On 26th February 2025, Ghana’s Ministry of Energy formally withdrew the Unitisation Directives that previously ordered the compulsory integration (unitisation) of Springfield Exploration and Production Limited’s Afina-1X discovery and ENI Ghana’s Sankofa Cenomanian Oil Field.
This decision marks a significant turning point in Ghana’s energy policy, offering valuable insights into the concept of unitisation and its implications for the country’s upstream petroleum sector.
Unitisation is a process used in the oil and gas industry to combine two or more adjacent petroleum discoveries or reservoirs into a single development unit. This typically happens when:
The goal of unitisation is to ensure optimal resource recovery, avoid unnecessary duplication of infrastructure, and enhance commercial viability for both license holders and the host government.
In April, October, and November 2020, Ghana’s Ministry of Energy issued directives compelling ENI Ghana and Springfield Exploration and Production Limited to unitise their discoveries, the Sankofa Cenomanian Field (ENI) and the Afina-1X Discovery (Springfield). These fields are located in neighbouring contract areas within the Offshore Cape Three Points region, with the government arguing that the two reservoirs formed a single continuous petroleum system.
However, the decision triggered strong opposition, particularly from ENI and its partner Vitol, who disputed the geological basis for the unitisation and the arbitrary allocation of participation interests (how much of the joint project each party would own). The dispute escalated into international arbitration at the Stockholm Chamber of Commerce (SCC).
The withdrawal follows a thorough review of the July 2024 Arbitral Award in the SCC Arbitration U2021/114 (ENI & Vitol v. Ghana & GNPC), as well as a legal opinion from Ghana’s Attorney General and Minister of Justice. The Tribunal found:
While the Tribunal found procedural flaws, it did not rule that unitisation itself was inherently unlawful—only that it must be implemented in accordance with proper legal procedures and supported by sound technical and commercial justifications.
By withdrawing the directives, the Ministry of Energy has regained flexibility to explore alternative approaches to resource management in the West Cape Three Points (WCTP) region. Ghana can now pursue solutions that balance regulatory oversight with commercial viability and investor confidence.
While withdrawing the directives, the Ministry reaffirmed its support for Springfield, a Ghanaian-owned operator, emphasising that the withdrawal does not reflect a policy shift away from promoting indigenous participation in the upstream sector.
Rather than imposing mandatory integration, the Ministry is encouraging ENI and Springfield to pursue collaborative commercial discussions—a voluntary, negotiated approach to unitisation or coordinated development.
The Afina discovery and the Sankofa field are both highly valuable resources. Afina’s significant gas potential could enhance Ghana’s energy security, while Springfield’s Tama Field, with an estimated 1.2 trillion cubic feet (TCF) of gas, represents another major strategic asset.
Efficiently developing these resources, whether through unitisation, coordinated development, or separate production will directly influence Ghana’s energy self-sufficiency, export revenues, and industrial growth.
Ghana is not alone in applying unitisation principles. Many resource-rich nations have well-established frameworks to manage cross-boundary petroleum resources:
Nigeria’s Petroleum Industry Act (PIA) 2021 provides a clear unitisation framework. The Aparo and Bonga Southwest oil fields were unitised to enable Shell and its partners to jointly develop a reservoir that crossed license boundaries.
Offshore blocks, especially in Block 14 and Block 15, have seen multiple unitisation cases. The Lianzi Field, which straddles the Angola-Republic of Congo maritime boundary, is a textbook example of cross-border unitisation.
Ghana itself has previously applied unitisation principles. The Tweneboa, Enyenra, and Ntomme (TEN) Fields underwent technical evaluations of possible unitisation before development.
Norway’s North Sea oil governance is a global model for unitisation. The Troll Field involved multiple operators working under a robust unitisation agreement to optimise recovery.
The UK’s North Sea sector also features extensive unitisation experience. The Brent Field required careful unitisation arrangements among various license holders.
In the Gulf of Mexico, the US government mandates unitisation when reservoirs cross lease boundaries. Similar practices apply onshore across state lines.
Brazil’s offshore pre-salt fields often span multiple blocks, triggering mandatory unitisation. The Libra Field required Brazil’s regulator to oversee the process involving Petrobras and partners.
The Neutral Zone fields are operated under a formal unitisation agreement, enabling both nations to share production and revenue.
The Malaysia-Thailand Joint Development Area (MTJDA) is a unique cross-border unitisation-like arrangement allowing both nations to jointly develop shared fields.
The Greater Sunrise gas field in the Timor Sea required a detailed unitisation treaty between Australia and Timor-Leste to share production and revenue.
With the directives withdrawn, Ghana’s policymakers have an opportunity for a strategic reset. Future unitisation efforts, if necessary, should be based on:
At the same time, Ghana’s commitment to nurturing indigenous players like Springfield remains intact. By balancing national development goals with regulatory predictability, Ghana can enhance its attractiveness to both local and international investors.
The ENI-Springfield case is a reminder that unitisation is not just a technical or legal process—it’s also a delicate balancing act between public policy, commercial interests, and investor confidence. Ghana’s decision to withdraw the directives signals a welcome return to evidence-based policymaking, which could position the country as a model for pragmatic and investor-friendly resource governance across Africa’s upstream oil and gas sector.
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