which would also erode efficiency in claims settlement and product development.

President Mahama responded to the GIA's concerns. On February 21, 2014, his Chief of Staff, Prosper D.K. Bani, issued a letter to all ministers, suspending the December 2013 directive with immediate effect. This suspension explicitly affirmed that MDAs were free to engage either state or private insurers, provided they could "demonstrate value for money." IMANI views this swift reversal, from directive to suspension within two months, as a critical precedent that underscores the importance of competitive practices. The current December 11, 2025 communication from SIGA, which again directs state entities to prioritize SIC Insurance PLC and SIC Life, is seen by IMANI as a troubling echo of the 2013 directive.

IMANI's latest analysis identifies several key institutions that must take action. It calls on the Presidency to unequivocally affirm that no insurer has an automatic entitlement to state business, that policy encouragement cannot override procurement law, and that all placements must meet competitive and technical standards. It urges SIGA to respect the boundaries of its mandate, focusing on coordination and monitoring rather than market allocation, cautioning that "Encouragement cannot evolve into compulsion through interpretation." The Public Procurement Authority (PPA) is called upon to demand disclosure of procurement methods, verification of value-for-money assessments, and documented approvals for any non-competitive methods. Furthermore, IMANI implores the National Insurance Commission (NIC) to break its silence on concerns about placement practices and market conduct, asserting that "Silence does not create neutrality. It creates uncertainty." Finally, the think tank reminds the boards of State-Owned Enterprises that they are fiduciaries, obligated to ensure every placement decision is "defensible in law, in process, and in value," warning of future consequences if structured commitments are altered without due process.

The Ghana National Gas Company (Ghana Gas) case serves as a poignant example at the heart of this dispute. IMANI raised specific legal and procurement concerns regarding changes to Ghana Gas's insurance arrangements. GLICO General Insurance Ltd had previously secured a two-year locked-in structured insurance program for Ghana Gas, involving A-rated international reinsurers from the London market and offering pricing advantages. However, GLICO's role as lead insurer was abruptly terminated effective December 31, 2025, with a different insurer taking over from January 1, 2026. IMANI's analysis questions whether this transition followed a competitive procurement process, if existing contractual obligations were properly reviewed and lawfully terminated, and whether the implications for international reinsurance commitments were thoroughly assessed prior to the change.

IMANI warns that unilaterally disrupting such established international reinsurance arrangements carries systemic consequences. Reinsurance capacity, once allocated, is not easily reversed, as it is priced, committed, and backed by balance sheets outside Ghana. Such disruptions could severely impact Ghana’s credibility in international insurance markets, influence future risk pricing adversely, diminish the availability of crucial reinsurance capacity, and ultimately escalate the long-term cost of insuring strategic national assets. "This is not theoretical risk," IMANI states, "It is how global insurance systems operate."

Beyond the procurement concerns, a significant regulatory issue emerged from GLICO's petition: questions about third-party involvement in reinsurance negotiations. IMANI highlights the potential conflict of interest if entities with regulatory or quasi-regulatory influence also hold competing commercial interests within the same market. If such engagements occur without the explicit authority of the insurer of record, they could violate provisions of the Insurance Act, 2021 (Act 1061), particularly concerning authorized placement structures, regulatory oversight, and market conduct standards. IMANI notes that at this juncture, the issue transcends commercial concerns and becomes a regulatory matter, where blurring boundaries could erode confidence. Given that Ghana Gas is a strategic national asset with complex operational risks, including gas processing infrastructure and pipeline networks, its insurance requirements typically demand detailed risk engineering, structured underwriting, and multi-year placement commitments, rather than simple administrative reassignment.

Ultimately, IMANI Africa clarifies that its stance is not against state participation in the insurance market, nor is it a defense of private insurers. Instead, it is a fervent call to uphold the integrity of decision-making processes. The think tank insists that any policy objective aimed at strengthening state-linked insurers must be pursued "deliberately, transparently, and within the law," ensuring that competition, rather than direction, dictates the allocation of public sector business.