An Open Letter To The Public Accounts Committee Of Parliament: Ghana’s Pension Funds Need An Independent Forensic Audit

To: The Chairperson and Members of the Public Accounts Committee, Parliament of Ghana

cc: The Auditor-General, Office of the Auditor-General

The CEO, National Pensions Regulatory Authority

The Chief Administrator, Social Security and National Insurance Trust

Subject: Petition for a Comprehensive Forensic Audit of SSNIT and NPRA, Including Unclaimed Benefits, Tier Two Funds and Pension Administration

Dear Honourable Chairperson and Members of the Committee,

I write to you as a concerned citizen, founder of Pensioners for Reforms (P4R), Co-Chairman of the Concerned SSNIT Pensioners Forum (CSPF), a former SSNIT employee and a pension advocate who believes that Ghana's pension system deserves a level of transparency, accountability and scrutiny commensurate with the importance of the funds entrusted to it. This letter is an appeal for action.

I respectfully urge the Public Accounts Committee (PAC) to initiate the appropriate parliamentary process for an independent, comprehensive forensic audit of the Social Security and National Insurance Trust (SSNIT) and the National Pensions Regulatory Authority (NPRA), covering their financial management, pension records, benefit administration, investments, regulatory oversight and handling of unclaimed pension entitlements.

I make this appeal because pensioners' concerns about accountability cannot be adequately addressed by annual announcements of pension increases, institutional press statements or assurances that management is doing its best. Ghana needs verifiable answers.

The PAC's constitutional role includes examining the Auditor-General's reports on Ghana's public accounts. The Auditor-General also has powers to identify financial irregularities and, where the law permits, disallow unlawful expenditure and surcharge persons responsible for losses arising from negligence or misconduct. These accountability mechanisms should be fully utilized where the evidence warrants it.

The scale of pension funds and the vulnerability of those who depend on them make this matter particularly urgent.

1. Does SSNIT have a fully reconciled record of every pensioner?

Honourable Members, one of the most fundamental questions I wish to raise is this:

Can SSNIT demonstrate, through a fully reconciled and independently verified database, the identity and status of every person receiving a monthly pension from the Trust?

I am concerned about the completeness, accuracy and continuing verification of the pension payroll. I am not asserting that SSNIT has no reliable records. Such a conclusion would require evidence. However, the history of reported pension-payroll irregularities makes it reasonable to demand independent verification rather than rely exclusively on management's assurances.

In July 2024, the Public Services Commission published a report of SSNIT's disclosure that the Trust had saved GH¢519 million by deactivating pensioners described as “ghost pensioners”. That reported amount and the circumstances surrounding the deactivations deserve to be examined in the context of the wider pension-control system.

1. What exactly did the exercise uncover?
2. Over what period did the irregularities occur?
3. How many records were affected?
4. What amounts were paid improperly, if any?
5. Were any recoveries made?
6. Were the persons or processes responsible identified?
7. What controls have since been introduced to prevent recurrence?

These are questions an independent audit should answer. The audit must distinguish between fraudulent payments, payments made after a pensioner's death because notification was delayed, duplicate records, administrative errors and legitimate payments that were temporarily flagged during verification. Those categories have different implications and must not be confused.

2. How many people have contributed but never claimed their benefits?

This is another question that deserves an authoritative answer. How many people have contributed to Ghana's pension system over the years but have not claimed the benefits to which they may be entitled? Some contributors may have retired but remained unaware of the procedures for claiming their benefits. Others may have emigrated, lost contact with former employers, changed their names or addresses, or died without their relatives knowing that pension entitlements existed. Some may have worked in Ghana for several years before travelling abroad. Their contributions should not simply disappear from the public conversation because they no longer live here. Others may have died before claiming benefits, leaving surviving spouses, children or other eligible beneficiaries unaware of their rights.

These are possibilities that must be investigated, not assumed to be proven cases of missing money. I therefore ask the PAC to require SSNIT and NPRA to provide a comprehensive statement of unclaimed benefits, distinguishing clearly between Tier One, Tier Two and Tier Three.

The statement should establish:

1. The total number of unclaimed benefit cases identified.
2. The total value of the associated entitlements.
3. The ages of the outstanding claims.
4. The number of cases involving retired contributors who have not claimed.
5. The number involving deceased contributors and potentially eligible dependents.
6. The number involving contributors who have emigrated or cannot be contacted.
7. The number of cases where beneficiaries are known but documentation remains incomplete.
8. The procedures used to trace beneficiaries.
9. The amounts recovered or paid following tracing exercises.
10. The arrangements for safeguarding unclaimed funds until they can lawfully be paid.
11. The audit should also determine whether records are sufficiently integrated to identify people who contributed under different employers, changed names, migrated or moved between employment categories.

A pension entitlement must not become invisible simply because its owner has moved, retired, become incapacitated or died.

3. NPRA has acknowledged the issue of unclaimed pensions

This is not merely a hypothetical concern. NPRA has published an official public notice specifically addressing unclaimed Tier Two and Tier Three pensions. The existence of that notice makes it especially important to establish the scale of the problem and the effectiveness of the arrangements for tracing beneficiaries. I urge the Committee to obtain the full notice, its supporting records and any subsequent reports on the implementation of its recommendations.

3.1 How much money is involved?
3.2 How many contributors or beneficiaries have been traced?

3.3 How many have actually received their benefits?

3.4 What happens to funds that remain unclaimed for five, ten or more years?

3.5 Who is responsible for monitoring those funds?

3.6 What happens if a pension fund manager, trustee or custodian changes ownership, merges with another institution or ceases operations?

3.7 What safeguards ensure that the beneficiary's right is preserved?

Ghana's Ministry of Finance announced in May 2026 that an inter-agency technical working group had been established to develop a comprehensive framework for unclaimed financial assets. The group included representatives from NPRA, SSNIT, the Bank of Ghana and other institutions.

That initiative is relevant, but establishing a working group is not the same as accounting for existing unclaimed pension entitlements. The PAC should establish what has already been identified, what remains unresolved and what measurable progress has been achieved.

4. Who are the Tier Two fund managers, and what are they doing with workers' money?

Honourable Members, the management of Tier Two pensions is one of the most important areas requiring scrutiny. Under Ghana's three-tier pension system, Tier Two is a mandatory, fully funded occupational pension scheme managed through the regulated private pension framework. Workers and employers make contributions with the expectation that the accumulated benefits will be available when the workers retire.

1. But how many ordinary contributors can confidently identify their Tier Two trustees, fund managers and custodians?
2. How many know the value of their accumulated benefits?
3. How many understand the management fees charged against their accounts?
4. How many can explain why a colleague who retired at the same time received a lump-sum benefit while another is still waiting?

NPRA publishes lists of registered pension fund managers, including a list of those in good standing. That is a useful starting point. However, registration alone does not establish whether every manager has administered every account correctly or whether every outstanding benefit has been paid.

I therefore request that the PAC obtain a complete list of Tier Two trustees, pension fund managers and custodians operating during the audit period, together with the schemes and assets for which each was responsible.

The Committee should also require information on:

1. Their registration and licensing status throughout the relevant period.
2. Their investment performance against appropriate benchmarks.
3. Their management fees and other charges.
4. The number and value of retirement claims received.
5. The number and value of benefits paid.
6. The number and value of outstanding claims.
7. The reasons for delays in payment.
8. Complaints received and their resolution.
9. Regulatory sanctions, remedial orders and outstanding compliance issues.
10. Any discrepancies between member statements, trustee records, custodian records and the underlying assets.

Where the evidence reveals misconduct, negligence, unlawful deductions or failures to remit funds, the appropriate institutions should investigate and take action under the law. Pensioners should not be expected to accept unexplained delays or discrepancies simply because the institutions involved operate within a complex financial system.

5. Why have some pensioners still not received their Tier Two benefits?

This question deserves a separate and urgent investigation. There have been documented disputes concerning Tier Two past credits and the transfer of funds between institutions. In 2024, reporting on the Auditor-General's findings stated that, at the beginning of 2021, fund managers still owed SSNIT approximately GH¢483.37 million in connection with outstanding four per cent contributions associated with the pension transition. The amount reportedly received during 2021 was approximately GH¢6.08 million, leaving about GH¢477.29 million outstanding at that time. These are historical figures, not proof that the same amount remains outstanding today. The PAC should obtain the latest reconciled position and determine how much was subsequently recovered, transferred, written off or otherwise accounted for.

The larger question is what these historical difficulties reveal about the transition arrangements, reconciliation procedures and accountability mechanisms. Why should a worker who has completed the required years of service and reached retirement have to chase institutions for money accumulated on his or her behalf? Is the delay caused by incomplete records, disputed past credits, unpaid contributions, administrative bottlenecks, disagreements between trustees and managers, or regulatory approval requirements?

Each case should be classified and resolved according to its actual cause. The audit should trace selected cases from the original contribution through the relevant accounts and investments to the final benefit calculation and payment. Where a benefit remains unpaid, the responsible institution should identify the precise reason, the amount involved, the steps being taken and the expected resolution date. No pensioner should be left in uncertainty while institutions pass responsibility from one desk to another.

6. Follow the money from contribution to final payment

A proper forensic audit must do more than inspect financial statements and confirm that figures balance. It must test whether the underlying transactions are genuine, complete, authorized and consistent with the law.

• For SSNIT, the audit should examine contributions received, benefit calculations, pension payroll changes, investment transactions, procurement, related-party transactions, major contracts, administrative expenditure and the handling of complaints.
• For NPRA, the audit should examine the use of public and regulatory funds, procurement, capital projects, investment-related oversight, licensing and monitoring of pension service providers, enforcement actions and the handling of complaints about unclaimed or unpaid benefits.

The audit should also examine the financial and operational relationship between the two institutions. Where a contribution or benefit passes through more than one institution, the records should reconcile.

If SSNIT's records show that money has been transferred to a Tier Two trustee, the trustee's records and the custodian's records should confirm receipt and subsequent handling. If a trustee reports that a benefit has been paid, the records should demonstrate that the correct beneficiary received the correct amount. If a benefit has not been paid, the money should be traceable and its legal status explained. The same principle should apply to all material transactions.

7. Were public funds and pension resources used for their intended purposes?

The Committee should examine major expenditure and investment decisions against their legal authority, business justification, value for money and consequences for contributors and pensioners. This should include contracts, procurement, consultancy engagements, property acquisitions and developments, major capital projects and payments to related parties. The purpose is not to presume that a particular expenditure was unlawful simply because it was large.

It is to establish whether the expenditure was properly authorized, necessary, competitively procured where required, supported by documentation and consistent with the institution's mandate. Every cedi spent on administration or development must be assessed against the duties the institution is expected to perform.

Where an institution proposes a major capital project, the audit should establish its cost, funding source, procurement process, contractual obligations, expected benefits and implementation status. Where funds have been borrowed or diverted from their originally stated purposes, the audit should establish the legal basis, repayment arrangements, interest costs and financial consequences. The central question should always be whether the decision protected the public interest and the interests of pension contributors.

8. Did the regulator adequately discharge its responsibilities?

An audit of SSNIT alone would not be enough. NPRA exists to regulate and monitor the pension system and protect the interests of contributors and pensioners. It is therefore appropriate to examine whether the Authority has acted effectively when problems arise.

The Committee should ask:
8.1 Did NPRA identify material risks in good time?

8.2 Did it follow up on audit findings and outstanding recommendations?

8.3 Were complaints investigated promptly?

8.4 Were trustees, fund managers and custodians monitored consistently?

8.5 Where violations were established, were sanctions imposed?

8.6 Were sanctions enforced?
8.7 Were repeated violations identified and addressed?

8.8 Did the Authority verify that corrective measures had actually been implemented?

8.9 Were there cases where warning signs were documented but meaningful action was delayed?

These questions should be answered from inspection reports, correspondence, enforcement records, complaints registers, board minutes where lawfully accessible, and other relevant evidence. If the regulator acted appropriately, the audit should establish that. If it failed to act, the audit should establish where the failure occurred and what remedial action is required. The purpose is to strengthen regulation, not merely to assign blame.

9. The audit must be independent and forensic

Honourable Members, I respectfully submit that an ordinary internal review would not adequately answer the questions raised in this letter. I am asking for a forensic audit that follows transactions, reconciles records, tests controls and identifies the individuals or institutions responsible where evidence establishes wrongdoing.

The exercise should be conducted by appropriately qualified and independent professionals, with the Auditor-General involved in accordance with the applicable constitutional and statutory framework. The audit team should have access to the necessary records, subject to lawful safeguards for personal information and confidential material.

It should use appropriate data-analysis techniques to identify duplicate records, suspicious payment patterns, unexplained changes in beneficiary status, inconsistencies in contribution histories and discrepancies between the records of SSNIT, trustees, fund managers and custodians.

It should also examine the adequacy of the controls used to verify deaths, changes of beneficiary status and the continued eligibility of pension recipients. Any potential criminal conduct identified should be referred to the competent investigative and prosecutorial authorities. Any financial loss attributable to unlawful expenditure, negligence or misconduct should be dealt with through the applicable recovery and surcharge procedures. Those who have acted lawfully should not be subjected to unsupported accusations. But neither should anyone responsible for proven misconduct be protected by institutional position or professional status.

10. What I respectfully ask the PAC to do

I therefore call on the Public Accounts Committee to consider the following actions:

10.1 Initiate the appropriate process for an independent forensic audit of SSNIT and NPRA, including their relevant subsidiaries, schemes and material transactions within the lawful scope of the exercise.

10.2 Obtain a current, independently reconciled register of SSNIT pensioners and establish the number and value of unclaimed benefits under all three pension tiers.

10.3 Require SSNIT and NPRA to publish an accessible summary of the unclaimed-benefits position, with appropriate protection for beneficiaries' personal information.

10.4 Investigate the historical and current position concerning outstanding Tier Two contributions, past credits and unpaid retirement benefits.

10.5 Require the identification of the trustees, fund managers and custodians responsible for the affected schemes and establish what each has done to resolve outstanding claims.

10.6 Examine the use of pension and regulatory funds on major contracts, investments, procurement and capital projects.

10.7 Assess whether NPRA has adequately exercised its regulatory and enforcement powers.

10.8 Obtain an implementation schedule for outstanding recommendations from previous Auditor-General reports and establish which recommendations remain unresolved.

10.9 Ensure that the findings and recommendations of the audit are presented to Parliament and that an appropriately detailed public summary is made available.

10.10 Require periodic follow-up reports to establish whether identified irregularities have been corrected, missing funds recovered and unpaid benefits settled.

I also ask the Committee to consider inviting recognized pensioner organizations and affected retirees to submit documented evidence and complaints. Their experiences may help the Committee identify recurring problems that are not immediately apparent from aggregate financial statements.

11. The human cost of poor pension administration

Honourable Members, behind every pension account is a human being. A person who contributed for decades may now be unable to work. A widow may be trying to establish her entitlement after the death of her husband. An elderly person may have migrated and lost contact with former colleagues. A retired worker may be waiting for a benefit needed to pay medical bills, rent or the cost of feeding a family. These are not merely accounting entries. They are people's retirement savings and legitimate entitlements.

A delay of several months may be an inconvenience to an institution. To a pensioner who has no other income, it may mean unpaid bills, interrupted treatment or dependence on relatives. That is why pension administration requires both technical competence and a strong sense of responsibility. The people who manage and regulate pension funds must understand that errors and delays have consequences beyond the balance sheet.

12. Accountability must be accompanied by recovery and reform

A forensic audit should not end with the publication of a report. If it identifies irregular payments, the responsible institutions must determine what can lawfully be recovered. If it identifies unclaimed benefits, the beneficiaries should be traced and paid according to the applicable law. If it identifies unpaid contributions, the amounts should be reconciled and recovery pursued. If it identifies weaknesses in pension records, the systems must be corrected. If it identifies regulatory failures, enforcement procedures must be strengthened. If it identifies misconduct, the appropriate legal process should follow. If it identifies deficiencies in Act 766 or its implementation, Parliament should consider the necessary amendments. The goal should be to restore confidence in the pension system.

A pension system cannot command public trust merely because it has existed for many years. It must continually demonstrate that contributions are accounted for, investments are responsibly managed and benefits are paid when due.

Conclusion: Parliament must help restore confidence

Honourable Chairperson and Members of the Public Accounts Committee, I am not asking you to accept every concern expressed in this letter as an established fact.

I am asking you to ensure that the concerns capable of verification are independently investigated and that the results are made known. I am not asking you to presume that SSNIT or NPRA has acted unlawfully. I am asking you to establish, through independent evidence, whether their records, controls, decisions and practices meet the standards expected of institutions responsible for pension security. The distinction is important.

A forensic audit protects pensioners, but it also protects honest public servants and professionals by separating evidence from rumour and proven wrongdoing from administrative error. Ghana's pension system must be beyond suspicion wherever possible, and where suspicion arises, it must be addressed through transparent and credible investigation.

We cannot continue to ask retired workers to trust a system without giving them sufficient information to understand what happens to their contributions and entitlements. We cannot allow unclaimed benefits to remain an unresolved statistical question. We cannot allow outstanding Tier Two claims to become a permanent source of frustration. And we cannot assume that the existence of regulators and auditors automatically guarantees effective accountability.

I therefore respectfully appeal to the Public Accounts Committee to treat this request as a matter of national importance and initiate the appropriate process for a comprehensive, independent forensic audit of SSNIT and NPRA.

The money involved represents years of work, sacrifice and contributions by Ghanaian workers. Those workers deserve answers. Those who have retired deserve security. The families of deceased contributors deserve clarity about any entitlements to which they may be legally entitled. And the public deserves assurance that pension institutions are being managed with integrity, transparency and accountability.

The ultimate purpose of the pension system is not to enrich institutions or protect reputations. It is to secure the retirement of the people whose contributions sustain it. The PAC has an opportunity to help ensure that this purpose is fulfilled.

I trust that the Committee will give this appeal the serious consideration it deserves.

Yours faithfully,
Fuseini Abdulai Braimah
(+233208282575/+233550558008; [email protected])

Concerned Citizen and Pension Advocate
Ghana