## GHANA: FOURTH REVIEW UNDER THE ARRANGEMENT UNDER THE EXTENDED CREDIT FACILITY, REQUEST FOR MODIFICATION OF PERFORMANCE CRITERIA, FINANCING ASSURANCES REVIEW, AND MONETARY POLICY CONSULTATION

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### Program status and performance
- IMF Executive Board completed the fourth review of the US$3 billion, 36-month Extended Credit Facility (ECF) Arrangement approved in May 2023.
- Completion of the fourth review allows for an immediate disbursement of about US$367 million (SDR 267.5 million), bringing Ghana’s total disbursements under the arrangement to about US$2.3 billion (text also cites about US$2.4 billion).
- Key implementation outcomes and corrective measures:
  - Program implementation deteriorated significantly at end-2024: preliminary fiscal data point to slippages in the run-up to the 2024 general elections, on account of a large accumulation of payables; CPI inflation exceeded program targets (end-2024 CPI inflation: 23.8 percent); several reforms and policy actions were delayed across the fiscal, financial, and energy sectors.
  - While all end-December 2024 performance criteria (PCs) and most indicative targets (ITs) were met, the IT on accumulation of payables was missed by a large margin (missed by 3.9 percent of GDP).
  - New authorities enacted corrective measures: enacted a strong budget and public financial management reforms; tightened monetary policy; adjusted electricity prices and resumed quarterly electricity tariff changes; committed to achieving a 1½ percent of GDP fiscal primary surplus in 2025 while protecting the vulnerable; launched a comprehensive audit of payables accumulated end-2024.

### Macroeconomic developments and outlook
- Growth and inflation projections (selected series):
  - Real GDP growth: 3.1 (2023), 5.7 (2024), 4.0 (2025), 4.8 (2026), 4.9 (2027), 5.0 (2028), 5.0 (2029), 5.0 (2030).
  - Non-extractive GDP: 3.3 (2023), 5.1 (2024), 3.6 (2025), 4.6 (2026), 5.0 (2027–2030 each year at 5.0).
  - Extractive GDP: 1.7 (2023), 9.4 (2024), 7.0 (2025), 5.9 (2026), 4.7 (2027), 4.9 (2028), 5.0 (2029–2030).
  - Real GDP per capita: 1.2 (2023), 3.7 (2024), 2.1 (2025), 2.9 (2026), 3.1 (2027), 3.2 (2028–2029), 3.3 (2030).
  - GDP deflator: 40.1 (2023), 25.4 (2024), 17.0 (2025), 7.8 (2026), 6.8 (2027), 6.9 (2028), 7.6 (2029), 7.8 (2030).
  - Consumer price index (end of period): 23.2 (2023), 23.8 (2024), 12.0 (2025), 8.0 (2026–2030 each year).
  - Consumer price index (annual average): 39.2 (2023), 22.9 (2024), 17.3 (2025), 9.3 (2026), 8.0 (2027–2030 each year).
- External sector and reserves:
  - Current account balance (percent of GDP): -1.6 (2023), 1.1 (2024), 1.8 (2025), 1.4 (2026), 1.5 (2027), 1.3 (2028), 1.1 (2029), 0.5 (2030).
  - Gross international reserves (program, US$ million): 3,661 (2023), 6,404 (2024), 8,366 (2025), 7,926 (2026), 9,585 (2027), 11,358 (2028), 13,614 (2029), 14,948 (2030).
  - Reserves in months of prospective imports: 1.5 (2023), 2.6 (2024), 3.3 (2025), 3.0 (2026), 3.5 (2027), 3.9 (2028), 4.5 (2029), 4.8 (2030).
- Recent developments (2024–2025):
  - Current account recorded an estimated surplus of 1.1 percent of GDP in 2024.
  - GIR reached US$6.4 billion (2.6 months) at end-December 2024 and US$7.6 billion at end-March 2025 (3 months).
  - Nominal exchange rate appreciated by 60 percent against the US dollar between November 2024 and May 2025.
  - Domestic gold purchases grossed over US$3.6 billion in 2024; revaluation of physical gold reserves contributed over US$500 million.

### Fiscal stance and public debt
- Central government budget (percent of GDP, selected):
  - Revenue: 15.2 (2023), 15.9 (2024), 15.9 (2025), 16.6 (2026), 16.8 (2027), 16.9 (2028), 17.0 (2029–2030).
  - Expenditure (commitment basis): 18.5 (2023), 23.2 (2024), 18.7 (2025–2026), 18.6 (2027), 18.9 (2028), 19.2 (2029), 19.6 (2030).
  - Overall balance (commitment basis): -3.4 (2023), -7.3 (2024), -2.8 (2025), -2.1 (2026), -1.8 (2027), -2.0 (2028), -2.2 (2029), -2.6 (2030).
  - Primary balance (commitment basis): -0.3 (2023), -3.3 (2024), 1.5 (2025–2029), 1.0 (2030).
  - Non-oil primary balance (commitment basis): -1.7 (2023), -5.0 (2024), 0.4 (2025–2026), 0.3 (2027), 0.2 (2028), 0.1 (2029), -0.4 (2030).
- Public debt (gross, percent of GDP): 79.1 (2023), 70.2 (2024), 66.0 (2025), 62.3 (2026), 59.5 (2027), 56.6 (2028), 53.8 (2029), 51.9 (2030).
  - Domestic debt: 37.1 (2023), 33.8 (2024), 29.2 (2025), 27.5 (2026), 26.1 (2027), 25.2 (2028), 24.1 (2029), 23.6 (2030).
  - External debt: 42.0 (2023), 36.4 (2024), 36.8 (2025), 34.8 (2026), 33.4 (2027), 31.4 (2028), 29.7 (2029), 28.3 (2030).
- 2024 fiscal outturn (selected figures):
  - Revenue and grants: 15.9; Taxes: 13.3; Nontax revenue: 2.4; Expenditure: 23.2.
  - Primary balance (commitment basis): -3.3; Overall balance (commitment basis): -7.3.
  - Payables (net change): 2.6; Pre-audited gross accumulation of payables: 5.7 percent of GDP; clearance: 3.1 percent of GDP.
  - Stock of energy sector payables largely unchanged at end-2024.
- Memorandum: Nominal GDP (billions of GHc): 887 (2023), 1,176 (2024), 1,431 (2025), 1,617 (2026), 1,812 (2027), 2,034 (2028), 2,299 (2029), 2,602 (2030).

### Monetary policy, banking, and financial stability
- BoG stance and instruments:
  - BoG tightened monetary policy and increased use of open market operations; policy rate: 30.0 (end-2023), 27.0 (end-2024), N.A. (2025–2030 in table).
  - Base money growth: 29.7 (2023), 47.8 (2024), 16.2 (2025), -1.1 (2026), 12.7 (2027–2028), 14.8 (2029), 9.8 (2030).
  - Broad money (M2+) growth: 38.7 (2023), 31.9 (2024), 23.4 (2025), 13.0 (2026), 12.1 (2027), 12.3 (2028), 13.0 (2029), 16.1 (2030).
  - Credit to the private sector (annual % change): 10.7 (2023), 26.3 (2024), 24.7 (2025), 17.0 (2026), 16.1 (2027), 16.3 (2028), 17.0 (2029), 19.2 (2030).
- Financial sector measures and outcomes:
  - Banking sector capital adequacy improving; most banks with post-DDE capital deficits on course to restore CAR of 13 percent (without reliefs) by end-2025 with GFSF support.
  - NPL-to-total loan ratio decreased from 26.7 percent to 21.8 percent between end-March and end-December 2024 due to faster expansion in nominal credit; NPL ratio reported at 22.6 percent (later series).
  - GFSF support in 2023 and 2024 was funded through issuance of marketable government bonds.
  - Authorities committed to intensifying monitoring, recapitalization of weak banks, strengthening risk management, and improving crisis management and resolution framework.

### Debt restructuring, external financing, and reserves
- Debt restructuring progress:
  - Memorandum of Understanding (MoU) with Ghana’s Official Creditors Committee (OCC) under the G20 Common Framework signed by all parties; focus now on finalizing bilateral agreements to implement the MoU.
  - Authorities pursuing good-faith efforts toward agreements with commercial creditors consistent with program parameters and comparability of treatment.
  - DDE and the Eurobond restructuring were completed in 2023 and October 2024 respectively.
  - Given progress, Moody’s, Fitch, and S&P upgraded Ghana’s credit risk rating in the past six months.
- External financing (selected flows, US$ million):
  - IMF financing: 600 (2023), 1,320 (2024), 720 (2025), 360 (2026), 0 (2027–2030).
  - World Bank financing: 27 (2023), 390 (2024), 886 (2025), 487 (2026), 0 (2027–2030).
  - AfDB financing: 60 (2023), 0 (2024), 44 (2025), 0 (2026–2030).
  - Debt restructuring related flows: 2,677 (2024), 12,031 (2025), 7,474 (2026), 2,812 (2027), 0 (2028–2030).
  - BOP financing gap (US$ million): 3,364 (2024), 13,741 (2025), 9,124 (2026), 3,659 (2027), 0 (2028–2030).
- Note: Projections assume full debt restructuring; large 2024–2026 financing gaps result from restructuring accounting, with both debt deferral and the nominal value of the debt exchanges included.

### Structural reforms, social protection, and sectoral priorities
- Structural priorities:
  - Strengthen revenue administration; bolster PFM; improve SOE management (energy and cocoa); complete debt restructuring; implement PIMA recommendations.
  - Public financial management reforms: strengthened budget controls, comprehensive audit of payables, integration of GHANEPS with GIFMIS, expansion of GIFMIS coverage (549 additional MDA/MMDA accounts onboarded).
- Social protection:
  - 2025 Budget increased allocation for social protection programs by 0.34 percentage points to 0.91 percent of GDP.
  - LEAP beneficiaries to increase from 350,000 to 400,000 by end-September 2025; benefits to have automatic indexation to inflation.
  - Increased allocations to GSFP, NHIS, and Capitation Grant to support poor households and health/education priorities.
- Energy and cocoa sector measures:
  - Energy: resumption of quarterly tariff adjustments, PURC tariff increase of 14.75 percent in April, MYTO assessment planned (end-September 2025 SB), validation of energy legacy debt; 2025 Budget allocated GHS27.1 billion (around US$1.7 billion) to cover energy shortfall assuming policy actions.
  - Cocoa: Cocobod turnaround strategy; farmgate price guidance and measures to phase out quasi-fiscal activities; World Bank support for functional and expenditure review.

### Risks and outlook summary
- Outlook: generally positive but growth is set to decline in the near term due to a large negative fiscal impulse and monetary tightening; staff lowered its 2025 growth projection to 4 percent with return to about 5 percent thereafter.
- Inflation path: inflation set to decline to 12.0 percent by end-2025; return to BoG target band (8±2 percent) delayed to 2026.
- Main risks:
  - External: intensification of regional conflicts, trade/investment shocks, geoeconomic fragmentation, commodity price volatility.
  - Domestic: policy slippages, delays in debt restructuring, postponement of energy reforms, delays in bank recapitalization and SDI legacy resolution.
- Mitigating policy emphasis:
  - Stay the course on macroeconomic adjustment and reforms; maintain tight monetary stance until inflation returns to target; reduce BoG footprint in FX market and allow greater exchange rate flexibility; complete debt restructuring in line with program parameters.

### Program conditionality, monitoring, and requested modifications
- Monitoring framework: semi-annual monitoring via quantitative PCs, continuous PCs related to Article VIII, MPCC, ITs, and SBs.
- Proposed modifications through end-December 2025:
  - Modify primary balance PC and non-oil revenue IT to accommodate macro developments while maintaining fiscal effort relative to GDP.
  - Shift MPCC bands upwards in September and December 2025.
  - Modify IT on social spending to reflect inflation indexation impacts.
  - Modify TMU to add GoldBod among public entities monitored and to improve monitoring of energy payables and clarify BoG claims exceptions.
- New conditionality through end-March 2026: ITs and six new SBs for end-August 2025 through end-December 2025 focused on macro-critical reforms.

### Staff appraisal — main findings and policy recommendations
- Overall assessment: despite election-related slippages, Ghana poised to make further progress toward stabilization; authorities show high program ownership and adopted corrective measures.
- Fiscal recommendations:
  - Preserve fiscal policy adjustment integrity to restore macro stability and debt sustainability while protecting the vulnerable.
  - Implement strategy to address 2024 fiscal slippages; be ready to adopt contingency measures such as frontloading MTRS revenue measures and reprioritizing MDAs’ budget allocations.
  - Maintain a primary fiscal surplus of 1½ percent of GDP in 2025 and beyond; improve domestic revenue mobilization and phase VAT reform carefully.
- PFM, governance and SOE recommendations:
  - Enact enhanced fiscal responsibility framework and ensure accountability; strengthen commitment controls and budget execution; streamline statutory funds; improve public procurement governance; implement PIMA recommendations.
  - GoldBod should adhere to highest governance standards and limit fiscal risks.
- Monetary and reserves policy:
  - BoG should maintain tight monetary stance; increase reliance on OMOs; adopt formal internal FX intervention policy; manage gold-related reserve risks carefully.
- Financial sector:
  - Sustain recapitalization and remediation of undercapitalized banks; finalize NIB strengthening plan; improve crisis management and resolution framework; enhance deposit protection and address SDI legacy issues.

### Staff recommendation and program decisions
- Staff supports:
  - completion of the monetary policy consultation;
  - the fourth review under the ECF arrangement;
  - the financing assurances review related to private sector creditors;
  - the request for modification of performance criteria.
- Program phasing and access:
  - Total under the ECF (May 17, 2023 to April 16, 2026): 2,241.9 millions of SDRs; 3,000 millions of U.S. dollars; 304 percent of quota.
  - Key review/completion dates include May 1, 2025 (completion of fourth review) and scheduled subsequent reviews through April 16, 2026.

*Source: IMF staff report — Fourth review under the ECF Arrangement (June–July 2025).*

### 2024. This reflected pre-election fiscal slippages; inflation above program targets—though

### GHANA: FOURTH REVIEW UNDER THE ARRANGEMENT UNDER THE EXTENDED CREDIT FACILITY, REQUEST FOR MODIFICATION OF PERFORMANCE CRITERIA, FINANCING ASSURANCES REVIEW, AND MONETARY POLICY CONSULTATION

### Program status and performance
- IMF Executive Board completed the fourth review of the US$3 billion, 36-month Extended Credit Facility (ECF) Arrangement approved in May 2023.
- Completion of the fourth review allows for an immediate disbursement of about US$367 million (SDR 267.5 million), bringing Ghana’s total disbursements under the arrangement to about US$2.3 billion (Executive Summary indicates about US$2.4 billion on completion—text cites both).
- Program implementation deteriorated significantly at end-2024:
  - Preliminary fiscal data point to slippages in the run-up to the 2024 general elections, on account of a large accumulation of payables.
  - Inflation exceeded program targets (end-2024 CPI inflation: 23.8 percent).
  - Several reforms and policy actions were delayed across the fiscal, financial, and energy sectors.
  - While all end-December 2024 performance criteria (PCs) and most indicative targets (ITs) were met, the IT on accumulation of payables was missed by a large margin.
- New authorities have enacted corrective measures to restore program performance:
  - Enacted a strong budget and public financial management reforms, including an enhanced fiscal responsibility framework and a 2025 budget consistent with program objectives.
  - Tightened monetary policy and adjusted electricity prices; resumed quarterly electricity tariff changes to reflect past costs and exchange rate developments.
  - Committed to achieving a 1½ percent of GDP fiscal primary surplus in 2025 via additional revenue mobilization and expenditure rationalization while protecting the vulnerable.
  - Undertaken measures to strengthen budget controls and to carry out a comprehensive audit of payables accumulated end-2024.

### Macroeconomic developments and outlook
- Growth and inflation
  - Real GDP growth: 3.1 (2023 actual), 5.7 (2024 preliminary), projected 4.0 (2025), 4.8 (2026), 4.9 (2027), 5.0 (2028), 5.0 (2029), 5.0 (2030).
  - Non-extractive GDP: 3.3 (2023), 5.1 (2024), 3.6 (2025), 4.6 (2026), 5.0 (2027), 5.0 (2028), 5.0 (2029), 5.0 (2030).
  - Extractive GDP: 1.7 (2023), 9.4 (2024), 7.0 (2025), 5.9 (2026), 4.7 (2027), 4.9 (2028), 5.0 (2029), 5.0 (2030).
  - Real GDP per capita: 1.2 (2023), 3.7 (2024), 2.1 (2025), 2.9 (2026), 3.1 (2027), 3.2 (2028), 3.2 (2029), 3.3 (2030).
  - GDP deflator: 40.1 (2023), 25.4 (2024), 17.0 (2025), 7.8 (2026), 6.8 (2027), 6.9 (2028), 7.6 (2029), 7.8 (2030).
  - Consumer price index (end of period): 23.2 (2023), 23.8 (2024), 12.0 (2025), 8.0 (2026–2030 each year).
  - Consumer price index (annual average): 39.2 (2023), 22.9 (2024), 17.3 (2025), 9.3 (2026), 8.0 (2027–2030 each year).
- External sector and reserves
  - Current account balance (percent of GDP): -1.6 (2023), 1.1 (2024), 1.8 (2025), 1.4 (2026), 1.5 (2027), 1.3 (2028), 1.1 (2029), 0.5 (2030).
  - Gross international reserves (program, US$ million): 3,661 (2023), 6,404 (2024), 8,366 (2025), 7,926 (2026), 9,585 (2027), 11,358 (2028), 13,614 (2029), 14,948 (2030).
  - Reserves in months of prospective imports: 1.5 (2023), 2.6 (2024), 3.3 (2025), 3.0 (2026), 3.5 (2027), 3.9 (2028), 4.5 (2029), 4.8 (2030).
  - External financing and debt-restructuring flows: BOP financing gap and debt restructuring related flows are large in 2024–2026 due to restructuring accounting (BOP financing gap: 3,364 (2024), 13,741 (2025), 9,124 (2026) — table shows 2023 as blank then these numbers).

### Fiscal stance and public debt
- Central government budget (percent of GDP)
  - Revenue: 15.2 (2023), 15.9 (2024), 15.9 (2025), 16.6 (2026), 16.8 (2027), 16.9 (2028), 17.0 (2029–2030).
  - Expenditure (commitment basis): 18.5 (2023), 23.2 (2024), 18.7 (2025–2026), 18.6 (2027), 18.9 (2028), 19.2 (2029), 19.6 (2030).
  - Overall balance (commitment basis): -3.4 (2023), -7.3 (2024), -2.8 (2025), -2.1 (2026), -1.8 (2027), -2.0 (2028), -2.2 (2029), -2.6 (2030).
  - Primary balance (commitment basis): -0.3 (2023), -3.3 (2024), 1.5 (2025–2029), 1.0 (2030).
  - Non-oil primary balance (commitment basis): -1.7 (2023), -5.0 (2024), 0.4 (2025–2026), 0.3 (2027), 0.2 (2028), 0.1 (2029), -0.4 (2030).
- Public debt (gross, percent of GDP): 79.1 (2023), 70.2 (2024), 66.0 (2025), 62.3 (2026), 59.5 (2027), 56.6 (2028), 53.8 (2029), 51.9 (2030).
  - Domestic debt: 37.1 (2023), 33.8 (2024), 29.2 (2025), 27.5 (2026), 26.1 (2027), 25.2 (2028), 24.1 (2029), 23.6 (2030).
  - External debt: 42.0 (2023), 36.4 (2024), 36.8 (2025), 34.8 (2026), 33.4 (2027), 31.4 (2028), 29.7 (2029), 28.3 (2030).
- Memorandum: Nominal GDP (billions of GHc): 887 (2023), 1,176 (2024), 1,431 (2025), 1,617 (2026), 1,812 (2027), 2,034 (2028), 2,299 (2029), 2,602 (2030).

### Monetary policy, banking, and financial stability
- Bank of Ghana (BoG) actions and stance:
  - BoG tightened monetary policy to sustain reduction in inflation and has been successful in rebuilding international reserves.
  - Policy rate (percent, end of period): 30.0 (2023), 27.0 (2024), N.A. (2025–2030 in table).
  - Base money growth: 29.7 (2023), 47.8 (2024), 16.2 (2025), -1.1 (2026), 12.7 (2027–2028), 14.8 (2029), 9.8 (2030).
  - Broad money (M2+) growth: 38.7 (2023), 31.9 (2024), 23.4 (2025), 13.0 (2026), 12.1 (2027), 12.3 (2028), 13.0 (2029), 16.1 (2030).
  - Credit to the private sector (commercial banks, annual % change): 10.7 (2023), 26.3 (2024), 24.7 (2025), 17.0 (2026), 16.1 (2027), 16.3 (2028), 17.0 (2029), 19.2 (2030).
- Financial sector measures:
  - Implemented risk containment measures to support banking system stability.
  - Intensified monitoring and escalated measures at weak, undercapitalized banks to promote timely recapitalization; strengthen risk management frameworks and practices, including to reduce NPLs; and ensure effective governance.
  - Authorities committed to sustaining efforts to bolster financial stability, including fully implementing plan to strengthen NIB, finalizing reform strategy for state-owned banks’ viability, and developing contingency plans for weak banks that fail to recapitalize.
  - Emphasis on improving crisis management and resolution framework, enhancing financial-sector safety nets, and addressing legacy issues at specialized deposit-taking institutions.

### Debt restructuring, external financing, and reserves
- Debt restructuring progress:
  - Memorandum of Understanding (MoU) with Ghana’s Official Creditors Committee (OCC) under the G20 Common Framework has been signed by all parties; focus now on finalizing bilateral agreements to implement the MoU.
  - Authorities pursuing good-faith efforts toward agreements with commercial creditors consistent with program parameters and comparability of treatment.
  - Against these policy actions and progress on restructuring, Ghana’s credit rating has been upgraded by key international credit rating agencies (statement in text).
- External financing and program support (selected flows)
  - IMF financing (US$ million): 600 (2023), 1,320 (2024), 720 (2025), 360 (2026), 0 (2027–2030).
  - World Bank financing (US$ million): 27 (2023), 390 (2024), 886 (2025), 487 (2026), 0 (2027–2030).
  - AfDB financing (US$ million): 60 (2023), 0 (2024), 44 (2025), 0 (2026–2030).
  - Debt restructuring related flows (US$ million): 2,677 (2024), 12,031 (2025), 7,474 (2026), 2,812 (2027), 0 (2028–2030).
  - BOP financing gap (US$ million): 3,364 (2024), 13,741 (2025), 9,124 (2026), 3,659 (2027), 0 (2028–2030).
- Note: Projections assume full debt restructuring; large 2024–2026 financing gaps result from debt restructuring accounting, with both debt deferral and the nominal value of the debt exchanges included.

### Structural reforms, social protection, and policy priorities
- Key structural priorities and reforms:
  - Ambitious structural reforms to create an environment conducive to private sector investment and to enhance governance and transparency remain central to boosting potential and underpinning sustainable job creation.
  - Priority areas: strengthening revenue administration, bolstering public financial management, improving SOEs management (including energy and cocoa sectors), and completing debt restructuring.
  - Public financial management reforms to align spending commitments to available resources, including strengthened budget controls and comprehensive audit of payables.
- Social protection and vulnerable groups:
  - Fiscal consolidation strategy emphasizes protecting the vulnerable from the impact of policy adjustment; steps include enhanced social safety nets and creating space for development priorities.
  - Strategy to achieve the 1½ percent of GDP fiscal primary surplus in 2025 through revenue mobilization and expenditure rationalization while protecting the vulnerable.
- Specific sectoral challenges:
  - Energy sector: forceful actions to address challenges and related arrears are critical to contain fiscal risks; accelerate restructuring of Ghana’s electricity company.
  - Cocoa sector: decisive tackling of challenges in the cocoa sector needed to preserve fiscal integrity and SOE performance.

### Risks and outlook summary
- Outlook: Generally positive but growth is set to decline in the near term due to a large negative fiscal impulse and monetary tightening.
- Main risks: significant downside risks if the external environment deteriorates or if policy and reform slippages occur.
- Policy emphasis to secure recovery and sustainability:
  - Stay the course on macroeconomic policy adjustment and reforms to restore macroeconomic stability and debt sustainability while fostering higher and more inclusive growth.
  - Maintain appropriately tight monetary stance until inflation returns to target, reduce BoG footprint in the foreign exchange market, allow greater exchange rate flexibility, and adopt a formal internal FX intervention policy framework.
  - Complete debt restructuring in line with program parameters and comparability of treatment principles.

*Source: IMF staff report — Fourth review under the ECF Arrangement (June–July 2025).*

### 18.4 percent in May,  notably due to significant nominal exchange rate appreciation.

### 1ghaea2025001-source-pdf - 18.4 percent in May,  notably due to significant nominal exchange rate appreciation.

### Recent economic developments
- Year 2024:
  - Current account recorded an estimated surplus of 1.1 percent of GDP.
  - Gross international reserves (GIR) reached US$6.4 billion (2.6 months of prospective imports) at end-December 2024 and US$7.6 billion at end-March 2025 (3 months of prospective imports).
  - Domestic gold purchases grossed over US$3.6 billion in 2024 and accounted for almost a third of the Bank of Ghana’s (BoG) FX inflows.
  - Revaluation of physical gold reserves contributed over US$500 million.
  - BoG FX inflows reached US$11 billion (up 42 percent from 2023) and FX sales (FXI) tripled to US$3 billion in 2024 (including US$2 billion in Q4).
  - Large-scale FXI continued in 2025, reaching US$1.4 billion in Q1.
  - Nominal exchange rate appreciated by 60 percent against the US dollar between November 2024 and May 2025.
- External flows and reserves:
  - Net private sector outflows were higher than projected, with gold-related transactions leading to NFA accumulation by banks.
  - GIR reached 3 months of imports coverage in March 2025, more than one year earlier than previously projected, and is expected to remain at this level in 2026.

### Fiscal performance and payables
- 2024 fiscal outturn:
  - Primary balance (commitment basis) recorded a deficit of 3.3 percent of GDP versus a programmed surplus of 0.5 percent of GDP.
  - Net accumulation of payables is tentatively estimated at some 2.6 percent of GDP.
  - Pre-audited data for 2024 shows a gross accumulation of payables of 5.7 percent of GDP and a clearance of payables of 3.1 percent of GDP.
  - Stock of energy sector payables was largely unchanged at end-2024.
- Text Table 1 (selected figures, 2024 actual):
  - Revenue and grants: 15.9
  - Taxes: 13.3
  - Nontax revenue: 2.4
  - Expenditure: 23.2
  - Compensation of employees: 5.7
  - Interest 1/: 4.0
  - Subsidies and transfers: 1.5
  - Net acquisition of nonfinancial assets: 2.5
  - Primary balance (commitment basis): -3.3
  - Overall balance (commitment basis): -7.3
  - Payables (net change): 2.6
  - Primary balance (cash basis): -0.7
  - Overall balance (cash basis): -4.8
  - Non-oil revenue (excl. Grants): 14.0
  - Oil revenue: 1.7
  - Primary expenditure: 19.2
  - Non-oil primary balance: -5.0
  - Nominal GDP (GHS, million): 1,176,220
  - Notes: 1/ Assume full debt restructuring.
- Box 1 — 2024 fiscal slippages:
  - Fiscal slippages of about 4 percent of GDP emerged ahead of the elections.
  - Out of the GHS67.5 billion (5.7 percent of GDP) gross accumulation of payables in 2024, GHS49.2 billion (4.2 percent of GDP) originated outside GIFMIS.
  - Breakdown of Accumulation of Payables Outside GIFMIS in 2024 (tentative):
    - Compensation: GHS463 mill.; Percent of total 0.9; Percent of GDP 0.04
    - Goods and Services: GHS17,021 mill.; Percent of total 34.6; Percent of GDP 1.45
    - Capital spending: GHS31,753 mill.; Percent of total 64.5; Percent of GDP 2.70
    - MDAs' Total: GHS49,237 mill.; Percent of total 100.0; Percent of GDP 4.19
  - The auditor general has launched a comprehensive audit of the payables accumulated at end-2024; preliminary audit results indicate a significant share may not be supported by valid documentation.

### Program performance and structural reforms
- Performance criteria and targets:
  - All end-December 2024 performance criteria (PCs) and most indicative targets (ITs) were met, except the IT on accumulation of net payables (missed by 3.9 percent of GDP).
  - CPI inflation was above the Monetary Policy Consultation Clause (MPCC)’s upper outer bands in December 2024 (and March 2025), triggering a consultation with the IMF Board.
  - The continuous PC related to Article VIII is met.
- Structural benchmarks (SBs) and reforms:
  - Only 3 out of 11 SBs due between January and May 2025 were met; some missed SBs were implemented with delay.
  - Quarterly electricity tariff adjustments resumed in April 2025 (delayed from end-January 2025).
  - Publication of the audit of Electricity Company of Ghana (ECG)’s collections and uses was achieved in February 2025.
  - Full integration of GHANEPS with GIFMIS (end-December 2024 SB) was achieved in May 2025 (prior action).
  - Forward-looking overarching restructuring plan for NIB completed in May (prior action); government recapitalized NIB to ensure a non-negative CAR (prior action) and to fully comply with minimum CAR of 13 percent (without forbearance), ahead of end-2025 timeline.
  - Two end-September 2025 SBs implemented ahead of schedule: amending the fiscal responsibility framework and adopting a strategy to restructure Ghana’s electricity company.

### Financial sector stability
- Banking sector indicators and actions:
  - Banking sector capital adequacy is improving amid strong liquidity and profitability.
  - Most banks with post-DDE capital deficits are on course to restore a CAR of 13 percent (without reliefs) by end-2025 with support from the Ghana Financial Stability Fund (GFSF).
  - NPL-to-total loan ratio decreased from 26.7 percent to 21.8 percent between end-March and end-December 2024 due to faster expansion in nominal credit.
  - A few banks face larger capital gaps due to slow recapitalization and increased non-performing loans.
  - BoG continued multi-pronged efforts to address increasing NPLs.
  - The GFSF support in 2023 and 2024 was funded through the issuance of marketable government bonds.

### Debt sustainability and macroeconomic outlook
- Debt assessment:
  - Ghana’s public debt is assessed to be sustainable as external debt restructuring is expected to be completed in line with program parameters.
  - Staff’s baseline assumes full post-restructuring macro-framework, domestic debt restructuring, treatment of official bilateral claims agreed with the Official Creditor Committee (OCC), and the recently completed Eurobond exchange.
  - Ghana is assessed at a high risk of debt distress due to near-term breaches of the DSA thresholds but is expected to reach a moderate risk of debt distress by end-2028 with all debt indicators falling below respective thresholds under the baseline.
  - Ghana’s exceptional financing gap is closed with international reserves reaching 3 months of imports at the end of the program.
- Growth and inflation projections:
  - Staff lowered its 2025 growth projection to 4 percent.
  - Growth is projected to return to potential rate of about 5 percent thereafter.
  - Inflation is set to decline to 12 percent by end-2025; return to the BoG’s target band (8±2 percent) delayed to 2026.
  - CA surplus projected to increase to 1.8 percent of GDP in 2025 on high gold prices and to gradually decline over the medium term as gold exports and remittances normalize (remittances expected to remain flat).
  - Net private sector financial outflows expected to remain elevated while external debt payments are increasing.

### Risks and vulnerabilities
- External risks:
  - Exposure to intensification of regional conflicts, trade policy and investment shocks, geoeconomic fragmentation, and commodity price volatility.
  - Volatile tariff policies could weaken external demand and financing availability.
- Domestic risks:
  - New policy slippages, including fiscal overruns, could lead to currency depreciation, higher inflation, deteriorated debt dynamics, and delays in debt restructuring finalization.
  - Postponement of energy sector reforms would require additional budgetary transfers; further accumulation of arrears to IPPs and fuel suppliers could lead to power outages.
  - Delays in recapitalizing banks and addressing legacy issues in the SDI sector could undermine financial sector stability.
  - Credit and liquidity risks add to vulnerabilities.

### Policy discussions and fiscal consolidation measures
- Main policy focus:
  - Corrective measures to address short- and medium-term implications of the 2024 policy slippages.
  - Consolidating stabilization and restoring debt sustainability.
  - Enhancing governance and fostering higher and more inclusive growth.
  - Technical assistance needs to support the reform agenda.
- MoF multipronged strategy to address 2024 slippages:
  - Short-term measures:
    - Reverse new hires of civil servants and pause unbudgeted projects originated by previous administration.
    - Enact a 2025 Budget consistent with a 1.5 percent of GDP fiscal primary balance (end-March 2025 SB).
    - Enact changes to the PFM and Public Procurement Acts to improve fiscal responsibility framework (end-September 2025 SB), enhance controls on commitments, and strengthen sanctions for noncompliance.
    - Launch a comprehensive audit of commitments and arrears at end-2024 with completion expected by end-August 2025 (SB).
  - Medium-term measures:
    - Curtail scope of payables and commitments based on audit findings, legally challenge disqualified payables, and enforce sanctions under the PFM Act.
    - Update centralized inventory of all ongoing and planned projects (estimated to largely exceed the 2025 capital budget) to cancel, rescope, and rephase projects drawing from 2024 audit findings (end-September 2025 SB).
    - Strengthen public investment management consistent with IMF PIMA mission findings.
    - Timely reporting of comprehensive information on all MDAs stock of payables per economic classification (quarterly SB).
    - Limit exemptions to undertake competitive procurement (end-December 2025 SB).
- 2025 Budget:
  - Targets a primary balance surplus of 1.5 percent of GDP on a commitment basis.
  - Measures to increase non-oil revenue collection by more than 0.6 percentage points of GDP (on an annual basis) and contain non-priority primary expenditure.
  - Revenue measures include elimination of several VAT exemptions.

*Source: 1ghaea2025001-source-pdf, https://www.imf.org/-/media/files/publications/cr/2025/english/1ghaea2025001-source-pdf.pdf*

### Box 2. Ghana: Strategy to Address the 2024 Fiscal Slippages

### Box 2. Ghana: Strategy to Address the 2024 Fiscal Slippages

### Overview
- 2024 fiscal slippages increased government debt stock directly and generated potential carryover effects through large accumulation of payables.
- Authorities adopted a multipronged strategy of corrective policy and administrative measures to limit direct impact and avoid carryover effects; most measures enacted, pending measures supported by program conditionality and expected by year-end.
- Comprehensive audit launched in April to ascertain legitimacy and size of 2024 commitments and payables.

### Direct impact: audit and resolution of payables
- A comprehensive audit is expected to be completed by end-August 2025 (SB).
- Government will take legal actions to void all disqualified payables following audit completion.
- Verified commitments and payables will be cleared by 2028 according to a repayment schedule consistent with program objectives.
- Preliminary audit findings indicate a significant part of the GHS67 billion (5.7 percent of GDP) of gross payables originated in 2024 will likely be deemed invalid due to lack of documentation.
- The share of disqualified payables could reach up to 50 percent of total based on similar past audits; if confirmed, the fiscal impact of 2024 slippages would be significantly smaller than staff’s baseline.

### Measures to prevent carryover effects and strengthen commitment control
- Suspension of execution of unbudgeted projects in 2024 until audit completion.
- Measures enacted or planned to ensure commitments align with 2025 Budget spending ceilings:
  - Requiring all MDAs to secure a commitment authorization from MoF before starting procurement (enacted in March 2025).
  - Bolstering the role of the compliance desk to ensure alignment between commitments and available resources and to foster MDAs accountability.
  - Realigning the investment portfolio to available resources by canceling, rescoping, and rephasing current projects drawing from the findings of the 2024 audit (end-September 2025 SB).
  - Restricting conditions for noncompetitive tendering (end-December 2025 SB).
  - Enhancing sanctions for noncompliance with PFM provisions (enacted in March).

### Fiscal framework and PFM reforms
- PFM Act amended ahead of schedule to adopt a fiscal rule centered on a debt anchor and a primary balance operative target, and to establish an independent fiscal council (¶22).
- Fiscal rule details:
  - Long-term debt-to-GDP anchor: 45 percent of GDP by 2034.
  - Operational target: primary balance on commitment basis.
  - Defines escape clauses and correction mechanisms.
  - Minister of Finance could be removed from office if the fiscal rule is breached more than two consecutive times.
  - If breaches emerge, authorities required to identify corrective measures to ensure timely convergence to the debt anchor.
- Integration of GHANEPS and GIFMIS systems completed and started operating in May 2025; coverage to reach 90 percent of total procurements by end-2025.
- Progress on single treasury account: additional 549 MDA and MMDA accounts onboarded onto GIFMIS at end-March 2025 (SB).
- Legislative amendments to merge selected statutory funds with line ministries are being prepared (end-June 2025 SB).

### Public investment management and audit of payables
- Public Investment Management Assessment (PIMA) update mission in April found improved institutional design since 2016 but implementation weaknesses contributed to overcommitment.
- Authorities committed to implement PIMA recommendations to improve project selection, implementation, and monitoring.
- Audit of payables conducted by Auditor General with assistance of two international firms to verify compliance with PFM provisions.

### Revenue measures and 2025 revenue package (Text Table 3 yields)
- Total yield (full year): 10,283 (GHS mn) — 0.72 (% of GDP)
- Total yield (Apr-Dec): 8,649 (GHS mn) — 0.60 (% of GDP)
- Selected line items (GHS mn and % of GDP exactly as presented):
  - Elimination of VAT exemption on Non-Life Insurance excluding motor policy: 1570.01
  - Elimination of VAT exemption on supply of residential property (real estate): 2,7770.19
  - Removal of the 10% WHT on all gross gaming winnings from lottery operations: -198-0.01
  - Removal of E-Transaction Levy of 1%: -2,480-0.17
  - Increase the Growth & Sustainability Levy rate from 1% to 3% on the gross production value of mining companies, and extend the levy to 2028: 3,9580.28
  - Reduce tax refund rate from 6% of non-oil tax revenue to 4%: 4,2230.30
  - Expand the coverage of the voluntary disclosure policy (VDP): 1,1750.08
  - Implementation of the Modified Taxation System to include taxpayers in the informal sector: 1,1440.08
  - One-off dividend from Minerals Income Investment Fund (MIIF): 2,1000.15
  - Erosion of non-oil revenue-to-GDP ratio due to the impact of inflation: -2,575-0.18
- Notes:
  - Some levies/taxes have never been fully implemented and yield zero revenues.
  - Yields for items 6 and 10 are not pro-rated although the Budget was announced in March as these measures can be applied retrospectively.

### Social spending and poverty
- Poverty rate declined from 26.4 percent in 2023 to 25.9 percent in 2024 (population living in extreme poverty measured at the international poverty line of US$2.15 per day).
- 2025 Budget increased allocation for social protection programs by 0.34 percentage points to 0.91 percent of GDP.
- LEAP beneficiary households to increase from 350,000 to 400,000 by end-September 2025 (SB); benefits to have automatic indexation to inflation.
- 2025 Budget increased allocations to GSFP, NHIS, and Capitation Grant to support basic education for the poor, compensate for high food inflation, allow purchases of essential vaccines and medicines, and implement new NHIS initiatives.
- Authorities simplifying administrative procedures to ensure timely disbursement of benefits and aim to expand social protection programs to eliminate extreme poverty over the medium term.

### Revenue administration and extractives framework
- Cleansing of taxpayer registry and ledger data delayed: planned end-June 2024 (SB) now expected end-June 2025 and end-December 2025 respectively.
- Operationalization of Integrated Tax Administration System (ITAS) delayed to end-March 2026.
- Medium-Term Revenue Strategy (MTRS) guides revenue mobilization efforts over 2024-27; review planned in early 2026 with Fund support.
- Fiscal Regime Framework for Extractive Industries (FRFEI) to be submitted to Parliament by end-July 2025.

### Energy sector fiscal risks and mitigation
- At end-December 2024, net payables to IPPs and fuel suppliers exceeded US$2 billion.
- In 2025, absent policy action, annual energy sector shortfall estimated to reach US$2.2 billion.
- 2025 Budget allocated GHS27.1 billion (around US$1.7 billion) to cover the shortfall, assuming policy actions to reduce it.
- Planned policy actions include resuming quarterly tariff adjustments (quarterly SB) and conducting a multi-year tariff assessment (MYTO) to reflect energy production costs (end-September 2025 SB), enhancing revenue collection, and limiting arrears accumulation.
- April: PURC announced a 14.75 percent increase in electricity tariffs.
- ECG Revenue/Collection Accounts Validation Reports for 2023Q4 and 2024 completed with delay; 2024 report highlighted:
  - Significant deviations between ECG’s validated and declared collections: GHS5.3 billion.
  - Deviations between Cash Waterfall Mechanism (CWM) allocations and actual payments: GHS3.9 billion.
  - Part of the difference diverted to emergency fuel purchases.
- Compliance with the CWM improved in 2025 with monthly ECG collections exceeding the minimum GHS1 billion, though some IPPs received less than expected.

### Cocoa sector developments
- 2024/25 production recovered due to favorable climate and interventions (artificial pollination, mass pruning, mass spraying and hi-tech); international cocoa prices remained high.
- Cocobod expected to honor rolled-over and current-season contracts except for a small agreed share.
- New financing model reduces reliance on syndicated loans and appears to have reduced liquidity constraints, delivering faster payments to farmers.
- Cocobod’s cash flow expected to remain balanced during the current season.
- Cocobod turnaround strategy aims to:
  - Strengthen financial oversight.
  - Maintain producer price within the range of 60-70 percent of international prices.
  - Rationalize costs based on a functional review.
  - Phase out quasi-fiscal activities (e.g., cocoa roads and fertilizer programs).
- World Bank supporting a functional and expenditure review and development of a cocoa sector modernization strategy; progress on rescoping or canceling road contracts has been slow.

*Source: Box 2. Ghana: Strategy to Address the 2024 Fiscal Slippages (extracted from the provided IMF content).*

### 29. The authorities have made significant

### 1ghaea2025001-source-pdf - 29. The authorities have made significant

### Debt restructuring and external creditors
- DDE and the Eurobond restructuring were completed respectively in 2023 and October 2024.
- Memorandum of Understanding (MoU) with the Official Creditor Committee (OCC) on the debt treatment agreement reached in June 2024 was signed by all parties in January 2025.
- Ghana is working with OCC members on bilateral agreements to implement the MoU and is pursuing good-faith efforts to reach agreements with other external commercial creditors on comparable terms and consistent with program parameters.
- Authorities have reached out to all external commercial creditors to advance debt data reconciliation and to eventually share debt treatment proposals.
- Given progress, Moody’s, Fitch, and S&P upgraded Ghana’s credit risk rating in the past six months, lifting the selected default status.
- Program anchor: restoring debt sustainability under the program aims to achieve a moderate risk of debt distress by 2028, bringing five external and overall debt ratios below their respective thresholds, and seeking sufficient external debt service relief to ensure the program is fully funded through 2026.

### External project loans and fiscal control
- Second round of prioritization of the estimated US$3.6 billion total project loan stock—signed but not disbursed before the external debt restructuring cut-off date (CoD) of December 2022—completed in May 2025.
- Revised list of 24 prioritized projects was shared with the OCC.
- Disbursements on bilateral and commercial projects signed before December 2022 are capped at US$250 million (IT) per year until 2026.
- 2024 disbursements were US$184.4 million.
- The 2025 Budget foresees US$250 million in disbursements.
- MoF is working with multilateral partners to pace project loan disbursements consistent with budget constraints and seeking a rebalancing of financial assistance toward budget support.

### Domestic bond market and government financing
- Since the 2023 domestic debt restructuring, the government has relied on T-bills as the main source of domestic financing.
- Most T-bills are issued through auctions; private placements were made in 2024 primarily with non-bank investors (individuals, insurance and investment funds).
- T-bill rates have dropped significantly since March 2025.
- Despite large fiscal adjustment in 2025, gross financing needs are expected to remain elevated due to large debt service obligations and arrears clearance (including the energy sector legacy debt).
- IMF TA planned for July 2025; authorities intend to resume T-bond issuance by gradually extending maturities to smoothen the debt repayment profile.
- Non-resident investors’ participation will be considered if consistent with the program’s debt objectives.

### Debt management capacity and transparency
- Authorities intend to increase surveillance on debt issuance by SOEs and other public entities and strictly limit borrowing on non-concessional or collateralized terms.
- IMF TA requested to support capacity building in debt sustainability analysis and liability management at the MoF’s Debt Management Office (DMO).
- Strengthening DMO’s role includes establishing an investment relations unit and upgrading the securities operation infrastructure system (CS-DRMS).
- MoF publishes Annual Public Debt Reports and will disseminate a revised medium-term debt management strategy based on the approved 2025 Budget.

### Monetary policy and exchange rate management
- BoG committed to maintaining a tight monetary policy stance until inflation returns to its target (MEFP¶22–25).
- In March 2025, the Monetary Policy Committee increased the policy rate by 100 basis points; the policy rate was kept unchanged in May 2025.
- Inflation target: 8±2 percent by 2026.
- BoG will scale up open market operations (OMOs) to make them the primary instrument for liquidity absorption and reduce reliance on the unremunerated cash reserve ratio (CRR).
- Outstanding OMOs reached a record GHS40 billion at end-April 2025.
- BoG plans to review its CRR framework (including its coefficient and the dynamic CRR) and add a 273-day BoG bill to supplement the 56-day bill in conducting OMOs.
- Ghana’s de facto exchange rate arrangement reclassified as “other managed” (from “crawl-like”) effective May 15, 2024.

### Reserves, FX interventions, and gold operations
- BoG scaled up the Domestic Gold Purchase Program (DGPP), becoming a large gold market intermediary.
- Gold holdings doubled in 2024, increasing risks to BoG’s balance sheet.
- Accumulation of foreign assets led to a 48 percent surge in base money in 2024 that was not fully sterilized through OMOs, with repercussions for inflation and the exchange rate.
- BoG conducted repeated ad hoc FXIs for about US$4 billion between October 2024 and April 2025, contributing to cedi appreciation and lessening domestic liquidity increases.
- BoG intends to adopt a comprehensive FXI policy (end-September 2025 SB) emphasizing transparency and rules-based transactions.
- BoG discontinued bilateral adjudications for FXI; they have been replaced by forward auctions.

### Multiple currency practices (MCPs)
- MCPs arise from several official actions (i to vi) including use of previous day’s BoG reference rates, application of fees, and use of Bloomberg regional bid rates in specific transactions.
- Most recent days when impermissible spreads arose:
  - i) and iii): May 23rd, 2025
  - ii) and vi): April 24th, 2025
  - iv): December 17th, 2024
  - v): November 27th, 2024
- Authorities consider economic impact minimal and are committed to eliminating MCPs through reforms.

### Gold sector developments (Box 3)
- Gold mining: key segment; almost 50 percent surge in gold prices since end-2023.
- In 2024, over 4.5 million ounces of gold worth US$10 billion were mined and exported, accounting for around 5 percent of Ghana’s GDP (at 2013 prices), a 20 percent increase compared to 2023.
- Increase in 2024 production was entirely attributable to artisanal and small-scale mining (ASM); large-scale mining is around 3 million ounces per year.
- DGPP in 2024 almost tripled FX gross proceeds to US$2.8 billion, in addition to US$800 million accumulated in physical gold.
- Value of BoG’s existing stock of gold increased by over US$500 million in 2024, lifting GIR.
- GoldBod established by Parliament in April 2025 with a US$279 million endowment; GoldBod’s stated objective is to turn over three tons of gold weekly.
- GoldBod replaces the Precious Minerals Marketing Company in most aspects and entails significant operational, fiscal and governance risks requiring strict accountability, transparency, and risk management.

### Financial sector stability, recapitalization, and NPLs
- Most of the thirteen banks with post-DDE capital deficits have met or exceeded recapitalization requirements at end-2024 and are on course to restore CAR of 13 percent (without reliefs) by end-2025.
- Some banks (including one state-owned) remain materially behind on recapitalization due to slow shareholder commitments, higher NPLs, and delayed booking of credit impairments; these banks face intensified BoG monitoring and corrective measures to reach CAR of 13 percent (end-March 2025 SB) by end-2025.
- Parliamentary approval and implementation of the World Bank funded segment of the GFSF could help some banks achieve CAR targets by end-2025, provided sufficient capital injections.
- NPL ratio remains at 22.6 percent (down from 26.7 percent at 2024Q1).
- Authorities’ measures to address NPLs include strengthening credit risk management, prompt recognition and provisioning for NPLs, monitoring bank performance against NPL reduction strategies, and intensifying corrective actions.
- BoG leading development of a multi-agency strategy to address structural obstacles to problem credit recovery.
- Specialized deposit-taking institutions (SDI) sector remains undercapitalized and weighed down by legacy issues; several GFSSS areas yet to be implemented.
- BoG reviewing/updating prudential and operational risk standards, advancing Basel II and III implementation; post-DDE regulatory reliefs will cease by end-2025.

### Crisis management, resolution framework, and state-owned banks
- High Court rulings (November 2024 and March 2025) reversing BoG’s 2019 revocations of two SDI licenses create risks to stability and resolution framework efficacy.
- Authorities will prepare, with Fund assistance, amendments to the crisis management and resolution framework and submit them to Parliament (end-December 2025 SB) to align further with international standards.
- Strategy to address NIB challenges adopted March 2024:
  - Recapitalization: authorities injected cash and bonds to bring NIB’s CAR to positive territory (prior action) and full compliance with minimum CAR of 13 percent (without forbearance), ahead of end-2025 timeline.
  - Forward-looking restructuring plan for NIB prepared (prior action) and approved by Cabinet for early implementation; plan completed end-March 2025 SB.
- Government will conduct a diagnostic review of other state-owned banks to inform reform strategy (end-April 2025 SB); preparation of the strategy delayed to end-August 2025 to draw from NIB plan.
- BoG announced intention to divest share ownership in Agricultural Development Bank.

### AML/CFT framework improvements
- Authorities committed to strengthening effectiveness of AML/CFT framework.
- Priorities include:
  - Enhancing availability and accessibility of beneficial ownership (BO) information and ensuring Registrar of Companies is comprehensive and up to date.
  - Making BO information regime more robust through enforcement of sanctions.
  - Addressing gaps in reporting of suspicious transactions by designated non-financial businesses and professions.
  - Enhancing AML/CFT supervisory coordination nationally and internationally.

*Sources: Ghanaian authorities and Fund Staff Calculations.*

### 43. The authorities consider enhancing governance and addressing vulnerabilities to

### 43. The authorities consider enhancing governance and addressing vulnerabilities to 

### Governance, anti-corruption, and transparency
- Authorities prioritize enhancing governance and addressing vulnerabilities to corruption (MEFP¶65–66).
- President Mahama’s manifesto emphasizes renewed efforts to eliminate pervasive corruption and improve governance.
- Actions underway or planned:
  - Reviewing a draft IMF Governance and Corruption Diagnostic Assessment (GDA) report, which they intend to publish.
  - In May 2025, the Presidency unveiled a Code of Conduct binding for all appointees, including commitments on conflicts of interest, corruption, asset declaration, transparency and public financial management.
  - The Auditor General published the COVID-19 Expenditure follow-up report to improve transparency and accountability on the use of public resources.
  - The authorities will submit to parliament a law on asset declaration for public officials (end-September 2025 SB).
  - Envisage measures to strengthen the integrity and efficiency of public procurement and revenue administration processes.

### Growth strategy and development priorities
- Government growth strategy focuses on boosting private investment, diversifying the economy, and fostering inclusive growth (MEFP¶67).
- Reflected in the 2025 Budget: “Big Push” infrastructure program, decentralization to district assemblies, agricultural transformation, specialized training and apprenticeship programs, and a Women’s development bank.
- Policy elements and measures:
  - “24-hour economy policy” (details not yet announced) promises tax, financing and other incentives for 24/7 production and support for “priority value chains”.
  - Development financial services will leverage existing financial and credit facilities specifically catering to women.

### Program financing and modalities—assurances and major financing commitments
- Program fully financed with firm financing commitments for the next 12 months and good prospects for adequate financing for the remainder of the program (Text Table 2).
- World Bank commitments:
  - DPO2 currently estimated at US$360 million to be disbursed mid-year.
  - DPO3 US$340 million by end-2025.
  - Increased amount for Program-for-Results financing (PforR) used for budget support instead of project support.
  - Total WB budget support under the program (2023-26) expected to increase by about US$270 million.
- African Development Bank (AfDB) grants of US$44 million were delayed to 2025; no further budget support expected from AfDB after 2025.
- Ongoing debt restructuring expected to generate financing consistent with program parameters and restore debt sustainability.
  - Signing of the MoU between the government and the OCC and preparation of bilateral agreements satisfy the Fund’s Lending into Official Arrears (LIOA) policy.
  - Arrears to other official bilateral creditors deemed away in application of the LIOA policy (Strand 1).
  - Following successful Eurobond restructuring, authorities making good faith efforts to reach debt restructuring agreements with other external commercial creditors on comparable terms and within program parameters.

### Proposed modifications to program conditionality
- Modifications through end-December 2025:
  - Primary balance PC and non-oil revenue IT will be modified to accommodate macroeconomic developments while maintaining the fiscal effort relative to GDP.
  - MPCC bands will be shifted upwards in September and December 2025 to reflect recent macroeconomic developments on disinflation.
  - IT on social spending will be modified to reflect the impact of inflation indexation on certain social benefits.
  - TMU modified to add GoldBod to the list of public entities included in PCs; to improve monitoring of the net change in energy sector payables for the primary fiscal balance PC and the central government payables IT; and to clarify exceptions to the BoG claims on the central government PC.
- New conditionality through end-March 2026:
  - ITs until end-March 2026 will be established along with six new SBs for end-August 2025 through end-December 2025, focused on macro-critical reforms.

### Text Table 4: Ghana—Proposed Program Financing (USD million)
- Pre-restructuring Financing Gap
  - 2023: 3,364
  - 2024: 4,340
  - 2025: 4,542
  - 2026: 2,328
  - Total: 14,574
- Debt service relief from restructuring
  - 2023: 2,677
  - 2024: 2,630
  - 2025: 2,892
  - 2026: 1,481
  - Total: 9,680
- Official creditors
  - 2023: 836
  - 2024: 750
  - 2025: 657
  - 2026: 604
  - Total: 2,847
- Commercial creditors
  - 2023: 1,841
  - 2024: 1,880
  - 2025: 2,235
  - 2026: 877
  - Total: 6,833
- Post-restructuring financing gap
  - 2023: 687
  - 2024: 1,710
  - 2025: 1,650
  - 2026: 847
  - Total: 4,893
- IMF
  - 2023: 600
  - 2024: 1,320
  - 2025: 720
  - 2026: 360
  - Total: 3,000
- World Bank
  - 2023: 273
  - 2024: 908
  - 2025: 864
  - 2026: 871
  - Total: 1,790
- African Development Bank
  - 2023: 600
  - 2024: 440
  - 2025: 104
  - 2026: (blank in table)

- Footnotes in table (as presented):
  - 1 Pre-restructuring financing gap before external debt treatment from bilateral and commercial creditors (and net of arrears bond debt service). Numbers presented here exclude the flows shown in the SEI, BOP and external financing tables related to debt exchanges (large outflows under portfolio and official flows).
  - 5 Beyond the IDA20 period, IDA financing figures are based on assumptions; actuals will depend on IDA replenishment volumes, country performance, and other operational factors. Delivery of DPFs will be dependent on an agreement with the government on a strong program of policy and institutional reforms, and adequacy of the macroeconomic policy framework. In addition, the World Bank is planning to disburse US$1.8 billion for project loans during 2023-26, already included in the baseline.
  - 2 Actual debt service arrears accumulated in 2023
  - 3 Based on June 2024 MoU between Ghana and G20 Common Framework OCC
  - 4 Based on October 2024 Eurobond restructuring and the authorities' restructuring strategy for other commercial creditors

### Enterprise risks, capacity to repay (CtR), and mitigating factors
- Enterprise risks significant but mitigated by strong program design, authorities’ high commitment, and financing assurances.
- Capacity to repay (CtR) assessment:
  - CtR adequate but subject to significant downside risks, including from significant repayments to the Fund in 2025 and beyond.
  - Assessment assumes successful program and debt restructuring implementation, predicated on achieving moderate risk of debt distress and restoring adequate market access.
  - Stock of debt to the Fund as a share of GDP peaks in 2025 at 4.2 percent of GDP.
  - Debt service obligations to the Fund will reach a peak of 12.0 percent of total debt service in 2030.
  - SDR holdings: SDR 31.9 million at end-February 2025.
- Downside risks stem from delays in implementing program policies and reforms, which could adversely affect key donors’ financing.
- Mitigating factors:
  - Ghana’s strong track record of debt service to the Fund.
  - Financing assurances provided by creditors and development partners.
  - Strong reserve accumulation.
  - Authorities’ strong commitment and ownership of the program, attested by adoption of corrective measures (¶14).

### Staff appraisal—main findings and policy recommendations
- Overall assessment:
  - Despite election-related slippages, Ghana is poised to make further progress toward stabilization and higher and more inclusive growth.
  - New authorities have shown high program ownership and adopted corrective policy and structural measures following fiscal overruns, high inflation and reform delays.
- Fiscal policy and public financial management:
  - Preserving fiscal policy adjustment integrity is essential to restore macroeconomic stability and debt sustainability while protecting the vulnerable.
  - Authorities should implement strategy to address 2024 fiscal slippages and stand ready to adopt contingency measures, such as frontloading revenue measures in the MTRS and reprioritizing MDAs’ budget allocations.
  - Beyond 2025, maintaining a primary fiscal surplus of 1½ percent of GDP will further reduce financing needs.
  - Further improve domestic revenue mobilization—including careful design and phasing of the announced VAT reform—and streamline nonpriority expenditures.
  - Strengthen social programs to protect the vulnerable from high cost of living and macroeconomic adjustment.
  - Commended for continued efforts to reach agreements with external commercial creditors consistent with program parameters and comparability of treatment.
- Fiscal structural reforms and governance:
  - Bring forward enactment of an enhanced fiscal responsibility framework and ensure accountability in accordance with applicable laws and procedures.
  - Complement framework with strengthened commitment controls and budget execution to foster effective compliance with PFM provisions and reduce spending overruns.
  - Bolster Ministry of Finance’s compliance desk to strengthen sanction system for noncompliance with PFM provisions.
  - More actions needed to streamline statutory funds, bolster governance and transparency in public procurement, and address weaknesses in public investment management.
  - Improve revenue administration, strengthen tax compliance, and support comprehensive tax reform, especially of the VAT regime consistent with MTRS priorities.
  - GoldBod should adhere to highest governance standards and limit fiscal risks.
  - Ensure steadfast implementation of the Cocobod turnaround strategy.
- Energy sector reforms:
  - Essential to reduce fiscal risks.
  - Staff welcomes decision to open electricity company operations to private sector and efforts towards energy sector financial sustainability, including resuming quarterly electricity tariff increases.
  - Short-term priorities: efficiency gains at ECG to reduce energy sector shortfall, full and consistent implementation of the Cash Waterfall Mechanism, address legacy arrears, and improve transparency, governance and accountability in the sector.
- Monetary policy and central bank governance:
  - BoG should maintain a tight monetary policy stance and pursue reforms.
  - Increased reliance on OMOs for liquidity absorption is warranted to bring inflation to BoG’s target band.
  - Submission to Parliament of amendments to the BoG Act (albeit delayed) is an important milestone toward strengthening central bank independence.
  - Further progress needed to address the Fund’s safeguard assessment recommendations.
- Reserves management and FX policy:
  - Rebuilding international reserves is a significant achievement; BoG should carefully manage gold-related risks and enhance its FXI framework.
  - Reserve accumulation overperformance reflects significant expansion of the DGPP; careful management of related portfolio risks and liquidity implications required.
  - Replacing bilateral adjudications with transparent auction-based FX auctions improves transparency of BoG’s FX operations.
  - Priority: deepen interbank FX market by reducing BoG’s footprint and allowing greater exchange rate flexibility, including adoption of a formal internal FX intervention policy framework.
- Financial sector stability and resolution framework:
  - Further strengthening financial sector stability remains paramount.
  - BoG implemented risk containment measures, intensified monitoring, and escalated measures at weak undercapitalized banks to promote recapitalization, strengthen risk management, reduce NPLs, and ensure effective governance.
  - Fully implement plan to strengthen NIB and finalize reform strategy to support state-owned banks’ viability and sustainability.
  - Develop contingency plans to address weak banks that fail to recapitalize.
  - Rapidly improve Ghana’s crisis management and resolution legislation framework, strengthen financial sector safety nets—including enhancing the Ghana Deposit Protection Corporation—and address legacy problems at SDIs in a cost-effective way.

*INTERNATIONAL MONETARY FUND*

### 56. Given Ghana’s forceful response to recent policy slippages and the commitments under

### 56. Given Ghana’s forceful response to recent policy slippages and the commitments under the program, staff supports the completion of the monetary policy consultation, the fourth review under the ECF arrangement, the financing assurances review related to private sector creditors, and the request for modification of performance criteria.

### Program status and staff recommendation
- Staff supports:
  - completion of the monetary policy consultation.
  - the fourth review under the ECF arrangement.
  - the financing assurances review related to private sector creditors.
  - the request for modification of performance criteria.

### Selected economic and financial indicators (highlights from Table 1)
- Real GDP (annual percent change): 3.1; 4.0; 5.7; 4.4; 4.0; 4.9; 4.8; 4.9; 5.0; 5.0; 5.0
- Non-extractive GDP (annual percent change): 3.3; 3.5; 5.1; 4.5; 3.6; 5.0; 4.6; 5.0; 5.0; 5.0; 5.0
- Real GDP per capita (annual percent change): 1.2; 2.0; 3.7; 2.5; 2.1; 3.0; 2.9; 3.1; 3.2; 3.2; 3.3
- GDP deflator (annual percent change): 40.1; 20.4; 25.4; 10.6; 17.0; 7.8; 7.8; 6.8; 6.9; 7.6; 7.8
- Consumer price index (end of period): 23.2; 18.0; 23.8; 8.0; 12.0; 8.0; 8.0; 8.0; 8.0; 8.0; 8.0
- Central government revenue (percent of GDP): 15.2; 17.1; 15.9; 17.2; 15.9; 18.1; 16.6; 16.8; 16.9; 17.0; 17.0
- Central government expenditure (commitment basis, percent of GDP): 18.5; 20.7; 23.2; 19.8; 18.7; 20.0; 18.7; 18.6; 18.9; 19.2; 19.6
- Overall balance (commitment basis, percent of GDP): -3.4; -3.5; -7.3; -2.7; -2.8; -1.9; -2.1; -1.8; -2.0; -2.2; -2.6
- Public debt (gross, percent of GDP): 79.1; 78.0; 70.2; 72.2; 66.0; 67.2; 62.3; 59.5; 56.6; 53.8; 51.9
- Credit to the private sector (commercial banks, percent of GDP): 10.7; 22.0; 26.3; 18.4; 24.7; 17.1; 17.0; 16.1; 16.3; 17.0; 19.2
- Gross international reserves (program, US$ million): 3,661; 5,381; 6,404; 6,905; 8,366; 7,789; 7,926; 9,585; 11,358; 13,614; 14,948
- Gross international reserves (months of prospective imports): 1.5; 2.3; 2.6; 2.8; 3.3; 3.0; 3.0; 3.5; 3.9; 4.5; 4.8
- Nominal GDP (millions of GHc): 887,748; 1,053,875; 1,176,220; 1,216,674; 1,431,278; 1,375,843; 1,616,898; 1,811,873; 2,034,005; 2,298,797; 2,602,217
- Population Growth Rate (percentage): 1.9; 1.9; 1.9; 1.8; 1.8; 1.8; 1.8; 1.8; 1.7; 1.7; 1.7

### Central government budget (Table 2a highlights)
- Revenue and grants (percent of GDP): 15.2; 17.1; 15.9; 17.2; 15.9; 18.1; 16.6; 16.8; 16.9; 17.0; 17.0
- Taxes (percent of GDP): 12.8; 14.6; 13.3; 14.7; 13.3; 15.6; 14.1; 14.3; 14.4; 14.5; 14.5
  - Direct taxes: 6.4; 7.3; 6.7; 6.5; 6.4; 6.4; 6.9; 7.0; 7.1; 7.2; 7.2
  - Indirect taxes: 4.9; 5.5; 4.9; 6.3; 5.2; 7.1; 5.4; 5.5; 5.5; 5.5; 5.5
- Interest (percent of GDP): 3.0; 4.0; 4.0; 4.2; 4.3; 3.4; 3.6; 3.3; 3.5; 3.7; 3.6
  - Domestic interest: 2.9; 3.4; 3.4; 3.4; 3.6; 2.7; 2.9; 2.6; 2.7; 2.9; 2.8
  - Foreign interest: 0.2; 0.6; 0.6; 0.7; 0.6; 0.7; 0.6; 0.7; 0.8; 0.8; 0.9
- Primary balance (commitment basis, percent of GDP): -0.3; 0.5; -3.3; 1.5; 1.5; 1.5; 1.5; 1.5; 1.5; 1.5; 1.0
- Non-oil primary balance (commitment basis, percent of GDP): -1.7; -1.2; -5.0; 0.1; 0.4; 0.2; 0.4; 0.3; 0.2; 0.1; -0.4
- Overall balance (cash basis, percent of GDP): -2.9; -4.6; -4.8; -3.7; -3.7; -2.9; -3.8; -3.4; -3.5; -2.2; -2.6

### Budgetary central government operations (GHS millions, Table 2b highlights)
- Revenue and grants (GHS millions): 134,672; 180,545; 186,593; 208,772; 227,195; 248,860; 268,534; 304,445; 343,747; 390,796; 442,377
- Expenditure (GHS millions): 164,556; 217,642; 272,620; 241,082; 267,316; 275,093; 301,694; 336,710; 384,561; 441,129; 511,189
- Interest (GHS millions): 27,055; 41,902; 47,150; 50,561; 61,110; 46,870; 57,413; 59,443; 71,324; 84,816; 94,834
  - Domestic interest (GHS millions): 25,674; 35,824; 40,416; 41,958; 51,859; 37,555; 47,350; 46,696; 55,866; 66,433; 72,561
  - Foreign interest (GHS millions): 1,381; 6,078; 6,734; 8,602; 9,251; 9,314; 10,063; 12,747; 15,458; 18,383; 22,272
- Primary balance (commitment basis, GHS millions): -2,829; 4,806; -38,877; 18,250; 20,989; 20,638; 24,253; 27,178; 30,510; 34,482; 26,022
- Overall balance (commitment basis, GHS millions): -29,884; -37,097; -86,027; -32,310; -40,122; -26,232; -33,160; -32,265; -40,814; -50,334; -68,812

### Public sector gross financing needs and sources (Table 2c highlights)
- Gross financing needs (GHS billions): 86.4; 121.7; 129.7; 132.7; 161.2; 155.2; 188.8; 212.0; 251.1; 240.0; 273.6
- Debt service (GHS billions): 82.1; 102.3; 122.5; 141.9; 160.9; 165.1; 188.0; 211.9; 254.2; 274.5; 298.5
  - External debt service: 5.7; 16.2; 12.1; 25.4; 26.1; 40.3; 41.8; 42.1; 56.9; 58.0; 70.2
  - Domestic debt service: 76.4; 86.1; 110.4; 116.5; 134.7; 124.8; 146.2; 161.6; 198.5; 211.7; 228.3
- Gross financing sources (GHS billions): 78.8; 96.3; 105.4; 109.0; 134.4; 142.8; 173.9; 212.0; 251.1; 240.0; 273.6
  - External financing (GHS billions): 9.4; 10.4; 10.5; 12.0; 8.9; 23.0; 22.6; 41.8; 42.1; 56.9; 58.0
  - Domestic financing (GHS billions): 71.6; 87.5; 96.9; 98.7; 127.1; 121.5; 153.1; 172.2; 211.4; 186.1; 218.9
- Financing gap (GHS billions): 7.6; 25.4; 24.3; 23.6; 26.8; 12.4; 14.9; 0.0; 0.0; 0.0; 0.0
  - Exceptional financing (GHS billions): 7.6; 25.4; 24.3; 23.6; 26.8; 12.4; 14.9; 0.0; 0.0; 0.0; 0.0
  - IMF (GHS billions): 6.6; 19.1; 18.7; 11.8; 11.7; 6.1; 6.3; 0.0; 0.0; 0.0; 0.0

### Monetary developments (Table 3 highlights)
- Money and quasi-money (M3, GHS millions): 250,019; 321,937; 329,739; 377,487; 406,750; 426,871; 459,501; 514,910; 578,037; 653,288; 758,334
- Broad money (M2, GHS millions): 185,426; 241,054; 247,762; 284,110; 306,997; 321,278; 346,811; 388,631; 436,277; 493,073; 575,370
- Net foreign assets (I, GHS millions): 21,711; 59,099; 87,417; 90,218; 138,434; 111,358; 141,234; 185,966; 236,308; 301,659; 354,963
- Credit to private sector (GHS millions): 77,464; 93,513; 97,439; 109,065; 119,874; 126,171; 138,335; 158,832; 183,003; 212,511; 251,590
- Base money (mem item): 29.7; 30.5; 47.8; 11.8; 11.6; 2.6; 6.7; -1.1; 12.7; 12.7; 14.8; 9.8

### External sector and financing needs (Tables 4 and 5 highlights)
- Current account (US$ millions): -1,289; 760; 924; 281; 1,596; 121; 1,312; 1,474; 1,355; 1,191; 566
- Trade balance (US$ millions): 1,707; 3,114; 3,773; 3,208; 4,659; 3,930; 5,077; 5,168; 5,390; 5,867; 5,907
- Exports, f.o.b. (US$ millions): 15,716; 18,158; 19,165; 18,721; 20,213; 20,274; 21,420; 22,123; 22,860; 24,117; 24,964
- Imports, f.o.b. (US$ millions): -14,009; -15,044; -15,392; -15,513; -15,554; -16,344; -16,343; -16,955; -17,469; -18,250; -19,057
- Financing gap (US$ millions): 3,364; 1,754; 13,741; 1,448; 9,124; 734; 3,659; 0; 0; 0; 0
- If financing gap is closed, gross international reserves (US$ millions): 3,661; 5,381; 6,404; 6,905; 8,366; 7,789; 7,926; 9,585; 11,358; 13,614; 14,948
- External financing needs (Total Needs, US$ millions): 3,728; 1,879; 2,850; 2,339; 6,662; 2,757; 110; 2,451; 2,709; 3,514; 3,289
  - Total Sources (US$ millions): 364; 125; -10,891; 891; -2,462; 2,023; -3,549; 2,451; 2,709; 3,514; 3,289
  - Financing Gap (I-II, US$ millions): 3,364; 1,754; 13,741; 1,448; 9,124; 734; 3,659; 0; 0; 0; 0
- Expected sources of financing (US$ millions):
  - IMF: 600; 1,320; 1,320; 720; 720; 360; 360; 0; 0; 0; 0
  - World Bank: 273; 90; 390; 907; 288; 863; 744; 870; 0; 0; 0
  - AfDB: 60; 44; 0; 440; 0; 0; 0; 0; 0; 0; 0
  - Debt restructuring-related flows: 2,677; 0; 12,031; 0; 7,474; 0; 2,812; 0; 0; 0; 0

### Financial soundness indicators (Table 6 highlights, Dec-24 prelim.)
- Regulatory capital to risk weighted assets: 17.8; 17.8; 15.6; 21.9; 20.9; 19.8; 19.6; 16.6; 13.9; 14.3; 14.0
- Nonperforming loans to total gross loans: 14.7; 17.3; 21.6; 18.2; 13.9; 14.8; 15.1; 14.8; 20.6; 24.1; 21.8
- Provisions to nonperforming loans: 69.3; 72.5; 77.7; 71.5; 82.7; 84.3; 83.2; 87.9; 73.2; 75.7; 78.7
- Return on assets (after tax): 4.5; 3.8; 3.7; 3.5; 4.0; 4.3; 4.6; 3.2; 5.4; 5.4; 5.0
- Liquid asset to total assets: 48.4; 53.7; 56.0; 58.6; 59.3; 63.0; 64.7; 61.7; 65.7; 67.5; 66.9

### Indicators of capacity to repay the Fund (Table 7 highlights)
- Fund obligations based on existing credit (principal, millions of SDRs): 198; 214; 233; 296; 362; 288; 315; 216; 153; 0; 0; 0; 0; 0
- Charges and interest (millions of SDRs, annual): 3; 2; 3; 2; 3; 2; 3; 2; 3; 2; 3; 2; 3; 2
- Total obligations based on existing and prospective credit (in millions of SDRs, selected): 231; 246; 264; 328; 394; 453; 507; 408; 345; 192; 58; 32; 32; 32
- Total obligations in millions of US$: 306; 328; 354; 440; 529; 611; 683; 550; 464; 258; 78; 42; 43; 43
- Outstanding Fund credit (in millions of SDRs): 2,851; 2,878; 2,664; 2,431; 2,135; 1,773; 1,351; 876; 500; 187; 270; 0; 0; 0
- Net use of Fund credit (in millions of SDRs): 304; 20; -264; -328; -394; -453; -507; -408; -345; -192; -58; -32; -32; -32
- Memorandum: Nominal GDP (in millions of US$): 88,098; 92,015; 96,495; 101,414; 110,352; 118,153; 126,531; 135,517; 145,153; 155,487; 166,733; 178,806; 191,556; 205,230

### Access and phasing under the arrangement (Table 8 highlights)
- Total under the Extended Credit Facility (May 17, 2023 to April 16, 2026): 2,241.9 millions of SDRs; 3,000 millions of U.S. dollars; 304 percent of quota
- Key availability dates and associated completions:
  - May 17, 2023: Board approval of the Extended Credit Facility
  - November 1, 2023: completion of first review (observance of end-June 2023 performance criteria)
  - May 1, 2024: completion of second review (observance of end-December 2023 performance criteria)
  - November 1, 2024: completion of third review (observance of end-June 2024 performance criteria)
  - May 1, 2025: completion of fourth review (observance of end-December 2024 performance criteria)
  - October 31, 2025: completion of fifth review (observance of end-June 2025 performance criteria)
  - April 16, 2026: completion of sixth review (observance of end-December 2025 performance criteria)
- Memorandum item: Ghana's quota: 738

*Source: Ghanaian authorities; and Fund staff estimates and projections.*

### Annex I. Risk Assessment Matrix

### Annex I. Risk Assessment Matrix

### Risk Framework and Methodology
- The Risk Assessment Matrix (RAM) shows events that could materially alter the baseline path.
- Likelihood categories (staff’s subjective assessment):  
  - "low" indicates a probability below 10 percent.  
  - "medium" indicates a probability between 10 and 30 percent.  
  - "high" indicates a probability between 30 and 50 percent.
- RAM reflects staff views on sources of risk and overall level of concern as of the time of discussions with the authorities.
- Non-mutually exclusive risks may interact and materialize jointly.
- Conjunctural shocks and scenarios: horizon between 12 to 18 months.  
- Structural risks: likely to remain salient over a longer horizon.

### Conjunctural Risks (Nature / Likelihood / Potential Impact / Policies to Mitigate)
- Trade policy and investment shocks.  
  - Likelihood: High  
  - Potential Impact: High: Disruptions in trade of food, energy, and fertilizer could worsen inflation and create social discontent. A stronger USD and lower FDI will put pressure on the BoP—including affecting the imports, external debt service, financial flows.  
  - Policies to Mitigate Risks:  
    - Build external buffers under the program.  
    - Reduce trade concentration risks.  
    - Implement structural reforms to boost competitiveness and support economic diversification.  
    - Improve governance and the business environment.

- Regional conflicts.  
  - Likelihood: Medium  
  - Potential Impact: High: Ghana may not be able to import needed goods, particularly food, the cost of imports may surge. The uncertain environment and investor risk aversion may depress financial inflows, including FDI.  
  - Policies to Mitigate Risks:  
    - Build external buffers under the program.  
    - Implement structural reforms to support domestic production / import substitution / economic diversification.  
    - Improve governance, business environment to attract investors.

- Commodity price volatility.  
  - Likelihood: Medium  
  - Potential Impact: High: Possible issues with essential commodity imports or their costs. A steep drop in commodity prices due to a global slowdown could weigh on exports and growth, raising social tensions in an already difficult economic situation.  
  - Policies to Mitigate Risks:  
    - Improve governance, business environment to support domestic commodity production, processing (e.g., fuel refining), diversification.  
    - Enhance social protection to shield the vulnerable from price / supply shocks.

- Social discontent.  
  - Likelihood: Medium  
  - Potential Impact: High: Social unrest in Ghana could slow down and/or delay reforms under the program.  
  - Policies to Mitigate Risks:  
    - Take measures to strengthen governance and anti-corruption frameworks.  
    - Implement orderly fiscal consolidation.  
    - Strengthen social and financial safety nets.

- Tighter financial conditions and systemic instability.  
  - Likelihood: Medium  
  - Potential Impact: High: Global factors exacerbate the impact of large domestic debt haircuts to banks holdings of sovereign claims on banks’ capital adequacy and adversely affect their capacity to lend and dampen credit to the private sector and economic activity.  
  - Policies to Mitigate Risks:  
    - Strengthen financial safety nets and closely monitor bank and NBFIs liquidity as well as asset quality.  
    - Design an adequate bank and NBFIs recapitalization strategy.  
    - Encourage acquisition, mergers if needed.

### Domestic Risks (Nature / Likelihood / Potential Impact / Policies to Mitigate)
- Delays in debt restructuring negotiation and implementation.  
  - Likelihood: Medium  
  - Potential Impact: High: Delayed financing would risk further lowering FX reserves, excessive depreciation and therefore inflation, resulting in social instability.  
  - Policies to Mitigate Risks:  
    - Engage with creditors and provide needed data and information to mitigate the risk of undue delay to Board approval of program reviews.

- Domestic policy slippages.  
  - Likelihood: High  
  - Potential Impact: High: With debt sustainability in question and IFI financing delayed, a BOP financing gap would emerge, the exchange rate and FX reserves would come under pressure, inflation would rise. Deviations from the programmed revenue path would widen fiscal imbalances with ensuing implications for achievement of debt sustainability.  
  - Policies to Mitigate Risks:  
    - Firm commitment to program implementation to ensure full fiscal and external adjustment, continued exceptional financing. Closely interact with development partners to ensure adequate BOP financing.

### Key Program Performance and Recent Developments (selected findings and numeric outcomes)
- From the Letter of Intent (Accra June 17, 2025): government requests completion of the fourth review, completion of the financing assurances review, and a disbursement of SDR 267.5 million.
- Program implementation challenges in second half of 2024: large expenditure overruns funded through accumulation of payables.
  - Primary balance on a commitment basis: deficit of 3.3 percent of GDP compared to a budget target of 0.5 percent of GDP.
  - Large accumulation of payables: 3.9 percent of GDP (reflected in an indicative target).
  - Inflation remained high, exceeding program target bands and the Bank of Ghana (BoG)’s inflation target.
  - Eight out of twelve structural benchmarks (SBs) due through end-June 2025 were missed (as noted in the Letter of Intent).  
  - Separately, all three structural benchmarks due through end-December were missed (as noted in the MEFP update).

- Corrective and reform actions taken (selected, with dates / magnitudes where specified):  
  - Increased the Bank of Ghana (BoG) policy rate by 100 basis points.  
  - Passed a 2025 Budget targeting a 1.5 percent primary surplus in 2025.  
  - Enacted amendments to the Public Financial Management and Public Procurement legislations to address vulnerabilities that led to the large accumulation of payables in 2024.  
  - Launched a comprehensive audit of the spending commitment and arrears at end-2023 and end-2024 expected to be completed by end-August 2025.  
  - Resumed quarterly electricity tariff adjustments in April/May 2025 (implementation resumed on May 1, 2025; quarterly adjustment resumed in April 2025 is also noted).  
  - Domestic debt restructuring completed in 2023; Eurobond exchange completed last year; Memorandum of Understanding (MoU) between Ghana and Official Creditor Committee under the G20 Common Framework signed in January (year implied by context).

- Program monitoring and technical changes requested by authorities:  
  - Request to modify nominal fiscal objectives (primary balance QPC and non-oil revenue IT) through end-December 2025 to reflect higher nominal GDP projection while keeping fiscal effort relative to GDP as envisaged.  
  - Request to change the TMU to broaden coverage of public entities, improve monitoring of energy sector payables for the primary fiscal balance PC and the central government payables IT, and clarify exceptions to the BoG claims.  
  - MPCC bands for September and December 2025 were raised to reflect the higher starting point and provide a credible disinflation path in 2025. Indicative targets were set for end-March 2026.

### Policies to Mitigate Risks (summary of cross-cutting measures cited)
- Build external buffers under the program.  
- Implement structural reforms to boost competitiveness, support economic diversification, and enhance domestic production / import substitution.  
- Improve governance and the business environment to attract investors and reduce corruption.  
- Enhance social protection and financial safety nets to shield the vulnerable from shocks.  
- Strengthen financial safety nets, monitor bank and NBFIs liquidity and asset quality, and design recapitalization strategies where needed.  
- Engage proactively with creditors and development partners to secure timely financing and support debt restructuring.

*Source: Annex I. Risk Assessment Matrix; Annex II; Letter of Intent; Attachment I. Memorandum of Economic and Financial Policies (excerpts) — as provided in the supplied PDF content.*

### 3. Since taking office, the new administration has taken bold corrective measures to

### 3. Since taking office, the new administration has taken bold corrective measures to 

### Corrective measures and institutional reforms
- 2025 Budget will allow us to remain on track to reaching a primary balance surplus of 1.5 percent of GDP in 2025, consistent with program objectives (end-March 2025 SB).
- Enacted amendments to the PFM and Public Procurement Acts to respectively accelerate implementation of an enhanced fiscal responsibility framework prepared in collaboration with the IMF (end-September 2025 SB) and strengthen control on new spending commitments.
- Resolved technical challenges that prevented timely implementation of the full integration of GHANEPS with GIFMIS (end-December 2024 SB; prior action).
- Bank of Ghana (BoG) raised its policy rate by 100 basis points in the March 2025 Monetary Policy Committee (MPC) meeting and took additional steps to enhance monetary policy implementation.
- Published the audit of Electricity Company of Ghana (ECG) collections and uses in February 2025—covering a longer period than mandated by the end-January 2025 SB—and resumed implementation of the quarterly electricity tariff adjustments in May (quarterly SB).
- Completed a forward-looking overarching restructuring plan for NIB in May (end-March 2025 structural benchmark and then prior action) and recapitalized NIB (prior action) to ensure a non-negative Capital Adequacy Ratio (CAR) and full compliance with the minimum CAR of 13 percent (without forbearance), ahead of the end-2025 timeline.
- Will submit to Parliament the amendments to the Bank of Ghana Act in June (end-May structural benchmark).

### Recent macroeconomic outcomes and resilience
- Real GDP growth accelerated to 5.7 percent in 2024, driven relatively broad-based across sectors, particularly in mining and construction; expenditure-side drivers included household consumption and a sharp recovery in both public and private investment.
- Inflation moderated from 23.8 percent in December 2024 to 18.4 percent year-on-year in May 2025, with food inflation at 22.8 percent largely contributing to the headline figure.
- External sector performance in 2024: large gold exports, some recovery of the cocoa sector, and strong remittance flows.
  - Surplus in the goods trade balance increased to 4.4 percent of GDP in 2024, from 2.2 percent in 2023.
  - Current account (CA) stood at 1.1 percent of GDP at end-December 2024 (3.6 percent non-interest CA), up from -1.6 percent at end-2023 (1 percent non-interest CA).
  - Gross international reserves (GIR) reached US$6.4 billion (2.6 months of prospective imports) at end-December 2024.
  - At end-March 2025, GIR stood at about US$7.6 billion (3 months of prospective imports).
- Improvement in reserves achieved through expansion of domestic gold purchases and valuation effects on BoG gold holdings, which more than offset continued low proceeds from cocoa and significant energy sector payments.

### Near-term outlook and projections
- Growth expectations:
  - Growth to decelerate to 4 percent in 2025 (revised down from the 4.4 percent at the time of the third ECF review).
  - Gradual increase toward long-term potential of around 5 percent in subsequent years as macroeconomic stability is restored and structural reforms accelerate.
- Inflation expectations:
  - Inflation reaching 12 percent by end-2025 given continuation of restrictive monetary and fiscal policies.
  - Inflation will be brought down to the BoG’s medium-term target of 8±2 percent in 2026.
- External sector and reserves:
  - Current account projected to remain in surplus in the medium term on the back of high gold prices and a large trade surplus, subject to uncertainty from volatile international commodity prices and demand.
  - Reserve buffers will be rebuilt to 3 months of import cover by the end of the current year.

### Macroeconomic policy objectives and reform pillars
- Overarching objectives: restore macroeconomic stability and debt sustainability, support strong and inclusive growth, and reduce poverty.
- Key components:
  - (i) restoring public debt sustainability and fiscal discipline by completing comprehensive debt restructuring and continuing to streamline spending and bolster domestic revenue mobilization;
  - (ii) strengthening social safety nets;
  - (iii) a more flexible exchange rate and appropriately tight monetary policy;
  - (iv) deep structural reforms to anchor economic stability and drive stronger and more inclusive growth while reducing poverty.

### A. Fiscal Policy — strategy, measures, and targets
- Commitment to an ambitious and lasting fiscal adjustment aimed at restoring debt sustainability.
- Program objective: achieve a primary surplus of 1.5 percent of GDP on commitment basis by 2025 and maintain it thereafter, consistent with the revamped fiscal responsibility framework (¶44).
- Revenue-side reforms:
  - Strengthen revenue mobilization consistent with the Medium-Term Revenue Strategy (MRTS) by reducing tax expenditures, simplifying the tax system (¶11), and enhancing enforcement and compliance.
- Expenditure-side reforms:
  - Achieve significant savings by i) eliminating selected programs with limited value for money, ii) limiting budget allocations to MDAs, and iii) rationalizing operations of several earmarked funds (e.g., GIIF and MIIF, Road Fund).
  - Reallocate some freed resources to new infrastructure priorities and an expansion of social protection programs.

- Immediate measures taken to address 2024 fiscal slippages:
  - Instructions to all MDAs to reverse new hires of public servants and halt projects associated to the 2024 slippages with interruption of associated payment of claims.
  - Issuance of a Presidential circular to MDAs reemphasizing the PFM sanctions heads of MDAs and other relevant public officers would be subject to in case of contraventions to the PFM Act.
  - Enactment of a 2025 Budget consistent with the IMF-supported program target (¶).
  - Enactment of amendments to the Public Procurement Act to strengthen control on the origination of new procurement and introduce new sanctions for public officials who approve unauthorized commitments (¶).
  - Enactment of amendments to the PFM act to adopt, ahead of schedule (end-September 2025 structural benchmark), an enhanced fiscal responsibility framework (¶44); amendments envisage sanctions for either the head of a covered entity or a Minister of State in case of fiscal slippages.
  - Launch of a comprehensive audit on the commitments and stock of arrears at end-2024, with the support of reputable international firms (¶43). The audit started in April and is expected to be completed by end-August (structural benchmark).
  - Bolstering the role of the PFM compliance desk to identify breaches and ensure observance of PFM provisions.

- Medium-term measures envisaged with IMF assistance:
  - Use audit findings to drastically curtail the scope of payables and commitments—including canceling projects not yet started or rescoping those not recognized as priority, legally challenge payables disqualified by the audit, and enforce sanctions under the PFM Act.
  - Adopt a timebound plan to gradually clear the validated payables consistent with fiscal objectives under the Fund-supported program.
  - Strengthen public investment management consistent with recommendations from a recent IMF PIMA mission (¶46); expand the scope and use of GHANEPS and amend procurement regulations to reduce scope for exceptions to competitive procurement (new end-December 2025 structural benchmark).
  - Ministry of Finance to update centralized inventory of all ongoing and planned projects; cabinet to approve a plan to cancel, rescope, and rephase projects drawing on the audit on 2024 commitments (new end-September 2025 structural benchmark).

- 2025 Budget specifics (end-March SB) and fiscal mechanics:
  - Objective: achieve a primary surplus (on commitment basis) of 1.5 percent of GDP on the back of a 0.6 percent of GDP improvement in non-oil revenue collection (on annual basis) and continued efforts to rationalize primary expenditures.
  - New revenue measures: elimination of some VAT exemptions (including on the supply of residential properties), increase in the Growth and Stability Levy on gold mining companies from 1 percent to 3 percent, reduction in allocations to the tax refund account, and tax amnesty for individuals.
  - Estimated yields of these measures would more than offset the revenue loss from the elimination of the e-levy and the winnings from lottery.
  - Expenditure containment measures: maintain public sector wage increases within budgetary constraints, cap foreign loan-financed capital expenditure to US$550mn, limit spending on goods and services, rationalize operations of several earmarked funds, and streamline some low value-added programs while making space for new infrastructure priorities and enhancing social spending.

- VAT reform plan:
  - Planning to adopt a comprehensive reform of the VAT in the 2026 budget to fold into the VAT a number of existing levies, adjust the VAT threshold and rate, and eliminate some exemptions; accompanied by capacity-building and anti-evasion measures with IMF TA support (¶11).

- Contingency measures:
  - Stand ready to fast track implementation of measures from the Medium-Term Revenue Strategy (MTRS), adjust/reprioritize MDAs’ budget allocations, and adjust quarterly spending allotments based on cash forecasts and domestic debt market conditions.

- Medium-term fiscal target:
  - Government objective to enact measures that will permanently raise the non-oil revenue-to-GDP ratio by at least 0.5 percentage points of GDP in 2026, with a view to achieving a non-oil revenue-to-GDP ratio of 15.3 percent in 2026.

### B. Social Protection — coverage, support, and efficiency
- 2025 Budget increased allocation for social protection programs by 0.34 percentage points to 0.91 percent of GDP.
- Rationalization of earmarked funds allows extra resources for social protection.
- LEAP (Livelihood Empowerment Against Poverty):
  - Reassessing beneficiaries to improve targeting to the extreme poor; aim to increase beneficiary households from 350,000 to 400,000 by end-September (structural benchmark).
  - Automatic inflation indexation of the LEAP benefit being implemented to preserve real value.
- Ghana School Feeding Program (GSFP): increased budgetary allocation by 33 percent to help compensate for high food inflation.
- Health sector:
  - Uncapped allocation to NHIF under the Earmarked Funds Capping and Realignment Act, 2017 (Act 947) to enable NHIS to honor claim payments, purchase vaccines and medicines, make up for foreign aid shortfalls, and implement initiatives such as Free Primary Healthcare.
- Basic education: increased allocation to the Capitation Grant by 73 percent.
- Operational improvements and monitoring:
  - Reduced delays in releases from CAGD to beneficiary MDAs except for NHIS (largely due to delays in submission of invoices).
  - Aim to complete update of the NHIS tariff schedule by end-June 2025 in collaboration with the WB to shorten disbursement delays.
  - Plan to publish the quarterly budget execution report to be submitted by relevant MDAs to improve transparency and monitoring.
- Medium-term social protection goals:
  - Gradually expand LEAP coverage to extreme poor and poor households and increase benefits to 20 percent of pre-transfer household consumption.
  - Increase GSFP meal benefit to cover 30 percent of children’s daily calory need.
  - Reach universal health care coverage and broaden medical interventions covered by NHIS while achieving operational efficiencies (reduce administrative cost, digitalization, enhanced medical audits).
  - Ensure statutory fund reform protects highly targeted national health insurance programs and recalibrate MDAs’ social spending to align with SDG targets and more targeted interventions.

### C. Public Debt Management Strategy
- Commitment to complete comprehensive public debt restructuring to restore public debt sustainability.
- Target to restore a moderate risk of debt distress (per IMF-WB LIC-DSF) by 2028, entailing bringing five external and overall debt ratios below respective thresholds.
- Specific targets include reducing the ratio of the net present value of public debt to GDP to 55 percent and the ratio of external debt service to revenues to 18 percent.
- Debt restructuring progress:
  - Domestic debt restructuring completed in 2023.
  - Agreement on a Memorandum of Understanding (MoU) with the Official Creditors Committee (OCC) under the G20 Common Framework in June 2024; secured signatures of all OCC members and working with creditors on bilateral agreements to implement the MoU.
  - Finalized restructuring of Eurobonds in October 2024.
  - Continuing “good-faith” efforts to reach collaborative agreements with other external commercial creditors on comparable terms.
- Controls on external project disbursements:
  - Disbursements on bilateral and commercial projects signed before December 2022 are capped at US$250 million per year until 2026.
  - 2024 disbursements were US$ 184.4 million and disbursements amounting toUS$250 million has been projected for 2025.
  - Total multilateral envelope limited to US$300 million in the 2025 budget.
  - Decision to restrict project loan disbursements by multilaterals to ensure adherence to primary balance targets and reduce future external liabilities; working with partners to prioritize projects.

*Source: 3. Since taking office, the new administration has taken bold corrective measures to (1ghaea2025001-source-pdf).*

### 20. Debt management will continue to focus on ensuring sufficient domestic financing in

### 1ghaea2025001-source-pdf - 20. Debt management will continue to focus on ensuring sufficient domestic financing in

### Debt management strategy and near-term financing
- Since 2022, financing of the government deficit has relied heavily on issuance of T-bills.
- Plan to resume domestic bond issuances in 2025, initially issuing T-bonds with maturities beyond 2028 to smoothen the debt service profile.
- May rely initially on private placements to meet auction shortfalls; preference to revert to competitive auctions once demand is established.
- Seek to encourage non-resident investor participation to reduce concentration risk and kickstart the domestic market, within Fund-supported program parameters.
- Increase surveillance on debt issuance from SOEs and other public entities.
- Strictly limit and monitor collateralized debt issuance.
- Strictly limit borrowing on non-concessional terms.
- Ensure that debt payments are made on time.
- Publish Annual Public Debt Report for 2024 in June 2025.
- Develop and publish a revised medium-term debt management strategy by June 2025 based on the approved 2025 Budget.

### Capacity building, systems, and institutional reform in debt management
- Requested IMF TA to support capacity building in debt sustainability analysis and liability management at the MoF’s Debt Management Office (DMO).
- Considering institutional reform to strengthen the DMO’s role in ensuring a sustainable medium-term financing strategy, including post-debt restructuring market development.
- Establish an Investment Relations Unit with skills and tools for investor engagement and credit rating agencies.
- Upgrade current securities operation infrastructure (CS-DRMS) to a modern system by end-August 2025.
- Implementation strategy to integrate all state institutions involved in contracting and servicing public debt to digitalize processes, increase pace of debt service processing, improve accuracy of debt recording and accounting, and improve debt transparency.
- System intended to enhance debt analysis and promote greater efficiency in public debt management.
- Immediate priority: strengthen monitoring of borrowing and contingent liabilities from key SOEs (COCOBOD, GOLDBOD, ECG, VRA, GWCL, TOR, GNPC, GNGC, and BOST) and any collateralized debt issuance.

### Monetary and exchange rate policies — stance and implementation
- CPI inflation overshot the MPCC upper outer band in both December 2024 and March 2025; supply-side factors drove very elevated food inflation; non-food inflation remains higher-than-expected and well above the BoG’s target.
- Tightened monetary policy (¶2323) and taking measures to improve monetary policy implementation (¶2424).
- Maintain tight monetary policy until inflation is firmly on track to reach the BoG’s medium-term objective of 8 ±2 percent in 2026 (timing slightly later than previously expected).
- MPC increased the policy rate by 100bps to 28 percent at its March meeting.
- MPC decisions will remain data-dependent; aim to maintain a sufficiently high positive real policy rate until disinflation is complete.
- BoG stands ready to adjust policy stance under the monetary policy consultation clause.

### Monetary policy instruments and framework improvements
- Gradually make open market operations (BoG bills) the primary instrument for liquidity absorption; reduce reliance on the unremunerated cash reserve ratio (CRR).
- BoG Bills outstanding more than doubled between end-2024 and end-April 2025, reaching a record of GHS 44 billion.
- Add a 273-day BoG bill to manage long-term liquidity, in addition to the 56-day bill currently in use.
- Ensure 56-day bills’ pricing is consistent with the objective of transmitting the policy rate; 273-day BoG bills will be auctioned to reflect market conditions.
- Decrease reliance on the CRR and review its implementation framework—including the dynamic (tiered) CRR—to align with international best practices.
- Improve MPC transparency: in March began publishing each MPC member’s vote and a detailed anonymized statement.
- Enhance inflation targeting framework via improvements in FPAS, macroeconomic data collection including a BoG inflation expectations survey, analytical capacity, and monetary policy communication.

### International reserves, FX intervention, and exchange rate policy
- Ahead of schedule on rebuilding official international reserves (program definition) to at least 3 months of import cover; consistently overperformed NIR targets since program start.
- Overperformance attributed to large-scale deployment of the domestic gold purchase program (DGPP) and larger-than-expected cocoa receipts, alongside significant increase in BoG FX interventions (FXI).
- Committed to further rebuilding foreign exchange buffers in the context of a large increase in external debt payments.
- Fully discontinued sell buy-back operations in December 2024 and earlier unwound swap arrangements with commercial banks.
- Domestic gold purchases will continue to be done at market prices.
- BoG actively managing portfolio risks arising from gold’s share of total reserves and its weight on the consolidated balance sheet.
- BoG Board to adopt an internal FX intervention policy specifying measurable objectives, instruments, transparency, and governance arrangements based on a discretion under constraint approach (new end-September 2025 structural benchmark).
- Discontinued bilateral adjudications; FXI now exclusively conducted through auctions (these auctions follow the Bank of Ghana Guidelines for Allocation of Foreign Exchange Through Forward Auctions (2019)).

### Multiple currency practices and safeguards
- Committed to eliminating multiple currency practices (MCPs).
- Adopted a more robust FX reference rate computation method in September 2024; after six months assessed as more robust and transparent.
- Will take necessary actions and reforms to ensure a unified foreign exchange market and flexible exchange rate arrangement; will not introduce policies that create, intensify or modify exchange rate restrictions or MCPs.
- Implementing recommendations of the 2023 IMF safeguards assessment.
- Cabinet approved amendments to the Bank of Ghana Act of 2002 (Act 612) in June 2024 (end-May 2024 structural benchmark); committed to submit these amendments to Parliament by end-June 2025 (end-May structural benchmark).
- BoG working with government on a timeline to exit the Gold-for-Oil (G4O) program.

### BoG recapitalization and balance sheet measures
- MoU on recapitalization of the BoG signed on January 6, 2025, outlining the process in broad terms.
- With IMF support, will assess BoG recapitalization needs considering projected medium-term improvements in BoG’s net equity and efficiency gains, ensuring recapitalization is consistent with fiscal commitments and debt targets under the program.
- Recapitalization options include budgetary or asset transfers, suspension of profit transfers, and/or use of buffers generated in program implementation.
- Adopt, by end-2025, a strategy to streamline BoG operational costs based on an external efficiency review with IMF technical assistance.

### Financial sector recapitalization, supervision, and NPL strategy
- Banks with capital shortfalls pledged to recapitalize by at least one-third of required capital annually for each of the three years ending in 2025; banks with significant shortfalls to front-load recapitalization to ensure positive CAR by end-2024.
- All banks pledged to reach a 13 percent CAR, without regulatory forbearance, by end-2025.
- Most banks met or exceeded 2024 recapitalization requirements and are on course to restore required CAR by end-2025.
- BoG intensified monitoring and remedial/corrective measures against five private and state-owned banks not compliant as of end-December 2024; these banks have fallen behind due to unmet capital commitments, increased NPLs, and incomplete booking of credit impairments identified under BoG’s 2023 asset quality assessments.
- Ministry of Finance measures in the March 2025 budget to ensure compliance by state-owned banks behind on recapitalization.
- BoG will escalate actions against banks not progressing toward full compliance with 13 percent CAR, without reliefs, by end-2025 (end-March 2025 structural benchmark).
- BoG has suspended dividend payments for all banks until further notice and restricts banks with shortfalls from excessive risk-taking and certain capital expenditures.
- BoG ready to deploy components of Prompt Corrective Action (PCA) framework as necessary.

### Ghana Financial Stability Fund (GFSF) and state support
- Under Fund A2 component of the GFSF, government injected funding up to January 2025 mainly via new bonds to recapitalize banks and insurance companies: GHS5.2 billion.
- Provided long-term secured loans (GHS0.3 billion) to some mutual funds and unit trusts.
- Measures to frontload further necessary recapitalizations of state-owned banks and ensure injections are underpinned by credible viability plans.
- Government plans to resubmit to Parliament the World Bank’s financial sector support operation under the GFSF targeting eligible undercapitalized banks and SDIs; funding conditional on prior shareholder injections and feasible viability plans.
- Government solvency support aims to minimize costs and moral hazard, incentivize private capital injections, foster governance and operational reforms, and allow for an orderly early government exit.

### NIB and state-owned banks strategy
- NIB strategy (adopted March 2024) aims to recapitalize NIB and prepare a forward-looking restructuring plan.
- Injected cash and bonds to bring NIB’s CAR to positive territory (prior action) and full compliance with the minimum CAR of 13 percent (without forbearance), ahead of the end-2025 timeline.
- Forward-looking restructuring plan for NIB completed (prior action) addressing business model changes, resource needs, residual recapitalization, operational strategy, and governance and risk management enhancements; includes strengthening Board size, composition, and expertise with majority independent directors.
- Updating and enhancing crisis management and resolution legislation framework; High Court decisions in November 2024 and March 2025 reversing BoG’s 2019 revocations of two SDI licenses highlighted legal gaps.
- BoG has filed appeals and committed to take measures to address legal framework gaps; requested technical support from international partners.
- Legislative amendments to the crisis management and resolution framework to be approved by Cabinet and submitted to Parliament by end-December 2025 (new structural benchmark).

### NPLs, credit risk management, and recovery framework
- NPLs increased post-2022 macro challenges but now rising more slowly than credit growth over the past few months.
- Developing a multi-pronged strategy to tackle increasing credit risks and support sustainable credit growth, including the state’s new SME credit expansion program.
- Banks must review and strengthen credit risk management systems and skills, ensure prompt recognition of asset quality risks, adequate provisioning, and timely work-out and collections.
- Banks with NPL ratios exceeding 15 percent provided credit action plans to BoG including credit growth targets, risk management strategies, and analyses informing provisioning and recovery.
- BoG pushing for full recognition of NPLs and provisioning by two banks that delayed booking impaired credits from the 2023 asset quality assessment.
- BoG will monitor progress and, where necessary, review/update prudential standards to support sound credit and operational risk management.
- Authorities committed to developing, by end-June 2025, a time-bound roadmap to strengthen the credit impairment and recovery framework.

### State-owned banks diagnostics and restructuring
- Launched hiring an expert to conduct diagnostics of structural challenges in state-owned banks (business models, governance, risk management, legal framework) to inform a strategy.
- Preparation of this strategy (end-April 2025 structural benchmark) delayed to incorporate NIB restructuring outputs; target completion by end-August 2025.
- Measures adopted for NIB to guide restructuring of ADB, including linking recapitalization and lifting of PCAs to a special review, governance reforms, business model rationalization, and strengthened risk management.
- Injected substantial capital into ADB in 2024 to attain a positive CAR.
- Launch a special review of ADB operations and complete a restructuring strategy by end-August 2025.
- Recapitalize ADB to full compliance with the required 13 percent CAR, with no forbearance, by end-2025.
- Implement systematic monitoring of state-owned banks against key performance indicators as for other banks that benefitted from GFSF support.
- BoG announced intention to divest its share ownership in ADB.

*Source: 1ghaea2025001-source-pdf - 20. Debt management will continue to focus on ensuring sufficient domestic financing in*

### 39. Regulatory forbearance introduced in response to the domestic debt exchange, and

### 39. Regulatory forbearance introduced in response to the domestic debt exchange, and

### Regulatory forbearance: timeline and roll-back
- Forbearance on recognition of debt exchange losses in CAR computations is being lifted by one-third each year from January 2023 through end-2025.
- Banks and SDIs have been formally advised that the temporary forbearances offered to the banking sector to facilitate the DDE, including those lowering minimum capital adequacy ratios (CAR), will be fully rolled back by end-2025.
- The current review of the dynamic (tiered) CRR will support elimination of supervisory forbearance on non-compliance by some banks.
- Authorities will closely monitor unintended consequences of forbearance measures and adjust them as needed to mitigate undue effects.

### Strategy for SDIs and NBFIs (legacy issues and government support)
- Implement in 2025 a comprehensive and cost-effective strategy to address legacy issues in SDIs and non-bank financial institutions (NBFIs) with government financial support as needed to mitigate risks to financial stability.
- Allocation and format of government support will consider: capital required, number of Ghanaians affected, financial inclusion needs, and moral hazard risks.
- Financial support for deposit-taking and other financial institutions will be determined case-by-case, predicated on regulators’ assessments of:
  - recapitalization efforts and plans;
  - operational and business strategies including corrective actions to prevent accumulation of further losses;
  - improvements in governance and risk management systems;
  - prospects for future viability and sustainability.
- Any government payouts will be made through a burden-sharing approach with stakeholders to minimize fiscal costs.
- Regulatory authorities are intensifying monitoring, enforcement of existing regulations, and stress-testing to support prompt measures to address risks to financial stability.

### Financial sector reforms to enhance stability and credit
Planned/completed measures to enhance financial sector stability and support credit:
- Review and monitor off-balance sheet items.
- Complete the roll out of Basel II and III capital, liquidity, and supervisory review reforms.
- Build and implement strategies to improve governance, operational efficiency, and business models and competitiveness of state-owned banks and other financial institutions.
- Enhance the crisis management and resolution framework.
- Strengthen the deposit insurance scheme.
- Implement initiatives to expand SME credit through qualifying participating financial institutions with support of the DBG and external development partners.
- Leverage existing financial and credit facilities that specifically cater to women (e.g. DBG, rural banks).
- Consider further measures to reduce the nexus between the sovereign and financial institutions to prevent crowding out of credit to the private sector.

### Structural fiscal reforms: overview and goals
- Prioritize structural fiscal reforms to address weaknesses that led to the 2024 fiscal slippage and entrench fiscal discipline while bolstering transparency.
- Reforms designed with assistance of Fund/WB staff and draw on comprehensive strategies in public financial management, medium-term revenue mobilization, energy sector recovery, and rationalization of statutory funds.

### Audit of arrears/payables and commitments
- Launched a comprehensive audit of arrears/payables and commitments at end-December 2023 and 2024.
- Audit conducted by the Auditor General with assistance of two international firms (Ernst and Young and PricewaterhouseCoopers).
- Preliminary findings: a significant share of the payables and commitments examined are invalid because originated in violation of existing PFM provisions and/or lacking reliable and complete supporting information.
- Expected conclusion of the audit by end-August 2025 (new structural benchmark).

### Enhanced fiscal responsibility framework
- Accelerated adoption and enactment of an enhanced fiscal responsibility framework (end-September 2025 structural benchmark).
- In March 2025, the 2016 PFM Act was amended to:
  - add a debt anchor covering central government and publicly guaranteed debt (with objective of broadening coverage over the medium term);
  - set an operational fiscal rule on the primary balance to ensure achievement of the anchor by 2034;
  - clearly define escape clauses and circumstances for activation and appropriate correction mechanisms.
- Reformed the Fiscal Advisory Council to provide strong operational independence and adequate resources; the Council will make an independent assessment of key macro-fiscal projections of the Budget at submission and evaluate fiscal performance against the fiscal rule.
- Plan to publish fiscal strategy document and fiscal risk statements in 2026 consistent with the PFM Law; extend fiscal risk statement coverage to risks stemming from GoldBod.

### Procurement controls and GHANEPS–GIFMIS integration
- Amended the 2003 Public Procurement Act to require central government-funded procurement to be accompanied by a commitment authorization issued by the Minister for Finance before procurement commences.
- PPA Board, tender review committee or entity tender committee prohibited from approving procurement without commitment authorization.
- Strengthened sanctions for approving unauthorized commitments resulting in government financial obligations.
- Integrated GHANEPS with GIFMIS (missed end-December 2024 structural benchmark and prior action for the 4th ECF review). The systems have been connected and at least one public entity has conducted procurement through the integrated system.
- Objective to reach 90 percent of total procurements (by value) conducted in GHANEPS during the first quarter of 2026 (applied to entities in GIFMIS).
- Publish 2021-2023 report on public procurement on the PPA website and provide direct link between GHANEPS and the ORC website for beneficial ownership information.
- Update strategy to reduce share of non-competitive procurement (measured in value) based on PPA annual procurement assessment reports.

### Public Investment Management (PIM) reforms
- April 2025 PIMA update mission found Ghana made good progress on PIM design but effectiveness deteriorated significantly since the 2016 PIMA.
- Weaknesses in implementation led to unsustainable overhang of outstanding projects and chronic over-commitment of resources.
- Steps taken to improve investment efficiency include:
  - mandate the compliance desk in MoF and MDAs (¶48) to enforce adherence to all aspects of the PIM framework;
  - complete an updated inventory of ongoing and planned projects (including investments under earmarked funds);
  - adopt a Cabinet decision to cancel, rescope, and rephase the updated inventory of project commitments drawing on the audit 2024 outstanding commitments and based on status of execution, value for money and alignment to available budget resources (new end-September 2025 structural benchmark);
  - amend procurement regulations to restrict exceptions to undertaking competitive procurement (new end-December 2025 structural benchmark);
  - overhaul medium-term budget planning of public investment by setting credible multiyear ceilings informed by previous multiyear spending outturns and determine and enforce binding limits within which MDAs undertake contractual commitments by end-November 2025.
- Publish an updated Public Investment Plan of all ongoing and planned Public Investment Projects (PIP) by end-December 2025.

### Independent Value-for-Money Office and SOE monitoring
- Established an Independent Value-for-Money Office to improve project selection and ensure alignment with priorities.
- Office adopted a standard project appraisal methodology with a rigorous pre-screening step, including cost-benefit and risk analysis.
- Criteria for project selection published in November 2024.
- Authorities will enhance fiscal risk management and closely monitor financial performance of SOEs, including financial strategies, investment plans, budgets, debt, and contingent liabilities.

### Arrears Clearance and Prevention Strategy; reporting and sanctions
- Annual arrears clearances to be consistent with the medium-term budget framework under IMF-supported program; prioritization of arrears with largest macroeconomic impact.
- Controller and Accountant General's Department (CAGD) will systematically collect and timely report (within three months) comprehensive information on the stock of payables made by all MDAs per economic classification (new quarterly structural benchmark, starting in September 2025 with no more than a one quarter lag).
- Appropriate sanctions will be applied by the MoF and Auditor General for non-compliance by MDAs.
- Ensure SOEs continue submitting financial reports to CAGD.

### Compliance desk, internal audit, and accountability measures
- Elevated the compliance desk at the MoF to the rank of division to strengthen fiscal responsibility and aggregate fiscal discipline.
- Desk will:
  - liaise with internal auditors of MDAs to verify compliance with commitment control procedures before new contracts;
  - ensure adherence to budget and allotment availability, acquisition of necessary approvals, and standard procurement procedures;
  - require internal auditors of MDAs to report quarterly on adherence and non-adherence to PFM commitment controls and expenditure monitoring measures;
  - publish a Commitment Control Compliance League Table ranking MDAs based on compliance levels;
  - report on sanctions applied for breaches of the PFM Act and their impact on arrears prevention.
- Confirmed cases of noncompliance will be forwarded to the Office of the Attorney General and the Minister for Justice for further action.

### Cash management, Treasury Single Account (TSA), and statutory funds reforms
- Cash management:
  - Aligned quarterly budgetary allotments to MDAs and Statutory Funds on GIFMIS with the 3-month cash forecasts and required MDAs to revise cash plans accordingly.
  - Enhancing coordination among Budget division, Treasury and Debt Management divisions (TDMD) and CAGD to improve cash and treasury management.
- Treasury Single Account (TSA):
  - All MDAs, MMDAs and IGFs accounts in BOG and commercial banks will be integrated to the TSA by end-March 2026.
  - GIFMIS tightly integrated with SWIFT, GhIPSS, ACH to ensure real time exchange of data on net balances.
  - Onboarded 549 additional MDA and MMDA spending unit accounts into GIFMIS (end-March 2025 structural benchmark).
  - Roll out automatic bank reconciliation (ABR) functionality for all GIFMIS-linked accounts by end-December 2025 with view to complete TSA reforms by end-March 2026.
- Statutory Funds:
  - Eliminated the Plastic Waste Recycling Fund; reformed the Minerals Investments Income Fund bringing most of its income to the Consolidated Fund; reformed District Assembly Common Fund.
  - Cabinet will adopt amendments to merge funds identified as redundant with their line ministries (end-June 2025 structural benchmark).
  - By end-September 2025, Cabinet will approve legislation to refocus the Road Fund’s mandate exclusively on road maintenance.
  - Extend GIFMIS coverage to all spending units and enforce its use through enhanced oversight for NHIF, GETFund, Road Fund, District Assemblies Common Fund and IGF-reliant institutions.
  - Establish mechanism to ensure earmarked funds do not engage in collateralization of receivables.
  - All earmarked funds required to submit audited financial statements, clear audit backlogs, and implement audits’ recommendations.
  - In March 2025, amended legislations of GETFund, Ghana Infrastructure Investment Fund, the Mineral Income Investment Fund, and District Special Capital Fund to improve efficiency and achieve budgetary savings.

### Payroll audit, functional review, and HRMIS integration
- Plan to conduct a comprehensive payroll audit and a functional review of selected MDAs:
  - Payroll audit expected to be completed by end-June 2025.
  - Functional review expected to be completed by end-September 2025.
- Intend to integrate HRMIS with GIFMIS budget module and the payroll system by end-December 2025 to strengthen controls on “ghost names”, promotions, hiring and payroll costs.

### Revenue administration, ITAS, and MTRS
- Expand database of new residential property developments and develop schedule for key elements of tax on new residential property transactions.
- Started communication campaign on presumptive turnover tax for small businesses and developed simplified tax return system.
- Reviewing the e-VAT system to strengthen compliance.
- Delays in cleansing GRA’s taxpayer data and revamping ITAS due to resource constraints:
  - Expect to complete cleansing of taxpayer registry data by end-June 2025.
  - Expect to complete cleansing of taxpayer ledger related to the three largest tax offices (representing 75 percent of revenue collection) by end-June 2025 with view to cover all tax offices by end-December 2025 (end-June 2024 structural benchmark).
  - Operationalization of ITAS (end-December 2024 structural benchmark) has been further delayed; implementation rephased in three phases.
  - First phase (data migration and functionality of three tax modules—registration, return processing, and payments for CIT, PIT, VAT) now expected to be achieved by end-March 2026.
- Compliance enhancements:
  - Enhance audits on large taxpayers and start publishing quarterly compliance report data on the GRA website.
  - Leverage the Global Forum on Transparency and Exchange of Information to improve compliance of residents with foreign income.
- Medium-Term Revenue Strategy (MTRS):
  - Reforms aim to broaden tax base, minimize tax avoidance, and foster a progressive tax system.
  - Use MTRS to promote equity and transparency, provide tax certainty and predictability.
  - Perform a mid-implementation review of the MTRS by end-March 2026 with support from the IMF to assess progress, including timeline, yield of adopted reforms, achievement of MTRS objectives, and identify timebound corrective actions.

*Source: 1ghaea2025001-source-pdf - 39. Regulatory forbearance introduced in response to the domestic debt exchange, and*

### 55. We intend to submit to Parliament a new Extractive Industry Fiscal Regime Bill

### 55. We intend to submit to Parliament a new Extractive Industry Fiscal Regime Bill

### Extractive Industry Fiscal Regime Bill
- The draft bill was prepared with support from the Fund.
- Once passed, the bill will:
  - help raise sufficient revenue;
  - provide adequate incentives to invest at reasonable cost to both the government and taxpayers;
  - improve transparency and governance in the sector.
- The bill will be submitted together with the 2026 Budget.

### Energy Sector Measures
- Holistic approach under the Energy Sector Recovery Programme (ESRP) combining:
  - immediate measures to reduce the energy sector shortfall and its budgetary impact;
  - measures to increase transparency and improve governance;
  - actions to promote sector financial recovery, reform ECG, and safeguard the energy sector and broader economy.

- Tariff adjustments and transparency:
  - Resumed quarterly electricity tariff adjustments as per current MYTO guidelines after PURC Board reconstitution.
  - PURC announced tariff increases of 14.75 percent effective May 3, 2025, per rate setting guidelines.
  - Decision notes (technical notes) with detailed explanations and key inputs were published with the tariff decision (quarterly structural benchmark).
  - Financial model and calculations shared with IMF and World Bank staff.
  - PURC conducting a multi-year tariff order (MYTO) for 2025-2030 (end-September 2025 structural benchmark), with a tariff adjustment effective from October 1, 2025.
  - Utility companies (ECG, VRA, BUI, NEDCo, GRIDCo, etc.) submitted investment plans; preliminary investment hearings conducted.
  - MYTO will revise the rate setting framework to ensure changes in the cost of production are reflected in tariffs.

- Transparency of the CWM and ECG commitments:
  - Published PURC Validation Report of ECG Revenue/Collection Accounts covering 2023Q4 and 2024 (end-January 2025 structural benchmark).
  - Report indicated deviations between validated collections from ECG’s cash settlement platform and those declared by ECG to the CWM: a GHS 5.3 billion difference in 2024.
  - Report indicated deviations between CWM allocations and payments: GHS 3.9 billion in 2024.
  - Commitment to conduct and publish audited quarterly validation of ECG’s revenue and collection account within three months after quarter-end and to take corrective actions.
  - Ministry of Energy directive of February 10, 2025: ECG to comply with CWM guidelines and operate a single account for collections and payments.
  - Government commits to ensuring continued payments against agreed amounts on current bills and legacy arrears through enforcement of the CWM and government transfers within existing budget appropriations.
  - PURC will publish monthly CWM Validation reports with a 2-month lag, including validated ECG collections and disbursements to Tier A and Tier B claimants.
  - In January and February 2025, ECG reported monthly revenue of over GHS 1 billion, the minimum requirement of CWM.

- Tackling energy sector legacy debt:
  - Validation of energy sector legacy debt for end-2023 and end-2024 to be completed in July 2025.
  - Going forward, annual validation of legacy debt within 4 months of the end of the validation period.
  - Ministry of Finance will provide IMF staff a quarterly debt matrix with a lag of 3 months to assess accumulation of payables.
  - Two out of five renegotiated PPAs with IPPs (AKSA, CENIT) are effective.
  - Remaining three (Cenpower, Twin City Energy (Amandi), Early Power) to be approved by Cabinet by 2025Q3 and subsequently submitted to Parliament for approval.
  - Government committed to concluding negotiations on legacy arrears and restructured contracts and to respecting payment plans associated with renegotiated PPAs.

- Long-term sector sustainability reforms:
  - Technical Committee recommended private sector concessions for entire distribution operation; Cabinet endorsed strategy for private sector participation in April 2025 (end-September 2025 structural benchmark).
  - Implementation to start in 2025Q2 with hiring of a transaction advisor; comprehensive technical and financial audit of ECG’s operations in 2025Q3.
  - Contracts expected to be awarded by 2026Q3.
  - With IMF TA, develop framework to guide energy sector subsidies by end-2025, including mechanism to insulate vulnerable population fully or partially from large tariff increases.

### Cocoa Sector Measures
- Cocobod turnaround strategy published in October 2024 with Fund and Bank consultation:
  - Farmgate prices set between 60-70 percent of the FOB international price inclusive of Living Income Differential.
  - 2024/25 season farmgate price: GHs 49,600 per ton, stated as consistent with average expected sales price and expected to help maintain balanced cash flow.

- Functional review and cost rationalization (with World Bank support):
  - Review all departments and subsidiaries to identify cost rationalization measures, including scaling back quasi-fiscal spending on cocoa roads, fertilizer, and pesticides.
  - Cocoa roads portfolio streamlined from GHS21 billion to GHS6 billion.
  - No intention to award new cocoa road construction contracts; road functions returned to ministry of roads.
  - World Bank supporting preparation of a strategy for the cocoa sector.

- Strengthened financial oversight of Cocobod:
  - Ministry of Finance actively participating in price setting deliberations; cocoa desk established at MoF.
  - Funding plans to be reviewed regularly and associated with contingency planning exercises.
  - Cocobod will scale down spending if downside risks materialize.
  - Cocobod to refrain from mobilizing any non-concessional funding and/or collateralized funding—except for its annual syndicated loan.
  - Cocoa Board Bill amended to change supervisory Ministry from Ministry of Food and Agriculture to Ministry of Finance, clarify mandates of Producer Price Review Committee and Producer Price Review Technical Committee, and limit Cocobod’s engagement in quasi-fiscal activities.

### Ghana Gold Board (GoldBod)
- Purpose and institutional consolidation:
  - Gold Board to improve management of gold sector activities and enhance benefits of gold exports, especially from small-scale mining.
  - Centralize purchase, trade, export, licensing, and regulatory enforcement in one institution to reduce smuggling, foreign exchange receipt losses, illegal mining, and environmental damage.

- Safeguards and risk management:
  - 2025 budget endowed Gold Board with initial capital of US$279 million to purchase around 3 tons of gold from domestic artisanal, small and medium-scale miners and resell for reserves accumulation to the Bank of Ghana or on international markets.
  - Objective to turn over 3 tons on a weekly basis.
  - Main revenue source: margin on gold purchases relative to quality-adjusted international gold prices, set to cover operational expenses, absorb market risk, and finance regulatory and oversight activities.
  - Gold Board to publish quarterly reports on volumes and prices of purchases and sales, revenue, spending and general operations, and an annual audited report (financial and operations); ensure access to reports through parliamentary scrutiny and public disclosure.
  - Board/CEO and deputies selected via transparent process based on fit and proper, independence and integrity criteria aligned with OECD Guidelines on Corporate Governance for SOEs.
  - All anti-corruption and integrity laws and frameworks fully applicable to Gold Board and personnel; mandated to adhere to the PFM Act.
  - Fiscal risk minimization measures: short turnover times from aggregators to exports, Minister of Finance signature required on all new borrowing, adjusting gold prices daily (to be published daily) based on market reference rates, and establishing a stabilization fund that receives excess profits to prepare for negative shocks.
  - Funds earmarked to support small-scale miners capped at 30 percent of the preceding year’s surplus (net profit); guidelines to be published in the official gazette ahead of any disbursement.
  - Gold Board to increase traceability of small-scale miners over time and support sustainability initiatives such as land reclamation and geological studies.

### Governance and Anticorruption
- Overall commitments:
  - Accelerate reforms across public sector and key areas to restore public trust, foster business environment, strengthen governance, reduce corruption, advance transparency and accountability, streamline administrative and regulatory processes, and uphold the rule of law.
  - Develop a comprehensive conflict of interest and Asset Declarations regime for public office holders and strengthen independent anti-corruption and oversight institutions.
  - Improve judicial integrity and efficiency.

- Specific actions and timelines:
  - Finalizing the Governance Diagnostic Report prepared with IMF technical assistance, with view to publish in coming months.
  - Update National Anti-Corruption Action Plan (NACAP) through participatory process by end-September 2025, informed by Governance Diagnostic and NACAP evaluation prepared in 2024 with UNODC support.
  - Prepare, in consultation with IMF staff, a new draft law on asset declaration and submit it to Parliament by end-September 2025 (structural benchmark). The bill will require, at minimum:
    - asset declarations by most senior officials (President, Vice President, Members of Parliament, Ministers and their deputies, the Chief Justice, heads of anti-corruption and accountability institutions, and managers and board members of public corporations and SOEs) upon assuming office, within reasonable intervals, and upon leaving office;
    - disclosure scope to include all assets owned directly or beneficially, in Ghana and abroad;
    - public disclosure of asset declarations of senior officials, with appropriate safeguards to protect personal information;
    - a robust sanctions regime to deter noncompliance.
  - Continue implementing recommendations from the Auditor General’s report on audit of Covid-19 spending; AG’s office verified reported progress with ministries and published implementation follow-up report in May.

### AML/CFT Framework Strengthening
- Preparations for GIABA Third Round Mutual Evaluation planned for 2026:
  - Stakeholders completed drafting the National Risk Assessment (NRA); validation of the NRA to be completed in early June.
  - First submission of the Technical Compliance questionnaire made in April 2025; iterative review process with stakeholders until final submission in August 2025.
  - Finalized NRA to inform National Action Plan mitigation measures.

- Capacity building and preventive measures:
  - Financial Intelligence Center (FIC) to continue engaging, sensitizing, training and building capacity of reporting entities on Customer Due Diligence (CDD), risk assessment, trends and typologies, and collaborate with sectoral supervisors for enforcement of targeted financial sanctions.
  - Strengthen preventive measures for Designated Non-Financial Businesses and Professions (DNFBP) by increasing sensitization and capacity building in priority sectors: real estate, casinos and dealers in precious metals and precious stones; enhance framework for filing suspicious transaction reports.
  - Strengthen transparency of Beneficial Ownership (BO) of legal entities, including implementing March 2022 updates to FATF’s Recommendation 24, and facilitate access to BO register for competent authorities and accountable institutions.
  - New software system (CRO) tested; will draw from FIC databases and eventually from National Identification Authority and Ghana Revenue Agency to facilitate timely access to BO register.

### Sustainable and Inclusive Growth
- Policy pillars to boost private investment, diversify the economy, and foster inclusive growth:

  - Improving business environment:
    - By September 2025, submit regulations for the PPP Act and Corporate Insolvency and Restructuring Act to Parliament.
    - Strengthen digital business registration platform: establish service centers and activate 24/7 helpline.
    - Conduct review of Ports’ taxes, fees and charges.
    - Submit Consumer Protection Competition and Business Regulatory Reforms Commission bills to Parliament.
    - Launch platform for sustained Government-private sector engagement by December 2025 and hold quarterly tax dialogue with business community.

  - Attracting FDI:
    - Re-submit Amendments to the Ghana Investment Promotion Centre Act to Parliament by end-2025 to address minimum foreign capital requirements.
    - By end-2025, with World Bank support, enact a new Investment Law.

  - Boosting export competitiveness and AfCFTA integration:
    - Pursue 24-Hour Economy policy and implement Economic Transformation Agenda (ETA).
    - By end-2025, take measures to enable Ghanaian businesses to leverage AfCFTA, support businesses to be AfCFTA certified, and update 2005 Trade Policy.
    - Crystalize reforms into a five-year Trade Sector Support Programme.
    - Accelerate implementation of WTO Trade Facilitation Agreement Implementation Action Plan measures.

  - Upskilling workforce:
    - Improve efficiency of Free Senior High School program and strengthen uptake by poorest households.
    - Provide support for out-of-school children to access formal education and skills training.
    - Implement National Apprenticeship Programme, expand access, and identify critical skills gaps with private sector.

  - Streamlining sectoral and industrial policies:
    - Agriculture for Economic Transformation Agenda (AETA) to underpin Feed Ghana Programme.
    - By end-2025, launch Farmers' Service Centres and make progress towards establishment of Farm Banks within agricultural zones.
    - Undertake comprehensive review of Made-in-Ghana Products Policy.

  - Improving access to finance:
    - Work with Development Bank of Ghana and partners to leverage financial services for women-owned and led businesses.
    - By end-2025, establish National Employment Trust to manage an investment fund to de-risk high-growth, high-job-potential areas.

  - Encouraging digitalization:
    - Establish One Million Coders Programme, Regional Digital Centres, a FinTech Growth Fund and Zonal ICT Parks.

*Source: 1ghaea2025001-source-pdf - 55. We intend to submit to Parliament a new Extractive Industry Fiscal Regime Bill*

### 69. The program will continue to be monitored on a semi-annual basis, through

### The program will continue to be monitored on a semi-annual basis, through

### Program monitoring framework
- The program will be monitored on a semi-annual basis through:
  - quantitative performance criteria,
  - continuous performance criteria related to the Article VIII,
  - a monetary policy consultation clause,
  - indicative targets, and
  - structural benchmarks.
- A Memorandum of Understanding between the government and the BoG has been established to set responsibilities for servicing financial obligations to the Fund.
- The phasing of access under the arrangement and the review schedule are set out in Table 1 of the memorandum that accompanied the program request.
- The quantitative performance criteria and indicative targets through end-March 2026 are set out in Table 2. The structural benchmarks are described in Table 3.

### Performance criteria and selected numeric outcomes (Table 1 excerpts)
- Net international reserves of the Bank of Ghana, cumulative change floor (millions of U.S. dollars):
  - Reported values: 9088861,719Met1669564934938248241,4501,450 50
- Changes to Bank of Ghana claims on the central government and public entities, cumulative ceiling (millions of cedis):
  - Reported target/outturn fragment: 0-1Met0-30000000
- Present value of newly contracted or guaranteed external debt by the central government and public entities, cumulative ceiling (millions of U.S. dollars):
  - Reported values: 231.5240.535Met50.0050.05050.05050.05070
- Primary fiscal balance of the central government, commitment basis, cumulative floor (millions of cedis):
  - Reported values: 4,805.77,128.610,871Met-1,276.1n.a.1,576.11,6909,31210,58818,25020,989-716
- Non-accumulation of external debt payments arrears by the central government and the Bank of Ghana, continuous ceiling (millions of U.S. dollars):
  - Reported fragment: 00Met000000000
- Newly contracted collateralized debt by the central government and public entities, continuous cumulative ceiling (millions of U.S. dollars):
  - Reported fragment: 00Met000000000

### Monetary Policy Consultation Clause (inflation bands and targets from Table 1)
- Twelve-month consumer price inflation (percent):
  - Outer band (upper limit): 22.019.016.516.514.019.012.016.014.0
  - Inner band (upper limit): 20.017.014.514.512.017.010.014.012.0
  - Central target rate: 18.023.8Not met15.0 22.4 12.512.510.015.08.012.010.0
  - Inner band (lower limit): 16.013.010.510.58.013.06.010.08.0
  - Outer band (lower limit): 14.011.08.58.56.011.04.08.06.0

### Indicative targets and selected figures (Table 1 excerpts)
- Non-oil public revenue, cumulative floor (millions of cedis):
  - Reported values: 154,087159,055Met36,42338,56876,88584,836125,545138,847182,564202,11349,074
- Social spending, cumulative floor (millions of cedis):
  - Reported values: 5,5725,723Met1,779n.a.3,3803,3995,3365,3677,1157,1552,242
- Net change in the stock of payables of the central government and of the energy sector, cumulative ceiling (million of cedis):
  - Reported values: 045,604Not met0n.a.0000000
- Total contracted but not yet disbursed external commercial and official project loans pre OCC cut-off date, continuous cumulative ceiling (millions of U.S. dollars):
  - Reported values: 250184.4Met25015250250250250250250250

### Attachment II — Technical Memorandum of Understanding (TMU): key definitions and parameters
- Purpose: sets out definitions of performance criteria (PCs), indicative targets (ITs), consultation clauses, methods for assessing program performance, and information requirements.
- Program exchange rates: specified in the Table (Rates as of February 28, 2023). The gold price for the purpose of the program is US$ 1,826.92 per ounce (as per Bloomberg data as of February 2023).

### Definitions and scope for monitoring
- Central government definition (¶3):
  - Comprises the central government, all special funds (including the Ghana Education Trust Fund, the Road Fund, the District Assemblies Common Fund, the National Health Insurance Fund and Mineral Income Investment Fund), and all subvented and other government agencies classified as government in the BoG Statement of Accounts (SOA).
  - Excludes the Social Security and National Insurance Trust (SSNIT) and public enterprises, including Cocobod.
- Public entities for monitoring (¶4) include (explicit list):
  - (i) Tema Oil Refinery; (ii) Ghana National Petroleum Company; (iii) Ghana National Gas Company; (iv) Volta River Authority; (v) Electricity Company of Ghana; (vi) Ghana Grid Company Ltd (GRIDCO); (vii) Ghana Water Company Limited; (viii) Ghana Infrastructure Investment Fund (GIIF); (ix) Daakye PLC; (x) Energy Sector Levy Act (ESLA) PLC; (xi) Asanti Gold Corporation; (xii) Cocobod; (xiii) Ghana Integrated Aluminium Development Corporation (GIADEC); (xiv) Bulk Oil Storage and Transportation (BOST); (xv) the Ghana Gold Board (GoldBod).

### Continuous performance criteria (standard to all Fund arrangements)
- No imposition or intensification of restrictions on the making of payments and transfers for current international transactions.
- No introduction or modification of multiple currency practices.
- No conclusion of bilateral payments agreements inconsistent with Article VIII of the IMF Articles of Arrangement.
- No imposition or intensification of import restrictions for balance of payments reasons.
- These criteria will be monitored continuously.
- The revision of the BoG reference rate methodology (end-August 2024 SB) and the introduction of competitive price-based FX spot auctions, being conducted in consultation with IMF staff, would not constitute an introduction or modification of multiple currency practices (MCPs).

### Net International Reserves (NIR) — definition and adjustors (Section A)
- NIR of the Bank of Ghana defined as reserve assets minus short-term foreign-currency liabilities and liabilities to the Fund. All values not in U.S. dollars are converted using program exchange rates and specified gold price.
- Reserve assets (RA) include: Bank of Ghana holdings of monetary gold, SDRs, foreign currency cash, foreign currency securities, deposit abroad, and the country’s reserve position at the Fund.
  - Excluded from RA: assets that are pledged, collateralized, or otherwise encumbered; claims on residents; precious metals other than gold; assets in nonconvertible currencies; and illiquid assets. Encumbered assets include Ghana Petroleum Heritage and Stabilization Fund and Bank of Ghana deposits with Ghana International Bank London.
- Short-term foreign-currency liabilities include contractual foreign-currency obligations scheduled to come due during the 12 months ahead (Deposits of International Institutions; Liabilities to International Commercial Banks; FX Swaps with non-resident and resident banks; foreign currency deposits held at the BoG). Liabilities with an asset counterpart that is encumbered are excluded.
- Liabilities to the Fund include all outstanding use of IMF credit, including IMF budget support for the MoF, but exclude SDR allocations.
- Adjustors to the NIR floors:
  - Upward adjustment for any excess of budget grants, loans, and foreign exchange received in the context of the sales of 5G spectrum licenses, except where used to repay outstanding domestic arrears faster than programmed.
  - Downward adjustment for any shortfall in budget grants and loans relative to the program baseline.
  - NIR floors will be adjusted upwards by the full amount of the debt service payments on commercial claims in the restructuring perimeter below the amounts in the program baseline.

### Expected budget grants, loans, and debt service payments (as presented)
- Ghana: Expected Budget Grants and Loans, 2024-2026 (Cumulative from the beginning of the year, USD millions) — table referenced in the TMU.
- Ghana: Expected Debt Service Payments on Commercial Claims in the Restructuring Perimeter, 2024-2026 (Cumulative from the beginning of the year, USD millions):
  - First reported row: 501409350699699704
  - Second reported row: 39011651661695094

### Changes to BoG claims on central government and public entities (Section B)
- Definition: Change measured from the start of the program of (i) all BoG loans and advances to central government and public entities; (ii) all central government and public entities overdrafts; (iii) face value for all outstanding Government of Ghana treasury bills, notes and bonds purchased by BoG in the primary and secondary market, net of the stock adjustment from the debt operation (e.g., capitalization of interest payments).
- Includes all called guarantees given by BoG for operations between the central government or public entities and a third party.
- Exclusions: (i) BoG holdings of Government of Ghana T-bills as collateral from commercial banks; (ii) BoG reversible market transactions involving Government of Ghana securities; (iii) claims related to transactions between central government and external institutions that do not involve BoG–government financial commitments and are fully offset by a corresponding liability (“contra” or “wash” accounts).
- On-lending of IMF resources from SDR holdings and PRGT loans are excluded from claims on central government for program monitoring; however, starting July 1st, 2025, interest, fees, charges or overdue principal payments related to on-lent SDR holdings and PRGT facilities not reimbursed to the BoG by the central government are included in claims on the central government.
- On-lending-related claims are considered extinguished only by a debit from the government’s deposit accounts at the BoG (payments from the BoG to the IMF notwithstanding).
- Claims on public entities exclude claims on wholly owned subsidiaries of the Bank of Ghana.

### Present value (PV) ceiling on newly contracted or guaranteed external debt (Section C)
- External debt defined on a residency basis; “debt” definition refers to paragraph 8(a) of the 2014 Guidelines on Public Debt Conditionality in Fund Arrangements.
- Debt forms include: (i) loans (deposits, bonds, debentures, commercial loans, buyers’ credits, repurchase agreements, official swap arrangements); (ii) suppliers’ credits; (iii) leases (PV at inception of lease payments).
- Arrears, penalties, and judicially awarded damages that constitute debt are included.
- The performance criterion applies to the cumulative PV of new external debt contracted or guaranteed by the central government and public entities, including commitments contracted or guaranteed for which value has not yet been received, and private debt with official guarantees.
- Contracting occurs when all conditions for entry into effect are met in accordance with contract terms and national legislation. Contracting of credit lines with no predetermined disbursement schedules or multiple disbursements is considered contracting of debt.
- Exclusions from the ceiling on cumulative PV of new contracted or guaranteed external debt:
  - (i) loans and bonds from restructuring/rescheduling/refinancing of external debt;
  - (ii) renewal of an existing suppliers’ credit;
  - (iii) rollover of a credit line;
  - (iv) short-term debt including suppliers’ credit and credit lines with a maturity of less than 6 months for public entities;
  - (v) debt contracted from the IMF, World Bank and AfDB;
  - (vi) Government of Ghana securities issued in domestic currency, placed in domestic primary or secondary markets, and held by non-residents.
- Guaranteed debt defined as an explicit promise by the central government and public entities to pay or service a third-party obligation.
- PV calculation: discount future stream of payments using unified discount rate of 5 percent (Executive Board Decision No. 15248-(13/97)).
- A debt is concessional if it has at least a grant element of 35 percent; grant element equals difference between PV debt and its nominal value as a percentage of nominal value. For grant element ≤ 0, PV set equal to nominal value.
- For variable-rate loans (benchmark + fixed spread), PV calculated using program reference rate plus fixed spread. Program reference rate for three-month USD SOFR is 2.97 percent and will remain fixed for the duration of the program.
  - Spread of three-month JPY TIBOR over three-month USD SOFR is -300 basis points.
  - Spread of three-month U.K. SONIA over three-month USD SOFR is equal to 50 basis points.
  - For currencies other than Euro, JPY, and GBP, the spread over three-month USD SOFR is 0 basis points.
  - Where variable rate linked to a benchmark other than three-month USD SOFR, a spread reflecting the difference between the benchmark rate and the three-month USD SOFR (rounded to the nearest 50 bps) will be added.

### Reporting requirements (PV of new external debt criterion)
- MOF must immediately report to IMF staff details of any new external loans before contracting or guarantees before issuance by the central government and public entities.
- MOF must provide, on a monthly basis and within 30 days from the end of each month, detailed data on all new concessional and non-concessional external debt contracted or guaranteed by the central government and public entities, including:
  - (i) amounts contracted or guaranteed;
  - (ii) currencies;
  - (iii) terms and conditions, including interest rates, maturities, grace periods, payments per year, commissions and fees, and collaterals.

*Ghanaian authorities; and IMF staff estimates and projections.*

### 24. The PV ceiling of newly contracted or guaranteed external debt by the central

### 24. The PV ceiling of newly contracted or guaranteed external debt by the central

### D. Primary Fiscal Balance of the Central Government, Commitment Basis, Cumulative Floor (Millions of Cedis) — Definition and Measurement
- The program’s primary fiscal balance is cumulative from the beginning of the fiscal year and is measured as the primary balance on cash basis (¶26) from the financing side minus the net accumulation of payables (¶29).
- The primary balance on cash basis is measured as the sum of net financial transactions of the central government (¶3)—comprising:
  - net foreign financing (¶27),
  - net domestic financing (¶28),
  - receipts from net divestitures and net drawing out of oil funds,
  - minus domestic and external interest payments.
- The primary balance on cash basis excludes financing for the financial sector recapitalization.
- Net foreign financing (¶27) is defined as the sum of project and program loans by official creditors and commercial external borrowing, minus amortization due.
  - Tabulated series: Dec-24Mar-25Jun-25Sep-25Dec-25Mar-26 8.800000
- Net domestic financing (¶28) is the change in government deposits plus domestic debt issuance proceeds, minus domestic debt amortization due.
- Net accumulation of payables (¶29) includes:
  - net change in the stock of central government payables originated in GIFMIS,
  - net accumulation of payables of the energy sector (¶31–32).
- Positive net change in payables means more payables are built up than cleared (primary balance on cash basis stronger than on a commitment basis).
- The fiscal primary balance excludes financial sector cost (government support to strengthen the financial sector as envisaged under the program).

### Payables — Definitions and Treatment
- Central government payables originated in GIFMIS include payables of statutory/earmarked funds (SFs), defined as outstanding payments from the consolidated funds to the SFs (¶30).
- Energy-sector payables:
  - Up until March 2025 (¶31): difference between total fixed cost bills received by Electricity Company of Ghana (ECG) from IPPs and fuel suppliers and payments made by ECG and the Government of Ghana on energy obligations (current and past years), including exchange rate adjustments and Natural Gas Clearinghouse credit notes.
  - After March 2025 (¶32): sum of gross payables of the Government of Ghana and state-owned enterprises to IPPs and fuel suppliers, net of receivables of the Government of Ghana and state-owned enterprises from IPPs and fuel suppliers.
  - Quarterly reporting of energy sector payables and receivables will be provided by the Ministry of Finance; net accumulation is measured in US dollars and converted to cedis at the average exchange rate for the quarter.

### Adjustors to the Primary Balance Floor (¶33–34, ¶44)
- The primary balance floor will be adjusted for excesses and shortfalls in disbursed concessional project loans relative to program assumptions:
  - Adjust downward for the full amount of any excess in concessional project loans.
  - Adjust upward for the full amount of any shortfall in concessional project loans.
- The primary balance floor will be adjusted upward by the full amount of non-tax revenue proceeds from the sale of 5G Spectrum licenses (¶34).
- The non-oil revenue floor will be adjusted upward (downward) by the amount received as the one-off dividends revenue from the ESLA bond closure program in excess (shortfall) of the program assumption (¶44).

### E. Non-Accumulation of External Debt Payment Arrears by the Central Government and the Bank of Ghana, Continuous Ceiling (Millions of U.S. Dollars) — Definition
- External payment arrears accrue when payments such as interest or amortization on debts of the central government (¶3) to non-residents are not made within the terms of the contract, taking into account all applicable grace periods (¶35).
- Definition excludes arrears relating to debt subject to renegotiation (dispute or ongoing renegotiation) or rescheduling.
- This performance criterion is monitored on a continuous basis.

### F. Newly Contracted Collateralized Debt by the Central Government and the Public Entities, Cumulative Zero Ceiling — Definition
- Collateralized debt is any contracted or guaranteed debt that gives the creditor rights over an asset or revenue stream that would allow it, if the borrower defaults, to rely on the asset or revenue stream to secure repayment (¶36).
- The performance criterion applies to debt contracted or guaranteed by the central government (¶3) and the public entities outlined in ¶4 (¶37).

### Monetary Policy Consultation Clause (¶38–40)
- Consultation bands around the projected year-on-year (12-month) rate of CPI inflation (headline CPI published by the Ghana Statistical Service) are specified in Table 1 of the MEFP (¶38).
  - Tabulated series: Dec-24Mar-25Jun-25Sep-25Dec-25Mar-26 574.4117.3175.0262.5350.0123.5
- If observed year-on-year CPI inflation falls outside the lower or upper outer bands in the PC table for relevant test dates:
  - Authorities will initiate consultation with the IMF Executive Board focusing on: (i) stance of monetary policy and program track; (ii) reasons for deviations and compensating factors; (iii) proposed remedial actions if necessary.
  - When consultation is triggered, access to Fund resources would be interrupted until consultation takes place and the relevant program review is completed (¶39).
- If observed year-on-year CPI inflation falls outside the inner bands, the authorities should conduct discussions with Fund staff (¶40).
- Key inflation observation: In December 2024, CPI inflation stood at 23.8 percent (year-on-year), breaching the 22 percent upper outer band (Attachment III).

### G. Non-Oil Public Revenue, Cumulative Floor (Millions of Cedis) — Definition and Adjustors
- Total non-oil revenue includes:
  - total tax revenue—all revenue collected by the GRA including Direct Taxes, Indirect Taxes (excises, VAT, NHIL, GETFund Levy, Covid-19 Health Levy, E-Levy, CST), and Trade Taxes;
  - total non-tax revenue—including IGFs retention, Fees and Charges, Dividend/interest and profits from oil and others, Surface rental from oil/PHF interest, property rate collection and yield from capping policy.
- Excludes grants, oil revenue (¶42)43, social security contributions and ESLA proceeds.
- Total non-oil revenue is recorded on a cash basis (¶41).
- Adjustors:
  - Floor adjusted upward by full amount of non-tax revenue proceeds of the sale of 5G Spectrum licenses (¶43).
  - Floor adjusted upward (downward) by one-off dividends revenue from ESLA bond closure program in excess (shortfall) of program assumptions (¶44).
- Tabulated series referenced: Ghana: Expected dividends revenue from the ESLA bond closure program, 2024-2025 (Cumulative from the beginning of the year, GHS millions).

### H. Ceiling on the Disbursement of Total Committed but not yet Disbursed External Bilateral and Commercial Project Loans pre-end-December 2022 (Millions in USD) — Definition and Reporting
- Ceiling applies to total contracted but not yet disbursed project loans to the central government from official external and commercial creditors, including disbursements from undisbursed projects contracted before the OCC cut-off date (¶45).
- External debt defined as in ¶15.
- Detailed data on contracted but not yet disbursed external project loans of bilateral creditors pre-OCC cut-off date will be provided quarterly, within 30 days from the end of each quarter, including amounts, currencies, creditors, and project names (¶46).

### I. Social Spending, Cumulative Floor (Millions of Cedis) — Definition
- Expenditure floor on poverty-reducing social programs includes:
  - disbursement of the National Health Insurance Fund used to pay for medical claims, essential medicine, and vaccines;
  - payment received from CAGD to line ministries for Ghana School Feeding Program, Livelihood Empowerment Against Poverty Program, and the Capitation Grant.
- Measured expenditure excludes donor-supported expenditure and is measured as consolidated funds’ releases to MDAs (¶47).

### J. Net Change in the Stock of Payables of the Central Government and of the Energy Sector, Cumulative Ceiling (Millions of Cedis) — Definition
- Net change defined as change in stock of central government payables (¶49) plus net accumulation of energy sector payables (¶50–51), cumulative from fiscal year start (¶48).
  - Tabulated series: Sep-24Dec-24Mar-25Jun-25Sep-25Dec-25Mar-26 800.0800.00.00.00.00.00.0
- Central government payables are the stock reported by CAGD covering payables of all budgetary central government entities and include payables to SFs reported by CAGD at quarter-end (¶49).
- Energy sector payables:
  - Up to March 2025 (¶50): energy-sector-related outstanding payments of ECG and GNPC (including those to be paid by MoF) to power generators and fuel suppliers; net accumulation is quarterly change denominated in US dollars converted to cedis at average daily exchange rate in last month of period.
  - After March 2025 net accumulation follows definition in ¶32 (¶51).

### Provision of Data to the Fund (¶52–53) and Table 1 Reporting Requirements (Selection of Key Items)
- Authorities will provide data on variables subject to performance criteria and indicative targets monthly with a lag no more than eight weeks, except where specific lags are specified (¶52).
- Authorities will share prospective debt agreements relevant for program monitoring with Fund staff before submission to cabinet and before contracting (¶53).
- Selected periodic reporting requirements from Table 1 (exact periodicities preserved in source):
  - Central budget operations for revenues, expenditures and financing: Monthly, within six weeks of the end of each month.
  - Stock and quarterly flows of buildup/clearance of GIFMIS payables: Quarterly, within six weeks of the end of each quarter.
  - Stock of CAGD payables for agreed MDAs: Quarterly, within 90 days of the end of each quarter.
  - Monthly cash flow projections for energy sector payments (next 12 months): Quarterly, at the beginning of each quarter.
  - Weekly gross international reserves and net international reserves: Weekly, within a week of the end of each week.
  - Total debt stock of central government and central government-guaranteed debt by creditor (loan-by-loan database for external debt): Monthly, within four weeks of the end of each month.
  - Detailed information on total contracted but not yet disbursed external project loans pre-OCC cut-off date: Quarterly, within 30 days from the end of each quarter.
  - Quarterly financial statements of main state-owned enterprises (specified list): Quarterly, within three months of end of quarter.
  - Monthly production and export data for key commodities (oil, gas, gold, cocoa): Monthly, within four weeks of the end of each month.
- Additional reporting items and frequencies are specified across fiscal, monetary, financial sector, balance of payments, debt, and energy pricing tables in Table 1.

### Attachment III — Consultation on Missed Inflation Targets
- December 2024 CPI inflation: 23.8 percent (year-on-year), which breached the 22 percent upper outer band agreed in the Monetary Policy Consultation Clause and defined in the TMU.

*Source: 1ghaea2025001-source-pdf - 24. The PV ceiling of newly contracted or guaranteed external debt by the central*

### 2. Progress on disinflation stalled in 2024. Ghana is recovering from a debt crisis that led to

### 2. Progress on disinflation stalled in 2024. Ghana is recovering from a debt crisis that led to

### Inflation developments and drivers
- Inflation surged to 54.1 percent by end-2022.
- Following rapid disinflation in 2023, CPI inflation remained virtually unchanged by end-2024 relative to end-2023.
- In 2024, the Bank of Ghana (BoG) cut interest rates by a cumulative 300 basis points in 2024, from 30 to 27 percent.
- Gross international reserves rose from 1.5 months of import cover at end-2023 to almost 3 by end-2025Q1, contributing to increased liquidity and requiring stronger sterilisation.
- Food price shocks:
  - Food inflation surged to 29.6 percent in March 2024 due to disruptions in the Sahel (Burkina Faso, Mali, Niger).
  - Food inflation eased temporarily but rose again in the final four months of 2024 due to dry conditions in northern Ghana affecting yields.
- Non-food inflation and exchange rate pressures:
  - The cedi depreciated by 24.8 percent year-to-date by September 2024.
  - Fuel prices at the pump rose, leading to a 25 percent increase in transport fares.
  - These factors compounded supply chain challenges and sustained inflationary pressures.

### Monetary policy and implementation changes (Policy Response)
- Monetary Policy Committee (MPC) actions:
  - The MPC raised the policy rate by 100 basis points in March 2025 and kept it unchanged in May 2025 despite easing inflation.
  - The BoG stands ready to take further action should inflationary risks intensify.
- Monetary implementation framework reforms:
  - BoG will intensify sterilization through enhanced open market operations (OMOs), including issuance of longer-dated instruments such as the 273-day BOG bill.
  - Over time, longer-dated BOG bills will replace the use of the unremunerated cash reserve ratio (CRR) as the principal monetary policy tool.
  - BoG plans to review the CRR framework to eliminate the tiering mechanism and lower the effective reserve requirement to create space for increased OMOs.
- Policy stance and commitments:
  - Monetary policy will remain tight until inflation clearly returns to the BoG’s target range of 8±2 percent.
  - The BoG will: maintain a tight monetary policy stance; implement prudent financial sector policies; ensure strict adherence to zero financing of the budget; use its gold purchase programme to smooth excessive exchange rate volatility; and maintain sterilization efforts.

### Inflation projections and risks
- BoG projected inflation to decline to 12 percent by end-2025, assuming the stated policy response.
- Preliminary data and developments:
  - The cedi appreciated significantly since 2024Q4.
  - Recent CPI releases aligned with end-year targets—with annualized inflation in 2025 through May at 12.1 percent.
- Medium-term target:
  - The BoG is committed to restoring inflation to the medium-term target of 8±2 percent by the second quarter of 2026, assuming no further external shocks.
  - Forecast shows a gradual disinflation path, with inflation returning to target within a six-quarter horizon.
- Risks to the projection:
  - Risks remain elevated and two-sided, particularly for food inflation given prior supply disruptions.
  - Broader supply chain challenges, escalating trade tensions, adverse terms-of-trade shifts, and volatility in financial risk premia could affect exchange rate and inflation forecasts.

### Debt restructuring progress and DSA findings
- Progress on debt restructuring:
  - Domestic debt restructuring completed in 2023.
  - Restructuring of Eurobonds completed in October 2024.
  - Memorandum of Understanding with the Official Creditor Committee under the G20 Common Framework codifying a debt treatment consistent with IMF-supported program parameters was signed by all parties in January 2025; bilateral agreements are being prepared.
  - DSA treats residual claims of other external commercial creditors as "deemed away" given their small share and ongoing "good faith" negotiations.
- Risk assessment:
  - Risk of external debt distress: High
  - Overall risk of debt distress: High
  - Granularity in the risk rating: Sustainable
  - Application of judgment: No
- Outlook and sustainability:
  - Policy and reform implementation deteriorated in the months before the report, with fiscal slippages and accumulation of domestic arrears.
  - With a targeted primary surplus as of 2025, higher growth and inflation, and a more appreciated exchange rate than expected, the authorities’ objective of bringing all debt ratios under LIC-DSF thresholds by end-2028 remains achievable.
  - PV of total debt-to-GDP and external debt service-to-revenue ratios are projected to fall below 55 and 18 percent by 2028, respectively.
  - Ghana remains at high risk of debt distress due to near-term breaches but is expected to reach moderate risk of debt distress in the medium term.
  - Debt is assessed to be sustainable on a forward-looking basis assuming completion of external debt restructuring in line with program parameters.
- Stress tests:
  - A commodity price shock would put overall public debt well above the current trajectory throughout the full DSA horizon.
  - External and overall debt ratios are sensitive to commodity prices, exports, and combinations of shocks.

### Public debt coverage, key fiscal and debt figures
- DSA coverage and inclusions:
  - Central government's public and publicly guaranteed (PPG) debt, plus additional important liabilities of the public sector.
  - Explicitly guaranteed debt of other public and private sector entities including SOEs.
  - Certain implicitly guaranteed SOE debt: (a) Energy Sector Levy Act (ESLA) debt; (b) Ghana Educational Trust Fund (GETFund/Daakye) debt; (c) debt related to Sinohydro-financed infrastructure projects; (d) gross debt of Cocobod.
  - The DSA includes domestic arrears to suppliers estimated at 8.4 percent of GDP at end-2024.
- Fiscal legacy and contingent liabilities:
  - Financial sector recapitalization fiscal cost estimated to have reached 7.1 percent of GDP over 2017-21.
  - Recapitalization bonds issued in December 2023; additional recapitalization costs expected—DSA baseline includes GHS 22 bn (equivalent to 2.6 percent of 2023 GDP).
  - Government accumulated arrears to independent power producers (IPPs) and fuel suppliers of 2.6 percent of GDP at end-2024.
  - DSA baseline assumes government will continue to cover annual energy sector shortfalls with budget transfers.
- Tailored stress-test shocks modeled as contingent liabilities:
  - Add 2 percent of GDP in non-guaranteed SOE debt.
  - Add 5 percent of GDP from further financial sector costs.
  - Add 2.4 percent of GDP (equivalent to 35 percent of outstanding PPP arrangements).
  - Total of these elements equals 9.4 percent of GDP in the tailored stress-test contingent liability tail.
- Debt trajectory and historical context:
  - Public debt rose from 63 percent of GDP in 2019 to 92.7 percent of GDP at end-2022, of which 16 percent of GDP was held by the Bank of Ghana.
  - Domestic debt service accounted for 81.7 percent of the public debt service burden in 2022.
  - Debt service-to-revenue ratio reached 127 percent in 2020.
  - Gross financing needs (GFN) reached 19.5 percent of GDP in 2022 (market financing risks benchmark is 14 percent).

### Decomposition of public debt at end–2024 (selected figures from Text Table 2)
- Total debt stock (2024): 56,193 (US$ mn) — 100.0 percent total debt — 70.2 percent of GDP
- External debt: 29,152 (US$ mn) — 51.9 percent total debt — 36.4 percent of GDP
  - Multilateral creditors: 11,365 (US$ mn) — 20.2 percent total debt — 14.2 percent of GDP
    - IMF: 3,377 (US$ mn) — 6.0 percent total debt — 4.0 percent of GDP
    - World Bank: 6,388 (US$ mn) — 11.4 percent total debt — 8.0 percent of GDP
  - Bilateral creditors: 5,364 (US$ mn) — 9.5 percent total debt — 6.7 percent of GDP
  - Bonds: 9,236 (US$ mn) — 16.4 percent total debt — 11.5 percent of GDP
    - Commercial creditors: 3,187 (US$ mn) — 5.7 percent total debt — 4.0 percent of GDP
    - Local-currency government debt held by non-residents: 913 (US$ mn) — 1.6 percent total debt — 1.1 percent of GDP
- Domestic debt: 27,041 (US$ mn) — 48.1 percent total debt — 33.8 percent of GDP
  - Short-term bills: 6,532 (US$ mn) — 11.6 percent total debt — 8.2 percent of GDP
  - Medium-to-long term bonds: 13,088 (US$ mn) — 23.3 percent total debt — 16.4 percent of GDP
  - Arrears: 6,736 (US$ mn) — 12.0 percent total debt — 8.4 percent of GDP
- Memo items:
  - Cocobod debt: 529 (US$ mn) — 0.9 percent total debt — 0.7 percent of GDP
  - Contingent liabilities: 398 (US$ mn) — 0.7 percent total debt — 0.5 percent of GDP
  - Nominal GDP (in GHS mn): 1,176,220

### Policy support and reform priorities
- Authorities launched an ambitious adjustment and reform program and a comprehensive public debt restructuring.
- Key measures taken:
  - Eliminated monetary financing.
  - Tightened monetary policy.
  - Limited foreign exchange interventions.
  - Initiated fiscal consolidation and reforms to build resilience.
  - Strengthened public debt management with TA support and upgraded securities operations infrastructure.
  - Improved monitoring of contingent liabilities from SOEs and requested Fund TA for an SOE oversight strategy.
  - Training using FAD’s SOE Health Check tool delivered by AFRITAC West 2 in 2024.
- External support:
  - Program supported by the IMF’s Extended Credit Facility (ECF) arrangement and the World Bank DPO series.

*Source: IMF staff and World Bank staff Debt Sustainability Analysis and Bank of Ghana monetary policy sections as presented in the provided content.*

### 8.      The authorities’ comprehensive debt restructuring aims at achieving debt sustainability and

### 8.      The authorities’ comprehensive debt restructuring aims at achieving debt sustainability and 

### Debt restructuring objectives and progress
- Aim: achieve debt sustainability and a moderate risk of debt distress under the LIC-DSF framework by bringing debt stock and flow ratios down to their respective thresholds.
- Specific targets: reduction in the PV of total debt-to-GDP and external debt service-to-revenue ratios to 55 and 18 percent, respectively, by 2028.
- Status:
  - Domestic debt restructuring completed in 2023.
  - Memorandum of Understanding (MoU) with the Official Creditor Committee (OCC) under the G20 Common Framework codifying debt treatment consistent with IMF-supported program parameters signed by all parties in January 2025; bilateral agreements for implementation are being prepared.
  - Eurobond exchange successfully finalized in October 2024.
  - Authorities reached out to all commercial creditors for debt data reconciliation and to share debt treatment proposals.

### Economic stabilization and recent macro developments
- Growth:
  - Real GDP growth slowed to 3.1 percent in 2023, rebounded to 5.7 percent in 2024.
- Inflation:
  - Headline inflation reached 54 percent in December 2022.
  - Inflation declined to about 23.2 percent at end-2023 and remained at 23.1 percent in February 2025.
- Reserves and external sector:
  - Gross international reserves fell by about $6.5 billion in 2022, reaching US$1.4 billion at end-2022.
  - Reserves recovered to US$6.4 billion (end-December 2024 – 2.6 months of imports).
- Public debt and fiscal:
  - Bank of Ghana’s holding of domestic debt increased from 11 percent of GDP in 2019 to 16 percent of GDP in 2022.  
  - Ghana’s debt stock decreased to 80.6 percent of GDP in 2023.
  - Effects of debt restructuring, more appreciated exchange rate at end-2024, higher inflation and nominal GDP allowed overall debt stock to decline to about 70.2 percent at end-2024.

### Fiscal developments and 2024 slippages
- 2023 fiscal improvement: reduction in the primary deficit by 4 percentage points to 0.3 percent of GDP.
- 2024 deterioration:
  - Large expenditure overruns mainly outside GIFMIS in run-up to December-2024 elections.
  - Staff baseline assumes net accumulation of arrears in 2024 amounted to 2.6 percent of GDP based on authorities’ estimates.
  - This raised the primary deficit on a commitment basis back to the 2022 level and increased domestic arrears and nominal domestic debt stock.
- Audit and arrears:
  - Authorities undertaking comprehensive audit of accumulated domestic arrears; preliminary audit results indicate significant amount may not be supported by valid documentation and may be revised down.

### Financing patterns since restructuring announcement
- Since December 2022, authorities have mainly relied on multilateral external financing and domestic T-bills issuance.
- Gross financing need tensions eased in 2023 and 2024 due to external debt service suspension.
- Since 2023 domestic debt restructuring, government relied on T-bills as main domestic financing source.
- Some private placements in 2024 primarily with non-bank investors (individuals, insurance and investment funds).
- Auctioned T-bill rates dropped significantly since March 2025, reflecting market segmentation and short-term abundance of cedi liquidity partly due to delay in enactment and implementation of the 2025 Budget.

### Macroeconomic framework underpinning the DSA (staffs’ baseline)
- Framework aims: restore macro stability and debt sustainability via a realistic fiscal adjustment, tighter monetary policy, enhanced exchange rate flexibility, and growth-enhancing structural reforms.
- The DSA accounts for the full debt restructuring.

Key 2023–24 outcomes and revisions:
- Real GDP growth: 3.1 percent in 2023 and 5.7 percent in 2024 (exceeding earlier expectations).
- Non-interest current account: estimated surplus of 3.6 percent of GDP in 2024.
- GDP deflator increased by 25.4 percent in 2024, raising nominal GDP by US$10 bn above the 3rd ECF review projection for 2024.
- Large public expenditure overruns in 2024 led to deterioration in the primary balance (commitment basis) by almost 4 percentage points of GDP.
- Q4 2024 FX interventions: US$2 billion, contributing to a more appreciated exchange rate.
- Official reserves reached 2.6 months of prospective imports at end-2024; over 3 months (US$7.6 billion) at end-March 2025.
- Large-scale FX interventions in 2025 reached US$1.4 billion in Q1 2025.
- Nominal exchange rate appreciated 60 percent against the US dollar between November 2024 and May 2025.

Projections and near-term outlook:
- 2025: growth expected to decline; CPI inflation revised up to 12 percent at end-2025; return to BoG target band (8±2 percent) delayed to mid-2026.
- Current account projected to remain in surplus in 2025, supported by gold exports.
- Medium-term growth: projected to reach 5 percent by 2027; non-extractive growth projected to strengthen to 5.0 percent by 2027.
- Real exchange rate assumed unchanged through 2028 under baseline; nominal GDP in USD revised up over medium term.

### Fiscal strategy and policy measures (2025 Budget and medium term)
- Fiscal anchor: central government primary balance on a commitment basis to improve by 5.9 percent of GDP between 2022 and 2026, to reach a surplus of 1.5 percent of GDP in 2025 and maintained at least until 2028.
- 2023 outcome: primary balance of -0.3 percent of GDP (about 4-percentage points adjustment vs. 2022).
- 2024 outcome: primary deficit (commitment basis) of 3.3 percent of GDP (pre-audited data).
- 2025 Budget aims to correct slippages and reconfirm previous target path (1.5 percent of GDP primary surplus).
- Cocobod: projections of central government revenues augmented with Cocobod’s net income that will be used for debt service and is part of debt coverage.

2025 Budget measures:
- Revenue: permanently improve non-oil revenue-to-GDP ratio by at least 0.6 percent of GDP (annual basis) via elimination of some VAT exemptions, increase of the Growth and Stability Levy on mining company profits, reduction of tax refund rate, offsetting costs of eliminating some taxes (e-levy, gaming levy).
- Expenditure: cap public sector wage increases to 10 percent; limit spending on goods and services; rationalize statutory funds; eliminate low value-for-money programs; carefully pace execution of foreign-financed investment; expand social benefits.
- Includes limited additional funding (staff estimate at less than 0.1 percent of GDP) for health and agriculture programs.
- Strengthen PFM: comprehensive audit of domestic arrears; results to underpin measures to strengthen PFM system.

Medium-term fiscal priorities:
- Mobilize additional domestic revenues and curtail spending to make room for development and social priorities.
- Continue raising revenue-to-GDP ratio via tax base broadening and tax system simplification; 2023 Medium-Term Revenue Strategy remains main anchor.
- Comprehensive VAT reform planned with IMF TA to improve compliance and efficiency.
- Eliminate extra-budgetary spending and arrears buildup; reduce large energy subsidies through tariff adjustments and cost reduction measures.
- Arrears clearance: Arrears’ Clearance and Prevention Strategy prepared (structural benchmark at end-June 2023); negotiations of legacy energy sector arrears progressing.

### DSA baseline scenario and detailed debt treatment (95 percent implemented by end-October 2024)
- Overview: baseline assumes comprehensive debt restructuring, fully implemented for 95 percent of claims at end-October 2024.

Components:
- Domestic Debt Exchange Program (DDEP):
  - Launched early-December 2022 as voluntary swap of outstanding medium- and long-term domestic bonds for lower-coupon and longer-maturity bonds.
  - First stage completed February 2023.
  - Second phase finalized in fall 2023 included Cocobills, US$-denominated domestic debt, and pension fund holdings.
  - Government restructured BoG’s holdings of non-marketable debt while ensuring central bank solvency.

- Treatment of bilateral external debt (OCC / G20 Common Framework):
  - MoU signed by all parties in January 2025.
  - Agreed debt treatment: full debt service relief over the program period from all bilateral claims committed and disbursed before December 2022.
  - Rescheduled debt service will be capitalized and accrues an additional interest rate (level depends on initial interest rate of each claim) until repayment in years 16 and 17 after the original due date (for each year of rescheduled debt service).
  - Disbursements of pre-CoD projects made after December 2022 will not be restructured.
  - Authorities and OCC creditors committed to limit such disbursements (including commercial) to US$250 million per year from 2024 to 2026; 2024 disbursements stood at US$184 million.

- Eurobond debt restructuring (October 2024):
  - Successfully implemented; debt service payments on new bonds resumed immediately.
  - Most bondholders received new bonds maturing in 2029 and 2035, with a nominal haircut of 37 percent and a coupon rate increasing from 5 to 6 percent in 2028.
  - Some bondholders chose longer-term bonds maturing in 2037, with no haircut but paying a coupon rate of 1.5 percent.
  - All bondholders received a downpayment bond maturing in 2026 and a post-default interest bond maturing in 2030.

- Restructuring of claims from other commercial creditors:
  - Authorities are making good faith efforts to reach agreements consistent with IMF Lending into Arrears policy and comparability of treatment principle.
  - Outstanding debt stock to residual external commercial creditors is US$2.7 billion, amounting to less than 5 percent of pre-restructuring total public debt.
  - Strategy: prepare restructuring offers tailored to creditor preferences (some prefer long-term rescheduling with no haircut; others prefer principal reduction with maximized short-term service).
  - Following Eurobond restructuring, authorities reached out to other external commercial creditors to advance debt data reconciliation, prepare NDAs, and share debt treatment proposals.

*Source: IMF staff report excerpt (content unit).*

### 19.      Financing assumptions under the baseline scenario:

### 19.      Financing assumptions under the baseline scenario:

### External financing assumptions and disbursements
- New external borrowing under the program is restricted to a PV of US$50 million and US$70 million in 2025 and 2026, respectively, excluding concessional multilateral loans.
- The DSA scenario assumes regain of some commercial lending in late 2026 and full external market access in 2027.
- External disbursement in 2025 is limited to the World Bank, IMF, AfDB and other bilateral development partners.
- Disbursement assumptions and commitments:
  - IMF disbursements of US$3 billion in 2023-26.
  - Net World Bank 2023-26 support estimated at US$ 2.6 billion (an increase of about US$ 170 million compared to the 3rd Review).
  - Expected total DPF support increased from US$ 1.15 to US$ 1.25 billion during 2023-26.
  - DPO financing increased from US$600 to US$700 million in 2025.
  - Other World Bank financing expected to fill a financing gap averaging around US$ 200 million in 2025 and 2026, with a total of US$ 540 million over 2023-26.
  - World Bank project loan disbursements estimated at US$1.8 billion over the program horizon.
  - AfDB disbursements assumed at US$343million overall, of which US$240 million of project loans and grants over 2023-26 and US$104 for budget support.
  - AfDB grant disbursement of US$44 million shifted from 2024 to 2025 due to delays in performance measures.
  - Total multilateral project loan disbursements capped at US$ 300 million in the 2025 budget.
  - Other bilateral development partners expected to contribute US$885 million from 2024-26, restricted by limits on pre-COD disbursements.

### Domestic financing and debt management
- Large issuance of T-bills in 2023-24 while bond market was closed; demand strong particularly from non-bank investors (corporate, pension funds and individuals).
- Baseline from 2025 assumes resumption of medium and long-term domestic debt issuance in line with authorities’ debt management strategy.
- About 78 percent of 2025 gross financing needs is expected to be met by domestic issuances, with similar ratios until the end of the program.
- Interest rate and arrears projections:
  - Effective real interest rate assumed to turn positive in 2026 and rise to around 5 percent in the long term.
  - Nominal interest rates expected to decline with inflation returning to its target.
  - Net issuance of domestic debt (including arrears) jumped in 2024 but expected to decline from 2025 as the government contains spending and clears arrears.
  - Domestic debt service expressed as a share of revenue will remain elevated relative to the average in other LICs but will be gradually reduced, consistent with a falling domestic debt-to-GDP ratio and full clearance of domestic arrears by end-2028.

### Realism of projections and fiscal consolidation
- Reform efforts and the debt restructuring are returning debt levels toward pre-pandemic forecasts.
- Staff projects a substantial decline in overall debt over the next 5 years of about 16 percent of GDP.
- External debt has declined by about 6 percent compared to expected developments in 2020 due to debt restructuring.
- Baseline projects a primary balance surplus of 1.5 percent of GDP this year on a commitment basis, expected to be maintained over the medium term.
- The size of the 3-year primary balance adjustment on a cash basis is within norms of comparable countries.
- Authorities committed to achieving a larger consolidation in 2025 after slippages in 2024.

### Risks to the baseline and climate considerations
- Baseline contingent on successful program implementation, full execution of external debt restructuring, and adequate development partner financing.
- Downside risks include delays in adjustment and reforms, delays in external debt relief, weak interagency coordination, lower agricultural and commodity production, deterioration in global conditions (regional conflicts, geoeconomic fragmentation, commodity price volatility, lower external demand and FDI).
- Domestic debt restructuring poses risks to domestic financial sector stability despite stabilization progress.
- Risks of higher inflation and lower current account if monetary policy does not respond timely to inflationary pressures and exchange rate volatility increases.
- Additional risk from potential need for higher support to the energy sector and larger-than-expected financial sector support due to the domestic debt exchange program.
- Climate vulnerability:
  - Ghana highly vulnerable to climate variability and change (flooding and droughts).
  - Existing climate-related policies and strategies include the National Climate Change Adaptation Strategy, the Low Carbon Development Strategy, and the National Climate Change Master Plan.
  - Ghana 2022 Country Climate and Development Report (CCDR) recommends integrated agriculture/environmental management, sustainable cities and resilient infrastructure, disaster risk preparedness, forest resource management, transition to clean energy, modernizing transport, climate resilience financing strategies, and adaptive health systems.
  - Key World Bank projects cited include the Greater Accra Resilient and Integrated Development Project and the Greater Accra Urban Resilience and Integrated Development Project focusing on flood and drainage improvements.

### Debt-carrying capacity and stress testing
- Debt carrying capacity assessed as “medium”; Composite Indicator (CI) score of 2.79.
  - CI remains between cut-off values for weak and strong debt-carrying capacity (2.69 and 3.05).
  - CI is weighted average of 10-year average World Bank CPIA score and macroeconomic variables from October 2024 WEO vintage.
- Standard stress tests:
  - Shocks calibrated at 1 standard deviation in 2025 from historical averages for GDP growth, primary balance, exports and FDI.
  - Exchange rate stressed with a one-time 30 percent depreciation in 2025.
  - Combined shock of all the above at half magnitude also applied.
- Tailored stress tests:
  - Commodity price test: one standard deviation drop in both fuel and non-fuel commodity export prices.
  - Market financing shock: 400bps increase in cost of borrowing for 3 years, shortening average maturities on external debt by 2 years, and a 15 percent exchange rate depreciation.
  - Contingent liability test: one-off increase in public debt-to-GDP ratio; contingent liability shock components include (i) a minimum starting value of 5 percent of GDP; and (ii) tailored components: financial market contingent liabilities (5 percent of GDP), PPPs (2.4 percent of GDP) and other SOEs debt not captured by debt coverage (2 percent of GDP).

### External DSA findings
- Under the baseline, all external debt burden indicators fall durably below or to their respective thresholds by 2028.
- Debt-service-to-revenue ratio, PV of PPG external debt-to-GDP, debt service-to-exports ratio, and PV of external debt-to-exports ratio remain below respective thresholds in the baseline.
- A shock to exports has the most negative impact, causing breaches in debt service-to-export and debt service-to-revenue ratios.
- PV of external debt-to-GDP and PV of external debt-to-exports ratios do not breach their 40 and 180 percent thresholds, respectively, under any shock scenario.

### Public DSA findings
- Under the baseline, the PV of total PPG debt-to-GDP is expected to fall durably below its 55 percent benchmark by 2028.
- A commodity price shock has the most severe impact and would breach the PV of debt-to-GDP 55 percent threshold over the entire forecast horizon; debt service-to-revenue and PV of debt-to-revenue also increase noticeably under that shock.
- Market financing risks assessed as “moderate” despite loss of market access.
  - Maximum gross financing need over the 3-year baseline projection horizon is 11.7 percent and does not breach the 14 percent of GDP benchmark.
  - Gross financing needs projected to peak at 12.3 percent in 2028 and decline to below 10 percent by 2034.
  - Eurobond spreads declined from around 2,000 to below 700 within a few days following the bond exchange but remain above the 570-bps benchmark; lack of market access persists.

### Sustainability assessment and policy implications
- Ghana is at high risk of distress due to near-term breaches of DSA thresholds, but expected to reach moderate risk of debt distress in the medium term as all DSA sustainability targets will be met by 2028.
- Debt assessed sustainable on a forward-looking basis contingent on completion of external debt restructuring in line with program parameters and continuing good faith negotiations with residual external private creditors.
- Residual arrears with other commercial non-bonded creditors are limited in size (less than 5 percent) and considered treated on comparable terms for risk rating purposes.
- Baseline assumes strong program ownership and full commitment by authorities to implement the Fund-supported program to restore debt sustainability and bring the debt risk rating to “moderate” by the medium term.
  - Targets include reducing PV of total debt-to-GDP and external debt service-to-revenue ratios to 55 and 18 percent, respectively, by 2028.
  - This entails revenue-based fiscal consolidation with higher spending efficiency, stronger social safety nets, structural reforms to support greater exchange rate flexibility, a more diversified economy and stronger growth.
- Need to enhance debt data and transparency to better identify PPG debt and contingent liabilities and more accurately assess debt vulnerabilities.
  - Materialization of contingent liabilities, off-budget operations, and domestic arrears have driven past debt accumulation.
  - SOEs represent potential undisclosed debt or contingent liabilities; more comprehensive coverage of SOE debt and guarantees, especially those engaging in quasi-fiscal activities, recommended to improve fiscal risk assessment and debt coverage.

*Source: 1ghaea2025001-source-pdf - 19.      Financing assumptions under the baseline scenario:*

### 33. The authorities generally shared staff’s assessment of debt sustainability and renewed

### 1ghaea2025001-source-pdf - 33. The authorities generally shared staff’s assessment of debt sustainability and renewed

### Authorities’ assessment and commitments
- The authorities generally shared staff’s assessment of debt sustainability and renewed their commitment to continue with their strong implementation of the IMF-supported program and continue the restructuring of their external debt to restore debt sustainability.
- The authorities acknowledged the importance of a successful implementation of the reform agenda underpinned by the IMF-supported program to restore economic stability—a critical pillar for restoring debt sustainability.
- As part of its Sustainable Development Finance Policy (SDFP), the World Bank supported the publication of the 2020 State Ownership Report in 2022, to provide a better picture on large SOEs’ financial liabilities.

### Stress tests and scenario assumptions
- Interest rate on additional borrowing resulting from the stress test is estimated at 9 percent (higher than the default rate of 4.9 percent) to reflect deterioration in Ghana’s creditworthiness and loss of market access.
- Note on extreme stress test selection: "The most extreme stress test is the test that yields the highest ratio in or before 2035. The stress test with a one-off breach is also presented (if any), while the one-off breach is deemed away for mechanical signals. When a stress test with a one-off breach happens to be the most extreme shock even after disregarding the one-off breach, only that stress test (with a one-off breach) would be presented."
- Commodity price shock magnitudes are based on the commodity prices outlook prepared by the IMF research department.
- All additional financing needs generated by the shocks under the stress tests are assumed to be covered by PPG external MLT debt in the external DSA. Default terms of marginal debt are based on baseline 10-year projections.
- The public DSA allows for domestic financing to cover additional financing needs generated by the shocks under the stress tests in the public DSA. Default terms of marginal debt are based on baseline 10-year projections.

### Baseline projections and external DSA findings (selected figures)
- External debt (nominal) as percent of GDP:
  - 2024: 42.2
  - 2025: 42.5
  - 2026: 40.5
  - 2027: 39.1
  - 2028: 37.2
  - 2029: 35.2
  - 2035: 28.8
  - 2045: 18.7
- Of which: public and publicly guaranteed (PPG) external debt (percent of GDP):
  - 2024: 36.4
  - 2025: 36.8
  - 2026: 34.8
  - 2035: 23.9
  - 2045: 14.8
- Identified net debt-creating flows (percent of GDP):
  - 2024: -6.5
  - 2025: -6.0
  - 2026: -6.2
  - 2035: -3.9
- Endogenous debt dynamics (percent of GDP):
  - 2024: -0.7
  - 2025: -0.6
  - 2026: -0.9
- Residual (percent of GDP):
  - 2024: 1.0
  - 2025: 6.3
  - 2026: 4.2
  - 2035: 3.0
- Sustainability indicators:
  - PV of PPG external debt-to-GDP ratio:
    - 2024: 29.3
    - 2025: 28.7
    - 2026: 28.1
    - 2035: 21.0
    - 2045: 13.5
  - PV of PPG external debt-to-exports ratio:
    - 2024: 85.3
    - 2025: 85.1
    - 2026: 83.0
    - 2035: 81.8
  - PPG debt service-to-exports ratio:
    - 2024: 3.5
    - 2025: 5.6
    - 2026: 8.1
    - 2035: 11.8
  - PPG debt service-to-revenue ratio:
    - 2024: 7.5
    - 2025: 11.9
    - 2026: 16.6
    - 2035: 18.0
- Gross external financing need (Million of U.S. dollars):
  - 2024: -2623.5
  - 2025: -1899.8
  - 2026: -1018.6
  - 2027: -1132.2
  - 2028: -1099.3
  - 2029: -1022.0
  - 2035: 473.6
  - 2045: 2592.7

### Key macroeconomic assumptions (selected)
- Real GDP growth (in percent):
  - 2024: 5.7
  - 2025: 4.0
  - 2026: 4.8
  - 2027–2035: 4.9–5.0 (notably 5.0 for many projection years)
  - 2045: 5.0
- GDP deflator in US dollar terms (change in percent):
  - 2024: -2.7
  - 2025: 2.2
  - 2026: -0.3
  - 2035: 2.1
- Effective interest rate (percent):
  - 2024: 1.9
  - 2025: 2.5
  - 2026: 2.5
  - 2035: 5.1
  - 2045: 6.8
- Government revenues (excluding grants, in percent of GDP):
  - 2024: 16.0
  - 2025: 15.9
  - 2026: 16.6
  - 2027–2035: 16.7–16.8 (persistently 16.8 in many years)
  - 2045: 16.8
- Aid flows (Million of US dollars):
  - 2024: 120.8
  - 2025: 1304.7
  - 2026: 1024.1
  - 2035: 815.6
  - 2045: 1279.0
- Grant-equivalent financing (in percent of GDP) (selected):
  - 2025: 1.0
  - 2026: 0.7
  - 2035: 0.3

### Public sector debt and dynamics (selected)
- Public sector debt (percent of GDP):
  - 2024: 70.2
  - 2025: 66.0
  - 2026: 62.3
  - 2035: 44.0
  - 2045: 33.0
- Change in public sector debt (percent of GDP):
  - 2024: -8.9
  - 2025: -4.2
  - 2026: -3.7
  - 2035: -1.4
- Identified debt-creating flows (percent of GDP):
  - 2024: -8.3
  - 2025: -5.4
  - 2026: -2.1
  - 2035: -1.4
- Primary deficit (cash basis, percent of GDP):
  - 2024: 0.4
  - 2025: -0.8
  - 2026: 0.0
  - 2029: -1.5
  - 2035: -1.0
- Automatic debt dynamics (percent of GDP):
  - 2024: -9.5
  - 2025: -4.9
  - 2026: -2.1
  - 2035: -0.4
- PV of public debt-to-GDP ratio:
  - 2024: 64.1
  - 2025: 59.8
  - 2026: 56.5
  - 2035: 41.8
  - 2045: 32.0
- Debt service-to-revenue and grants ratio:
  - 2024: 34.8
  - 2025: 74.7
  - 2026: 80.0
  - 2035: 63.6
- Gross financing need:
  - 2024: 6.8 (percent of GDP)
  - 2025: 11.2
  - 2026: 11.7
  - 2035: 9.8

### Debt dynamics drivers and realism tools (figures referenced)
- Figures show decomposition of debt-creating flows and drivers including residuals, price and exchange rate effects, real GDP growth, nominal interest rate, current account + FDI, change in PPG debt, and other debt-creating flows.
- Realism tools illustrate:
  - Contribution to real GDP growth from public and private investment rates and contribution of government capital.
  - Fiscal adjustment and possible growth paths under different fiscal multipliers (Multiplier = 0.2, 0.4, 0.6, 0.8).
  - Distribution of projected 3-year adjustment in primary balance across Fund-supported LIC programs; top quartile implies 3-year PB adjustment greater than 2.5 percentage points of GDP.

### Market-financing and domestic debt indicators
- Market-financing risk indicators note that "Both the baseline and market financing shock scenarios display very similar paths for PV of debt-to-exports, debt service-to-exports and debt service-to-revenue ratios due to the low level of new envisaged commercial borrowing in the 3 years from the second year of the projection (2024-26)."
- EMBI spreads referenced; EMBI value indicated as 570 in figure annotations.
- GFN benchmark and potential heightened liquidity needs flagged as "Moderate" with "Breach of benchmark: Yes" in figures.
- Indicators of domestic public debt, 2020–2034:
  - Net domestic debt issuance is estimated (definition provided).
  - Historical ratio values shown including domestic debt-to-GDP ratios and domestic debt service to revenues inc. grants.
  - Example domestic values appearing in figure annotations: 73%, 27%, 6.1%, 5, 0, 4.7% (presented as figure labels).

### Sensitivity analyses (selected results)
- Table 3: Sensitivity Analysis for Key Indicators of Public and PPG External Debt, 2025–35 (selected entries)
  - Baseline PV of debt-to-GDP ratio:
    - 2025: 28.7
    - 2026: 28.1
    - 2027: 27.2
    - 2035: 21.0
  - Alternative scenarios and bound tests show higher PV ratios under combinations of shocks and historical-average assumptions (e.g., A1 and B6 scenarios display increases into the 30s and beyond in some years).
  - Debt service-to-revenue ratio (baseline and scenarios):
    - Baseline: 2025: 11.9; 2026: 16.6; 2027: 18.2; 2035: 18.0
    - Several tailored and bound tests produce elevated ratios exceeding benchmarks.
- Table 4: Sensitivity Analysis for Key Indicators of Public Debt, 2025–35 (selected entries)
  - Baseline public debt (percent of GDP):
    - 2025: 66.0
    - 2026: 62.3
    - 2027: 59.5
    - 2035: 44.0
  - Alternative scenarios and tailored tests can raise public debt and PV of public debt-to-revenue ratios considerably in some tests (specific numeric paths provided in tables).

### Program context and administrative details
- Document heading: FOURTH REVIEW UNDER THE EXTENDED CREDIT FACILITY ARRANGEMENT, REQUEST FOR MODIFICATION OF PERFORMANCE CRITERIA, FINANCING ASSURANCES REVIEW, AND MONETARY POLICY CONSULTATION—SUPPLEMENTARY INFORMATION.
- The supplement provides additional information to the Staff Report circulated to the Executive Board on June 24, 2025, including an update on recent developments and performance against structural conditionality and views regarding the Monetary Policy Consultation Clause (MPCC), triggered with the June 2025 inflation data release.
- The supplement does not alter either the staff recommendations or the thrust of the staff appraisal.
- Prepared by the Ghana team of the African Department; Approved by Annalisa Fedelino and Guillaume Chabert; Date: July 2, 2025.

*Sources: Country authorities; and staff estimates and projections. (Content as provided in the document excerpts.)*

### 1. The 2025Q1 GDP data confirmed a robust expansion in economic activity. Real GDP

### 1ghaea2025001-source-pdf - 1. The 2025Q1 GDP data confirmed a robust expansion in economic activity. Real GDP

### Recent macroeconomic developments and outlook
- Real GDP increased by 5.3 percent year-over-year in the first quarter of 2025 (from 3.6 percent in 2024Q4), driven by robust activity in the agriculture, service, and manufacturing sectors.
- Headline consumer price inflation declined to 13.7 percent year-over-year in June, reflecting a broad-based slowdown in both food and non-food prices; this outturn was within the inner bands under the program’s Monetary Policy Consultation Clause (MPCC).
- Disinflation resumed in 2025 after a CPI inflation rate of 23.8 percent at end-2024; by end-May 2025, inflation had declined to 18.4 percent. Inflation is projected to decline to 12 percent by end-2025 and to reach the Bank of Ghana’s medium-term target range of 8 ± 2 percent by the second quarter of 2026, absent unforeseen shocks.
- External sector improvements in 2024 included a current account surplus of 1.1 percent of GDP and gross international reserves reaching 3 months of import cover by end-March 2025 (program definition). The cedi appreciated sharply in 2025 supported by policy measures.
- Growth momentum continued into 2025Q1 with the highest first-quarter growth in five years.

### Program performance, policy actions, and governance reforms
- Program performance and actions taken:
  - All end-December 2024 QPCs and most ITs were met; several SBs due between January-May 2025 were missed or implemented with delays.
  - Corrective measures implemented include:
    - a 100 basis point increase in the Bank of Ghana’s policy rate;
    - passage of the 2025 Budget aligned with program objectives;
    - amendments to the Public Financial Management and Public Procurement laws;
    - launch of a comprehensive audit of spending commitments and arrears at end-2023 and end-2024;
    - electricity tariff increases in April and July 2025;
    - submission to Parliament of amendments to the Bank of Ghana Act (end-May 2025 Structural Benchmark);
    - recapitalization of the National Investment Bank (NIB) and adoption of a governance strategy for it.
  - Two Structural Benchmarks originally set for end-September 2025 were implemented ahead of schedule: amendment of the fiscal responsibility framework and formulation of a strategy to restructure Ghana’s electricity company.
- Bank of Ghana governance and multiple currency practices:
  - Authorities submitted amendments to the BoG Act to Parliament on June 24 (end-May 2025 Structural Benchmark) to strengthen independence and safeguards, limit monetary financing, introduce provisions for covering capital shortfalls, and clarify Board and Monetary Policy Committee membership criteria.
  - Despite commitment to remove all multiple currency practices (MCPs), new impermissible spreads arose: remittances on May 28, 2025; government transactions and cocoa exports on May 26, 2025; transactions from mining, oil and gas companies on April 24, 2025.
- Public Utilities and tariffs:
  - Public Utilities Regulatory Commission announced an electricity tariff increase of 2.45 percent effective July 1 (decision consistent with program’s quarterly Structural Benchmark for end-June).

### Fiscal policy, public financial management, and debt
- Fiscal targets and revenue measures:
  - The approved 2025 Budget targets a primary surplus of 1.5 percent of GDP (on a commitment basis) and maintaining it thereafter.
  - Authorities are advancing a Medium-Term Revenue Strategy focusing on tax enforcement, compliance, streamlining VAT exemptions, improving tax and customs administration, and simplifying the tax system; contingency plans will back these measures if revenue falls short.
- Expenditure control and PFM reforms:
  - A validation audit of end-2024 commitments and arrears was launched in April 2025; the audit report is expected by end-August 2025. Authorities commit to act on recommendations including cancellation, rescoping, and rephasing of projects.
  - The amended 2016 PFM Act introduces a new fiscal rule centered on a debt ceiling and a primary balance operational target, enhances the Fiscal Advisory Council’s autonomy, and introduces sanctions for fiscal slippage.
  - The amended Public Procurement Act grants the Minister for Finance exclusive authority to issue commitment authorization before procurement and introduces sanctions for unauthorized commitments; e-procurement has been operationalized within the Ghana Integrated Financial Management Information System and all enrolled agencies directed to use it exclusively.
  - A PFM Compliance Division has been established at the Ministry of Finance.
- SOE oversight and energy sector measures:
  - Strengthened safeguards and risk management across SOEs, with Cocobod brought under the Ministry of Finance to prevent quasi-fiscal activities.
  - Authorities committed to settling current obligations, clearing legacy arrears, finalizing the 2024 agreement with Independent Power Producers (IPPs), advancing quarterly utility tariff adjustments, and fully implementing the Cash Waterfall Mechanism.
  - Parliament has passed the 2025 Energy Sector Levy (Amendment) Bill—pending implementation—which introduces a GHS1 fuel levy to help reduce arrears and stabilize the sector.
- Debt management and restructuring:
  - Authorities prioritize near-term domestic financing, arrears clearance and prevention strategy, strengthening debt management capacity, and securing concessional financing while strictly limiting non-concessional borrowing.
  - Comprehensive debt restructuring efforts continue; remaining commercial creditors hold less than 7 percent of pre-restructuring debt.

### Financial sector and monetary policy
- Monetary policy stance and objectives:
  - Bank of Ghana committed to a proactive, data-driven stance to accelerate disinflation toward the 8 ± 2 percent target, including increasing the policy rate and strengthening liquidity management while refraining from monetary financing of the budget.
  - Amendments to the BoG Act were submitted to Parliament to reinforce autonomy; assessment of BoG recapitalization needs will continue with staff support.
  - BoG will enhance exchange rate flexibility by adopting a rules-based FX intervention policy (in consultation with staff) and eliminate multiple currency practices.
- Financial stability actions:
  - Authorities prioritize risk-based supervision, regulatory compliance, timely recapitalization of banks, operationalization of the Ghana Financial Sector Stability Fund, and resolution of solvency challenges in state-owned banks with strengthened governance and risk management.
  - Recapitalization and restructuring plans for the NIB have Cabinet approval.
  - Enhancements to the AML/CFT framework to align with FATF standards are underway.

### Structural reforms and social protection
- Structural reform priorities:
  - Authorities advance a comprehensive reform strategy aligned with the 24-hour economy policy and the “Big Push” infrastructure program, focusing on human capital development (particularly for women), agricultural transformation, specialized training and apprenticeships for youth, and expanding financial inclusion.
  - Governance and anti-corruption measures include review of the IMF Governance and Anti-Corruption Diagnostic Assessment report (to be published once finalized), publication of a binding code of conduct for public officials, and commitment to submit a bill to Parliament to establish a legal framework for asset declaration by public officials.
  - A follow-up report on the COVID-19 Expenditure Audit has been published to enhance transparency and accountability.
- Earmarked funds and social protection:
  - While the end-June 2025 Structural Benchmark on legislation to merge some statutory funds with their line ministries was not met, authorities made progress by prioritizing reforms of large earmarked funds (District Assemblies Common Fund, Minerals Income Investment Fund, Ghana Infrastructure Investment Fund) and abolished the Plastic Waste Recycling Fund by amending the Customs and Excise (Duties and Other Taxes) Act, freeing public resources for the consolidated fund.
  - Authorities remain committed to preserving the value of Livelihood Empowerment Against Poverty (LEAP) benefits through automatic indexation and to improving targeting, expanding coverage, and enhancing operational efficiency of social protection programs, including greater use of digital technologies.

### Key risks and policy priorities
- Key downside risks:
  - Ongoing fiscal adjustment and heightened global uncertainties pose downside risks to the growth outlook.
  - Recent emergence of new impermissible spreads related to MCPs signals ongoing exchange rate and FX market vulnerabilities.
- Policy priorities and commitments:
  - Maintain ambitious, multi-year expenditure-based fiscal adjustments and strengthen revenue mobilization to restore debt sustainability.
  - Rigorously implement PFM and procurement reforms, enforce sanctions for fiscal slippage, and operationalize e-procurement and the PFM Compliance Division.
  - Strengthen SOE oversight, settle energy sector obligations, and implement tariff adjustments and the Cash Waterfall Mechanism.
  - Continue BoG autonomy reforms, implement rules-based FX intervention, eliminate MCPs, and pursue targeted recapitalization and restructuring of banks.
  - Advance governance, anti-corruption, climate resilience measures, and social protection reforms.

### Conclusion and authorities’ request
- The new authorities demonstrate strong commitment to sound macroeconomic management and structural reforms, with decisive corrective measures already implemented.
- In light of their renewed commitment and progress, the authorities are seeking the Executive Directors’ support for completing the fourth review under the Extended Credit Facility (ECF) arrangement and associated requests to consolidate macroeconomic gains.

*Source: https://www.imf.org/-/media/files/publications/cr/2025/english/1ghaea2025001-source-pdf.pdf*

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_Source: https://www.imf.org/-/media/files/publications/cr/2025/english/1ghaea2025001-source-pdf.pdf_