Independent analysis

Independent analysis. Built from public sources, checked on 2 November 2026. Not legal or financial advice.

By Nana Krobea Asante Sekyere, Accra

The strongest argument against this piece

Funding often ends for reasons that have nothing to do with how well an organisation is run.

In 2025, US government funding to many organisations in Ghana was cut (STAR-Ghana Foundation, June 2025). Well-run organisations lost money too. The State of the Humanitarian System 2026 report from ALNAP surveyed practitioners. It found that 43.15% agreed with this statement: "cuts were donor imposed, we did not have much choice" (ALNAP, 2026).

STAR-Ghana Foundation asked 113 Ghana-based civil society organisations about the freeze. The survey ran online from 25 March to 9 May 2025 (STAR-Ghana Foundation, June 2025). Here is what it found:

• 58% (65 organisations) said they were affected. 20% said they were affected directly.
• Of those affected, 91% had not secured other funding.
• 320 staff were laid off across those 65 organisations.

The same report also cuts against a simple story. 46% of all respondents got less than 20% of their money from USAID. And 72% of the affected organisations had at most half of their 2024 budget from USAID.

The sample chose itself. People answered an online survey. It does not speak for every organisation in Ghana.

So this piece does not say weak organisations lose funding and strong ones keep it. It says something smaller. Some gaps make a funder lose confidence sooner. Closing them may reduce avoidable loss. It will not protect you from a donor changing its mind.

One more point, plainly. Nobody has measured how common these five gaps are among Ghanaian NGOs. I found no published figure. Everything below comes from what funders ask for, and from documented cases. It does not come from a count.

Why "quietly"

This section is my view, not a finding. Funding trouble often does not arrive as one clear message. A report may be questioned, a reply may take longer, or a renewal may not come. By then, a gap may have been there for months.

Funders see a different picture from the one you see. They see your papers, your reports and your answers to their questions. So the gaps below are the ones that show up on paper first.

Gap 1: Where the money goes

Funders want to see how money enters, moves and leaves your organisation.

FCDO is the UK government's foreign and development department. Its guidance for partners, updated in June 2026, covers governance and internal controls, and financial stability. It also covers how a partner manages the organisations it passes money to. Partners need a written risk register for each programme (FCDO guidance, updated June 2026). The depth of checking depends on the level of risk.

FCDO also said in May 2024 that its due diligence checks that partners have robust fraud policies. It checks that they can manage downstream partners. And it monitors and recovers fraud and error it identifies (FCDO response to ICAI recommendations, 7 May 2024).

So the plain question is this. Can you show, from your own records, where each grant went? Can you show who approved each large spend?

Gap 2: What you hold and can get back

This is the gap with the thinnest evidence for NGOs.

The best public evidence I found is about public programmes, not NGOs. A Global Fund audit of grants in Ghana in 2019 looked at public-sector recipients. It reported that data quality audits in 2018 found significant inaccuracies. It also reported that 24 of 30 health facilities (80%) had no documented tracking of patients who stopped coming for treatment (Global Fund Office of the Inspector General, 2 April 2019).

That tells us what a funder looks for. It does not tell us how many NGOs keep poor records.

I found no public evidence on whether NGOs in Ghana can recover their records after a lost laptop, a failed phone or a closed email account. I will not guess. But you can test it yourself in an hour.

Gap 3: Who decides, who can reach what, who answers

This gap has three parts. Who decides? Who can open which records and accounts? Who answers when something goes wrong?

Who decides. The same 2019 audit looked at why grants were slow to spend. It found 32% absorption. It said duplicated roles and unclear reporting lines "contributed to delays, poor grant absorption and weak performance". It also found no material financial irregularities in its limited testing (Global Fund Office of the Inspector General, 2 April 2019). Again, these were public-sector recipients, not NGOs. The lesson is about roles, not honesty.

Who answers. In 2025 the Global Fund's inspector published an audit of grants in Ghana. It found that two programme recipients did not report allegations of sexual exploitation and abuse at organisations they funded. The Code of Conduct required them to report. The Fund learned of it in February 2023, during an audit. It could not check that victims were protected. The implementers' own investigations had substantiated wrongdoing (Global Fund Office of the Inspector General, 3 May 2025). The audit pages I read did not state what happened to the grants afterwards.

I draw one lesson only. A funder can accept bad news. It struggles when it is the last to hear it.

FCDO asks partners for a signed staff code of conduct, complaints and whistleblowing policies with a case register, and a board-level safeguarding lead (FCDO guidance, updated June 2026). Each of these answers the question "who answers".

Who can reach what, and the law. Ghana's Data Protection Act, 2012 (Act 843) is the law as it stands. The Data Protection Commission enforces it. In October 2026 the Commission said it had registered 2,575 data controllers in 2026. It said registration does not equal compliance. It said it will no longer rely on persuasion alone, and it described spot checks, complaint investigations and registration checks across public and private bodies (Ghana News Agency, October 2026).

If you hold names, phone numbers or case notes about people, this may apply to you. Please check the official text, or ask a lawyer.

Laws can change. Check the Data Protection Commission's own site for the current text before you rely on any of this.

The rules for non-profits are also moving. On 18 September 2026 the NPO Secretariat launched policy and operational documents on registration, licensing and compliance monitoring. The Minister called for a risk-based, proportionate approach. An update on a Non-Profit Organisations Bill, 2026 was given. The report did not say what stage the Bill had reached (MyJoyOnline, 21 September 2026). I have no evidence that it is law.

Gap 4: Seeing trouble early and proving results

Two things belong together here. You need to spot trouble before a funder does. And you need to show results with records.

FCDO asks for a written risk register for each programme. It also asks for a complaints case register and mandatory training (FCDO guidance, updated June 2026). These are early-warning habits written down.

The Global Fund audit of 2025 shows the cost of the opposite. An allegation was not passed up. The funder found out later, in an audit (Global Fund Office of the Inspector General, 3 May 2025).

Proof of results has the same root. The 2019 audit found significant inaccuracies in data quality audits (Global Fund Office of the Inspector General, 2 April 2019). A result you cannot prove is hard for a funder to count.

The STAR-Ghana survey found that 91% of affected organisations had not secured alternative funding (STAR-Ghana Foundation, June 2025). That shows how little cushion many had. It does not show whether an earlier warning would have helped. I cannot show that early warning reduces loss, and no public study I found tests it. It is a reasonable idea, not a proven one.

Gap 5: What happens when a person, vendor or platform is gone

The public evidence here is thin. I found no public study of what happens at Ghanaian NGOs when a key person leaves, a vendor stops or a platform shuts.

The only indirect signs come from funders' own rules. FCDO asks for mandatory training and for standards to be passed to downstream partners (FCDO guidance, updated June 2026). These are not about key-person cover directly.

I will say no more than that. The question is still worth asking, because the answer sits in your records.

What we do not know

• How common these five gaps are among Ghanaian NGOs. Nobody has measured it.
• Whether closing these gaps keeps funding. No public study I found tests this.
• Whether the Data Protection Act has changed since 2 November 2026.
• What stage the Non-Profit Organisations Bill, 2026 has reached.
• What happened to the grants after the 2025 Global Fund audit.
• Anything about Gap 5 specific to Ghanaian NGOs.
• Public audits report only the cases a funder chose to investigate. They are not a fair sample.

Five questions to ask this week

1. Pick your largest grant. Can you show, from records alone, where every cedi went and who approved the big spends?
2. If your main laptop or phone were lost today, which records would you lose? Could you get them back?
3. Who is allowed to approve, and who can open your bank, email and records? Is that written down, and is the list current?
4. If a serious complaint reached you today, who would tell the funder, and by when?
5. If your most important person, supplier or platform vanished tomorrow, what would stop? Who knows how to restart it?

Disclosure

I advise organisations on this kind of work. This piece is not client work and names no client.

Sources

• SEAH due diligence guidance for FCDO implementing partners. UK government (FCDO), updated 30 June 2026. Link
• FCDO response to ICAI recommendations on tackling fraud in UK aid. UK government (FCDO), 7 May 2024. Link
• Govt unveils new guidelines to improve regulation of non-profit organisations. MyJoyOnline, 21 September 2026. Link
• DPC strengthens enforcement after registering 2,575 data controllers. Ghana News Agency, October 2026. Link
• Global Fund Grants in Ghana: failure of Principal Recipients to report SEAH allegations (GF-OIG-25-003). Global Fund Office of the Inspector General, 3 May 2025. Link
• Global Fund Grants in the Republic of Ghana (GF-OIG-19-009). Global Fund Office of the Inspector General, 2 April 2019. Link
• The Impact of USAID funding cuts on Ghanaian CSOs. STAR-Ghana Foundation, June 2025. Link
• State of the Humanitarian System 2026, chapter 1.3. ALNAP, 2026. Link