BY Nadia Ntiamoah
The Ghana Audit Service has formally rejected a Minerals Income Investment Fund (MIIF) request to restate its 2024 audited financial statements, underscoring tensions between the sovereign fund and oversight institutions over transparency and compliance with financial reporting standards.
In a letter dated 12 November 2025, Deputy Auditor-General Elizabeth Botchey addressed MIIF CEO Justina Nelson regarding the Fund’s 31 October 2025 request to review and amend the already-signed 2024 financial statements.
The request followed a meeting on 7 November 2025 where MIIF management raised concerns about alleged “material and pervasive misstatements” in the audit.
The Audit Service firmly maintained that the issues raised by MIIF did not constitute misstatements capable of misleading users.
“Describing the alleged misstatements as ‘pervasive’ is inherently misleading,” the letter stated, explaining that in audit terminology, “pervasive” refers to errors affecting the financial statements as a whole, not isolated transactions or line items.
Key Audit Disputes Clarified
The correspondence addressed specific areas of contention raised by MIIF management:
1. Agyapa Royalties Ltd Investment – The MIIF had argued that costs associated with establishing and listing the subsidiary on the London Stock Exchange should be expensed, potentially implying a write-off of public funds. The Audit Service, citing International Financial Reporting Standards (IFRS 10) and IAS 27, and legal requirements under Section 53 of the PFM Act, 2016 (Act 921), agreed with MIIF’s treatment of these costs as an investment, noting that any changes would require Ministerial or Attorney General approval.
2. Gold Trade Investment – Despite concerns over trading suspensions, auditors found no evidence that investments in gold were irrecoverable. An emphasis-of-matter paragraph was included in the audit to note the trading suspension without indicating financial impairment.
3. Budget vs. Actuals – The Audit Service recognized a board resolution from 31 October 2024 approving revised budgets, which explained minor deviations between actual expenditures and projected figures.
4. Dividends Receivable – The legally mandated 10% dividend was not impaired, as it could only be modified through parliamentary provision.
5. Exchange Gains – Gains were accounted for consistently with prior years, as reflected in MIIF’s 2024 Trial Balance, and could only be changed via formal accounting policy adjustments.
Audit Service Reaffirms Independence
The letter emphasized that the Board of MIIF is responsible for preparing and presenting fair financial statements in accordance with IFRS and relevant laws.
The auditors’ role is to provide reasonable assurance that the statements are free from material misstatement due to fraud or error—a standard that does not guarantee detection of every possible discrepancy.
“It is therefore improper to present the alleged misstatements as if the auditors prepared the 2024 financial statements,” the Audit Service noted.
The office reaffirmed its opinion in the original 2024 audit report and underscored its willingness to collaborate on decisions impacting the 2025 financial year, but refused to alter the 2024 audit.
Context
The 2024 MIIF audit has been at the center of a prolonged transparency dispute. MIIF’s new leadership, under CEO Justina Nelson, had repeatedly questioned the 2024 audit and attempted to pressure the Audit Service into restating the report—months after the Auditor-General had signed it.
These actions followed Right to Information requests by former MIIF board members and public scrutiny over the Fund’s financial operations, including investments in Agyapa Royalties Ltd and gold trading initiatives.
Observers note that the Audit Service’s refusal highlights the independence of statutory oversight institutions and the importance of protecting public accountability.
Analysts warn that repeated attempts to alter audited financial statements could undermine investor confidence and public trust in the sovereign wealth management.
The Auditor-General’s response serves as a decisive rebuke to MIIF’s leadership, reaffirming that signed audits cannot be arbitrarily amended and that statutory financial disclosures must be respected. With MIIF under increasing public scrutiny for transparency and governance, the resolution of this dispute may set a precedent for how Ghanaian state-owned institutions handle audit challenges in the future.
