Bright Simons writes: No, Ghana Card is not “for” Ghana; it is ripping off Ghana

This is a fairly long essay, so here is the quick take for those too busy to read.

• Ghana Card’s main technology asset base belongs to Margins Group, not the government of Ghana.
• This makes it impossible for the government to save cost by using smart procurement to obtain the printed cards, biometric devices, and system integrations. It must get everything from Margins alone.
• Ghana Card, as a system, cannot be operated without Margins, so the idea that the government “owns” the data is meaningless.
• The government agency in the Ghana Card PPP, NIA, has become a “zombie”; it lacks the capacity to develop specifications and to exercise serious oversight. Some senior parliamentarians are also mere praise-singers of Margins.
• Due to the stranglehold Margins has over the Ghana Card, each unit costs Ghana nearly 20 times what a similar smartcard costs Rwanda.
• The Ghana Card PPP was supposed to be cost neutral to the government. It was to pay a startup contribution of $124 million and then recoup over time as revenues come in. However, the “revenues” are a sham since they come from the same government.
• Government of Ghana is therefore going to end up paying up all the $1.44 billion revenues the system is designed to generate by 2033, and Margins will get virtually all of the money.

Now, let us get into the meat.
Some senior MPs are making it hard to take Ghana’s Parliament seriously

A few weeks ago, members of the “subsidiary legislation” committee of Ghana’s Parliament visited one of the factories of Margins Group, the company that owns Ghana’s National Identification System, the so-called “Ghana Card”. The powerful committee makes virtually all the administrative and regulatory laws that govern many day-to-day functions of the administrative state and its government.

Even though concerns about Ghana Card are a matter of periodic inquiries before the Parliament, the Chair of the Committee, the Member for Bolgatanga East, could not contain his enthusiasm to declare the Opposition Party’s unrestrained support for anything Ghana Card. Given his premature and prejudicial excitement, one wonders how anyone can expect the Parliament, as presently constituted, to exercise any serious oversight in the matter.

The MP’s behaviour is reminiscent of another visit to another company, whose business relationship with Ghana has come under severe scrutiny, SML. Even whilst the matter was under investigation by Parliament, and concurrently by the Presidency, the Chair of a powerful parliamentary committee rushed to the premises of the company to pass very prejudicial comments about the ongoing investigations. He insisted that he had observed “world class monitoring” activity on the premises, the very issue being probed. This was curious since the President of Ghana had announced a suspension of the company’s activities whilst investigations continued.

How then was the MP, the Honourable Member for Akim Abuakwa South, able to observe “world class monitoring” in an operation halted by no mean person than the President of the Republic? How?

State Enchantment
It has become clear for some time now that the institutions set up to safeguard the public interest in Ghana have been performing below par. In some cases, the results suggest that they may even have become compromised.

Even more concerning is a trend best described by this term: “state enchantment”, a process by which projects primarily intended to enrich private actors are wrapped up in spectacular clothes of national glory, so radiant that the public is perpetually blinded as to the underlying commercial motives. The “haze of glory” surrounding these projects makes any call for scrutiny easily dismissible as bizarre negativity.

Such state enchantment programs benefit massively in an environment such as Ghana, where the official watchdogs like Parliament and the anti-graft institutions have powerful actors within who compromise these institutions’ oversight functions in relation to these same programs.

This author recently had the opportunity to talk about this at an event organized by some respected institutions. One of the case studies highlighted in the talk was, unsurprisingly, Ghana Card.

Ghana Card, for reasons to be offered shortly, is one of the most brazenly potent examples of state enchantment ever conceived.

What is Ghana Card?
Creating a general-purpose ID card for Ghanaians is a national dream of old. The military regime after the Second Republic acted on this and distributed some cards starting with areas around Ghana’s land borders. Not much progress was made thereafter.

After various fits and starts, the National Identity Authority was set up in 2003 and its enabling legislation passed in 2006 (Act 707). A strategy was taken to issue cards to both Ghanaians at home and abroad.

In the perennial confusion and amidst the jostling for rents by elites that attend every public project in Ghana, the project got stuck. Even though loans sourced from France for French contractor, Sagem Morpho, and “counterpart funding” from the Ghanaian government, led to a $60 million budget being put together by 2008, time was too short; the government of the day lost elections at the end of that year and the new government, as is customarily, decided to restructure the entire project. Margins was a subcontractor to Sagem in that initial run.

After 8 years, some progress had been made, but significant challenges remained. Activist organisations like IMANI pointed out a wide range of defects in the prevailing regime which unchecked would undermine outcomes over time. Before the sitting government could get a grip on the project, they also lost power.

Wastefulness
When the new government arrived on the scene in 2017, 15 million Ghanaians were already captured in the national database, and the entire infrastructure (except the foreigners segment) was primarily controlled by the State.

What remained was the development of value-adding authentication modules on top of the national database, the perfection of a higher-spec physical card production process, and a distribution system to ensure that printed cards could get to their owners. So weak was the initial logistics solution that even though 2.7 million cards had already been produced by 2013, only 900,000 had been distributed by then. By the end of 2016, 50% of the 3 million printed cards remained uncollected. A new biometric data collection system held data for 4.5 million Ghanaians (less than 30% target penetration).

Fixing project challenges, the Ghana Way

When the new government took the reins of power in 2017, the usual review of programs occurred. Having identified the problem as being one of inadequate resources, all that was necessary was to determine the right level of government financial commitment, prioritise efficient procurement, and cut out waste due to poor logistics planning.

Instead, the government decided to start all over again, discard the old databases on grounds of forward-incompatibility of the technology stack, and enter into a new public-private partnership (PPP) contract with the Margins group. This is the precise moment when the state enchantment effort began.

What had been a routine bureaucratic program of identifying citizens, something that many Francophone countries have been doing for decades without fanfare, suddenly became a messianic affair of Marian proportions. All of a sudden, every problem in Ghana was only solvable by “Ghana Card”.

Many have been swayed by these antics, and the more hard-nosed among the population merely dismiss the hype as the usual dross of PR-centric Ghanaian political showboating. In this essay, however, the intent is to show how the PPP model by its very design requires such high levels of state enchantment to operate. It also explains why all levers of state power has been brought to bear to force the Ghana Card on the population in order to artificially inflate its importance.

How did Margins get in? (Nice contract if you can get it)

The subsidiary of the Margins group that entered into the PPP with the NIA to roll out the Ghana Card solution is Identity Management Services (IMS). IMS got its muscle from a joint venture it initiated with American and Danish investors to print cards for the first incarnation of the Ghana Card in 2003 when the design was based on State control of the system, with contractors just producing the cards and selling equipment. IMS had the local relationships, the Danes and Americans had the technology and fund-raising capacity.

With both local and international connections in place, the Margins Group would benefit from a million-dollar grant from the Danish government to cover its part of the joint investment. In total, $3.5 million in Danish funding went to the partners in a nice blend of grant funding and commercial credit. The Danish development finance institution, IFU, doubled down on the project with additional credit of $5 million by 2015.

With financial muscle comes influence, and so Margins was able to convince the NIA to enter into a PPP in 2013 to handle just the registration of foreigners in Ghana. The template was thus set for the current wide-ranging relationship consummated with the 2018 PPP agreement.

Why PPPs can unblock resources in Ghana

The impression created that somehow the PPP for the national ID card program in Ghana unlocked fresh private sector resources and saved the government money is of course abject nonsense. regardless of the precise model, in the end, the money would have come from the government.

What is true however is that crafting the program as a PPP did make the government more willing to release money. Somehow, just having a big private beneficiary driving outcomes propels government institutions to unlock large amounts of money they would never otherwise had released if a government agency was the one driving the project. Furthermore, entrusting the asset base of the project to a private businessman appeared to have created the necessary motivation across all levels for the project to succeed. This is the only reason why Ghana Card issuance has successfully been boosted to ~17 million Ghanaians.

Who owns the Ghana Card Assets
There are a number of key systems that make the Ghana Card work:

• A datacenter to store the data, including the biometrics.
• Database software to organize the data effectively for retrieval, validation and updating.
• A special memory chip to contain the identification information stored on the physical smartcard.
• Unique cryptographic and encryption solutions, plus the accompanying cybersecurity techniques, to prevent manipulation of the data and enable authentication of the individual.
• A stack of security features to prevent unauthorized issuance, alteration and duplication of cards.
• Biometric capturing, de-duplication, and validation systems.

As mentioned previously, the data collected is meaningless unless organized and deployed by such assets. That is why the 15 million citizen data points collected by 2016 did not translate into much; the asset base was not adequate.

When Margins Group says that “government of Ghana” owns the Ghana Card data, it is not being candid. It owns the assets and infrastructure that makes the data usable.

The best way to emphasise the reality of things as currently pertains in Ghana is to say that WITHOUT MARGINS, GOVERNMENT OF GHANA CANNOT OPERATE THE GHANA CARD.

The licenses covering the critical technologies and the service contracts for their maintenance are all owned and controlled by the Margins Group and not the government of Ghana. The government can easily put minds at ease by publishing the inventory of technologies with a map of ownership.

Ghana’s fingers are in Margins’ mouth

To underscore the point about ownership, let us ask a simple question: could the government of Ghana ask another contractor to print Ghana Cards or to supply biometric authentication devices for any purpose related to national identification, such as a mass registration campaign, service center setup (offices where one can go to replace their Ghana Cards or seek technical assistance), or integration into the information system of another government agency without the Margins Group? The answer is an emphatic, NO. It cannot.

And the issue is not just about requiring the expertise of to provide technical support. We are talking here about the actual provision of goods and services related to national identification. No other company can produce the physical cards for the government, supply biometric devices, or handle data integration activities for any national identification purpose in Ghana EXCEPT Margins group. No matter how cheaper any other company can print ID cards (which, by the way, is a commodity business today), procure and supply biometric devices, or handle integration between another agency and the National Identity Register, the government of Ghana is bound to use Margins.

This is absolutely not the kind of PPP most have in mind when they hear about the Ghana Card project, and yet that is what the country is saddled with.

Of course, a rational strategist designing a Ghana Card system purely in the public interest would have unbundled the architecture such that the underlying registry containing the biometric data would have been entirely government controlled.

They would then have ensured that assets purchased and configured by the private contractor for authentication and validation would have been transferred to the government.

And, no doubt, they would have ensured that the peripherals such as the physical ID cards and biometric devices are uncoupled from the core infrastructure such that anytime the government or any of its agencies want to acquire some cards or biometric terminals, they would simply issue a tender and award the contract to the most cost-effective and technologically advanced vendor. This is how it is done in Malaysia. This is how it is done in Indonesia. And this is how it is done in South Africa. And, in fact, this is how it is done in every serious jurisdiction concerned about fiscal prudence and fairplay. Even Rwanda’s card production (even though it was coupled with data collection) was subject to open tender. Of course, tenders can be rigged, but without even the option to tender, a country is essentially locked in a pattern of poor procurement.

Pretend Nationalisation
Constant complaints by a few activists like this author about the way the National Identification System was set up finally convinced the authorities to act. In 2022, they began the process of migrating the Ghana Card database to the national datacenter and transferring the Public Key Infrastructure (PKI) associated with the project to the National Information Technology Agency (NITA).

However, this effort has been cosmetic because the essential design and structure of the database system makes it very difficult for the government to pursue a flexible vendor strategy: letting anyone other than Margins print cards remains a practical impossibility. As for the PKI model, it has never been fully implemented, except for the deposit of Ghana’s public keys in Montreal, with ICAO, as part of the comical e-Passport fiasco. This year, the Ministry of Communications is requesting yet more money to build this mysterious PKI thing. Ghana Card’s encryption and cryptographic domains remain the exclusive province of Margins.

In fact, Margins simply used the half-hearted nationalisation process to secure more lucrative contracts. They billed the government more than 55 million GHS to establish the Disaster Recovery System that they claimed the transfer required to be successful.

Furthermore, the authentication software is still closely-coupled with the data system (with related licenses, such as those covering the Entrust technology and its durashield module, remaining with Margins). The net effect of all these is that any vendor brought in to compete for jobs like cards production, biometric device supply, and API integrations for government agencies, will be entirely reliant on Margins. In fact, they will be redundant.

This pretense of a transfer continues unchallenged because of the extreme opacity of the entire architecture and process.

Some readers may still be unconvinced at this point about whether these serious institutional defects are having any tangible adverse effects. And the answer is, yes. Plenty.

Ghana Card has become a MASSIVE rip-off

The big justification for the PPP model used in rolling out the National identification System is that it unlocked private resources and thus overcame the old “no money” syndrome bedeviling so many public sector initiatives. But this is a big lie. It merely UNLOCKED GOVERNMENT MONEY.

As part of the April 2018 Agreement signed between Margins and the government of Ghana, which was never published for the benefit of the general public, the government of Ghana agreed to make guaranteed payments every month to Margins. These payments are due if the fantastic revenue amounts anticipated under the agreement do not materialise.

Since the agreement was based on agencies like SSNIT (the public pensions fund), Ghana Revenue Authority, the National Health Insurance Authority (NHIA), the Drivers & Vehicles Licensing Authority (DVLA) and others paying Margins hundreds of millions of Ghana Cedis over the 15-year lifecycle of the project, it was always a foregone conclusion that the burden would ultimately be transferred to the central government. NHIA, GRA, CAGD and the likes are not primarily profit-making institutions. To buttress the point, note NIA’s projected revenue from Ghana Card operations of barely 8 million GHS in 2024.

Source: Ministry of Finance, Ghana
The projected 2024 figures are based on a recognition that the premium services forced down the throats of Ghanaians in the last few years at 250 GHS per person, and the integrations forced on some state institutions, leading to revenues of nearly 78 million GHS in 2023, have ceased having attraction, with premium service centers now lying mostly empty.

Source: Ministry of Finance, Ghana
It was thus a ruse to pretend that there was something financially innovative about how the PPP was set up. Government was always going to have to pay for the system, except that in the specific type of PPP model selected, the cost burden on the government was heavily inflated just so that a private company can make fantastic returns that other private companies struggle to make in any industry.

It is mind-boggling reflecting on the whole financial design of the Ghana Card

The April 2018 agreement was based on the premise of the setup of the card costing a little less than $300 million, and operations and maintenance costing another $900 million over the 15-year period (i.e. 780 million Ghana Cedis a year). The private partner was guaranteed a minimum 17% return.

For the numbers to work out, the system must generate income of at least $93 million a year (far more than that, actually, if one considers the time value of money, which we are ignoring to keep things simple). If the system doesn’t, then the government is indebted to Margins since the “profits” and “losses” are shared in a way whereby Margins is guaranteed a profit only. Essentially, the government bears all the risks, and Margins has none of the downside. On top of all these, Margins has already been granted tax exemptions of at least ~$177 million.

It was thus highly deceitful when the impression was earlier created that the government’s liability was limited to the $124 million it had to contribute to setting up NIA’s offices, buying vehicles, and hiring people. The approval of the PPP by Cabinet and the Ministry of Finance (and later by Parliament) was based on this erroneous impression of a one-off cost and self-sustenance thereafter.

In the end, the government of Ghana had to hire roughly 1400 more people to provide the NIA with the manpower needed for national operations. Actually, the NIA wanted to hire 3265 people, but the Ministry of Finance refused. The total personnel cost of running the government side of the system was barely 5.2 million GHS in 2017. Total admin costs in 2019 were 3.3 million Ghana Cedis in 2019. Today, the goods and services budget alone is over 165 million GHS per annum and compensation has gone up by more than ten times.

Source: Ministry of Finance
The idea of a one-time cost has now been thrown out of the window and government contributions both to the NIA and Margins keep ballooning even as arrears pile up.

The government’s maximal exposure could well exceed $1 billion if the evasive revenues don’t show up. Remember, however, that the revenues are mostly supposed to come from government agencies that often struggle to balance their books, and whose liabilities always end up being transferred to the government anyway. Like the NHIA policy that was supposed to find innovative financing through “insurance” but is today 98% tax-funded, the Ghana Card project is today predominantly tax-financed.

One-half of the Ghana Card PPP, the portion focused on the Ghanaian diaspora, had already racked up losses of nearly $300 million by 2021. Losses that the government of Ghana is expected to make whole for Margins.

Source: Ministry of Finance, Ghana
How then can one attribute the successful issuance of 17 million cards as an outcome of some innovative PPP, except for the fact that the mere existence of private incentives has made the government more willing to spend money that in the past it was not willing to spend?

Squeezing every drop from Ghanaians
Margins, with the strong support of the NIA and various other elite enablers, constantly find ways to squeeze more money from Ghanaians. It’s justification is that it invested massively to set the system up and as a private investor, it is entitled to recoup. But this claim is dubious in a number of respects.

It is true that the PPP strategy envisaged an upfront investment of $169 million by Margins. But no one has ever audited the actual expenses made. Even though Margins was supposed to be totally responsible for the entire technical infrastructure setup, including all equipment etc., the situation right now is that government agencies are buying the equipment and paying for activities that per the April 2018 agreement Margins was expected to fund.

Heavily incentivized to make the most money possible, Margins constantly induces the NIA to shift strategy towards approaches that cost more money.

For example, an earlier decision was made to produce 2D barcoded cards (instead of cards with chips) for children under 15 years since their risk of impersonation and identity fraud in general is so low. A plastic card without a smart chip can cost about one-tenth of the price of one that has a chip. Imagine the surprise of analysts then when it was recently announced that NHIA will procure smartcards from Margins for children.

It stopped being surprising, however, when the cost was revealed. Just for the physical cards, NHIA will pay 81.9 Ghana Cedis per unit, that is nearly $9 at the time the procurement decision was made. Just for the cards. Adding ancillary costs like equipment and data capture, which are also being billed to the NHIA, take the cost to nearly $20, about the same price Margins and NIA charges for those who want to acquire the Ghana Card outside the government’s poorly organized mass registration campaigns. Rwanda, because it could use open tender to obtain smartcards and data capture services spends just $0.9 per card.

The unconscionable unit costs reflect in the total NHIA budget for the Ghana Card for Children project.

Source: Parliament of Ghana
NHIA’s Parliament-approved allocation model for the NHIF levies all Ghanaians pay when they buy VAT-rated products for 2023 shows that the 4^th largest budget item, at 405 million GHS, was for spending on Ghana Card. Thus, every time anyone in Ghana pays NHIL on any item, a massive amount is pumped through schemes like this into Margins’ ever-ready pocket.

In the end, instead of the 6.87 billion GHS spending plan, the total budget for 2023 came down to 4.53 billion GHS, of which 4.37 billion GHS was actually spent. The allocation to Ghana Card thus reduced to 180 million GHS, but it still remained the 4^th largest budget item. Consider that the entire call center operation of the NHIA, so essential to customer service, was allocated just 1 million GHS. NHIA’s entire sensitization budget was just 3 million GHS. Only 42 million GHS was spent on emergency medical care. Public education, social marketing and sensitization was lucky to get 9 million GHS.

In 2024, the NHIA intends to spend more than 300 million GHS on Ghana Cards.

Why on Earth would a health insurance service prioritise ID cards to such a great extent when everyone knows that its anti-fraud concerns are not about people impersonating other people (no point in doing that as packages are virtually identical) but about service providers inflating costs? In most countries, ID cards don’t even merit their own line item in the budgets of public health insurance bodies. Why couldn’t Parliament push back when confronted with these mind-boggling figures? Simple answer: State Enchantment.

The NHIA is of course not the only organisation being squeezed to ensure that the $1.2 billion revenue target (plus extra return) is reached at all cost by 2033 so that Margins can make its guaranteed returns. Organisations like SSNIT, GRA and others have large bills outstanding for so-called integration services. As at 2022, GRA alone owed Margins at least $12 million. And, of course, citizens must bear the inconvenience of being denied services like banking and drivers’ licenses if they can’t show a Ghana Card in order to induce them to part with nearly $20 for the privilege.

Somehow, someone has been able to hypnotise the whole country into believing that Ghana Card is actually saving government entities money. That somehow GRA needed to pay tens of millions of dollars just to integrate into a national identity system. And that impersonation is such a big problem that instead of a cheap plastic card with a 2D barcode costing about 20 cents ($0.2), NHIA instead needs a $9 smartcard.

When the previous government secured a loan promise from China of $115 million in 2013 to rollout a truly national system, many were those who criticized the government for profligacy. Yet, in the name of an innovative PPP, the government is on course to spend a billion dollars for an identical system.

The NIA is a zombie partner
It is not entirely clear how much the NIA sees its role as simply facilitating the profit margins of Margins Group versus defending the public interest.

One thing, however, is for sure, the NIA is quite clueless in serving as some kind of technical bulwark to Margins in the defence of the national interest. It is clear that it is simply out of its depth and cannot shadow the shrewd Margins operators in this fairly complex domain.

How do we know? In attempting to shed a bit of light on the notoriously opaque Ghana Card system, NIA simply went over to the websites of various government agencies in the United Arab Emirates and copied everything verbatim, a clear sign that they had no hand in designing the specifications. Because of a history of webpages disappearing in the heat of national debates, we have ensured that the screenshots below have the exact web addresses so that readers can make their own screenshots (here, for example).

We have NOTHING against Margins Group
No one is disrespectful of the entrepreneurial acumen of the people behind Margins Group. In fact, many of us with an exposure to entrepreneurship in Africa admire their tenacity and shrewdness. Most businesspeople who get the chance to milk an unserious client, who seems all too happy to be milked, will do so. The founders of Margins are in business to make money.

The people who deserves our ire are the politicians in Parliament and elsewhere who are busily working to throw wool in the eyes of the citizens, even as the hypnotic effect of state enchantment works to siphon off hundreds of millions of dollars into private pockets.