COMPARATIVE GUIDE
1 September 2025

ESG Comparative Guide

ESG Comparative Guide for the jurisdiction of Ghana, check out our comparative guides section to compare across multiple countries
Ghana Corporate/Commercial Law
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1 Legal and enforcement framework

1.1 What regulatory regimes and codes of practice primarily govern environmental, social and governance (ESG) regulation and implementation in your jurisdiction?

Ghana's ESG landscape is shaped by a combination of:

  • statutory instruments;
  • regulatory guidelines; and
  • voluntary frameworks.

Key legal regimes include the following:

  • Environmental Protection Agency Act, 1994 (Act 490): Environmental governance.
  • Companies Act, 2019 (Act 992): Corporate governance and disclosures.
  • Labour Act, 2003 (Act 651): Social and labour protections.
  • Minerals and Mining Act, 2006 (Act 703): Environmental and community provisions in extractives.
  • Bank of Ghana (BoG) Sustainable Banking Principles (2019): ESG guidelines for the financial sector.
  • Ghana Stock Exchange (GSE) ESG Disclosure Guidelines: Applicable to listed companies.

1.2 Is the ESG framework in your jurisdiction primarily based on hard (mandatory) law and regulation or soft (eg, 'comply or explain') codes of governance?

The ESG regime is a hybrid of:

  • statutory and regulatory obligations; and
  • soft law (voluntary codes such as BoG principles and GSE guidelines).

1.3 Which bodies are responsible for implementing and enforcing the rules and codes that make up the ESG framework? What powers do they have?

  • Environmental Protection Agency: Enforces:
    • environmental permits;
    • compliance; and
    • penalties.
  • Registrar of Companies: Oversees:
    • company filings; and
    • governance-related disclosures.
  • BoG: Supervises financial institutions on ESG risk management.
  • Securities and Exchange Commission (SEC): Ensures capital market compliance.

1.4 What is the regulators' general approach to ESG and the enforcement of the ESG framework in your jurisdiction?

Enforcement is still evolving. Regulators are increasingly focused on:

  • building ESG capacity;
  • promoting voluntary disclosures; and
  • gradually tightening compliance expectations, especially in the finance, mining and listed sectors.

1.5 What private sector initiatives have been launched in your jurisdiction to complement the ESG framework?

Yes, there are private sector initiatives in Ghana and globally relating to ESG. These vary by industry but generally include the following.

ESG reporting and disclosure: Many companies – especially in finance, extractives, telecoms and manufacturing – have begun issuing ESG or sustainability reports aligned with the principles and standards of:

  • the Global Reporting Initiative;
  • the Sustainability Accounting Standards Board; and
  • the Task Force on Climate-related Financial Disclosures (TCFD).

For example:

  • Absa Bank Ghana and Stanbic Bank include ESG disclosures in their annual reports; and
  • Kosmos Energy Ghana and Tullow Oil publish sustainability reports covering:
    • local content;
    • environmental protection; and
    • community engagement.

Corporate governance reforms: Firms are improving governance by:

  • establishing independent boards;
  • implementing:
    • whistleblower policies;
    • anti-corruption frameworks; and
    • gender diversity targets; and
  • signing up to codes such as the Ghana Corporate Governance Code.

Green finance and renewable projects:

  • Private banks (eg, CalBank, Fidelity Bank) are investing in green financing.
  • Independent power producers such as BXC Ghana are involved in renewable energy projects.
  • Venture funds and fintechs are now tying capital to ESG performance (eg, impact investing criteria).

Social impact and corporate social responsibility (CSR):

  • Companies in the fast-moving consumer goods and telecoms sectors (eg, MTN, Unilever) support:
    • education;
    • healthcare; and
    • digital inclusion.
  • Some are shifting from CSR to measurable social impact models, tied to ESG metrics.

ESG ratings and benchmarking: A few Ghanaian firms are seeking ESG ratings or working with external consultants to develop ESG strategies to prepare for foreign investment, listing or supply chain requirements.

2 Scope of application

2.1 Which entities are captured by the rules and codes that make up the principal elements of the ESG framework in your jurisdiction?

Banks, listed companies, mining companies and companies in regulated sectors (eg, insurance, pensions, energy) are subject to formal ESG compliance.

2.2 How are entities in your jurisdiction that are not subject to specific rules or codes implementing ESG?

In Ghana, aside from companies that are directly subject to ESG regulation (eg, extractives, energy, listed companies), suppliers, financiers, exporters, real estate developers, service providers and even non-governmental organisations (NGOs) are indirectly impacted. Their exposure arises mainly through:

  • supply chain obligations;
  • financing conditions;
  • foreign regulations; and
  • stakeholder pressure.

Different players are affected in the following ways:

  • Supply chain partners: Small and medium-sized enterprises, contractors and suppliers to ESG-regulated companies face compliance pressure.
  • Financial institutions: Impacted through:
    • sustainable banking principles;
    • sustainable lending conditions; and
    • green financing requirements.
  • Exporters and traders: Must comply with foreign ESG standards (eg, EU deforestation laws, human rights due diligence) to access markets.
  • Real estate and construction: Pressured by investors and clients to adopt green building and social safeguards.
  • Professional services: Law firms, auditors and consultants must align practices to support ESG-compliant clients.
  • NGOs and civil society: Indirectly affected as their advocacy shapes companies' social licence to operate.

2.3 What are the principal ESG issues in your jurisdiction that are either part of the ESG framework or part of the implementation of ESG?

Environmental:

  • Deforestation and land degradation from illegal mining and agriculture.
  • Water and air pollution due to mining and poor waste disposal.
  • Climate vulnerability, including:
    • floods;
    • droughts; and
    • coastal erosion.
  • Waste management challenges, especially plastic waste in urban areas.

Social:

  • Labour rights violations, especially child labour in the cocoa and mining industries.
  • Land rights and community conflicts, in particular over poor compensation and consultation.
  • Limited access to health and education, with rural areas most affected.
  • Gender inequality – low female representation and gender-based violence.

Governance

  • Corruption and weak enforcement, particularly in resource licensing.
  • Poor corporate governance, with limited transparency and board accountability.
  • Regulatory gaps, especially in relation to:
    • land use;
    • environment; and
    • tax.
  • Data privacy risks, especially given increased digital activity.

3 Disclosure and transparency

3.1 What primary disclosure obligations relating to ESG apply in your jurisdiction?

  • Companies listed on the Ghana Stock Exchange (GSE):
    • must disclose corporate governance and material risks; and
    • are encouraged to report on ESG.
  • Banks and financial institutions must report on ESG risk exposure under the Bank of Ghana Sustainable Banking Principles.
  • Companies in the mining and extractive industries must file environmental impact assessments (EIAs) and community development plans with regulators.

3.2 What voluntary ESG disclosures are also commonly made in your jurisdiction?

  • ESG/sustainability reports, by banks, telecoms companies and law firms; and
  • Global Reporting Initiative-aligned or Sustainable Development Goals-linked reporting.

Some companies also adopt international ESG frameworks to attract investors or meet lender requirements.

3.3 What role is played in this regard by (a) the board and (b) other corporate bodies and/or officers?

The key roles of governance bodies include:

  • setting ESG reporting guidelines and policies;
  • monitoring and enforcing compliance with ESG disclosure rules; and
  • promoting accountability and ethical governance in organisations.

Key governance bodies include the following:

  • Bank of Ghana: Enforces ESG risk disclosure for banks and licensed companies.
  • Securities and Exchange Commission: Requires ESG risk and corporate governance disclosures.
  • GSE:
    • Requires listed firms to report governance practices; and
    • Encourages sustainability reporting.
  • Environmental Protection Agency: Regulates environmental disclosures (eg, EIAs).
  • Minerals Commission: Oversees ESG-related disclosures in the mining sector.
  • Registrar of Companies: Ensures corporate compliance supporting transparency.

3.4 What best practices should be considered in relation to ESG reporting and disclosure?

Best practices for ESG disclosure in Ghana include:

  • aligning with international standards;
  • embedding ESG in corporate reporting;
  • ensuring board oversight;
  • engaging stakeholders; and
  • using third-party assurance.

4 Strategy and governance

4.1 How is ESG strategy typically designed and implemented in companies in your jurisdiction?

In Ghana, ESG strategies are developed through:

  • materiality assessments;
  • alignment with regulatory and global frameworks; and
  • internal goal setting.

Implementation involves:

  • governance oversight;
  • operational integration;
  • monitoring; and
  • stakeholder engagement.

4.2 What role is played in this regard by (a) the board and (b) other corporate bodies and/or officers?

Governance bodies in Ghana play a central role in:

  • leading ESG strategy development;
  • overseeing risk and policy;
  • ensuring implementation and disclosure;
  • holding management accountable; and
  • driving stakeholder trust and long-term value.

4.3 What mechanisms are typically utilised to monitor the implementation of ESG strategy in your jurisdiction?

  • ESG dashboards or compliance checklists; and
  • Periodic board reporting and internal audits.

4.4 What role is played in this regard by (a) the board and (b) other corporate bodies and/or officers?

  • The board provides oversight; and
  • ESG officers or committees execute and report.

4.5 How is executive compensation typically aligned with ESG strategy in your jurisdiction?

In Ghana, executive compensation is rarely tied to ESG performance in a formalised way. However, a few leading firms are starting to integrate ESG metrics, often influenced by global standards or investor expectations.

This is likely to become more common as ESG disclosure norms strengthen and stakeholders demand more accountability.

4.6 What best practices should be considered in relation to the design and implementation of ESG strategy?

  • Ensure top-level ESG ownership;
  • Embed ESG KPIs into performance management; and
  • Train leadership on ESG issues.

5 Financing

5.1 What is the general approach of lenders towards ESG in your jurisdiction? What internal and external information regarding a prospective borrower will they typically consider in this regard?

Banks are beginning to incorporate ESG risk into credit assessments, especially under the Bank of Ghana's (BoG) Sustainable Banking Principles.

5.2 Are bonds/loans that are marketed as green bonds/loans, social bonds/loans, sustainability bonds/loans or similar a feature of the markets in your jurisdiction?

Ghana:

  • has launched frameworks (eg, the Sustainable Financing Framework); and
  • is developing green bonds with development partners.

Yes, Ghana has established a robust domestic framework for issuing green, social, sustainability and sustainability-linked bonds, supported by:

  • the Securities and Exchange Commission (SEC);
  • the Ghana Stock Exchange (GSE); and
  • the Ministry of Finance.

The government expressed a strong intention to issue sovereign green and social bonds back in 2021, but public evidence of completed issuance remains limited.

Regardless, corporates, financial institutions and public bodies now have the structures needed to issue such bonds in Ghana's evolving bond market.

5.3 What key developments have taken place in the structuring of these instruments in your jurisdiction?

  • Ghana's Green Finance Taxonomy was launched in 2023; and
  • The GSE and the SEC are working on ESG bond listing standards.

Ghana's ESG finance landscape has matured rapidly, as evidenced by the following developments:

  • Stronger regulation and disclosure standards are in place.
  • Green finance instruments (bonds, loans, taxonomies) are being rolled out.
  • Institutions and banks are embedding ESG in operations and lending.
  • Clean energy and climate finance are gaining momentum.

However, key challenges remain, including:

  • capacity gaps;
  • greenwashing risks; and
  • small and medium-sized enterprise inclusion.

5.4 What best practices should be considered in relation to ESG in the financing context?

Ghanaian regulators and market participants increasingly align with:

  • the International Capital Market Association Principles (green, social and sustainability bonds);
  • International Financial Reporting Standards Sustainability Disclosure Standards (International Sustainability Standards Board);
  • the EU Taxonomy and Sustainable Finance Disclosure Regulation frameworks (used as reference points); and
  • the United Nations Principles for Responsible Investment.

These help to:

  • promote market confidence;
  • prevent greenwashing; and
  • support cross-border investment compatibility.

Mandatory ESG disclosure guidance: The Ghana Stock Exchange requires listed companies to follow its ESG Disclosure Guidance Manual (2022), offering tiered reporting based on company size and readiness. Companies are expected to disclose:

  • governance structures;
  • environmental impact (carbon, energy use, waste);
  • social impact (labour, community, inclusion); and
  • ESG risks and strategy.

Integration of ESG into risk management: Financial institutions are encouraged (eg, by the BoG) to embed ESG risks into:

  • credit risk assessments;
  • investment decision making; and
  • board-level governance and risk appetite frameworks

Use of ESG taxonomies and impact metrics: Ghana is developing a green finance taxonomy to classify environmentally sustainable activities. Best practice institutions apply:

  • lifecycle carbon accounting;
  • gender and inclusion metrics;
  • Sustainable Development Goals-aligned impact key performance indicators; and
  • double materiality assessments (impact on and by the business).

Third-party verification and impact reporting: Green, social and sustainability bonds must have:

  • external review or second-party opinions; and
  • post-issuance reporting on proceeds and impacts (at least annually).

Some firms are adopting assurance models to validate ESG data (aligned with AA1000 and ISAE3000).

Capacity building and ESG education: Best-in-class firms invest in:

  • training for board and executive teams;
  • ESG literacy for financial and operational teams; and
  • participation in summits, such as:
    • the Africa ESG Reporting Summit; and
    • Oxford Sustainable Finance programmes.

6 ESG activism

6.1 What role do institutional investors and other activist shareholders play in shaping ESG in your jurisdiction?

Limited but growing. Development finance institutions and pension funds are influencing ESG expectations.

6.2 How do activist shareholders typically seek to exert influence on corporations in your jurisdiction in relation to ESG?

  • Engaging on:
    • climate;
    • diversity; and
    • human rights; and
  • Pushing for disclosure and board diversity.

6.3 Which areas of ESG are shareholders currently focused on?

  • Governance and anti-corruption;
  • Climate change; and
  • Social impact and community rights.

6.4 Have there been any high-profile instances of ESG activism in recent years?

There are few public examples, but growing pressure is being exerted in the extractive and infrastructure sectors (eg, gold mining, dams).

6.5 Is ESG activism increasing or decreasing in your jurisdiction? How and why?

ESG activism is increasing, driven by:

  • international investor pressure;
  • local civil society advocacy; and
  • rising ESG awareness.

7 Other stakeholders and rights holders

7.1 What role do stakeholders or rights holders (eg, employees, pensioners, creditors, customers, suppliers, and Indigenous communities) play in shaping ESG in your jurisdiction? What influence can they exert on a company?

Legal frameworks: The Constitution, the Companies Act (2019) and Environmental Protection Agency regulations require:

  • community consultation;
  • stakeholder consideration; and
  • environmental transparency.

Stakeholder roles:

  • Communities: Engaged in environmental assessments and benefit sharing.
  • Investors: Use annual general meetings and ESG disclosures to influence decisions.
  • Non-governmental organisations/activists: Drive accountability and public engagement.
  • Employees: Involved in workplace safety, equity and ethics. Employees and unions influence labour and diversity practices.
  • Traditional authorities: Consulted on land and environmental issues.

Rights holders: Especially in the extractive industries, rights holders are consulted under FPIC principles to protect land, health and livelihoods.

  • Disclosure requirements: The Ghana Stock Exchange ESG Guidelines promote stakeholder engagement reporting.
  • Challenges:
    • Superficial consultations;
    • Limited access to ESG information; and
    • Weak enforcement.

Stakeholder and rights holder engagement in ESG is growing in Ghana, but deeper inclusion and stronger protections are still needed.

8 Trends and predictions

8.1 How would you describe the current ESG landscape and prevailing trends in your jurisdiction? Are any new developments anticipated in the next 12 months, including any proposed legislative reforms?

Ghana's ESG framework is maturing. Key trends include:

  • growth in sustainability-linked finance;
  • gradual regulatory tightening (Bank of Ghana, Environmental Protection Agency, SEC);
  • a push for harmonised ESG reporting; and
  • ESG becoming integral to risk and board discussions.

9 Tips and traps

9.1 What are your top tips for effective ESG implementation in your jurisdiction and what potential sticking points would you highlight?

Top tips:

  • Conduct a materiality assessment early;
  • Tailor ESG to your sector and stakeholder expectations; and
  • Embed ESG in governance, not just corporate social responsibility.

Potential pitfalls:

  • Underestimating compliance gaps;
  • Greenwashing in disclosures; and
  • Neglecting social and governance pillars.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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