Publican AI in Customs Valuation Law, Limits and the Risk of ‘Impossible’ Bills

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By Dr. Isaac Amoako-Mensah | CEO CAGL LOGISTICS ――――――――――――――――――――――――――――――――――――――――――――――――――
Ghana’s customs administration is undergoing a
significant transformation with the introduction of
the Publican AI system. At its core, the reform is
driven by a legitimate objective: to curb
undervaluation, protect government revenue, and
modernize import assessment processes. However,
the March 2026 directive operationalizing the system
raises important legal and policy concerns that must
be carefully addressed.
The directive makes the use of Publican AI
mandatory and positions its outputs as the “primary
basis” for customs valuation. More critically, it
prohibits customs officers from finalizing
assessments below the values generated by the
system. In effect, this elevates AI-generated figures
above statutory valuation rules.
Under the Customs Act, 2015 (Act 891), which aligns
with the WTO Customs Valuation Agreement, the
primary method of valuation is the transaction
value—the actual price paid or payable for the goods.
This is not optional; it is the legal starting point. Only
when that value is unreliable or unverifiable can
alternative methods be applied.
By preventing officers from accepting values below
AI outputs—even where importers provide valid
commercial documentation—the directive risks
creating what is, in practice, a minimum value
regime. Such systems are explicitly prohibited under
international trade rules because they disregard real
transaction values and undermine fairness in trade.
The consequences are not merely theoretical. A
recent Bill of Entry shows a used 2012 Toyota Voxy
being assessed at nearly GH¢14 million, resulting in
duties of approximately GH¢7.96 million. For most
importers, this is economically unviable.
This situation raises serious due process concerns.
Importers have a legal right to challenge valuations
and present supporting evidence. However, if officers
are constrained by policy from exercising discretion,
that right becomes ineffective.
In practice, importers are left with two difficult
options: pay the inflated duty and pursue redress
later, or delay clearance while disputing the
valuation. Both options come at a cost due to rising
demurrage and storage charges.
Transparency is another critical issue. AI outputs
must be explainable and open to scrutiny. Without
this, the system risks being perceived as opaque and
arbitrary.
The way forward is not to abandon AI, but to align it
with the law. Publican AI should serve as a risk
assessment tool—not a replacement for statutory
valuation methods. Customs officers must retain
authority to apply the law based on evidence.
Additionally, a fast, decentralized appeals mechanism
is essential to resolve disputes quickly and reduce
port congestion.
Ghana can modernize customs while upholding the
rule of law. Without this balance, the system risks
producing “impossible” bills that undermine both
trade and revenue.