The practice doing most damage to Ghana’s fish stocks is not clearly illegal, and the practices that are illegal are barely enforced: Ghana’s fisheries enforcement unit spent forty hours at sea in 2023 and had collected only about 1 to 2 per cent of the fines imposed by the time it reported, a share that rose to about two thirds of the 2023 fines by mid-2025.1 What the fleet lands, and how cleanly it is handled ashore, risks an export licence, a European clearance and every processing business in the chain.
Ghana’s small pelagic stocks, assessed together, have been overfished and subject to overfishing continuously since 2004.2 Industrial licences, tuna aside, name no target species, so a bottom trawler may lawfully fill its hold with sardinella provided each fish clears the minimum landing size, 18 cm for both round and flat sardinella, and 6 cm for anchovy3, against a 60 mm codend mesh4.
| What happens at sea | Where it sits in law | What it costs the operator if proved |
|---|---|---|
| A bottom trawler targets and lands small pelagic fish | Lawful above the minimum landing size. Licences name no target species except tuna vessels | Nothing |
| Landing undersized fish | Prohibited, and a distinct offence of illegal, unreported and unregulated fishing | US$200,000 to US$1 million |
| Threading a rope through the codend mesh, or covering it, to close it | Possession of prohibited gear, and separately illegal fishing | US$5,000 to US$500,000 as gear, or US$200,000 to US$1 million as illegal fishing |
| Dumping fish fit for human consumption | An offence, priced far below the others | Up to 500 penalty units, about GH¢6,000 |
| Trans-shipping at sea from an industrial vessel to a canoe | Prohibited, and again where the fish are undersized | US$100,000 to US$2 million |
| Fishing inside a designated inshore exclusion zone | Prohibited, but no zone had been designated and gazetted | The general penalty, and only once a zone exists |
Sources: Fisheries Regulations 2010 (L.I. 1968) and its Schedule; Fisheries and Aquaculture Act 2025, sections 40, 161 and 170, read directly from the statute; and the compilation of offences and penalties in Environmental Justice Foundation, Breaking the Vicious Circle, Box 1. Penalty units converted at the GH¢12 unit used there.4
The loophole that matters more than the enforcement.The pressure on Ghana’s food fish comes largely from vessels committing no offence, so harder policing would not stop it. What would is a licence naming demersal species and nothing else, still sitting with the unmade Regulations. A small pelagic recovery depends heavily on that one clause.
Bycatch is the voyage’s revenue: crew put it at 53 to 60.5 per cent of landings against the 15 per cent allowed until 2022, and 70 per cent said their net was modified after inspection4.
Independent sampling (2019 to 2025) puts undersized fish at 97 per cent of round sardinella and 96 per cent of chub mackerel in trawler slabs below the minimum landing size4. Of the 69 slabs analysed, 69 per cent of the fish belonging to regulated species were below legal size and 42.5 per cent belonged to species the Regulations do not cover, only 15 of 84 species being regulated.
Most regulated species sit at or close to 1.00: almost none of their fish clears the line meant to protect it, and the average across all regulated species is 0.69. Atlantic bumper and round scad, both with a 10 cm minimum, are the only two species shown whose fish mostly clear it.
One intervention appears to have worked, on EJF’s reading of the balance of probabilities: after the 2022 selective-net directive, mean round sardinella landing size rose 5.22 cm and chub mackerel 3.42 cm between 2022 and 20254, Atlantic bumper up 4.2 cm. Yet sardinella and chub mackerel remain overwhelmingly undersized, and no trawling company has been prosecuted for landing undersized fish, to the Environmental Justice Foundation’s knowledge.
Saiko was illegal trans-shipment at sea from a trawler to a canoe. In 2017, the only year measured, about 101,660 tonnes landed this way through Elmina, Apam and Axim, worth US$52.7 to US$81.1 million; against the trawl fleet’s reported 67,205 tonnes, only about 40 per cent was declared5. At about 1.5 jobs per 100 tonnes against 60 in the canoe fishery, nearly three in ten of 2017’s 342,427 tonnes of marine catch shifted from a sector employing over 100,000 people to one at most 1,5006.
After the 2021 carding the government suppressed trans-shipment, which has all but ceased; demand did not, so logo fish now lands at Tema and moves by road: EJF recorded no fewer than 131 van shipments into Elmina and 32 into Apam across 2024 to 2025, half of processors and 36 per cent of fishmongers sourcing mainly from the vans4.
The part of this that is an opening. Ghanaian enforcement moves when a market it cares about applies pressure, so the carding signals what gets enforced next. The frozen fish sold in Elmina and Apam now travels by road from one port, far easier to trace, inspect and compete with than at sea.
Prices show the trade was displaced: a slab that cost GH¢35 to GH¢50 at saiko’s peak now sells in boxes of two slabs from the vans at GH¢300 to GH¢600, about GH¢150 to GH¢300 a slab in nominal cedis, a rise respondents put down mainly to higher transport costs.4 The sea route is not fully closed: the state met night-time trans-shipments in late 2024 and early 2025 with twelve month suspensions from 1 April 2025 on four industrial vessels, the Meng Xin 10, Florence 2, Long Xiang 607 and Long Xiang 608, for unauthorised transshipment, dumping of fish, fishing in restricted zones and harvesting juvenile fish under the 2002 Act. The Fisheries Commission chose suspension over fines because operators simply earned fines back, and kept the vessels tied up in Tema under monitoring.1 The suspensions ran to 31 March 2026.7
The local industrial licence is reserved for Ghanaians: section 47(1) of the 2002 Act required wholly Ghanaian beneficial ownership, tuna excepted at fifty per cent8. Yet about 90 per cent of Ghanaian-flagged trawlers are linked to Chinese beneficial owners through front companies9. Fifty-two Ghanaian companies have held trawl licences since 2015, most declaring envisaged revenue below US$10,000 and nearly half below US$1,000, while eight Chinese companies held 75 per cent of vessels licensed at end-201910. The three Ghanaian companies behind the four vessels suspended in 2025 are that structure at the enforcement end.
2018 trawl licence fees came to US$474,438, about US$5,786 a vessel, against a trawl landed value of about US$116.2 million (GH¢552,921,872), or 0.4 per cent. On Guinea’s fees Ghana could cut the fleet from 75 vessels to about 10 and still double 2018 revenue10. In 2023, after the fee rose to US$135 per gross tonne, 41 licensed trawlers paid GH¢10.65 million against a trawl landed value of GH¢1.40 billion, about 0.8 per cent.6 A 2020 cost-benefit study put the fleet matching maximum sustainable yield at 52 trawlers against the 80 then fishing, with 52 per cent of attainable rents forgone;11 licensed trawlers have since fallen to 41 in 2023 and 45 in 2024,612 so the pressure now comes from what each licence permits more than from the number of hulls.11
What this means.A fee at 0.4 per cent of landed value states who the resource is managed for, and answers anyone claiming Ghana cannot afford monitoring: the gap between what the fleet pays and what a regional peer would charge exceeds the cost of enforceable surveillance. Demersal access is underpriced, so it can be repriced, and any model resting on today’s licence fee carries an unnamed policy exposure.
The ministry’s 2023 report states fines paid twice and inconsistently, GH¢592,600 in words and GH¢275,000 in figures, against GH¢28,533,900 imposed, plus US$15,000 paid against US$115,000 imposed. So by the report date the state had collected about 1 to 2 per cent of the cedi fines it levied and 13 per cent of the dollar fines. Collection caught up later: by June 2025 about 66 per cent of the GH¢31 million levied on 32 companies and 71 vessels for 2023 offences had been recovered, with repeat offenders among the unpaid.16
| What was measured | The record | Year |
|---|---|---|
| Sea patrols | 3 patrols, 40 hours, 6 canoe fishermen arrested, no semi-industrial or trawler crew and nothing seized; none at all in 2022 | 2023 |
| Land patrols (beach combing) | 30 patrols, 345 hours, 20 communities, 43 generators and 43 tripods seized | 2023 |
| Observer coverage of the trawl fleet | 100 per cent, 243 placements | 2023 |
| Infractions arising from patrol operations | Recorded as nil; the Fisheries Settlement Committee separately determined and fined 2020 to 2023 dumping cases from observer reports, plus inshore-zone and vessel-monitoring cases | 2023 |
| Fines imposed against fines paid | GH¢28,533,900 and US$115,000 imposed; GH¢275,000 in figures or GH¢592,600 in words, plus US$15,000, paid by the report date; about 66 per cent of 2023 fines recovered by June 2025 | 2023 |
Source: Fisheries Commission, 2023 Annual Performance Report, Tables 4.7 and 4.8 and sections 4.3 to 4.5.6
Detection works here; follow-through fails. Every trawler carries a government observer, coverage complete since 2018, and the settlement committee imposed GH¢28.5 million of fines from observer reports for 2020 to 2023 while patrols returned nothing; 86 per cent of crew later admitted dumping4. Observer independence is weak: their salaries are paid by the vessel owners10.
Behind the patrols sits a data problem. Ghana has not owned a fisheries research vessel for about two decades, and every survey in that period was run from a foreign vessel13. In 2023 Ghana published online nine of 34 applicable transparency elements, nothing for twenty, and did not compile five at all;14 it has since joined the Fisheries Transparency Initiative and inaugurated a national multi-stakeholder group in August 2025.1514 On a ten-principle benchmark it fully implements one, the at-sea trans-shipment ban, and partially the other nine, beneficial ownership disclosed to the regulator alone16.
The intervention with the best evidence behind it.The best-rated intervention in Ghana’s national cost-benefit study of fisheries options is a camera. A cost-benefit analysis for the National Development Planning Commission rated on-board video monitoring of the trawl fleet at about 21 to 1 at an 8 per cent discount rate, the highest of the three options costed: about GH¢10.8 million of equipment, GH¢22.4 million all in the first year and GH¢10.7 million a year after, against roughly GH¢260 million a year of recovered artisanal profit11. Ghana piloted it on three trawlers in 2023 with USAID funding and planned full trawl coverage by 2025; by June 2026 electronic monitoring ran on tuna vessels but had not been extended to trawlers, and Ghana had made no financial commitment to do so.17 Watch whether the draft Regulations make it a licence condition.
Ghana’s fisheries statute is in force and carries no commencement provision of its own, so on the reading of its August 2025 Gazette notification it took effect on assent while its Regulations remained in draft1819. Yet two of its best-known protections do not exist as enforceable instruments, and no new law is needed to switch them on.
The government, the Environmental Justice Foundation and most press reports say the Act extended the inshore exclusion zone from six to twelve nautical miles.4 The text is less clear. It contains a twelve nautical mile limit that section 170 defines but does not itself impose, since section 40 requires the Minister to designate any such zone by publication in the Gazette18. No designation had been published by September 2026. CEMLAWS Africa reads the repeal of the 2002 Act as ending the zone that statute declared outright, to the 30 metre isobath or six nautical miles offshore, whichever was farther; but section 40(4) applies to an area ‘declared or designated’ and section 171(2) keeps acts done under the 2002 Act in effect, so the old zone may survive until a new one is gazetted.1819 The question has been open for more than a year: a live compliance question for trawlers, lost protection for canoe communities. A breach now falls to the general penalty at section 161, a fine of US$200,000 to US$500,000 for a foreign vessel, US$20,000 to US$100,000 for a Ghanaian vessel and 250 to 500 penalty units for an artisanal vessel, with catch and gear liable to forfeiture18. Take Ghanaian legal advice.
Ghana introduced closed seasons in 2016 and closed the canoe fishery too in 2019 and from 2021 to 2024, with no season in 2020; the 2025 season exempted canoes for the first time,20 and the 2026 notice, issued on 29 April 2026 under section 47 of Act 1146, repeats that, closing industrial tuna vessels from 17 March to 30 April, industrial trawlers from 1 July to 31 August and semi-industrial vessels through July, with marine artisanal canoes exempt21. The canoe exemption, now in its second year, cites economic hardship and follows research finding no significant production gain after four years and more than 80 per cent of respondents reporting no earnings improvement22. After the 2023 closure mean sizes rose across all three main species, both sardinellas still below the 18 cm minimum23. Plan throughput around a trawl and tuna gap, since canoes keep fishing, and confirm dates yearly.
The protected-area baseline was no formally designated marine protected area anywhere in the exclusive economic zone as at March 202524, after mapping across 21 communities and an April 2024 commitment to designate by 2026. The ministry now reports its first marine protected area, declared on 14 April 2026 at Busua in the Western Region and covering the Greater Cape Three Points area25, extent about 703 square kilometres between Ampatano and Domunli, with a core no-take zone and surrounding multiple-use zones where regulated fishing continues26. The ministry says the declaration was made under section 39 of Act 1146, which requires a Gazette notice; none had been published online by September 2026. The management plan for the area is not expected to operate until 2027, its boundaries had not been marked at sea, and no dedicated domestic funding had been allocated.27 A no-take origin story reaches a buyer once the instrument and boundaries are published.
The pattern underneath the instruments. Within twelve months Ghana left the status of its two-decade-old inshore zone in doubt for want of a Gazette designation, and declared a marine protected area whose management plan will not operate until 2027. The rules are written faster than the instruments that enforce them. Model the compliance line as a range with a named trigger, and watch the Gazette for it.
A wild fishery has no herd, so health is the product’s, governed by two overlapping bodies, the Ghana Standards Authority and the Food and Drugs Authority28. An exporter satisfies both; neither alone opens Europe, where Food and Drugs Authority approval is necessary but not sufficient.
The standard is hazard analysis and critical control point, enforced by the Food and Drugs Authority under the Public Health Act 2012. An EU Better Training for Safer Food programme has run since 2010, training the competent authority and exporters in the standard and its certification platform28: the compliance vocabulary is European before it is Ghanaian.
The licensed route for industrially smoked exports has been narrow, with only a handful of firms holding Standards Authority permits.28
Under the statute in force, hygiene gates fishing as well as selling: a licence application must carry a sanitary inspection report, and section 63(4)(a) ties the grant to identity markings from the competent authority (Fisheries and Aquaculture Act 2025).
The European Union’s rapid alert system has flagged Ghanaian smoked fish for smoke contamination: a notification in early 2024 recorded benzo(a)pyrene at 14.9 and 124 µg/kg against a limit of 2, and total PAH at 116 and 685 µg/kg against 12, in smoked fish from Ghana traded via Belgium.29 Ghanaian tests find fish smoked on the traditional Chorkor kiln above the EU limits for these compounds and fish from gas kilns below them.30 At home, the Food and Drugs Authority seized smoked and dried fish processed in unhygienic conditions at Tema in July 2026.31 On documentation Ghana has a catch certification regime already in force for exported fish, assessed as partially implemented because it does not require key data such as the identity of the exporting and importing companies4, the instrument being the Fisheries Regulations 2010 as amended by L.I. 2217, which carries the catch certification and vessel record provisions4. An exporter who can show PAH and hygiene results batch by batch answers the first question a European buyer asks, so a testing service for smokers and exporters, and smoking on improved or gas kilns, is an opening.
One instrument reaches the export account. Ghana holds a second European Union yellow card, issued 2 June 2021 and still in place in September 2026, when the minister led a delegation to the European Commission’s fisheries directorate to seek its removal.3233The card only warns; a red card would ban imports of fish caught by Ghanaian vessels across the European Union, which took 45 per cent of Ghana’s fish export value in 2025.
The grounds were an expired marine fisheries management plan, transshipment at sea, inconsistencies in the fisheries legal framework, and deficiencies in the monitoring, control and surveillance of fleets6. None concerns tuna, yet the exposure falls almost entirely on tuna exporters and canneries. The first card (November 2013 to October 2015) lifted on five reforms: dissuasive sanctions in law, a 2015 to 2019 management plan with capacity reduction, a national plan of action against illegal fishing, the Fisheries Enforcement Unit, and mandatory vessel monitoring34. The 2021 card reads as those reforms having lapsed.
Ghana has been in bilateral dialogue with the European Commission since June 2021 and filed six progress reports, and the card is still not lifted6. The missing items are those set out above: a designated inshore exclusion zone, sanctions collected not merely imposed, published beneficial ownership, and a management plan in force (the 2022 to 2026 plan, gazetted in April 2023 according to the then minister, expires at the end of 2026, so its successor is now the item to watch).35 None needs new primary legislation and two need only a Gazette notice. The Act itself is still awaiting its licensing Regulations, which were still in draft when the first of a series of regional stakeholder workshops was held at Takoradi on 14 and 15 July 2026,36 although section 169 required them within twelve months of the Act coming into force in August 2025.36
Where the money is in a compliance problem.Lifting the card creates a market. Everything the European Commission asks Ghana for is a service somebody must supply: monitoring hardware and people to watch it, catch documentation, port inspection, the audit trail a catch certificate needs. Beyond the ministry’s existing vessel monitoring contract, none is sold here at scale; the buyer is a government under a deadline it did not set, and a European retailer will demand the same capability of a Ghanaian supplier anyway. The cheapest version is digital: satellite and vessel-tracking analytics such as Global Fishing Watch and Skylight already run over West African waters, so a monitoring and catch-documentation service can start as analytics on tracking data that already exists: Global Fishing Watch data show 72 vessels logging 17,336 fishing hours in Ghana’s exclusive economic zone between May and September 2026.27 Pillar 7 sets out the opening in full.
Ghana has held a European yellow card since June 2021, its second, still unlifted. Escalation would prohibit fishery imports from Ghanaian vessels into the European Union. The conduct behind it is the trawl and canoe fleets'; the loss falls on tuna exporters, canneries and their lenders, who control none of it.
The first card, issued November 2013, took 23 months and five named reforms to lift34. More than five years into the second, no inshore exclusion zone has been gazetted under the new Act and its Regulations remain in draft, although recovery of 2023 fines had reached about two thirds by mid-2025.16
Tuna processors and canneries, their European buyers, any investor whose exit assumes European market access, and the state as foreign exchange earner.
Carry carding status as a covenant-level item reviewed at board level, and ask any Ghanaian counterparty for its own catch documentation. Price a second market in even if never used. The opening: monitoring and traceability services are what lifting requires.
The frozen slab and box trade feeding much of the Central Region carries heavy volumes of undersized fish, now landed at Tema and moved by road. A buyer into it inherits a defect it did not create. Catch certification reaches the export leg, not the domestic frozen trade, and even there need not name the handling companies, so existing paperwork will not clear it.
Sixty-nine per cent of regulated fish in 69 trawler slabs analysed between 2019 and 2025 were below minimum landing size, 97 per cent for round sardinella, and 42.5 per cent were unregulated species4. Catch certification sits in the Fisheries Regulations 2010 as amended by L.I. 2217, sections 24Z to 24DD, assessed as only partially implemented16.
Processors, exporters, cold store operators, hotel and institutional buyers, and any lender financing inventory in this chain.
Buy against a named landing and a dated record as well as price, and start collecting that record now, since it costs a notebook today and a contract later. Specify a minimum size in purchase terms and reject on it, since the legal minimum is already written down. The opening: correctly sized, traceable supply is scarce in Ghana and the first thing any export buyer asks for.
Ghana's fisheries rule set is in force and incomplete, harder to plan against than a clean transition. The 2002 Act is repealed, the 2025 Act operative, the licensing Regulations in draft, the inshore exclusion zone needs a Gazette designation before it exists, the first marine protected area was declared without a published instrument, and canoes have been exempt from the closed season since 2025.
The 2025 Act received assent on 14 August 2025 and carries no commencement provision, so it took effect then. Section 40 requires Gazette designation of any inshore exclusion zone; none had been published by September 2026, and whether the old six mile zone survives is contested. The Regulations were due within twelve months of assent and remain in draft. The 2025 and 2026 closed seasons both exempt marine artisanal canoes.
Anyone costing a licence, siting a vessel or plant against a zone boundary, contracting supply across a closed season, or financing any of it.
Model the compliance line as a range with the Gazette as its trigger. Take Ghanaian legal advice on the zone question, since the statute can be read two ways. Contract supply with a closed-season clause that survives a date change. The opening: operators who read the statute itself will be positioned before the Regulations land.
What lifting the card takesTraceable, compliant supply is scarce, and buyers already ask for it. Correctly sized, traceable fish is the first thing any export buyer asks for, and few in the domestic chain can document it. Buying against a named landing and a dated record as well as price is a business built on a notebook today and a contract later.
Monitoring and catch-documentation services. Everything the European Commission asks Ghana for is a service somebody must supply: monitoring hardware and people to watch it, catch documentation, port inspection, the audit trail a catch certificate needs. Satellite and vessel-tracking analytics already run over West African waters, so the service can start as analytics on tracking data that already exists (Pillar 7).
A licence clause that would end the loophole by itself. Industrial licences, tuna aside, name no target species, so the pressure on Ghana's food fish comes largely from vessels committing no offence. A licence naming demersal species and nothing else would remove the economic reason to target small pelagics at all, at the cost of a drafting cycle.
Much of the pressure on Ghana's food fish is not illegal. Industrial licences name no target species, so a trawler may land small pelagics lawfully once the fish clear minimum size, and most do not.
Saiko was measured once, in 2017, at about 101,660 tonnes. Suppressed at sea by 2022, it moved onto the road as Tema-landed logo fish, at GH¢300 to GH¢600 a box of two slabs against GH¢35 to GH¢50 a slab at the peak.
The Fisheries Enforcement Unit spent forty hours at sea in 2023 and its patrols recorded no infractions, while observer reports generated cases and fines. By the report date the state had collected 1 to 2 per cent of what it imposed, rising to about two thirds of the 2023 fines by mid-2025. Detection works; collection is slow.
Trawl licence fees were 0.4 per cent of landed value in 2018 and about 0.8 per cent in 2023. Charging Guinea's rate would let ten vessels raise twice the revenue seventy-five did.
The 2025 Act is in force but its instruments are not: no inshore exclusion zone has yet been gazetted under the new Act, leaving the status of the old six mile zone in doubt, and the first marine protected area was declared in April 2026 with no published instrument. The unlifted European yellow card is that gap's cost; closing it is a market for monitoring and traceability services.
Where this connects. The stock condition these practices produced is in Pillar 1. The export concentration and market access this enforcement record puts at risk are in Pillar 2. The fleets, their gear and premix are in Pillar 4, and the statute, Regulations and compliance finance are in Pillar 8.