IES calls on government to immediately enforce Ghana’s Domestic Market Obligation regulations

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The Institute for Energy Security (IES) is calling on government to immediately enforce Ghana’s Domestic Market Obligation (DMO) regulations, arguing that the return of the Tema Oil Refinery (TOR) to operations has removed the main practical obstacle to implementation.

In a policy research paper released on August 14, 2026, the energy think tank said the legal framework for securing domestic crude supplies already exists and requires consistent administrative enforcement.

IES is specifically calling for the implementation of Regulation 32 of the Petroleum (Exploration and Production) (General) Regulations, 2018 (L.I. 2359), as amended by L.I. 2390.

The regulation operationalises Section 71 of the Petroleum (Exploration and Production) Act, 2016 (Act 919), which empowers the sector Minister to require petroleum contractors to sell a defined portion of their crude entitlement on the domestic market.

“What has been missing is not legal design but consistent administrative enforcement,” the paper stated.

IES believes the resumption of refining operations at TOR in December 2025 has addressed the strongest practical argument previously raised against enforcing the DMO — the absence of a functioning domestic buyer of crude.

TOR resumed operations on December 19, 2025, following extensive Turnaround Maintenance (TAM) on its Crude Distillation Unit between August and October that year.

The refinery is currently operating at about 28,000 barrels per stream day, with plans to restore its nameplate capacity of 45,000 barrels per stream day and eventually expand to 100,000 barrels per stream day.

IES said Ghana’s estimated daily petroleum consumption of about 100,000 barrels means TOR, if restored to its intended capacity, could meet more than half of national demand.

The think tank has cited experiences from Nigeria and Indonesia to demonstrate the importance of having an effective domestic crude supply framework.

In Nigeria, despite a Domestic Crude Oil Supply Obligation established under the Petroleum Industry Act, 2021, local refineries reportedly received less than half of the crude allocated to them in the first quarter of 2026.

IES said only 28.5 million barrels were supplied out of 61.9 million barrels allocated.

It warned that the shortfall, combined with the requirement for refineries to sell refined products domestically in naira under Nigeria’s naira-for-crude arrangement, created a currency mismatch between dollar-denominated import costs and naira-denominated domestic revenues.

Indonesia, by contrast, has incorporated its DMO into production-sharing contracts from the outset, providing domestic refineries with more predictable access to crude feedstock, according to the paper.

IES is urging government to take four immediate steps to operationalise the DMO.

It wants the Energy Minister to issue the 90-day written notices contemplated under Regulation 32(1), placing TOR’s crude feedstock requirement on a recurring calendar-year basis.

The think tank also wants the Energy Commission and Ghana National Petroleum Corporation (GNPC) to publish annual domestic supply requirements under Regulation 32(4) to (7), with the volumes broken down by month.

It further recommends publication and consistent application of the weighted-average pricing methodology under Regulation 32(8).

IES is also calling for the formal constitution of the independent expert dispute-resolution mechanism provided for under Regulation 32(9), ahead of any potential disagreements.

According to IES, consistent enforcement of the DMO could strengthen Ghana’s downstream petroleum security in several ways.

A guaranteed domestic crude allocation would allow TOR to refine a portion of Ghana’s petroleum needs locally, reducing exposure to international shipping schedules, financing delays and fluctuations in freight costs.

The think tank also argues that the pricing mechanism under Regulation 32(8), if applied consistently, could reduce TOR’s exposure to sharp short-term movements in international crude prices.

IES further believes increased domestic refining could reduce demand for foreign exchange by replacing some imported refined petroleum products with locally produced fuel.

It argues that this could help ease one source of dollar demand in the  economy and potentially support efforts to stabilise the cedi.

IES is cautioning government against allowing domestic crude allocations to depend on the discretion of successive administrations.

The think tank warned that without a binding and adequate supply obligation, even a restored refinery could be forced to compete with international markets for crude, potentially undermining the gains made from the rehabilitation of TOR.

“A restored or newly built refinery that must compete for feedstock against export markets, without a binding, volume-adequate domestic supply obligation, will be forced into international crude purchases priced in foreign currency,” the paper stated.

IES said Ghana risks eroding the gains made from TOR’s turnaround if domestic crude supply continues to be handled through ad hoc arrangements.

The think tank is therefore urging government to move from policy discretion to a predictable, rules-based system for supplying domestic refineries.

It said the restoration of TOR’s operations has made enforcement of Regulation 32 both necessary and practicable, and called for its immediate implementation on a calendar-year basis.

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