NPRA Investment Guidelines and the Question of True Diversification in Ghana’s Pension System

 

By Delali Herman Agbo                  

 Some months ago, I wrote about the over-investment exposure of Ghana’s pension funds to Government of Ghana (GoG) assets. That discussion sparked important debate within the pensions and investment community. However, upon a deeper review of the National Pensions Regulatory Authority (NPRA) Investment Guidelines, it has become increasingly clear that the issue is not merely one of fund manager preference, but one embedded within the structure of the permissible asset allocation framework itself.

While the NPRA guidelines are well-intentioned and designed primarily to protect contributors through capital preservation, their current configuration has resulted in a pension system that is highly conservative and structurally concentrated around a single issuer that is the Government of Ghana.

Understanding the NPRA Investment Guidelines

Under the current NPRA investment guidelines, pension funds may be allocated as follows:

• Government of Ghana Bonds: maximum 75%
• Local Government and Agencies: up to 30%, with a 5% per issuer limit
• Corporate Bonds and Debt Instruments (including REITs, mortgage-backed securities, asset-backed securities, and debentures): 30%, with a 5% per issuer limit
• Money Market Instruments: 35%, with a 5% per issuer limit
• Ordinary Shares (Equities): 10%, with a 5% per issuer limit
• Open and Closed-End Funds: 5%, with a 2% per issuer limit

On the surface, this framework appears diversified. In practice, however, it tells a very different story.

The Reality Behind the Numbers

With the exception of ordinary shares and a portion of corporate bonds and debt instruments, almost every cedi contributed by pension workers finds its way directly or indirectly back to the Government of Ghana.

The 75% allocation to GoG bonds is explicit and straightforward. The 35% money market allocation, however, is more subtle. These funds are largely placed with commercial banks, which in turn invest heavily in Treasury bills and other government securities. Ironically, banks often issue fixed deposits to pension funds at rates lower than Treasury bill rates, allowing banks to earn risk-free margins while pension contributors bear opportunity costs.

Similarly, the 5% allocation to open and closed-end funds includes money market funds, fixed income funds, and balanced funds. Apart from equity funds, most of these collective investment schemes hold substantial exposure to government securities as underlying assets.

Even within corporate debt markets, limited depth means many instruments are priced off sovereign risk or carry implicit government exposure.

The outcome is a pension system where diversification exists more in form than in substance.

A Capital Preservation Framework with Structural Risks

There is no dispute that pension funds must prioritize safety. However, excessive conservatism creates its own risks, including:

• Concentration risk to a single issuer
• Lower long-term real returns
• Limited inflation protection
• Reduced support for private-sector growth
• Weak linkage between pension savings and productive economic activity

A pension system that preserves capital without growing it meaningfully over the long term fails contributors in real terms, especially in an inflationary environment.

Why Ghana Must Re-Assess Its Pension Asset Allocation

International pension systems guided by OECD and World Bank standards recognize that true diversification is achieved through issuer diversity, asset class balance, and economic relevance, not just compliance with percentage limits.

Globally, well-managed pension funds:

• Limit sovereign exposure to avoid fiscal concentration risk
• Use money market instruments primarily for liquidity, not returns
• Allocate meaningfully to equities and alternatives for long-term growth
• Support infrastructure, private credit, and real assets under strong governance frameworks

Recommendations Aligned with International Best Practice

To achieve real diversification while maintaining prudence, Ghana’s pension system could gradually transition toward an allocation framework such as:

• Government Bonds: 40%–50%
• Corporate Bonds & Private Debt: 25%–30%
• Equities (Local & Foreign): 20%–25%
• Alternative Investments (Infrastructure, REITs, Project Finance, Private Equity): 10%–15%
• Money Market (Liquidity Management): 10%–15%

 This approach:

• Reduces single-issuer risk
• Improves long-term real returns
• Enhances inflation protection
• Channels long-term capital into productive sectors
• Aligns pension assets with national development priorities

Conclusion: Beyond Compliance Toward Sustainable Retirement Security

The NPRA investment guidelines have provided stability and discipline to Ghana’s pension industry. However, the time has come to move beyond compliance and examine outcomes. True diversification requires continuous reassessment of asset classes, market development, and professional fund management.

At EcoCapital Investment Management Limited, we believe pension funds can achieve capital preservation, competitive returns, and genuine diversification simultaneously. Through disciplined portfolio construction, strong governance, and a deep understanding of both traditional and alternative assets, we remain committed to safeguarding contributors’ funds while supporting Ghana’s long-term economic development.

The future of retirement security in Ghana depends not only on how much we save but how wisely we invest these funds.