For the few past decades, the topic of restitution of art and heritage has gradually made waves through academic circles as well as through public debates via social media, journalistic publications and the media in general. Colonial countries have however had mixed views and responses to these calls for the return of artefacts taken during colonisation.

This is in stark contrast to the overwhelming support for the return of Nazi looted artefacts a sin which originally took place only about 80 years ago. In this instance, efforts began almost immediately right at the end of the second world war. It all began through the establishment of the Monuments, Fine Arts, and Archives (MFAA) framework in 1943 by the Allies which helped to recover thousands of looted artefacts.

The hollywood film, Monuments Men depicts the legacy of those who served in this program some of whom went on to become art historians, museum administrators and collectors in their own right.

The Washington Principles of 1998 also marked a significant milestone in the development of another international institutional framework to guide the return of Nazi-looted artefacts. It established non-binding guidelines to help identify, validate and return Nazi confiscated art. This process helped improve transparency and visibility of these artefacts. In 2024, in honour of the 25th anniversary of the Washington Principles, further amendments and best practices were introduced.

Similarly, the Terezin Declaration of 2009 was adopted by 47 countries, reinforced this international commitment to addressing the issue of restitution as it concerns Nazi looted artefacts. These initiatives paint a picture of a relatively successful campaign of restitution to the benefit of mainly European nations who were victims of Nazi looting.

For artefacts taken from colonised Africa hundreds of years ago the story seems drastically different. Governments have for years rejected such calls and complained over the mountain of bureaucracy that prevents this from becoming a reality.

In fact in the case of the United Kingdom, two key pieces of legislation specifically prohibit this from happening. The British Museum Act of 1963 and the National Heritage Act of 1983 were passed to preserve the ”integrity” of British national archives by legally binding museums and their trustees to forever preserve their archives. This principle takes the stance that British archives cannot and must not be altered, reduced or varied unless under very specific and narrowly defined conditions.

This was the subject of the documentary-style film, ”You Hide Me” by the prolific Ghanaian filmmaker Nii Kwate Owoo in 1970. Which was one of the first films to examine the case for repatriation of the artefacts to their countries or origin. Ironically it was filmed in the British Museum which in itself was a major character of the film symbolising colonial oppression, and cultural appropriation.

In 2009, an exception was made to the British laws preventing the return of artefacts. You may not be surprised to hear that this legal exception was made to facilitate the return of Nazi-looted artefacts. This amendment recognised the fact that historical injustices such as the scourge of Nazism were justification enough to enforce restitution. As of today, the international consensus on the return of Colonial looted artefacts from Africa is not yet as far reaching. Many European and Western countries continue to hold on to vast amounts of artefacts taken from former colonies. With no widely accepted international framework, restitution takes place on a case-by-case basis.

The disparities between these two global discussions are striking. The restitution of Nazi-looted art is very often seen as an urgent matter of justice and historical reconciliation. The process of returning colonial looted artefacts (predating the Second World War by hundreds of years), is, on the other hand, marked by resistance; lacking the same sense of urgency and plagued with legal and political complexities.

The process has, for centuries, remained slow.

A possible shift?

Over the last 3-5 years, there have been signs of the emergence of a new era slowly taking shape. Several European countries have started to acknowledge the injustice of colonial looting and have either issued statements to that effect or taken visible, tangible steps towards restitution. While it is nowhere close to the kind of international consensus that we have seen in relation to Nazi-looted artefacts, it is a huge step in the right direction, marking what could go down as a significant turning point.

One of the first landmark events came in 2021, when the French government, spearheaded by President Emmanuel Macron, oversaw the return of 26 objects from France’s Musée du Quai Branly to the Republic of Benin. These pieces, which were taken by a French military expedition in the 1890’s were part of a broader collection of looted artefacts in the French collection. It was a remarkable gesture aimed at setting a precedent for future restitution efforts.

This was quickly followed by the return of over 1,000 Benin Bronzes by the German government to the Nigerian government, with close cooperation with the Kingdom of Benin, the rightful custodians of the Benin Bronzes. These artefacts had previously been on display in major museums around the world, including the Berlin Museum and the British Museum. This decision to repatriate the items was seen as a major victory for the restitution movement after several years of negotiations.

Similarly, in 2025, after extensive provenance research by an independent Colonial Collections Committee, the Netherlands made headlines by returning 119 looted artefacts to Nigeria from the Dutch State Collection. It was framed as part of a broader policy to return any looted objects with a colonial origin. 113 of the artefacts came directly from the State Collection, and 6 came from the collection of the Municipality of Rotterdam. 4 items now in the possession of the Wereldmuseum, through a loan agreement from the Nigerian government, aim to provide a solution that allows for continued access to the artefacts whilst correcting longstanding injustices over the ownership and preservation of similar artefacts.

The Role of Loan Agreements

Loan agreements have emerged as a potential solution to the contentious issue of ownership and education. These agreements allow museums and institutions to retain access to significant artefacts while giving the rightful owners an opportunity to display their heritage. This model offers a compromise that benefits both parties, ensuring that cultural knowledge can continue to be shared globally while respecting the original cultures and communities from where these objects originate.

In 2024, the Manhyia Palace of the Asantehene, the King of the Asante people in Ghana, received a significant loan of items from the British Museum. This included a selection of artefacts that had been looted during colonial conflicts in the 19th century. The loan marked an important step in the ongoing efforts to reconcile the past and strengthen cultural ties between the UK and Ghana. The loan agreement negotiated provides a term of 3 years, renewable for an additional term to 6 years in total. The agreement came with support for the development of the Manhyia museum in Kumasi, as well as other forms of cooperation between the two museums.

That same year, the Fowler Museum in Los Angeles returned several important items to their rightful owners. The full restitution of these artefacts is seen as a reflection of growing international awareness and sensitivity to the importance of cultural restitution. As a sign of goodwill, the Asantehene promised the production of replicas that will be used for educational purposes and will carry the story of Asante back to the museums where they were once displayed. This ensures that the educational component continues and more awareness is created about the true origin and rightful home of these artefacts.

More recently, earlier this month, in November 2025, the Asante king, Otumfuo Osei Tutu II, received 130 gold and bronze artefacts at a ceremony in Kumasi, Ghana. These items, which include royal regalia, ceremonial gold weights, and drums, had been looted during colonial conflicts in the 1870s or purchased on the open market.

This handover was a joint effort involving British art historian Hermione Waterfield and the South African mining company AngloGold Ashanti. The return of these items has been hailed as an act of cultural respect and reconciliation, strengthening the ongoing call for the broader return of African heritage.

More recent Repatriations: A Growing Momentum

The global momentum for the return of looted African artefacts is not confined to Benin or Ghana. Also, about a week ago, in November 2025, a German family made headlines for returning a collection of Ethiopian artefacts that had been looted during the 19th century. These items, which had been taken by the British during the Battle of Maqdala in 1868, were returned after decades of public pressure and private negotiations.

The story of the German family’s return of the Ethiopian artefacts is just one example of the broader shift in how formerly colonising nations are engaging with their colonial past. In a similar vein, the UK has seen increased pressure to return looted artefacts from its vast collection, including the Elgin Marbles and the Benin Bronzes. Although the UK has resisted such efforts, the growing global consensus on the importance of restitution is putting pressure on governments and institutions to reconsider their positions.

Conclusion: A Shift in the Dialogue

The return of some looted African artefacts marks a significant shift in the global conversation around cultural restitution. As discussed above, a number of countries and institutions have recently taken tangible steps toward righting historical wrongs, returning artefacts that were wrongfully taken during colonial and imperialist periods. This historical reckoning is part of a broader recognition of the cultural significance of these objects, as well as a growing commitment to reconciling with the peoples and nations from whom they were stolen.

Whilst these events mark a significant shift in the public discourse surrounding the restitution of colonial looted artefacts, it is still a far cry from the international consensus and multilateral efforts on Nazi-looted artefacts. There are growing calls for a more holistic approach. The journey of these artefacts from being stolen centuries ago to their eventual repatriation should and must be documented, archived in the context of colonial exploitation and cultural erasure. In their stead come a new form of loan agreements that aim to continue the educational and cultural exchange that has taken place since the end of Colonisation. It is a vital step in healing historical wounds, signalling mutual respect and acknowledgement of colonial injustice. As commitments continue to grow, the restitution movement grows, and so will mounting pressure. The world is watching, and there is renewed hope that more countries and institutions will follow suit.