Ghana’s landmark Environmental Protection Act, 2025 (Act 1124) is in danger of becoming ‘law on paper’ unless the National Democratic Congress (NDC) administration urgently moves to operationalise its core institutions, according to Dr. John Kingsley Krugu, former CEO of the Environmental Protection Authority.
In a new assessment paper reviewing the 2026 Mid-Year Fiscal Policy Review, Dr. Krugu says while the government deserves credit for macroeconomic stabilisation and renewed enforcement against illegal mining, there is “comparatively limited evidence” that the broader institutional reforms envisaged under Act 1124 are being implemented.
“Legislation, however ambitious, does not transform institutions on its own. Its success depends on sustained political commitment, adequate financing, institutional capacity, effective regulations and consistent administrative leadership,” Dr. Krugu stated.
Act 1124: From Regulation to National Development Pillar
Assented to on 6 January 2025 by then President Nana Addo Dankwa Akufo-Addo, Act 1124 was framed as the most comprehensive reform of Ghana’s environmental governance since Act 490 in 1994.
Dr. Krugu, who led the EPA during the final stages of the Act’s development, said Parliament designed it to move beyond pollution control and permitting. The law created four pillars:
1. A Stronger Institutional Framework – replacing the EPA with an expanded Environmental Protection Authority to coordinate environmental governance across government.
2. Climate Governance as National Policy – embedding climate action through the Ghana Carbon Registry, Carbon Market Committee and Mitigation Fund.
3. Sustainable Environmental Financing – establishing the National Environment Fund and Mitigation Fund to provide predictable resources.
4. Accountability and Evidence-Based Governance – improving monitoring, audits, and public reporting.
“Parliament’s vision for Act 1124 extended well beyond enforcement. The Act envisaged a comprehensive governance framework that would strengthen institutions, mobilise sustainable financing, mainstream climate considerations across government, improve environmental accountability and position Ghana as a regional leader in environmental governance and green economic transformation,” he said.
What the 2026 Mid-Year Review Shows — and What It Misses
Dr. Krugu notes the Mid-Year Fiscal Policy Review highlights important wins: fiscal consolidation, arrests and equipment seizures related to illegal mining, and the registration of small-scale miners.
“Efforts to restore macroeconomic stability and strengthen enforcement against environmental crime deserve recognition,” he said.
However, he argues the review provides little detail on the operationalisation of Act 1124’s transformative parts. There is limited mention of the Environmental Protection Authority’s new mandate, the National Environment Fund, the Ghana Carbon Registry, the Carbon Market Committee, or integrated environmental information systems.
“This observation should not be interpreted as a dismissal of the progress reported by Government… The distinction is significant. Effective enforcement addresses immediate environmental harm, while effective governance builds the institutions needed to prevent future harm, attract investment, manage environmental risks and support sustainable development,” Dr. Krugu explained.
He added that with international carbon markets evolving under Article 6 of the Paris Agreement, delays in setting up the Registry and Committee could cost Ghana investment and climate finance opportunities.
“The Environmental Sector Operated Without Dedicated Ministerial Leadership”
A key concern raised in the paper is leadership. Dr. Krugu pointed out that for much of the current administration’s first year, the environmental sector operated without a dedicated minister.
“Whether intentional or circumstantial, such an extended leadership gap may have contributed to the slow pace of implementation and diminished policy attention to one of Ghana’s most important governance reforms. Environmental institutions require sustained political direction if ambitious legislative reforms are to translate into measurable outcomes,” he said.
Call to Action: Strategy, Budget, and Leadership
Dr. Krugu is calling on President John Dramani Mahama to take three immediate steps:
1. Publish a comprehensive implementation strategy for Act 1124 with clear timelines.
2. Make dedicated budgetary allocations and capitalise the National Environment Fund and Mitigation Fund.
3. Appoint a dedicated minister for environment to provide oversight and political direction.
He also urged development partners to support institutional strengthening for the Environmental Protection Authority.
“This is not a criticism for its own sake nor is it a partisan argument. Environmental degradation does not distinguish between political parties. Climate change does not recognise electoral cycles. Polluted rivers do not discriminate between governments. The Environmental Protection Act, 2025 belongs to Ghana, not to any political administration. Its successful implementation should therefore become a shared national project,” Dr. Krugu stressed.
Conclusion: Implementation is the test
Dr. Krugu concluded that Ghana has completed the hard part of passing the law. The harder part is making it work.
“The enduring success of Act 1124 will not be judged by its enactment but by the strength of the institutions it builds, the environmental outcomes it delivers and the confidence it inspires among citizens, investors and development partners,” he said.
“Environmental governance is not a luxury to be pursued after economic recovery. Above all, it requires Government to treat environmental governance as a national development priority rather than a peripheral administrative function.”
With Ghana facing intensifying pressures from illegal mining, flooding, drought, and the global shift to green investment, Dr. Krugu argues that how Act 1124 is implemented in the next 12 months will determine whether Ghana leads or lags in Africa’s green transition.
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