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Revocation of 278 Small-Scale Mining Licenses: A Good Move Marred by Legal and Political Flaws — Ing. Wisdom Gomashie

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Ing. Wisdom Edem Gomashie,


Mining engineer and resource governance advocate, Ing. Wisdom Gomashie, has described the government’s revocation of 278 small-scale mining licenses as a commendable but legally flawed exercise that risks deepening tensions and illegality within Ghana’s small-scale mining sector.

The Minerals Commission, on Thursday, October 23, 2025, announced that the licenses were revoked or terminated by the Minister of Lands and Natural Resources, Hon. Emmanuel Armah-Kofi Buah, following an audit that uncovered several regulatory breaches and expired permits.

The decision forms part of the government’s broader effort to sanitize Ghana’s mineral cadastral system. However, Ing. Gomashie believes that while the intent is good, the process raises serious legal and procedural concerns.

Commendable Action, But Risky Execution

In a detailed analysis, Ing. Gomashie commended the Minister for continuing the clean-up efforts initiated by previous administrations, notably the Tutu-Agyare-led Minerals Concession Audit Committee established in 2021.

He noted that the exercise aligns with the country’s ongoing reforms to strengthen mining governance and improve compliance.

“This is a good administrative step that must be encouraged. However, such actions must strictly conform to law, procedure, and equity,” he stated.

According to him, most of the small-scale mining licenses currently in operation were either granted or renewed under the previous NPP administration, given that the last NDC government exited office in 2016, and licenses typically have a five-year lifespan.

Possible Legal Breaches

Ing. Gomashie raised strong concerns about the legality of the revocations, citing breaches of key provisions under the Minerals and Mining (Licensing) Regulations, 2012 (L.I. 2176).

He explained that under Regulation 251(3), the Minerals Commission is required to serve written notice to license holders indicating the specific breaches and allow up to 120 days for remediation before termination.

“My checks reveal that this was not done. Ghana is a country of rule of law, and due process must be followed,” he warned.

He also pointed out that licenses granted after December 7, 2024, cannot be revoked merely based on their timing, adding that some of the affected permits were issued lawfully in December 2024 and early January 2025.

Failure to follow procedure, he cautioned, could expose the state to multiple lawsuits and potential judgment debts.

Unequal Application of Mining Laws

Gomashie further criticized what he described as unequal application of mining laws between large-scale multinational mining firms and local small-scale operators.

“Companies like Future Global Resources and Heath Goldfields were given formal notices and 120 days to rectify breaches. Why should small-scale miners be treated differently?” he queried.

He called for fair and consistent application of mining regulations across all scales of operation, adding that arbitrary closures without due process will worsen illegal mining (galamsey) and undermine formalization efforts.

Recommendations for the Ministry and Minerals Commission

In his concluding remarks, Ing. Gomashie made several recommendations to enhance transparency, fairness, and institutional efficiency in Ghana’s mining sector:

  1. Review the revocation list and ensure decisions are based on clear legal grounds and due process.
  2. Disclose the specific breaches of each license to the public for accountability and education.
  3. Avoid politically motivated revocations, especially for licenses granted close to election periods.
  4. Prevent political reallocation of revoked concessions; instead, allow existing holders to reapply.
  5. Strengthen district and regional oversight, ensuring that qualified mining inspectors handle compliance.
  6. Establish dedicated small-scale mining units in all regional Minerals Commission offices.
  7. Uphold uniform standards for both small-scale and large-scale miners in line with Ghana’s single mining code.

A Call for Balance and Rule of Law

Ing. Gomashie emphasized that Ghana’s small-scale mining industry remains the backbone of local gold trade, employing thousands and sustaining rural economies.

“Decisions tainted with political connotations and procedural breaches will only worsen the illegal mining problem,” he cautioned.
“Let’s work together to make Ghana’s mining industry a great one.”

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