Policy think tank IMANI Africa has raised serious concerns about whether the ongoing shift in state insurance placements is complying with Ghana's public procurement law, warning that what is happening in the sector may amount to allocation rather than procurement.

In the second instalment of its Insurance Question series, IMANI associate Kay Codjoe examines the legal framework governing insurance placements for State-Owned Enterprises and specified entities, and finds it is not being followed.

"Insurance placement for State-Owned Enterprises and specified entities is not discretionary," the analysis states.

"It falls squarely within Ghana's public procurement framework, governed by the Public Procurement Act, 2003 (Act 663), as amended by Act 914."

That law requires public entities to ensure competitive tendering, transparency in evaluation, value for money, and non-discrimination among qualified providers.

Exceptions exist, but IMANI notes they are narrow sole sourcing, for instance, must be justified under strict conditions such as exclusive capability, urgency, or standardisation, and are not a default option.

IMANI's concern is that those conditions are not being met.

Following a December 2025 communication from the State Interests and Governance Authority (SIGA) directing state entities to prioritise SIC Insurance PLC and SIC Life, the think tank says renewals have shifted, participation by private insurers has narrowed, and in some cases, existing placements have been disrupted before their natural contractual cycle.

"Where is the tender? Where is the evaluation? Where is the documented justification?" the analysis asks.

"Because without those, the process is no longer procurement. It is an allocation. And allocation without process is precisely what Act 663 was designed to prevent."

IMANI also challenges any suggestion that directing state business toward SIC could be justified as an internal government allocation. SIC Insurance PLC is a publicly listed commercial company in which the government holds a minority stake, while private investors hold the majority.

It competes in the same market as Enterprise Insurance, GLICO, Hollard, and Star Assurance.

"Any preferential placement of state insurance business with SIC cannot be justified as internal government allocation," the analysis states.

"It must meet the same competitive and legal standards as any other insurer."

IMANI warns that the pattern emerging in the insurance sector is a policy signal, a preferred direction, adjusted market behaviour, and shifted contracts sets a dangerous precedent that could spread beyond insurance.

"Today, it is insurance. Tomorrow it could be energy procurement, infrastructure contracts, or financial service mandates," the analysis cautions.

The think tank insists the core question is not whether state insurers should participate in public sector business, but whether they win that business through competition or receive it through direction.

"The difference between those two paths," it states, "is the difference between a functioning market and a managed one."

IMANI's petition on the matter was formally acknowledged by the Office of the President on April 1, 2026, with the Secretary to the President confirming the contents had been noted and would be brought to President Mahama's attention for necessary action.