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Key Text Characteristics of Different External Audit Systems

Author: Department for International Development (DFID)
Date: 2004
Size: 13 pages (454KB)

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Summary

Accountability for the use of public funds is a cornerstone of good public financial management. Supreme Audit Institutions (SAIs) are the national bodies responsible for scrutinising public expenditure. How do they operate? This paper by the United Kingdom Government Department for International Development gives an overview of the principal characteristics of the three most common systems, their potential strengths and weaknesses, and some of the implications of working with SAIs from different traditions.

There are three major external audit models - the Westminster model, also known as the Anglo-Saxon or Parliamentary model, the Judicial or Napoleonic model and the Board or Collegiate model. The United Kingdom and most Commonwealth countries including many in sub-Saharan African, a few European countries such as Ireland and Denmark, Latin American countries such as Peru and Chile follow the Westminster model. The Judicial model is used in the Latin countries in Europe, Turkey, francophone countries in Africa and Asia and several Latin American countries including Brazil and Colombia. The collegiate system is followed in some European countries including Germany and the Netherlands, Argentina, Asian countries including Indonesia, Japan and the Republic of Korea.

However, even where a SAI broadly follows one of the three audit models, every country is different and there are likely to be some national variations in its remit and the way it is organised. Under a Westminster model, the work of the Supreme Audit Institution (SAI) is intrinsically linked to the system of parliamentary accountability. Under the judicial model, the SAI is an integral part of the judicial system operating independently of the executive and legislative branches. It is likely to have only a limited relationship with the national Parliament. Under the collegiate system the SAI, has a number of members who form its college or governing board and take decisions jointly.

Despite their different approaches, the four objectives of public sector auditing are to promote:

The proper and effective use of public funds.
The development of sound financial management.
The proper execution of administrative activities.
The communication of information to public authorities and the general public through the publication of objective reports.

These fundamental objectives guide the work of all SAIs but the different public external audit models have different characteristics, for example:

The basic elements of the Westminster system include authorisation of expenditure by Parliament; production of annual accounts by all government departments; the audit of those accounts by the SAI; the submission of audit reports to Parliament for review by a dedicated committee.
A key aspect of judicial accountability systems is that relevant government officials are normally held personally liable for the sums involved should an unauthorised or illegal payment be made.
In addition to the SAI’s judicial role, a complementary high-level system of parliamentary accountability for public expenditure is normally in place.
Collegiate audit bodies normally are part of a parliamentary system of accountability. Reports and opinions agreed by the college are submitted to Parliament, where there is some form of Public Accounts Committee to act on them. Collegiate bodies do not have judicial functions.
The basic structure of the accountability model is thus similar to the Westminster model, with the key differences being in the internal structure of the audit institution.

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Source: Department For International Development (DFID), 2004, ‘Characteristics of Different External Audit Systems’, Policy Division Briefing Paper
Author: Department for International Development (DFID), http://www.dfid.gov.uk