Committee on the Protection of the Rights of All Migrant Workers and Members of Their Families
Concluding observations on the second periodic report of Ghana *
1.The Committee considered the second periodic report of Ghana at its 633rd and 635th meetings, held on 2 and 3 June 2026. At its 649th meeting, held on 12 June 2026, it adopted the present concluding observations.
A.Introduction
2.The Committee welcomes the submission of the second periodic report of the State Party, which was prepared in response to the list of issues prior to reporting, and the additional information provided by the high-level delegation, which was headed by the Minister of Labour, Jobs and Employment, and was comprised of representatives of the Office of the Attorney-General and Ministry of Justice, the Bank of Ghana and the Ministry of Labour, Jobs and Employment, as well as the Permanent Representative of Ghana and officials of the Permanent Mission of Ghana to the United Nations Office at Geneva.
3.The Committee appreciates the dialogue held with the delegation, the information provided by the State Party’s representatives and the constructive approach to the meetings, which allowed for collaborative analysis and reflection. The Committee is also grateful to the State Party for its replies and the additional information it submitted within 24 hours of the dialogue.
4.The Committee recognizes that Ghana has made progress in protecting all the rights of migrant workers and members of their families. It notes, however, that as a country of origin, transit, destination and return, the State Party faces a number of challenges in protecting these rights.
B.Positive aspects
5.The Committee notes with appreciation the ratification of or accession to the following instruments:
(a)The Work in Fishing Convention, 2007 (No. 188) of the International Labour Organization (ILO), on 28 August 2024;
(b)The Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, on 23 September 2016;
(c)The Optional Protocol to the Convention on the Rights of the Child on the involvement of children in armed conflict, on 9 December 2014.
6.The Committee also welcomes the adoption of the following institutional and policy measures:
(a)The Ghana Accelerated Action Plan against Child Labour (2023–2027);
(b)The Diaspora Engagement Policy (2023);
(c)The National Plan of Action for the Elimination of Human Trafficking in Ghana (2022–2026);
(d)The National Plan of Action for the Elimination of the Worst Forms of Child Labour in Ghana (2022–2026);
(e)The National Labour Migration Policy (2020–2024);
(f)The Labour (Domestic Workers) Regulations (2020);
(g)The National Migration Policy for Ghana (2016).
Legislative measures
7.The Committee views as positive that the State Party voted in favour of the Global Compact for Safe, Orderly and Regular Migration, adopted by the General Assembly in its resolution 73/195. It also notes as positive the State Party’s decision to serve as a Global Compact Champion country. The Committee recommends that the State Party continue to make efforts to implement the Global Compact within the framework of its international obligations contained in the Convention and other international human rights instruments.
C.Principal subjects of concern and recommendations
1.General measures of implementation (arts. 73 and 84)
Legislation and application
8.The Committee notes the existence of various legislative and policy measures governing migration, including the Immigration Act 2000 (Act 573), labour laws and sectoral regulations, as well as national migration policies. It is, however, concerned that the State Party does not yet have a comprehensive and rights-based legislative framework that fully incorporates all provisions of the Convention. The Committee notes in particular that the existing legal framework remains fragmented across multiple instruments, with the primary migration legislation focusing largely on entry, residence and control of foreign nationals, rather than on the full range of rights of migrant workers and members of their families. It is further concerned that important policy commitments have not been systematically translated into binding legislative provisions, and that gaps persist in key areas, including labour migration governance, recruitment regulation and data collection, thereby limiting effective protection of the rights enshrined in the Convention.
9. The Committee recommends that the State Party :
(a) Adopt a comprehensive national migration law to fully incorporate the rights set out in the Convention into domestic legislation and establish clear obligations, implementation measures and accountability mechanisms;
(b) Review and harmonize existing laws, including immigration, labour and anti-trafficking legislation, to ensure coherence and full alignment with the Convention;
(c) Establish a legally grounded, coordinated framework for migration governance, including clear institutional mandates and responsibilities to ensure effective implementation of the Convention.
Articles 76 and 77
10.The Committee notes that the State Party has not yet made the declarations provided for under articles 76 and 77 of the Convention recognizing the competence of the Committee to receive and consider communications from States Parties and individuals.
11. Reiterating its previous recommendations, the Committee recommends that the State Party make the declarations provided for under articles 76 and 77 of the Convention.
Ratification of relevant instruments
12. The Committee welcomes the State Party ’ s ratification of eight of the ten ILO fundamental conventions and invites it to consider ratifying the remaining conventions: the Occupational Safety and Health Convention, 1981 (No. 155) and the Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187). It further recommends that the State Party give consideration to ratifying the Migration for Employment Convention (Revised), 1949 (No. 97); the Domestic Workers Convention, 2011 (No. 189); the Employment Policy Convention, 1964 (No. 122); the Migrant Workers (Supplementary Provisions) Convention, 1975 (No. 143); and the Private Employment Agencies Convention, 1997 (No. 181).
Comprehensive policy and strategy
13.The Committee notes with appreciation the adoption of the National Migration Policy for Ghana (2016), the National Labour Migration Policy (2020–2024) and the Labour (Domestic Workers) Regulations (2020). However, it remains concerned that the State Party has yet to adopt a comprehensive policy encompassing all the rights protected under the Convention.It further notes with concern that many policy documents contain broad commitments that are not translated into concrete actions and programmes, lack clear timelines, and are not supported by systematic monitoring and evaluation mechanisms. The Committee also observes that these policies have not been allocated sufficient funding to ensure their effective implementation.
14. The Committee recommends that the State Party adopt a comprehensive migration policy covering all aspects of the Convention, ensuring that it is gender ‑ responsive, child-sensitive, and grounded in a human rights-based approach. Such a policy should be supported by concrete measures, including clear timelines, indicators, and robust monitoring and evaluation frameworks, and be allocate d adequate human, technical and financial resources to ensure its effective implementation.
Coordination
15.The Committee notes with appreciation the establishment of the National Coordination Mechanism on Migration in 2023 as a platform to enhance coordination among government stakeholders across ministries and institutions. However, it remains concerned about the delay in establishing the National Commission on Migration, as envisaged in the National Migration Policy (2016), which has contributed to fragmented institutional and structural coordination in migration-related matters, with various ministries, departments and agencies continuing to implement their respective mandates without a coherent, unified approach.
16.The Committee further notes with concern the limited technical, human and financial resources available to the Mechanism and the relevant institutions to effectively discharge their mandates.
17. With reference to its previous recommendations, the Committee recommends that the State Party establish a permanent, high-level interministerial body with a comprehensive mandate covering all migration-related issues and vested with authority to coordinate activities for the effective implementation of the Convention, ensuring that it is provided with adequate human, technical and financial resources for its sustainable operation. It further recommends that the State Party develop and implement clear time frames, indicators and monitoring and evaluation benchmarks for the implementation of the Convention, and include in its next periodic report detailed, statistics-based information on progress achieved.
Data collection
18.The Committee notes the measures taken by the State Party to improve migration data collection and management, including efforts to develop a labour migration database system that harmonizes data across various government institutions.However, the Committee remains concerned about significant gaps in migration data collection and management, including on labour recruitment processes and on the employment sectors of migrant workers. It further notes with concern the fragmentation of information management platforms and the limited interoperability among existing databases, which, together with inconsistent inter‑agency coordination, undermines effective migration governance. The Committee also highlights the limited involvement of consular services in collecting data on nationals abroad and the insufficient human, technical and financial resources allocated to data-related functions.
19. The Committee recommends that the State Party :
(a) Establish a comprehensive, coordinated and centralized system for the collection and management of migration data, covering all aspects of the Convention, and aligned with relevant regional frameworks, including those of the Economic Community of West African States (ECOWAS);
(b) Ensure the systematic collection of reliable and disaggregated data on migrant workers and members of their families, including by sex, age, nationality, migration status, type of work performed, recruitment channel, disability and other relevant characteristics, in order to formulate and effectively implement human rights ‑ based policies;
(c) Strengthen coordination, interoperability and data-sharing among all relevant institutions, including through harmonized data collection methodologies, integrated databases and clear mechanisms for information - exchange and reporting;
(d) Enhance institutional capacity by providing adequate human, technical and financial resources, promoting the digitization of data systems, and establishing clear protocols for data management, analysis and use;
(e) Involve consular services in the systematic collection of data concerning nationals abroad, including on labour disputes, protection needs and requests for repatriation;
(f) Improve the use of migration data in policymaking, including through the development of indicators and benchmarks to monitor progress and assess the impact of policies and programmes.
Independent monitoring
20.The Committee welcomes the reaccreditation of the Commission on Human Rights and Administrative Justice with “A” status in 2025 by the Global Alliance of National Human Rights Institutions, in accordance with the principles relating to the status of national institutions for the promotion and protection of human rights (the Paris Principles). However, it notes with concern that eligibility for appointment as Commissioner or Deputy Commissioner is limited to lawyers, which may unduly restrict the pluralism of the Commission, as observed by the Global Alliance. It further notes that these positions are appointed by the President through a process not clearly prescribed in law. In addition, the Committee notes with concern the lack of gender sensitivity in the composition of the Commission.
21.The Committee notes the mandate of the Commission on Human Rights and Administrative Justice to investigate human rights violations, and the establishment of a Migration Desk in 2023 to handle migrant-related complaints and provide information on available remedies. Nevertheless, it is concerned that the Commission’s work remains largely reactive, being limited to the handling of complaints rather than including proactive investigations. It also notes the limited human, technical and financial resources available to the Commission, as well as the lack of available information on the number and nature of the cases addressed by the Migration Desk.
22.The Committee further notes that the Commission on Human Rights and Administrative Justice has been designated as the State Party’s national preventive mechanism in accordance with the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment. While noting that the Commission has already conducted visits to places of detention, the Committee remains concerned that its mandate to carry out unannounced visits is not yet explicitly enshrined in law.
23.The Committee also expresses concern that national legislation does not establish a clear process for allocation of the Commission’s budget. It notes that, in practice, the Commission prepares its budget on the basis of a ceiling set by the Ministry of Finance.
24. The Committee recommends that the State Party :
(a) Review the procedures for appointing Commissioners of the Commission on Human Rights and Administrative Justice to ensure they are fair, transparent and inclusive, and expedite amendments to national legislation to establish a participatory, merit-based selection and appointment process, as recommended by the Constitution Review Commission , while taking measures to ensure gender balance in the Commission ’ s composition;
(b) Strengthen the mandate of the Commission on Human Rights and Administrative Justice by enabling it to conduct investigations on its own initiative, in addition to handling individual complaints, and enhance its enforcement powers in its interaction with courts;
(c) Ensure the systematic collection and publication of disaggregated data on complaints, including migration-related cases;
(d) Expedite amendments to the Commission on Human Rights and Administrative Justice Act 1993 (Act 456) to explicitly empower the Commission with unrestricted access and the authority to conduct unannounced visits to places of detention;
(e) Guarantee the Commission ’ s financial autonomy, including in law, and ensure that the process for allocating the Commission ’ s budget is not constrained by ceilings set by the Ministry of Finance.
Training and dissemination of information on the Convention
25.The Committee notes that the State Party has implemented training programmes for officials providing services to migrant workers and members of their families, including the Immigration Service, the Ministry of Foreign Affairs, the Labour Department, law enforcement authorities and security forces. However, it remains concerned about gaps in the scope and targeting of these programmes, as well as the absence of systematic and comprehensive efforts to ensure that the Convention is widely known among all stakeholders involved in migration governance. The Committee is also concerned about the limited outreach to migrant workers and members of their families, and that many remain unaware of their rights under the Convention.
26. The Committee recommends that the State Party ensure that training programmes for all relevant officials comprehensively cover the rights enshrined in the Convention and are implemented in a systematic manner, while also developing and implementing targeted awareness-raising and training initiatives for all stakeholders engaged in migration-related fields. It further calls for strengthened cooperation with media and civil society organizations to promote and disseminate information on the Convention both within the State Party and in destination countries. In addition, the Committee recommends that all necessary measures be taken to ensure that migrant workers and members of their families have access to information and guidance on their rights under the Convention, in languages commonly used in the State Party and without discrimination, including through pre-employment and pre-departure orientation programmes addressing conditions of admission and employment, and the corresponding rights and obligations.
Participation of civil society
27.The Committee welcomes the report of the Commission on Human Rights and Administrative Justice and notes with appreciation that the Government engaged in dialogue with civil society organizations during its preparation. It further notes that, through the national mechanism for reporting and follow-up, civil society representatives were able to contribute to the drafting of the State Party’s second periodic report.
28. The Committee recommends that the State Party enhance its support to civil society organizations working on issues affecting migrant workers and members of their families, including by providing them with the necessary tools and resources to contribute effectively to the preparation and review of State reports and to submit alternative reports independently and without fear of reprisals. It also recommends strengthening dialogue with civil society organizations and ensuring their meaningful participation in migration governance, while guaranteeing their freedom of action and protection in the implementation of the Convention.
2.General principles (arts. 7 and 83)
Non-discrimination
29.The Committee is concerned that certain vulnerable groups, including lesbian, gay, bisexual, transgender and intersex persons, persons deprived of liberty, and stateless or unregistered individuals, do not enjoy equal protection of their rights. It further notes with concern the persistence of discrimination against migrant women and girls across various sectors, particularly in the labour market, where they are exposed to violence and exploitation. In addition, the Committee is concerned about allegations of discriminatory treatment affecting migrant workers, especially those in irregular situations or in transit.
30.The Committee also notes with concern that environmental and climate-related changes, including floods, droughts and heatwaves, are significant drivers of migration. While acknowledging the broad objectives set out in the National Migration Policy and the National Climate Change Policy, it notes that specific, concrete measures to address the human rights impacts of these phenomena on migrant workers and members of their families affected by environmental issues remain limited and discriminatory.
31. The Committee, in accordance with its general comment No. 7 and No. 8 (2026) issued jointly with the Committee on the Elimination of Racial Discrimination, recommends that the State Party amend its legal framework to ensure equal protection of all persons, and take all necessary measures to guarantee that migrant workers and members of their families, irrespective of their migration status, enjoy the rights recognized in the Convention without discrimination in law and in practice. It further recommends adopting and effectively implementing measures to eliminate discrimination against migrant women and girls, including by ensuring their inclusion in gender-related policies, providing targeted training to officials, and guaranteeing access to justice, remedies and services in areas such as health, employment and education.
32. The Committee remains concerned about climate change that affects the planet as a whole and recommends that the State Party integrate a human rights-based approach into its climate change, disaster risk reduction, preparedness, adaptation and mitigation policies to ensure the protection of migrants. It also encourages the development of targeted strategies on environmental drivers of migration, including risk monitoring as well as adequate, shock-responsive social protection measures supported by dedicated resources.
Right to an effective remedy
33.The Committee notes the information provided by the State Party regarding the existence of various complaint and redress mechanisms available to migrant workers, including the Commission on Human Rights and Administrative Justice, the National Labour Commission, the Labour Court and the Labour Division of the High Court. However, it remains concerned about the lack of information on migrant-related complaints examined in recent years, including their outcomes and the remedies provided.
34.The Committee further notes that migrant workers face multiple barriers to accessing justice, including limited awareness of available remedies, limited access to support services, language barriers and insufficient consular assistance. These challenges are compounded by procedural constraints, administrative delays and weak enforcement of decisions, which collectively hinder access to effective remedies. The situation is further compounded by fragmented institutional mandates and weak coordination, with different government agencies handling complaints depending on the nature of the alleged violation.
35.The Committee also notes that women migrant workers, especially those engaged in domestic work, face heightened gender-specific barriers, including social stigma, restricted freedom of movement and an increased risk of exploitation and abuse, further limiting their access to complaint mechanisms and judicial redress.
36. The Committee recommends that the State Party :
(a) Take comprehensive measures to ensure effective access to justice and accountability for migrant workers and members of their families, including by improving access to information, legal assistance, interpretation services and affordable procedures through the Legal Aid Commission, and by addressing specific barriers faced by migrants in irregular situations, including by strengthening consular support;
(b) Develop a coherent and coordinated system for handling labour migration-related complaints across all stages of migration, including by strengthening the capacity to respond effectively to grievances arising during employment abroad, and streamline institutional mandates through clear referral mechanisms and well ‑ defined responsibilities;
(c) Ensure that complaint mechanisms are gender- and child-sensitive and accessible to all migrant workers and members of their families;
(d) Systematically collect and publish data on complaints and outcomes, disaggregated by sex, age, nationality, sector of employment and migration status, and include such information in its next periodic report.
3.Human rights of all migrant workers and members of their families (arts. 8–35)
Labour exploitation and other forms of ill-treatment
37.The Committee notes the existence of a legal and regulatory framework governing private employment agencies, including the requirement under the Labour Act 2003 (Act 651) and the Labour Regulations 2007 for all private employment agencies to be registered with the Registrar General’s Department and licensed by the Labour Department. However, it remains concerned about significant gaps in implementation, as informal recruitment practices remain widespread, particularly in relation to employment abroad, and operate largely outside effective State oversight. In particular, the Committee notes that the framework does not extend to informal recruiters and intermediaries, whose activities often contribute to deceptive and exploitative practices, including misleading information, excessive fees, and contract substitution or absence of written contracts, and increased exposure to exploitation and abuse, including risks of forced labour in destination countries, especially for women domestic workers.
38.The Committee is further concerned about barriers to compliance with the regulations, including complex registration procedures and high costs, which discourage formalization and contribute to the proliferation of unregistered agencies. It also notes weak monitoring and enforcement capacity of the labour inspectors, insufficient inter-agency coordination, and constrained institutional capacity within the Labour Department. The absence of a statutory ceiling on recruitment fees and the lack of disaggregated data on labour exploitation further aggravate these concerns. The Committee regrets that the State Party did not provide statistics on labour exploitation disaggregated by migration status.
39. The Committee recommends that the State Party :
(a) Strengthen the legal and regulatory framework governing recruitment, including by finalizing the review of the Labour Act 2003 (Act 651) and establishing clear limits on recruitment fees;
(b) Enhance enforcement and oversight by increasing the number and capacity of labour inspectors, strengthening sanctions for non-compliance, and ensuring regular monitoring and reporting by recruitment agencies – in line with recommendations from the ILO Committee of Experts on the Application of Conventions and Recommendations;
(c) Facilitate formalization by simplifying registration procedures and enabling informal recruiters to regularize their activities;
(d) Strengthen coordination among relevant institutions, including through joint inspections and information-sharing mechanisms;
(e) Enhance the protection of migrant workers by ensuring the use of written contracts, combating deceptive recruitment practices, providing targeted awareness-raising on the risks of migration for work, and holding recruitment agencies accountable for abuses, including ensuring the safe return of affected workers where necessary;
(f) Systematically collect and publish data on labour exploitation and recruitment practices, disaggregated by migration status and other relevant factors, and include such information in its next periodic report;
(g) Prioritize the conclusion of bilateral agreements with countries hosting Ghanaian migrant workers to safeguard their rights under the Convention.
40.The Committee expresses concern about reports that certain faith-based organizations identify and connect young persons with informal recruitment intermediaries, at times encouraging migration for work abroad with the expectation that remittances will support religious communities. Such practices may increase the risk of migrant workers being exposed to abuse and exploitation.
41. The Committee recommends that the State Party strengthen the monitoring and oversight of non-State actors, including faith-based institutions, to ensure that they do not facilitate or encourage migration through informal recruitment channels, and to prevent situations that may expose individuals to violations of their rights under the Convention.
Due process, detention and equality before the courts
42.The Committee regrets the lack of data on the number of detained migrant workers and members of their families. It is further concerned about reports of overcrowding and inadequate detention conditions, as well as prolonged pretrial detention, limited access to legal aid and weak procedural safeguards. It notes with particular concern that many migrants detained for immigration-related offences are held in ordinary police cells alongside criminal detainees.
43. In light of the Committee ’ s general comment No. 5 (2021), the Committee recalls that administrative detention should only be used as a measure of last resort, and recommends that the State Party :
(a) Systematically collect and publish disaggregated data on detained migrant workers and members of their families;
(b) Improve detention conditions and reduce overcrowding, including by expanding the use of non-custodial measures, and ensure the separation of migrant detainees from criminal detainees;
(c) Strengthen procedural safeguards, including timely judicial review and effective access to legal assistance;
(d) Ensure that the irregular entry, stay and work of migrants is not considered a criminal offence and that any administrative sanctions applied to irregular entry are proportionate and reasonable, taking into account all circumstance s of entrance, in particular in the event of death, divorce or spousal separation from a migrant worker with a regular status in line with the provisions of the Convention.
44.The Committee notes the existence of several legal instruments governing the treatment of non-citizens, including the Immigration Act 2000 (Act 573), the Refugee Law 1992, the ECOWAS Protocol relating to Free Movement of Persons, Residence and Establishment, and relevant constitutional provisions. The Committee is concerned, however, about the absence of time limits for immigration detention and the lack of specific safeguards for migrants. It is further concerned that the Refugee Law 1992 permits detention or expulsion on grounds of national security or public order without adequate procedural guarantees.
45.The Committee is also concerned about reports of deportations of children, about the absence of explicit legal safeguards prohibiting the immigration detention of children, and about the limited access of migrant children, particularly those in an irregular situation, to protection and essential services. The Committee is further concerned about gaps in identification and referral mechanisms for migrant children, as well as tensions between host communities and asylum-seeking and refugee populations regarding access to services.
46.While noting that domestic legislation incorporates the principle of non-refoulement and allows applications for refugee status irrespective of the manner of entry, the Committee remains concerned about its effective implementation, including the lack of systematic protection risk assessments prior to removal and insufficient access to asylum and protection procedures, particularly in cases involving possible chain refoulement.
47. The Committee recommends that the State Party :
(a) Review and amend the Immigration Act 2000 (Act 573) to introduce safeguards for immigration detention, including time limits, judicial oversight and alternatives to detention, and to explicitly prohibit the immigration detention of children and families with children, while establishing clear procedures for identification, registration, referral and guardianship of all migrant children, regardless of their status;
(b) Strengthen procedural guarantees under the Refugee Law 1992, ensuring that detention or expulsion is subject to due process and judicial review;
(c) Ensure effective implementation of the principle of non-refoulement, including through individual protection risk assessments prior to removal and access to asylum procedures, as well as by enhancing coordination among relevant authorities and providing training to officials on international protection obligations;
(d) Promote social cohesion in border communities, including by addressing disparities in access to services and strengthening dialogue and cooperation between host communities and asylum-seeking and refugee populations.
Expulsion
48.The Committee is concerned about the lack of information regarding the number of expulsions carried out and the procedures applied. It is also concerned about the State Party’s agreement with the United States of America to accept deported third-country nationals, who, upon arrival, have reportedly been held in airport holding facilities and under armed guard in military camps, before being deported to countries where they may face persecution. The Committee is concerned that the reception, detention and onward transfer of these individuals may have exposed them to direct, indirect or chain refoulement, contrary to section 1 of the Refugee Law 1992. The Committee is also concerned about the absence of information on measures taken to prevent possible refoulement, as well as the lack of data on the number of persons received and the conditions of their detention. In addition, the Committee notes with concern that the agreement has not been made public by the Government.
49. The Committee recommends that the State Party systematically collect and publish disaggregated data on expulsions carried out and the number of persons received, as well as on the reception, detention conditions and onward transfer of deported third-country nationals. The Committee calls on the State Party to take all necessary measures to ensure that the principle of non-refoulement is upheld effectively in practice. In addition, the Committee recommends that the State Party ensure transparency by publicly disclosing all agreements relating to the deportation of third ‑ country nationals, including any arrangements with the United States. It also invites the State Party to evaluate the impact of this agreement on the protection of the rights of migrant workers and members of their families.
Consular assistance
50.The Committee notes the efforts of the Government in training consular officers in handling migration-related issues. However, the Committee also remains concerned about the limited resources and capacity of consulates to effectively provide protection and assistance, particularly in countries where the State Party does not maintain diplomatic representation. The Committee also observes that diaspora desk officers within diplomatic missions often lack sufficient capacity to adequately engage with and respond to the needs of the diaspora, including due to competing responsibilities. It further notes with concern the low levels of registration of migrant workers with consulates, especially among those in an irregular situation, which further constrains the delivery of consular support.
51. The Committee recommends that the State Party :
(a) Strengthen consular outreach and support to migrant workers, including by establishing accessible and flexible registration systems, such as online platforms, to better reach migrants regardless of their status;
(b) Enhance the human, technical and financial capacity of diplomatic missions, including consulates, to provide effective protection and assistance to migrant workers abroad;
(c) Institutionalize regular capacity-building programmes for diaspora desk officers and relevant consular staff, in cooperation with relevant stakeholders, to increase their ability to respond to the needs of migrant workers and diaspora communities.
Remuneration and conditions of work
52.The Committee notes that, although the legal framework of Ghana provides for the equal treatment of migrant workers in employment, it does not fully and explicitly guarantee the principle of equal remuneration for men and women for work of equal value. The Committee also stresses that the current legal framework does not adequately address hostile work environment situations, including those related to sexual harassment.
53. The Committee recommends that the State Party :
(a) Amend sections 10 (b) and 68 of the Labour Act 2003 (Act 651) to give full legislative expression to the principle of equal remuneration for men and women for work of equal value and ensure its effective implementation in practice;
(b) Improve data collection and enforcement, including by providing sex-disaggregated data on employment and wages, addressing occupational segregation and adopting measures to reduce the gender wage gap;
(c) Strengthen the accessibility of complaint mechanisms to ensure that women, including migrant women, irrespective of migration status, can report violations such as sexual harassment and can access remedies, including compensation, without fear of reprisals or expulsion;
(d) Expand the definition of sexual harassment in the Labour Act 2003 to include hostile work environment situations .
Social security
54.The Committee notes with concern that budget allocations for social protection in Ghana remain below the average for lower- and middle-income countries and may not be fully adequate to meet national coverage targets set out in relevant policy frameworks, including the National Social Protection Policy and the National Medium-Term Development Policy Framework 2022–2025, as well as global commitments such as target 1.3 of the Sustainable Development Goals. It further notes that migrant workers, particularly migrant women concentrated in the informal sector, have limited access to social protection systems.
55. The Committee recommends that the State Party :
(a) Increase budget allocations for social protection in line with national and international commitments, including by progressively expanding the coverage and adequacy of benefits;
(b) Ensure that migrant workers and members of their families, especially women in the informal sector, regardless of migration status, have effective access to social protection schemes;
(c) Allocate adequate human, technical and financial resources for the effective implementation of the Social Protection Act 2025, in order to strengthen safety nets at the community level and improve service delivery to migrant workers and members of their families.
Medical care
56.The Committee is concerned about gaps in access to essential services for migrants, including their low participation in the national health insurance scheme. It is further concerned about persistent challenges in access to maternal health services, including preventable maternal mortality linked to unsafe abortions, which indicates barriers in access to safe, affordable and regulated reproductive health services.
57. The Committee recommends that the State Party :
(a) Ensure the effective inclusion of migrants in the national health system, including by integrating them into the national health insurance scheme and conducting targeted awareness-raising campaigns;
(b) Strengthen efforts to reduce maternal mortality, including by reviewing and aligning laws, policies and practices related to the voluntary interruption of pregnancy with human rights standards, in order to prevent unsafe abortions and ensure access to safe, affordable and quality reproductive health services for migrant workers and members of their families.
Birth registration
58.The Committee is concerned about capacity constraints in civil registration and identity management systems, which limit access to identity documentation and increase the risk of document fraud. While noting that birth registration is compulsory under the Registration of Births and Deaths Act 2020, that children of refugees, asylum-seekers and migrants are registered in camps, and that registration is free for children under 1 year of age, the Committee remains concerned about the limited staffing and infrastructure of the Births and Deaths Registry, particularly in rural and remote areas. It also notes with concern the limited coordination among relevant institutions, which affects the timeliness and completeness of registration.
59. The Committee recommends that the State Party :
(a) Strengthen civil registration systems by allocating adequate human, technical and financial resources and expanding services to rural and hard-to-reach areas, including through mobile and digital registration mechanisms;
(b) Improve coordination and interoperability between the health system and civil registration authorities to ensure the registration of children at birth;
(c) Ensure universal and accessible birth registration by extending free registration and removing barriers to late registration;
(d) Facilitate access to identity documentation for all children, including migrant, asylum-seeking and refugee children, regardless of place of birth or migration status;
(e) Enhance awareness-raising and outreach efforts on birth registration, particularly in underserved and remote communities.
Education
60.The Committee notes with appreciation that the Free Compulsory Universal Basic Education Programme is being implemented in schools in refugee camps, providing free education from kindergarten to junior high school, and that the Free Senior High School Policy, of 2017, provides access to free enrolment in secondary education.
61. The Committee recommends that the State Party ensure the full inclusion of migrant children in national education policies and programmes , on an equal basis with nationals. It further recommends strengthening measures to remove practical and administrative barriers to school enrolment, attendance and completion, and to enhance support services, including language assistance, documentation processes and social integration measures. The Committee also recommends addressing indirect costs – such as of school uniforms – which may contribute to school dropout among migrant children, in order to facilitate equitable access to quality education .
4.Other rights of migrant workers and members of their families who are documented or in a regular situation (arts. 36–56)
Pre-departure programmes and the right to be informed
62.The Committee takes note of awareness-raising efforts, including compulsory pre-departure orientation programmes for migrant workers undertaken by the Labour Migration Unit of the Labour Department. However, it remains concerned that the content of such programmes reportedly focuses more on workplace expectations and contractual obligations than on workers’ rights and available remedies.
63. The Committee recommends that the State Party strengthen pre-departure orientation programmes to ensure that they comprehensively address the rights of migrant workers, including available remedies and mechanisms to respond to exploitation and abuse abroad.
Right to form trade unions
64.The Committee notes the information provided by the State delegation indicating that national legislation does not prevent migrant workers from forming trade unions and that most are represented through existing sectoral and national trade unions. However, the Committee notes with concern the lack of information on the extent to which migrant workers and members of their families enjoy the right to form and join trade unions in practice.
65. The Committee recommends that the State Party collect and provide detailed information on this matter in its next periodic report.
Right to vote and to be elected in the State of origin
66.The Committee is concerned that Ghanaian nationals residing abroad are not able to effectively exercise their right to vote, despite the recognition of this right under the Representation of the People (Amendment) Act 2006 (Act 699).
67. The Committee recommends that the State Party take all necessary measures to implement the relevant legislation to ensure that Ghanaian emigrants are able to effectively exercise their right to participate in public and political life, including the right to vote from abroad.
Right to transfer earnings and savings
68.The Committee notes the State Party’s commitment to develop a national remittance strategy but remains concerned that transaction fees for remittances remain high. It notes that existing regulatory restrictions limit access to affordable and formal remittance channels, particularly for intra-African transfers, thereby reducing the development potential of remittances, especially for migrant workers and their families in rural areas.
69. The Committee recommends that the State Party :
(a) Strengthen the regulatory framework for remittances, including by promoting greater competition and enabling the participation of non-bank financial service providers;
(b) Reduce remittance transaction costs by addressing regulatory and infrastructural barriers and expanding access to affordable financial services, particularly in rural and underserved areas;
(c) Facilitate safe, accessible and affordable remittance flows, including through the promotion of mobile and digital transfer systems and regional transfer mechanisms.
Work permits and residency
70.The Committee regrets the lack of information on the number of work permits issued to migrant workers, as well as on measures taken by the State Party in the event of loss of employment by migrant workers before the expiry of their work permit.
71. The Committee recommends that the State Party collect information on the number of work permits issued to migrant workers. It also recommends that, for migrant workers who lose their job before the expiry of their work permit, the State Party grant them a residence permit for a sufficient period of time so that they do not find themselves in an irregular situation and are able to find alternative employment or to challenge their dismissal before the courts, while at the same time being entitled to unemployment benefits in accordance with article 49 of the Convention, and refrain from expelling them.
5.Provisions applicable to particular categories of migrant workers and members of their families (arts. 57–63)
72.The Committee notes with concern that there is no legislation or policy governing the stay or work of frontier, seasonal and itinerant workers.
73. The Committee invites the State Party to provide information on measures taken to ensure that frontier, seasonal and itinerant workers enjoy treatment equal to that enjoyed by national workers, in particular with respect to remuneration and conditions of work, and to ensure systematic monitoring by the relevant authorities of employers ’ compliance with relevant international labour standards.
6.Promotion of sound, equitable, humane and lawful conditions in connection with the international migration of workers and members of their families (arts. 64–71)
Children in situations of international migration
74.The Committee notes the adoption of the Ghana Accelerated Action Plan against Child Labour (2023–2027) and the Strategic Plan for Street-Connected Children and Young Persons (2024–2028), as well as the development of the protocols and guidelines for establishing child labour-free zones. The Committee also notes that the Government is reviewing the Hazardous Child Labour Activity Framework, which is currently before Parliament for approval. However, the Committee also notes with concern the high risk of violence, abuse and exploitation of children in the State Party, particularly in fishing, mining and agriculture, as well as the risk of engaging in unsafe migration. The Committee remains concerned about the increasing prevalence of child labour, including in hazardous conditions, with every fourth child aged between 5 and 17 engaged in paid work. In addition, the Committee expresses concern about reports of sexual exploitation of children, including commercial sexual exploitation, and notes the fragmented nature of existing sectoral policies, in the absence of a comprehensive, adequately resourced national policy on children’s rights, as well as the lack of reliable data and adequate funding, which hinders effective implementation and monitoring.
75.In line with joint general comments No. 3 and No. 4 (2017) of the Committee on the Protection of the Rights of All Migrant Workers and Members of Their Families and No. 22 and No. 23 (2017) of the Committee on the Rights of the Child, the Committee recalls its previous recommendation and recommends that the State Party :
(a) Strengthen the legal and policy framework by revising the Children ’ s Act 1993 and related legislation to comprehensively prohibit child labour, including setting forth a detailed list of hazardous activities, and ensure the effective implementation of existing laws, particularly in high-risk sectors such as mining;
(b) Enhance enforcement and accountability by allocating adequate resources, strengthening labour inspections, systematically investigating violations, prosecuting perpetrators , and ensuring that child victims receive protection, assistance, rehabilitation and compensation;
(c) Address the root causes of child labour, abuse and unsafe migration , by tackling socioeconomic vulnerabilities, strengthening multisectoral social services and intensifying awareness-raising efforts to combat harmful practices;
(d) Improve data collection through the Social Welfare Information Management System and evidence-based policymaking , by establishing reliable, disaggregated data systems, and use such data to design targeted protection and reintegration measures, including through the application of the Compendium of Statistics on Child Labour in Ghana (2025);
(e) Address the risks faced by children in the context of migration, including by developing targeted protection, prevention and awareness-raising measures for children migrating to and from the State Party , particularly those in vulnerable situations.
International cooperation with countries of transit and destination
76.The Committee notes with concern that, following the State Party’s ban on labour migration to Gulf countries in 2017 in response to reported abuses of migrant workers, migration channels have increasingly shifted towards informal pathways. It is concerned that migrants are resorting to informal recruitment agencies that are not monitored effectively due to limited capacity and resources within the Labour Department of the Ministry of Labour, Jobs and Employment. While noting that the ban was intended to facilitate the development of formal arrangements, including bilateral labour agreements, the Committee remains concerned that, in practice, migrants continue to face heightened risks of physical and emotional abuse, exploitation, deceptive or insecure contracts, extortion and debt bondage. The Committee is particularly concerned about gender-specific violations, as women migrant workers may be subjected to discriminatory and degrading practices, including invasive and arbitrary pre-employment assessments by prospective employers.
77. The Committee recommends that the State Party :
(a) Review the impact of the labour migration ban to ensure that it does not unintentionally drive migrants towards irregular channels, and accelerate the conclusion of bilateral agreements, in particular with Gulf countries, to facilitate safe, orderly and regular migration;
(b) Strengthen regulation, monitoring and enforcement mechanisms to combat informal recruitment practices, including by enhancing the capacity and resources of relevant institutions;
(c) Enhance protection measures for migrant workers, particularly women, by addressing gender-specific risks and ensuring safeguards against discriminatory and abusive practices throughout the recruitment and deployment process;
(d) Intensify awareness-raising efforts on the risks associated with informal recruitment channels and strengthen cooperation with civil society, trade unions and licensed agencies to promote ethical recruitment practices.
78.The Committee notes the State Party’s commitments under the ECOWAS Protocol relating to Free Movement of Persons, Residence and Establishment. However, it notes with concern the requirement for migrant workers, including ECOWAS citizens, to obtain work permits subject to labour market tests, and restrictions on access by non-nationals to employment in the public sector, except in limited circumstances, as well as provisions under the Ghana Investment Act 2013 (Act 865) which restrict certain economic activities for migrant workers.
79. The Committee recommends that the State Party take all necessary legislative and administrative measures to ensure the full and effective implementation of the ECOWAS Protocol relating to Free Movement of Persons, Residence and Establishment , including by reviewing work permit requirements and labour market tests that may hinder access to employment for ECOWAS migrant workers.
Return and reintegration
80.The Committee notes with concern that return and reintegration processes are largely implemented and financed by international organizations and civil society actors. It is concerned that existing frameworks, including the National Migration Policy, do not provide a sufficiently comprehensive and sustainable approach to return and reintegration. The Committee further notes that returnees often face challenges related to access to livelihood opportunities, social reintegration and community acceptance.
81. The Committee recommends that the State Party :
(a) Strengthen its efforts in ensuring return and reintegration, including by taking greater responsibility for the design, coordination and implementation of programmes in line with national policies;
(b) Enhance the comprehensiveness and sustainability of reintegration measures, including by expanding access to livelihood opportunities and addressing stigma and community acceptance challenges;
(c) Expand the coverage of return and reintegration programmes, ensuring that support is accessible to returnees from all countries of destination.
Trafficking in persons
82.The Committee notes the efforts undertaken by the State Party, including activities led by the Ministry of Gender, Children and Social Protection, to prevent smuggling and trafficking in persons. However, the Committee remains concerned about the low level of awareness among potential migrant workers regarding the legal status of recruitment agencies, the distinction between formal and informal intermediaries, and the risks associated with unethical recruitment practices. The Committee further notes with concern the significant risks linked to the use of informal recruitment channels, which include trafficking in persons and other forms of exploitation. It highlights reports indicating that migrant workers recruited through such channels are exposed to deception, abuse, arbitrary detention and extortion, both in transit countries and in destination countries.
83. The Committee recommends that the State Party :
(a) Strengthen the regulation and monitoring of informal recruitment channels, including online platforms, to prevent human trafficking and exploitation of migrant workers and members of their families;
(b) Intensify awareness-raising efforts by providing clear and accessible information to prospective migrant workers on safe and ethical recruitment practices and available legal migration channels;
(c) Strengthen labour protections for migrant workers within the State Party , including those employed in the informal sector, to prevent abuse, trafficking and exploitation;
(d) Improve access to reliable information, including by establishing effective mechanisms to identify licensed recruitment agencies and by conducting targeted outreach and public information campaigns on the risks associated with informal intermediaries.
84.The Committee notes with concern the prevalence of trafficking of women and girls, notably in sectors such as domestic work and informal urban employment. The Committee notes the heightened vulnerability of women migrant workers and unaccompanied girls to exploitation in domestic settings, where conditions of isolation, unequal power relations and insufficient legal protection increase their exposure to trafficking and constrain access to reporting mechanisms and support services. It observes that these vulnerabilities are exacerbated by poverty, limited access to education, gender-based violence and the widespread use of informal recruitment practices.
85.The Committee is further concerned about challenges in the identification of victims of trafficking, widespread underreporting, and the low number of investigations, prosecutions and convictions. It also highlights weaknesses in coordination, data collection and referral mechanisms for trafficking cases. In addition, the Committee notes gaps in the legal framework, including penalties for human trafficking and migrant smuggling that may not be sufficiently deterrent, as well as the limited effectiveness of measures for the protection, rehabilitation and reintegration of victims. While acknowledging training initiatives for law enforcement personnel, the Committee remains concerned about reports of abuse by police against exploited migrant women, including those subjected to sexual exploitation.
86. The Committee recommends that the State Party :
(a) Strengthen the implementation of anti-trafficking legislation and policies, including by allocating adequate resources and ensuring effective enforcement of the Human Trafficking Act 2005 and the Anti-Trafficking National Action Plan 2022–2026;
(b) Enhance investigation and prosecution efforts, including by improving coordination among law enforcement and judicial authorities, increasing referrals and ensuring that penalties are commensurate with the gravity of offences;
(c) Improve identification and protection of victims, including by strengthening access to the National Trafficking in Persons Referral Mechanism, expanding shelter capacity and providing comprehensive, trauma-informed services;
(d) Address the root causes of trafficking, including poverty, gender inequality and unsafe migration pathways, while reinforcing prevention and awareness-raising measures;
(e) Strengthen child protection measures, including improving identification and referral systems for child victims, increasing shelter capacity and ensuring access to appropriate services;
(f) Enhance data systems and interoperability, ensuring that relevant actors, including law enforcement and social services, have access to reliable and shared information;
(g) Ensure the protection of migrant women from all forms of violence, discrimination and abuse, including sexual violence, by strengthening oversight of police conduct, and by guaranteeing access to justice, healthcare, social services, education and alternative livelihood opportunities;
(h) Ensure adequate technical and financial resources for support services for victims of trafficking, including shelters, counselling, and medical referrals, including through the Human Trafficking Secretariat and the Department of Social Welfare under the Ministry of Gender, Children and Social Protection;
(i) Provide comprehensive data in the next periodic report on trafficking in persons and exploitation, including information on investigations, prosecutions, convictions and the impact of measures taken.
7.Dissemination and follow-up
Dissemination and implementation
87. The Committee requests the State Party to ensure the timely dissemination of the present concluding observations, in the official language of the State Party, to the relevant State institutions at all levels, including to government ministries, the legislature, the judiciary and relevant local authorities, as well as to non-governmental organizations and other members of civil society.
88. The Committee recommends that the State Party consider establishing a comprehensive mechanism for the implementation of the present concluding observations and involve the Commission on Human Rights and Administrative Justice and non-governmental organizations, in particular migrants ’ organizations, in the work of the mechanism, taking into account the four key capacities of a national mechanism for reporting and follow-up, namely engagement, coordination, consultation and information management.
Technical assistance
89. The Committee recommends that the State Party further avail itself of international and intergovernmental assistance for the implementation of the recommendations contained in the present concluding observations in line with the 2030 Agenda for Sustainable Development. It also recommends that the State Party continue its cooperation with specialized agencies of the United Nations system and with programmes of the United Nations. The Committee remains at the State Party ’ s disposal, particularly for follow-up to the present concluding observations and the preparation of its third periodic report.
Follow-up to concluding observations
90. The Committee requests the State Party to provide, within two years (that is, by 1 July 2028), written information on the implementation of the recommendations contained in paragraphs 19 (data collection), 39 and 41 (labour exploitation and other forms of ill-treatment) and 49 (expulsion) above.
Next periodic report
91. The State Party ’ s third periodic report is due by 1 July 2031. The Committee will adopt a list of issues prior to reporting under the simplified reporting procedure at one of its sessions preceding this date, unless the State Party has explicitly opt ed for the traditional reporting procedure. The Committee draws the State Party ’ s attention to its harmonized treaty-specific guidelines.