Aspects of the Work of Supreme Audit Institutions in Various Countries
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Aspects of the Work of Supreme Audit Institutions in Various Countries Written By: Rony Blank and Gideon Zeira | Approved by: Shelly Levy, Team Leader Date: January 17th 2017 Overview Knesset Research and Information Center Editing: Knesset Minutes Staff www.knesset.gov.il/mmm 2 | Aspects of the Work of Supreme Audit Institutions in Various Countries Table of Contents Introduction .......................................................................................................... 3 1. Australian National Audit Office (ANAO) ..................................................... 6 2. Austrian Court of Audit (Rechnungshof) ..................................................... 10 3. Office of the Auditor General of Canada (OAG) .......................................... 14 4. German Supreme Audit Institution (Bundesrechnungshof) .................... 16 5. Danish Supreme Audit Institution (Rigsrevisionen) .................................. 20 6. Court of Auditors of Portugal (Tribunal de Contas) .................................. 23 7. National Audit Office of Finland ................................................................... 24 8. Netherlands Court of Audit (Algemene Rekenkamer) .............................. 27 9. Ireland's Office of the Comptroller and Auditor General ......................... 30 10. New Zealand's Controller and Auditor-General ........................................ 33 11. Swedish National Audit Office (Riksrevisionen) ........................................ 35 12. Swiss Federal Audit Office ............................................................................ 37 13. Italian Court of Audit (Corte dei conti) ........................................................ 41 14. Discussion Questions..................................................................................... 43 Appendix: Questionnaire for Supreme Audit Institutions............................... 48 Knesset Research and Information Center www.knesset.gov.il/mmm 3 | Aspects of the Work of Supreme Audit Institutions in Various Countries This document was originally prepared in Hebrew at the request of Members of Knesset David Bitan, Micky Rosenthal, and Karin Elharrar. It discusses various aspects of the work of supreme audit institutions in 13 OECD countries that responded to a uniform questionnaire sent to them by the Knesset Research and Information Center. Introduction More than 190 countries around the world currently have a Supreme Audit Institution (SAI).1 According to the Organisation for Economic Co-operation and Development (OECD), the role of the SAI—along with the legislative branch and other oversight agencies—is to oversee government activity and hold the government to account for its use of public funds.2 In Israel, this role is performed by the State Comptroller’s Office, which also serves as the Office of the Ombudsman.3 In this document, we were asked to examine various aspects of the work performed by SAIs. For this purpose, the Knesset Research and Information Center (RIC) developed a uniform questionnaire comprised of several sections (for the English questionnaire, see Appendix 1; for the Hebrew questionnaire see Appendix 2).4 The questionnaire was sent by the RIC to supreme audit institutions in 20 OECD countries (including Israel). The countries were selected to obtain as broad a picture as possible in order to provide exposure to diverse models. As of this writing, 13 audit institutions from the following countries have responded to the questionnaire: Austria, Australia, Italy, Ireland, Germany, Denmark, the Netherlands, New Zealand, Portugal, Finland, Canada, Sweden, and Switzerland. No response has been received from SAIs in the US, Belgium, the UK, Norway, Spain, and France. In addition, as of this writing, no response has been received from Israel's State Comptroller. Note that audit institutions in different countries do not necessarily perform the same role. More than 190 institutions from different countries, including Israel, are full members of the International Organization of Supreme Audit Institutions (INTOSAI), a voluntary organization which provides standard protocols for the 1 INTOSAI, Membership List, accessed: January 17th 2017. 2 Whenever there is more than one audit institution in a country, the "supreme audit institution" is the one to which legislation grants greater independence. See OECD, Supreme Audit Institutions and Good Governance: Oversight, Insight and Foresight, 2016, pp. 18, 30. 3 Website of the State Comptroller and Ombudsman's Office [Hebrew], International Relations, accessed: January 9th 2017. 4 The editing of the questionnaire on which this document is based, as well as the correspondence with supreme audit institutions in different countries, was performed by Dr. Adi Inbar of the Knesset Research and Information Center. Knesset Research and Information Center www.knesset.gov.il/mmm 4 | Aspects of the Work of Supreme Audit Institutions in Various Countries activities of audit institutions, among other activities.5 However, different audit institutions vary in their goals, roles, operating methods, and legal status due to the different contexts in which they developed and differences between countries' systems of government,6 justice systems, political structures, and political cultures.7 In light of the difficulties of carrying out direct comparisons, we shall present the information on each country separately based on some of the main parameters that were found in the responses. This document is based primarily on responses received from 13 audit institutions in the aforementioned countries. Each section will present the following parameters about the individual audit institution: background information (the country's population, the number of SAI employees, and the SAI's budget); sources of regulatory authority (in this section we specify the laws but do not elaborate on their content); the SAI's status; audited entities; types of audit; audit requests (from different bodies); audit timetables; work plan, considerations when performing an audit, and auditing guidelines; submission and publication of reports; recommendations and their status; the SAI's reports on its activities, internal auditing, and external oversight. When key aspects of the responses were not sufficiently clear, we used other available sources, particularly English-language publications on websites of individual SAIs and annual reports. However, due to variations between the countries regarding the additional English-language sources of information, we mostly relied on the responses we received. In some cases, particularly when the response came from an SAI in a non-English- speaking country, we presented the terms verbatim, in order to preserve the original meaning. The process of analyzing the responses led to additional difficulties. In some cases, responses were vague and inconclusive—for example, on the question of the SAI's status and the degree of independence from state authorities. Note that this question has been discussed extensively, and to our understanding, there is no single, standard definition of SAI independence. According to INTOSAI's 2007 Mexico Declaration on SAI Independence, 5 In addition to full members, the organization has five associated institutions. The organization's goal is to promote collaboration, knowledge transfer, creation and assimilation of international state auditing standards. In addition to this organization, there are seven regional organizations, such as the African Organisation of Supreme Audit Institutions (AFROSAI) and the Asian Organization of Supreme Audit Institutions (ASOSAI). Israel is a member of the INTOSAI, as well as the European Organization of Supreme Audit Institutions (EUROSAI) and ASOSAI. See INTOSAI, Membership list, accessed: January 17th 2017; About us, accessed: January 1st 2017; EUROSAI, Members, accessed: January 1st 2017; ASOSAI, Membership list, accessed: January 1st 2017; website of the State Comptroller and Ombudsman's Office [Hebrew], International connections, accessed: January 9th 2017. 6 The World Bank, Features and functions of supreme audit institutions, Premnotes 59, October 2001. 7 OECD, Supreme Audit Institutions and good governance: Oversight, insight and foresight, 2016, p. 20; Orly Fishman and Lior Ben-David, State comptroller status and powers—Comparative review [Hebrew], Knesset Research and Information Center, May 15th 2006; Michal Tamir, Critical view of state auditing [Hebrew], Israel Democracy Institute, November 2009, pp. 80–81. Knesset Research and Information Center www.knesset.gov.il/mmm 5 | Aspects of the Work of Supreme Audit Institutions in Various Countries in order for the SAI to perform its duties, it must be independent of audited entities and protected from external influences. The Mexico Declaration recognizes that SAIs cannot be completely independent, but they must have sufficient functional and organizational independence to exercise their authority. Furthermore, according to the declaration, SAIs can achieve an independent status through various means.8 In light of this complexity, when presenting the response to the question on the SAI's status, we decided to add a footnote citing the full response as it appears in the countries' responses to the questionnaire. In other cases, we tried to verify information as much as possible by cross-checking; when this was not possible, the information is not presented, and in other cases, we presented the information while noting the contradiction