The Fisheries Commission has lodged a formal protest against the grant of an offshore reconnaissance licence to Gold Coast GRC Ghana Ltd to explore for gold on Ghana’s shallow continental shelf.
The Commission warned that the licence was prepared from a purely land-based mining perspective without regard for fisheries and the marine environment.
In a letter dated September 29, 2026, and addressed to the Chief Executive Officer of the Minerals Commission, the Executive Director of the Fisheries Commission, Prof. Benjamin Betey Campion, said the Commission is concerned about the potential impact on fisheries resources, fishing activities and the livelihoods of fishing communities.
The letter was in response to a communication dated July 15, 2026, received by the Fisheries Commission on September 7, 2026, notifying it of the grant.
Prof. Campion said after reviewing the documentation, the Commission found that the reconnaissance programme for an approximately 10,000 km² offshore area appears to have been prepared “substantially from a terrestrial/land-based mining perspective, without adequate consideration of Ghana’s marine environment.”
10 Flaws Cited
The Commission listed 10 specific flaws:
a. No involvement of Fisheries Commission: Despite the activity being located entirely offshore in an area that supports fishing, the Fisheries Commission was not meaningfully involved in assessment, planning or permitting.
b. Terrestrial third-party rights: The licence provisions refer to rights to “hunt game, gather firewood, collect snails” – provisions that are disconnected from offshore realities. The Commission says relevant rights should be those of artisanal, semi-industrial and industrial fishers, fish processors and traders.
c. No assessment of customary marine rights: No assessment of impacts on access to fishing grounds, fish behaviour, fishing gear, navigation and compensation.
d. Irrelevant sacred areas: The documentation contains restrictions relating to sacred areas, forest reserves, pylons, markets, burial grounds, cemeteries, towns, villages, public roads and dams – largely irrelevant to the continental shelf. Instead, it should address fishing grounds, spawning and nursery areas, marine protected areas and navigational routes.
e. Terrestrial baseline: Environmental description relies heavily on climate, physiography, relief and vegetation, instead of bathymetry, seabed characteristics, oceanography, water quality, marine habitats, plankton, marine mammals, sea turtles and seabirds.
f. Budget excludes Fisheries Commission: The proposed budget makes no provision for statutory involvement of the Fisheries Commission, a Fisheries Impact Assessment, or engagement with fishing communities.
g. & h. Inadequate marine safety and risk: Environmental impact and risk assessment is land-based and does not address vessel operations, interaction with fishing vessels, marine pollution, underwater noise, weather and sea-state, man-overboard, drowning, emergency evacuation and search and rescue. Labour and operational schedule also assumes land-based logistics, ignoring vessel mobilization, weather windows and port logistics.
i. & j. Wrong references and conditions: References are mining-related with little reference to fisheries science or oceanography. Licence conditions about preventing damage to adjoining farms, villages, trees, crops, forest reserves, rivers and railways are structured for terrestrial mining.
Background: BBNJ and Ocean Governance
The Commission situates its concerns within Ghana’s growing commitment to responsible ocean governance.
It notes that Ghana ratified the Agreement under the United Nations Convention on the Law of the Sea on the Conservation and Sustainable Use of Marine Biological Diversity of Areas Beyond National Jurisdiction (BBNJ Agreement) on 14 January 2026, which entered into force on 17 January 2026. The agreement establishes frameworks for environmental impact assessments and area-based management tools.
While acknowledging the BBNJ governs areas beyond national jurisdiction and not Ghana’s continental shelf directly, the Commission argues ratification demonstrates Ghana’s commitment to stronger, science-based and precautionary marine governance.
It also cites growing international concern about seabed mineral extraction, with calls by the Deep-Sea Conservation Coalition and the Deep-Sea Mining business coalition for a precautionary pause until environmental, economic and social risks are understood.
Nine Demands
The Fisheries Commission is therefore requesting the Minerals Commission to:
1. Formally register its objection over the inadequacy of the documentation;
2. Suspend or refrain from authorising any offshore field reconnaissance until deficiencies are addressed;
3. Require a marine-specific environmental and fisheries baseline assessment;
4. Require a Fisheries Impact Assessment in accordance with Section 50 of the Fisheries and Aquaculture Act, 2025 (Act 1146);
5. Require formal consultation with the Fisheries Commission, fishing communities, fisher organisations and researchers;
6. Require a Marine Fisheries and Livelihood Management Plan;
7. Require a marine-specific Health, Safety and Emergency Response Plan;
8. Review licence conditions to reflect marine realities; and
9. Establish an inter-agency review mechanism involving the Fisheries Commission, Minerals Commission, Environmental Protection Authority, Ghana Maritime Authority, Water Resources Commission, Petroleum Commission and others.
The Commission stressed it is not opposed to responsible investment or scientific investigation of Ghana’s natural resources, but said such activities must recognise the importance of fisheries to food security, employment, coastal livelihoods and the national blue economy.
“An offshore reconnaissance programme of this magnitude represents a significant intervention in Ghana’s marine space. It is therefore essential that the regulatory and scientific processes supporting the activity are fit for purpose, marine-specific, evidence-based, precautionary and consistent with Ghana’s obligations concerning sustainable use and protection of its aquatic resources,” Prof. Campion wrote.
The letter was copied to the Chairperson of Parliament’s Committee on Food, Agriculture and Cocoa Affairs, the Minister for Fisheries and Aquaculture, the Ghana Maritime Authority, EPA, Water Resources Commission, Petroleum Commission and the National Fisheries Association of Ghana (NAFAG).
