State Audit in the European Union Contents Introduction Acknowledgements 1 Summary 3 Rechnungshof 35 Austria Court of Audit 51 Belgium Rigsrevisionen 61 Denmark State Audit Office 73 Finland Cour des Comptes 93 France Bundesrechnungshof 109 Germany Hellenic Court of Audit 125 Greece Office of the Comptroller and Auditor General 141 Ireland Corte dei Conti 157 Italy Cour des Comptes 171 Luxembourg Algemene Rekenkame 179 Netherlands Tribunal de Contas 193 Portugal Tribunal de Cuentas 205 Spain Riksrevisionsverket 217 Sweden National Audit Office 231 United Kingdom European Court of Auditors 251 Introduction ccountability for the use of public funds is a cornerstone of democratic Agovernment. At a national level this usually involves the executive government accounting for its stewardship of taxpayers' money to the elected representatives in Parliament. The state audit office makes an important contribution to this process by providing independent information, assurance and advice to Parliament about the accounts presented by the Executive. All state audit offices have essentially the same basic purpose - described by one writer as 'making public accountability a reality' - but the way that each fulfils this purpose is influenced by its historical background and its place in the constitutional and governmental structure. In 1996 the United Kingdom National Audit Office published a book which examined the role of each state audit office - often referred to as a Supreme Audit Institution (SAI) - in the European Union and the European Court of Auditors. The book examined the accountability relationships that then existed between the parliament, government and a variety of public sector bodies in each country, the way that state audit offices had responded to changes in the machinery of government, and the reasons for other developments in their roles. In the five years since the original book was published, there have been developments in the organisation of government, the way that government programmes are delivered and the role of the SAI in a number of European Union countries, including the United Kingdom. The National Audit Office considered, therefore, that it would be timely to update the information contained in the original book. The chapters that follow describe the audit and accountability arrangements in place in the year 2001 in each member state, as well as the European Union as a whole, without seeking to form a judgement about the effectiveness or relative merits of the systems. Each chapter is structured along similar lines. The first part deals with the political and administrative background to the work of the SAI, the second describes the audit institution and its remit, while the third part considers the audit process in more detail. Introduction The updates of the chapters relating to individual countries and the European Court of Auditors have been based upon information supplied by the SAI concerned. The first chapter is a summary of the National Audit Office's own analysis of the key aspects of accountability through audit across the European Union. It highlights similarities and differences and illustrates them with examples drawn from the other chapters. The purpose is to bring out themes and it is not intended as a comprehensive summary of the situation in every country. Although the chapter focuses primarily on the national SAIs, aspects of the role and work of the European Court of Auditors have been included where relevant. As with the original book, the project did not aim to define an ideal system of state audit, but rather to identify the differences between the systems and seek to understand the reasons for them. The chapters which follow should provide readers with a clear understanding of the role of each SAI and the environment in which it operates, and perhaps help to stimulate debate and discussion about how these roles might develop in the future. Introduction Acknowledgements his publication updates an earlier book on State Audit in the European TUnion, which was published by the National Audit Office in 1996. In updating the book the National Audit Office drew largely on the advice, knowledge and expertise of all 15 State Audit Institutions in the European Union and the European Court of Auditors. Each audit institution took the lead in updating the chapter that referred to them, and the National Audit Office are grateful to them and their staff for their co-operation and support. The National Audit Office would also like to thank Peter Keemer (formerly of the National Audit Office and the European Court of Auditors) for his advice during the project. In addition, the National Audit Office drew on a number of books and pamphlets and, in particular, would like to acknowledge reference to The Statesman's Year-Book 2000 (Macmillan). Acknowledgements 1 2 State Audit in the European Union Summary Introduction he chapters on the 15 Supreme Audit Institutions (SAIs) and the European TCourt of Auditors describe their work and the environment in which they operate. They illustrate different approaches to the task of examining public funds and reporting the results of such examinations. Some approaches are common to a number of countries, but others are specific to perhaps one or two, reflecting particular historical developments or circumstances. This chapter summarises the key aspects of accountability through audit across the European Union. It highlights similarities and differences and illustrates them with examples drawn from the previous chapters. The purpose is to draw out themes and it is not intended as a comprehensive summary of the situation in every country. Although the chapter focuses primarily on the national SAIs, aspects of the role and work of the European Court of Auditors have been included where relevant. While the content of the individual SAI chapters has been based on updates provided by the institutions themselves, this summary is the National Audit Office's own analysis. Background information he member states of the European Union are not a homogeneous group in Tterms of population, size or structure. They vary enormously, from Luxembourg with a population of 420,000 to Germany with a population 200 times bigger. In terms of land area France and Spain are the largest, with Luxembourg the smallest, followed by Belgium. And the Union includes some of the most densely populated countries in the world - the Netherlands, for example - and others such as Finland and Sweden with vast, largely uninhabited areas. Table 1 shows the population and size of each country. Summary 3 Table 1: Member states of the European Union Country Type Population Land size EC/EU m'ship (million) (sq km) Austria Republic 8.2 83,900 1995 Belgium Monarchy 10.3 30,500 1957 Denmark Monarchy 5.3 43,100 1973 Finland Republic 5.2 304,600 1995 France Republic 59.0 544,000 1957 Germany Republic 82.7 357,000 1957 Greece Republic 10.6 132,000 1981 Ireland Republic 3.7 68,900 1973 Italy Republic 57.5 301,300 1957 Luxembourg Monarchy 0.4 2,600 1957 Netherlands Monarchy 15.9 41,500 1957 Portugal Republic 9.8 91,800 1986 Spain Monarchy 39.8 504,800 1986 Sweden Monarchy 8.9 450,000 1995 United Kingdom Monarchy 59.5 244,800 1973 Source: The Statesman's Year-Book 2000 4 State Audit in the European Union The economies of the member states also vary considerably, although most could reasonably be described to a greater or lesser degree as mixed. A number - Belgium, Germany, France and the United Kingdom - are heavily industrialised, while others such as Greece and Portugal have large agricultural sectors. In recent years the services sector has grown in size and importance in a number of states, such as the United Kingdom, Portugal and the Netherlands. The balance of power varies within member states. Some, such as the United Kingdom, Portugal, Ireland and Greece, are unitary states while others, such as Belgium and Germany are federal states. Others, notably Denmark, Finland and Sweden, have devolved considerable responsibility for delivery of public services to municipalities. A requirement of membership of the European Union is that each member state must have a democratic parliamentary system. This takes a number of forms. Table 1 shows that seven member states are monarchies while the remainder are republics. The structure and size of the legislatures differ (Table 2), with six countries having a unicameral legislature and the remainder having two chambers. The electoral systems also vary, although a large majority are based on a system of proportional representation. Table 2: Legislatures - number of members Note: *Only the 400 or so non-hereditary peers have a right to speak and vote in the House of Lords. Country Lower Chamber Upper Chamber Austria 183 64 Belgium 150 71 Denmark 179 - Finland 200 - France 577 321 Germany 669 69 Greece 300 - Ireland 166 60 Italy 630 315 Summary 5 Table 2: Legislatures - number of members continued... Country Lower Chamber Upper Chamber Luxembourg 60 - Netherlands 150 75 Portugal 230 - Spain 350 255 Sweden 349 - United Kingdom 659 1,200* European Parliament 626 - The countries examined in this report do not form a complete geographical unit. The focus is solely on members of the European Union, thereby excluding Norway, which narrowly voted against membership in 1994, and Switzerland, which has traditionally avoided such commitments. The European Union has developed gradually over the past 40 years. Table 1 shows the date that each country joined the European Union (previously the European Community). In conclusion, there is much dividing the countries under consideration including history, culture and language. However, the 15 are linked by common membership of the European Union and by their shared democracy, even though the democratic processes and systems vary in many ways. It is against this background of distinct parliamentary, constitutional and administrative systems that each Supreme Audit Institution operates.