A coalition of trade and business associations has strongly opposed a directive by the Ministry of Finance requiring all marine cargo bound for Ghana to be compulsorily insured with local insurance companies, describing the policy as an unnecessary burden on businesses and a form of regulatory overreach.
The Coalition of Concerned Exporters, Importers, Traders and Freight Forwarders, together with the Food and Beverages Association of Ghana (FABAG) and the Traders Advocacy Group Ghana (TAGG), said the directive, intended to enforce Section 222 of the Insurance Act, 2021 (Act 1061), would increase the cost of doing business and undermine free commercial decision-making.
In a statement signed by the Convener of the Coalition of Concerned Exporters, Importers, Traders and Freight Forwarders, Mr. Michael Obiri-Adjei, the groups argued that marine cargo insurance is a private commercial risk arrangement between buyers, sellers and financiers, and does not present any public third-party risk that justifies compulsory regulation.
The statement stressed that mandatory insurance is only justified in circumstances where activities pose clear risks to third parties, such as motor third-party insurance or insurance for public commercial facilities. “Marine cargo insurance does not fall within this category,” the coalition noted.
The groups further criticised the directive for creating a de facto local monopoly, warning that it is anti-competitive and would force businesses to purchase more expensive policies, costs that would eventually be passed on to consumers. They argued that compelling traders to insure cargo locally, even when foreign insurers offer more competitive options, contradicts government efforts to reduce the cost of doing business.
The coalition also highlighted practical challenges within the shipping industry, noting that most international trade is conducted under Cost, Insurance and Freight (CIF) terms, where suppliers already procure insurance. According to the statement, enforcing an additional local insurance requirement would lead to unnecessary double insurance with no added benefit.
It added that in credit-based transactions, suppliers often retain ownership interests in goods, making it impractical for local traders to dictate insurance arrangements.
While commending recent fiscal measures that have stabilised the cedi, the coalition warned that the insurance mandate could reverse cost-saving gains. The statement urged the Ministry of Finance to withdraw the directive, scheduled to take effect on February 1, 2026, and to engage stakeholders to develop a more practical marine insurance policy framework.
Below is the full statement on the rejection of the mandate to compel insurance for Ghanaian imports:
The Coalition of Concerned Exporters, Importers, Traders and Freight Forwarders; Food and Beverages Association of Ghana (FABAG) and the Traders Advocacy Group Ghana (TAGG) has taken notice of the Ministry of Finance’s mandate for all marine cargo bound for Ghana to be compulsorily covered by insurance obtained from local insurance companies.
This mandate is intended to enforce Section 222 of the Insurance Act, 2021 (Act 1061). The policy is purported to be a necessary measure to strengthen and retain value within the local insurance industry. The Coalition of Concerned Exporters, Importers, Traders, and Freight Forwarders, FABAG, and TAGG categorically reject the attempt to make the acquisition of insurance for marine cargo mandatory.
Our position is that the policy is an unnecessary imposition on business owners’ commercial decisions and must not be subject to government regulation. It is clear that this law is the product of lobbying by local insurance companies, which have failed to offer viable product offerings to players in the Ghanaian shipping industry, seeking to force market penetration rather than earn it.
The only circumstances under which the acquisition of insurance can be compelled are situations where an activity presents obvious risks to third parties who must be insured. These include mandates for third-party insurance on vehicles to protect other road users and for commercial properties to protect facility users. In every other instance, entities are at liberty to assess their risks and decide whether they need to acquire insurance.
Marine cargo insurance is a purely private risk between seller, buyer, and financier, with no compelling public third-party risk to justify regulatory mandates. Even if the government had a legitimate interest in ensuring cargo bound for the Ghanaian market is insured, mandating a local monopoly on that insurance is anti-competitive, increases business costs, and represents regulatory overreach that favours a specific industry.
It is an overextension of regulatory authority to dictate where private entities must obtain insurance policies, especially when foreign insurance companies offer more competitive policies.
It is antithetical to sound business practice and to government efforts to reduce the cost of doing business to compel businesses to adopt more expensive policies for the benefit of local insurance companies, when the increased cost will inevitably be passed on to consumers.
Furthermore, the policy fails to account for the practical realities of the shipping industry and the typical trading terms between suppliers and consignees. The predominant commercial terms used in international trade are Cost, Insurance and Freight (CIF).
Under these terms, the seller is required to procure insurance to offset risks during the voyage. To require the compulsory acquisition of local insurance in addition to this creates a double insurance phenomenon, which offers no additional benefits to business owners.
Also, the majority of trade transactions rely on the supply of goods on credit, which causes suppliers to retain an interest in the cargo, thereby necessitating insurance coverage. Therefore, it would not be feasible for a trader to dictate to a supplier which insurance the supplier must obtain when the supplier has not transferred ownership of the goods to the trader.
All of these concerns have been raised with the National Insurance Commission in its previous attempts to implement this policy since 2022. From all of our previous engagements, the National Insurance Commission and the insurance community have not been able to provide meaningful justifications for the policy measures that address these concerns.
Therefore, it would not be well-placed for the Ministry of Finance to go ahead with this mandate, especially when avenues for stakeholder consultations have not been explored at all in this current attempt to implement the policy. Regrettably, no stakeholder engagements have been initiated since the mandate was announced.
The trading community has benefitted from significant cost-saving advantages through the Ministry of Finance’s efforts that have caused the cedi to appreciate and become more stable. These savings have positioned us to begin restoring business health after years of significant hardship. It would be counterproductive to the efforts to generate cost-saving advantages to impose policy measures that introduce new cost lines to businesses.
The Coalition of Concerned Exporters, Importers, Traders, and Freight Forwarders; Food and Beverages Association of Ghana (FABAG), and the Traders Advocacy Group Ghana (TAGG) support well-intended efforts to boost various sectors of the economy, but will not countenance measures that negatively affect our members.
We recognise that we represent a lucrative but underexplored business offering to the insurance community. However, it rests on the insurance community to build capacity and present viable offerings which would encourage us to make considerations to patronise them. This is the only way to attract our business and not through mandates of compulsion.
We join other well-meaning stakeholders to urge the Ministry of Finance to withdraw the mandate to make local insurance for marine cargo mandatory from 1st February, 2026 until stakeholder engagements have been held. We are confident that these engagements would present optimal outcomes for policy direction for marine insurance going forward. END.
