Beyond Ownership: Five Models Reshaping How Africa Recovers Its Cultural Heritage

Beyond Ownership: Five Models Reshaping How Africa Recovers Its Cultural Heritage

The question dominating debates over African cultural heritage has long been “who owns it?” But as restitution accelerates across the continent—with the African Union declaring 2025 the “Year of Justice Through Reparations” and countries from Nigeria to Ghana to Benin Republic receiving returned treasures—a more productive question is emerging: “How should communities steward their returning heritage?” Across Africa, five distinct governance models are providing answers, each with lessons for the continent and the world.

When Felwine Sarr and Bénédicte Savoy delivered their landmark 2018 report to French President Emmanuel Macron, they didn’t merely advocate for moving objects from one location to another. They called for “a new relational ethics”—a fundamental reimagining of how formerly colonized peoples and their former colonizers might share responsibility for preserving, interpreting, and transmitting cultural memory. Seven years later, that reimagining is happening in practice, not just theory.

The models emerging across Africa reject both the paternalistic universalism of Western encyclopedic museums and the simplistic nationalism that treats cultural objects solely as state property. Instead, they offer something more complex and, ultimately, more honest: frameworks that acknowledge multiple stakeholders, navigate tensions between traditional authority and modern governance, and recognize that objects carry meaning that transcends legal ownership.

Model 1: Traditional Authority Custodianship — The Nigeria Approach

In March 2023, Nigerian President Muhammadu Buhari issued a presidential decree that upended assumptions about how repatriated artifacts would be governed. The decree declared the Oba of Benin—not the Nigerian federal government—as the legal owner and custodian of returning Benin Bronzes. This was not a symbolic gesture. It was a fundamental restructuring of heritage governance that places traditional royal authority, not the modern nation-state, at the center.

The decision emerged from decades of tension. When Western museums began signaling willingness to return Benin Bronzes, Nigerian institutions initially jockeyed for control. The National Commission for Museums and Monuments (NCMM), the Edo State government, and the Benin Royal Court all advanced competing claims. The federal decree resolved this by recognizing a basic historical fact: the bronzes were taken from the Oba’s palace, not from a Nigerian national institution that didn’t exist in 1897.

Implementation has required careful negotiation. A February 2025 Memorandum of Understanding formalized “shared custodianship” between the Oba and the NCMM. The Oba holds legal ownership; NCMM provides professional conservation support and manages public access through the planned Benin Royal Museum. The Oba Ovonramwen Storage Facility, completed in late 2024, meets international conservation standards while remaining under traditional authority.

This model carries risks. Critics worry about accountability: What happens when a traditional ruler’s interests conflict with public access? What oversight mechanisms exist? The model also depends heavily on the character of the individual ruler—Oba Ewuare II has been an effective advocate, but succession could bring different priorities.

Yet the model also offers something Western museums have struggled to provide: spiritual and cultural authority. As the Oba stated when receiving 119 bronzes from the Netherlands in June 2025, these objects are not merely artistic treasures—they are ancestors, sacred presences that require proper ritual care. A government bureaucracy, however well-intentioned, cannot provide this.

Model 2: Traditional Authority With International Partnership — The Ghana Model

Ghana’s approach to the Asante treasures offers a variation on traditional authority custodianship, one that acknowledges current legal constraints while building toward full restitution. When the British Museum and Victoria & Albert Museum agreed in 2024 to return 32 looted Asante gold and silver objects, they couldn’t legally transfer ownership—UK heritage law prohibits permanent deaccessioning. Instead, they negotiated directly with Asantehene Otumfuo Osei Tutu II for long-term loans.

The crucial innovation was bypassing the Ghanaian national government entirely. The partnership exists between UK museums and the Asante monarch, with objects housed at the Manhyia Palace Museum in Kumasi under the direction of Ivor Agyeman-Duah. The Fowler Museum at UCLA went further, permanently transferring ownership of seven objects in February 2024—the first unconditional returns to reach Ghana.

This model creates a potential blueprint for navigating legal barriers. V&A Director Tristram Hunt has publicly called for reform of UK heritage legislation, and the Ghana partnership buys time while advocacy continues. Meanwhile, the Manhyia Palace Museum has signed an MOU with Justice and Repair, an Accra-based advocacy organization, to continue pursuing additional returns.

The model’s strength lies in its recognition that traditional authority carries legitimacy that transcends national borders. The Asantehene commands respect as a cultural sovereign, not merely as a private citizen receiving a museum loan. UK institutions treating him as a peer—rather than a supplicant—shifts power dynamics in subtle but significant ways.

Visitor numbers illustrate the impact: the Manhyia Palace Museum expects to grow from 90,000 annual visitors to 200,000 following the returns. This isn’t just heritage recovery—it’s economic development anchored in cultural sovereignty.

Model 3: State-Led Institutional Development — The Benin Republic Model

When France returned 26 royal treasures from the Kingdom of Dahomey in November 2021, Benin Republic was ready. President Patrice Talon had spent years preparing: commissioning world-class museum facilities, training conservators, and developing a comprehensive cultural infrastructure strategy with approximately €1 billion in investment over four years.

The Benin model centers on purpose-built state institutions rather than traditional authority. The returned treasures are displayed at the Presidential Palace in Cotonou while permanent facilities are completed. The Musée de l’épopée des Amazones et des Rois du Danhomè in Abomey—on the UNESCO World Heritage site where the objects originated—will ultimately house them. Additional facilities under development include the Musée International du Vodou in Porto-Novo, which awaits the return of the iconic God Gou sculpture currently in France.

Historian Alain Godonou, special advisor to President Talon on heritage, has been instrumental in shaping this approach. “If you come to Benin today and go to Porto-Novo,” he told journalists in January 2026, “at the entrance to the city, you will see this museum already built, majestic, which is already in itself something very important in the urban planning of the city.”

The Benin model demonstrates that African states can meet or exceed international museum standards when given the opportunity. It refutes the longstanding argument—deployed by Western institutions resisting restitution—that African countries lack capacity to care for their heritage. French financing supported museum construction through the French Development Agency, modeling how former colonial powers might contribute to heritage infrastructure as part of restitution processes.

The limitation is cost. Not every African nation can mobilize billion-euro cultural investments. Benin Republic benefits from a focused scope (primarily Dahomey-era objects), relatively small population (13 million), and presidential commitment. Larger countries with more dispersed heritage face greater challenges.

Model 4: Federated Governance With Community Involvement — The Emerging AU Framework

The African Union has moved beyond rhetoric to develop continental frameworks for heritage governance. The Accra Proclamation on Reparations, building on Agenda 2063’s cultural heritage provisions, calls for repatriation not just as bilateral transactions but as components of broader reparatory justice.

Key AU initiatives include:

Common African Position on Restitution: A unified negotiating framework enabling African states to present coordinated demands rather than competing claims. This addresses situations where colonial-era borders divided cultural communities—objects taken from areas now spanning multiple nations require cooperative governance.

Framework for Action on Negotiations: Technical guidance on provenance research, legal strategies, and diplomatic engagement. Developed through the 2021 Continental Consultations on Restitution of Cultural Property held in Dakar, this framework helps states build institutional capacity.

Decade of Reparations (2026-2036): A coordinated advocacy campaign keeping heritage recovery on the international agenda. The AU recognizes that restitution requires sustained pressure; a single year of attention won’t achieve transformative change.

Proposed African Heritage Agency: A continental body to coordinate policy, provide technical assistance, and advocate internationally. This would institutionalize expertise currently scattered across national ministries and civil society organizations.

The AU framework’s strength is its recognition that heritage governance is inherently political. Restitution is not merely a museum management question—it’s bound up with economic justice, historical memory, and international relations. The 2025 “Year of Justice Through Reparations” explicitly links artifact returns to broader demands: restructuring global trade systems, reforming international financial arrangements, and achieving formal acknowledgment of colonial crimes.

This political framing has strategic value. It places African heritage claims within the same moral framework as other reparations demands, building coalition support across the diaspora and among Global South allies. Turkey’s January 2026 offer to return Nigerian artifacts, for instance, emerged partly from this South-South solidarity framework.

Model 5: Digital Complementarity — Enhancing, Not Replacing, Physical Returns

Digital technology offers tools for heritage access that didn’t exist when restitution debates began. But as Afroditi Karatagli argued in a December 2025 analysis for the Center for Art Law, “digital repatriation does not constitute repatriation at all; it is, at best, yet another form of documentation and at worst, a cynical strategy to avoid legal and moral responsibility.”

The strongest African voices on this question reject digital surrogates as substitutes for physical returns while embracing technology as a complement to restitution. The Digital Benin project—an online database documenting over 5,000 looted Benin objects across 100+ global collections—exemplifies this approach. It doesn’t claim to replace physical returns; it provides research infrastructure enabling more effective advocacy for those returns.

Similarly, 3D scanning and replication have found appropriate use in restitution processes—not as alternatives to return but as tools enabling holding institutions to maintain study copies after returning originals. When UCLA’s Fowler Museum permanently returned seven Asante objects in 2024, the Asante kingdom permitted creation of replicas. This satisfied the museum’s educational mission while affirming that authentic objects belong in their communities of origin.

Nigerian artist Chidi Nwaubani’s LOOTY project takes a different tack, using AR/VR and 3D reconstruction to create “digital heists” that symbolically reclaim artifacts like the Rosetta Stone. This provocative approach treats digital technology as artistic intervention and political statement rather than heritage governance solution.

The lesson: technology serves restitution when it supports community goals, not when institutions deploy it to avoid accountability. Digital tools should amplify African voices and enable African scholarship, not perpetuate control by holding institutions over digitized surrogates.

What These Models Share: Principles for Heritage Governance

Across these diverse approaches, common principles emerge:

Community determination: Source communities—whether defined as traditional authorities, national governments, or cultural groups—must lead decisions about how heritage is governed. External institutions can support but cannot dictate.

Multiple stakeholders: Heritage governance is not zero-sum. Traditional rulers, national governments, local communities, international partners, and diaspora populations all have legitimate interests. Effective models create mechanisms for negotiating among these stakeholders rather than privileging one absolutely.

Capacity as process: “Capacity” is not a prerequisite for restitution but an outcome of it. Benin Republic built museum infrastructure partly because returns were imminent. The expectation of receiving heritage creates incentive for investment; withholding heritage pending “capacity” creates a circular trap.

Spiritual and cultural authority: Objects carry meanings that transcend their material properties. Governance models must account for sacred dimensions, ceremonial requirements, and community protocols—something bureaucratic management often cannot provide.

Transparency and access: Heritage belongs to communities, but communities include future generations and global publics. Governance models should ensure objects remain accessible for research, education, and cultural exchange, not sequestered from view.

Ongoing relationship: Restitution is not a transaction concluded when objects change hands. It initiates new relationships between communities and former holding institutions—relationships that might include collaborative research, traveling exhibitions, and continued dialogue.

Challenges Ahead

These models face significant challenges. Coordination between traditional authorities and national governments remains fraught in Nigeria, where the Museum of West African Art (MOWAA) controversy revealed deep tensions between the Edo State government, federal authorities, and the Benin Royal Court. Similar tensions exist elsewhere.

Funding sustainability poses another challenge. Initial investments in museum infrastructure often depend on government priorities that may shift with political transitions. Building enduring institutions requires financial models that survive changes in leadership.

Legal frameworks remain inadequate. The French Senate’s January 2026 restitution bill represents progress, but UK law still prohibits permanent returns from major national collections. Even where legal barriers fall, practical obstacles—insurance, shipping, conservation—require ongoing negotiation.

Finally, the scale of African heritage dispersal defies easy solutions. The Sarr-Savoy report estimated 90% of sub-Saharan African heritage is held outside the continent—hundreds of thousands of objects scattered across thousands of institutions. No governance model can address this without decades of sustained effort.

Toward a New Relational Ethics

The question “who really owns these objects?” may be less productive than asking “who is capable of deserving their memory?” This reframing, implicit in Sarr and Savoy’s work and explicit in emerging African practice, shifts attention from legal possession to moral stewardship.

Stewardship implies ongoing responsibility, not terminal ownership. It suggests relationships rather than transactions. And it opens space for the complex, negotiated arrangements that African communities are developing—arrangements that may look unfamiliar to Western legal frameworks but that honor the multidimensional nature of cultural heritage.

These models aren’t perfect. They’re experiments, works in progress, adaptations to specific circumstances. But they share a common conviction: that African communities can and must determine how their heritage is governed, and that the role of former colonial powers is to support rather than control this process.

As the AU’s Decade of Reparations begins, this conviction will face sustained testing. The outcomes will shape not just African cultural institutions but the global museum landscape—and perhaps, ultimately, how humanity collectively cares for our shared heritage.

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