Is there an independent audit office? To what extent is it capable of exercising effective oversight?
There exists an effective and independent audit office.
10
Austria
There is an independent and powerful audit office. Formally, the Austrian Court of Audit (Rechnungshof) is an instrument of parliament. Its president is elected by parliament for a period of 12 years, without the possibility of reelection. This gives the president a high degree of independence. The Court has a well-educated staff of more than 300.
The Court of Audit reports regularly to parliament, which can order it to perform specific tasks. Consequently, the parliamentary majority determines how to handle audit reports and, in cases of doubt, the majority supports the cabinet. Thus, the primary means to compel the government to respond positively to audit reports is public opinion. The Court of Audit enjoys an impeccable public reputation, which affords it a powerful role in constitutional practice.
In several key areas, such as monitoring party finances, the Court’s competencies have been recently expanded, enabling it to play a more proactive role than in the past. Additionally, the Court’s frame of reference is not limited to financial or accounting issues. For instance, in August 2023 the Court criticized the government for lacking a comprehensive and coherent strategy for addressing violence against women (Ruep 2023).
The Court of Audit reports regularly to parliament, which can order it to perform specific tasks. Consequently, the parliamentary majority determines how to handle audit reports and, in cases of doubt, the majority supports the cabinet. Thus, the primary means to compel the government to respond positively to audit reports is public opinion. The Court of Audit enjoys an impeccable public reputation, which affords it a powerful role in constitutional practice.
In several key areas, such as monitoring party finances, the Court’s competencies have been recently expanded, enabling it to play a more proactive role than in the past. Additionally, the Court’s frame of reference is not limited to financial or accounting issues. For instance, in August 2023 the Court criticized the government for lacking a comprehensive and coherent strategy for addressing violence against women (Ruep 2023).
Citations:
Ruep, Stefanie. 2023. “Was die Regierung zum Schutz vor Gewalt an Frauen umgesetzt hat.” https://www.derstandard.at/story/3000000195715/was-die-regierung-zum-schutz-vor-gewalt-an-frauen-umgesetzt-hat
Ruep, Stefanie. 2023. “Was die Regierung zum Schutz vor Gewalt an Frauen umgesetzt hat.” https://www.derstandard.at/story/3000000195715/was-die-regierung-zum-schutz-vor-gewalt-an-frauen-umgesetzt-hat
Canada
All the provinces and the federal government have independent auditor-generals, responsible to parliaments and legislatures, not the government. These entities are well-funded and effective. In addition, it is typical for an auditor general to be appointed for a fixed term and to be removed only under specific conditions outlined in the Auditor General Act (Taft 2016).
The Auditor General of Canada plays a crucial role in ensuring transparency, accountability, and good governance within the Canadian federal government. The position is an independent officer of the Parliament of Canada, and the auditor general reports directly to the House of Commons rather than to the government. The auditor general submits annual and other reports to the Speaker of the House of Commons, who then tables them in Parliament. Due to this relationship with the House rather than with the government, the auditor general is expected to operate independently from the government. This independence is crucial for maintaining the credibility and integrity of audit findings.
The role and responsibilities of the auditor general include auditing the federal government’s financial statements and its entities to ensure compliance with best practices in public finance. This involves examining the financial transactions and reporting of government departments, agencies, and crown corporations.
The auditors general also conduct performance audits to assess whether government programs are managed effectively and achieve their intended objectives. These audits focus on areas such as efficiency, effectiveness, and compliance with laws and regulations. The auditor general typically evaluates whether government programs and operations provide value for money. This involves examining whether resources are used efficiently and whether the expected outcomes are achieved in a cost-effective manner.
The auditor general may also conduct special examinations of crown corporations and other entities as requested or on its own initiative. These examinations assess the entities’ financial management, control systems, and compliance with laws and regulations. The auditor general also monitors and reports on the government’s progress in implementing recommendations from previous audit reports. This follow-up process is intended to ensure that the government takes corrective action and is held accountable for addressing identified issues.
The Auditor General of Canada plays a crucial role in ensuring transparency, accountability, and good governance within the Canadian federal government. The position is an independent officer of the Parliament of Canada, and the auditor general reports directly to the House of Commons rather than to the government. The auditor general submits annual and other reports to the Speaker of the House of Commons, who then tables them in Parliament. Due to this relationship with the House rather than with the government, the auditor general is expected to operate independently from the government. This independence is crucial for maintaining the credibility and integrity of audit findings.
The role and responsibilities of the auditor general include auditing the federal government’s financial statements and its entities to ensure compliance with best practices in public finance. This involves examining the financial transactions and reporting of government departments, agencies, and crown corporations.
The auditors general also conduct performance audits to assess whether government programs are managed effectively and achieve their intended objectives. These audits focus on areas such as efficiency, effectiveness, and compliance with laws and regulations. The auditor general typically evaluates whether government programs and operations provide value for money. This involves examining whether resources are used efficiently and whether the expected outcomes are achieved in a cost-effective manner.
The auditor general may also conduct special examinations of crown corporations and other entities as requested or on its own initiative. These examinations assess the entities’ financial management, control systems, and compliance with laws and regulations. The auditor general also monitors and reports on the government’s progress in implementing recommendations from previous audit reports. This follow-up process is intended to ensure that the government takes corrective action and is held accountable for addressing identified issues.
Citations:
Taft, Jordan. 2016. “From Change to Stability: Investigating Canada’s Office of the Auditor General.” Canadian Public Administration 59 (3): 467–85. https://doi.org/10.1111/capa.12176
Taft, Jordan. 2016. “From Change to Stability: Investigating Canada’s Office of the Auditor General.” Canadian Public Administration 59 (3): 467–85. https://doi.org/10.1111/capa.12176
Denmark
There are two main independent audit functions in Denmark: the institution of the ombudsman and the National Audit Office (Rigsrevisionen).
In 1955, Denmark became the third country in the world, after Sweden and Finland, to introduce the institution of the ombudsman. The ombudsman is appointed by parliament, and the office operates as an independent institution. Distinguished law professors have often held the position, especially in the early years. The ombudsman office audits bureaucracies to ensure they follow the law and defends citizens’ rights vis-à-vis the bureaucracy. The ombudsman can decide to take up a case on its own or, more commonly, based on a complaint from a citizen. In 2021, the ombudsman handled 5,272 cases, of which 148 were initiated by the office (Ombudsman 2022). Criticisms from the ombudsman normally lead to a change in practice or policy.
The National Audit Office is an independent institution under the authority of parliament and employs approximately 300 academically trained staff. The National Audit Office assists the parliamentary Public Accounts Committee in processing public accounts and supports Danish parliament members in their assessment of these accounts. The office issues independent audit opinions at the ministry level and provides opinions on the overall Danish public accounts. Additionally, the National Audit Office undertakes major studies of specific policy areas, with the results reported to the Public Accounts Committee.
The National Audit Office’s work is highly respected and can lead to policy action. This was seen recently, for instance, in the case of a report on the security surrounding critical IT infrastructure. The National Audit Office found that seven out of 12 systems were insufficiently secure (Rigsrevisionen 2023), which led the government to propose increased funding to enhance the security of these systems.
In 1955, Denmark became the third country in the world, after Sweden and Finland, to introduce the institution of the ombudsman. The ombudsman is appointed by parliament, and the office operates as an independent institution. Distinguished law professors have often held the position, especially in the early years. The ombudsman office audits bureaucracies to ensure they follow the law and defends citizens’ rights vis-à-vis the bureaucracy. The ombudsman can decide to take up a case on its own or, more commonly, based on a complaint from a citizen. In 2021, the ombudsman handled 5,272 cases, of which 148 were initiated by the office (Ombudsman 2022). Criticisms from the ombudsman normally lead to a change in practice or policy.
The National Audit Office is an independent institution under the authority of parliament and employs approximately 300 academically trained staff. The National Audit Office assists the parliamentary Public Accounts Committee in processing public accounts and supports Danish parliament members in their assessment of these accounts. The office issues independent audit opinions at the ministry level and provides opinions on the overall Danish public accounts. Additionally, the National Audit Office undertakes major studies of specific policy areas, with the results reported to the Public Accounts Committee.
The National Audit Office’s work is highly respected and can lead to policy action. This was seen recently, for instance, in the case of a report on the security surrounding critical IT infrastructure. The National Audit Office found that seven out of 12 systems were insufficiently secure (Rigsrevisionen 2023), which led the government to propose increased funding to enhance the security of these systems.
Citations:
Ombudman. 2022. Folketingets Ombudsmands beretning 2022. https://www.ombudsmanden.dk/findviden/fob/fob2022/
Rigsrevisionen. 2023. “Beretning om statens it-beredskab II.” https://rigsrevisionen.dk/revisionssager-arkiv/2023/dec/beretning-om-statens-it-beredskab-ii
Ombudman. 2022. Folketingets Ombudsmands beretning 2022. https://www.ombudsmanden.dk/findviden/fob/fob2022/
Rigsrevisionen. 2023. “Beretning om statens it-beredskab II.” https://rigsrevisionen.dk/revisionssager-arkiv/2023/dec/beretning-om-statens-it-beredskab-ii
Finland
Legislative accountability in Finland is advanced by the Audit Office, which is accountable to parliament. Formerly, parliamentary oversight of government finances was performed by parliamentary state auditors. However, this institution has been abolished. In its place is the parliamentary Audit Committee, which was created by combining the tasks performed by the parliamentary state auditors with the related functions of the administrative and audit section of the Finance Committee. The office of the parliamentary state auditors has also been replaced by the National Audit Office of Finland, an independent expert body affiliated with parliament.
The role and duties of the National Audit Office of Finland (NAOF) are defined in the country’s constitution (Section 90). The NAOF audits central government finances, monitors fiscal policy, and oversees political party and election campaign funding (National Audit Office of Finland 2023). It is also tasked with auditing the legality and propriety of the state’s financial arrangements and reviewing compliance with the state budget.
The office is directed by the auditor general, who is elected by parliament. The National Audit Office of Finland (NAOF) examines the legality, productivity and adherence to the budget of government finances, as mandated by section 90 of the Finnish Constitution. It verifies the accuracy of information presented to parliament regarding central government finances, their management and adherence to fiscal policy regulations.
The NAOF does not audit parliament’s finances, funds under parliament’s jurisdiction, the Bank of Finland, the Financial Supervisory Authority or the Social Insurance Institution. Internal audit guidelines based on ISSAI auditing standards form the basis for NAOF’s audit processes, supplemented by manuals tailored to compliance audits, performance audits and fiscal policy audits.
NAOF plays a crucial role in monitoring and overseeing fiscal policy to ensure the stability and sustainability of public finances, as well as compliance with fiscal policy rules. Empowered by the Fiscal Policy Act, it supervises the establishment and adherence to these rules.
Additionally, the NAOF oversees election campaigns and political party funding to ensure compliance with the Act on Political Parties and the Act on a Candidate’s Election Funding. Starting in 2024, lobbying activities directed at parliament and ministries must be reported to the transparency register. The NAOF will act as the registrar and oversee compliance with this disclosure obligation.
In 2021, the Audit Office was embroiled in a scandal that temporarily undermined its operational capacity. Parliament ultimately decided to fire the body’s general director and appoint a new, independent general director. The decision was made in parliament without consultation with the judiciary. However, the person at the center of the scandal was later convicted in court (YLE, 2021).
With about 150 staff members, the financial and personnel resources align with the requirements of the Audit Office to effectively carry out its mandate.
The Audit Office also conducts follow-up investigations to determine if its recommendations have been implemented. The findings of both the original and follow-up reports are reported in the media and used by the legislature.
The role and duties of the National Audit Office of Finland (NAOF) are defined in the country’s constitution (Section 90). The NAOF audits central government finances, monitors fiscal policy, and oversees political party and election campaign funding (National Audit Office of Finland 2023). It is also tasked with auditing the legality and propriety of the state’s financial arrangements and reviewing compliance with the state budget.
The office is directed by the auditor general, who is elected by parliament. The National Audit Office of Finland (NAOF) examines the legality, productivity and adherence to the budget of government finances, as mandated by section 90 of the Finnish Constitution. It verifies the accuracy of information presented to parliament regarding central government finances, their management and adherence to fiscal policy regulations.
The NAOF does not audit parliament’s finances, funds under parliament’s jurisdiction, the Bank of Finland, the Financial Supervisory Authority or the Social Insurance Institution. Internal audit guidelines based on ISSAI auditing standards form the basis for NAOF’s audit processes, supplemented by manuals tailored to compliance audits, performance audits and fiscal policy audits.
NAOF plays a crucial role in monitoring and overseeing fiscal policy to ensure the stability and sustainability of public finances, as well as compliance with fiscal policy rules. Empowered by the Fiscal Policy Act, it supervises the establishment and adherence to these rules.
Additionally, the NAOF oversees election campaigns and political party funding to ensure compliance with the Act on Political Parties and the Act on a Candidate’s Election Funding. Starting in 2024, lobbying activities directed at parliament and ministries must be reported to the transparency register. The NAOF will act as the registrar and oversee compliance with this disclosure obligation.
In 2021, the Audit Office was embroiled in a scandal that temporarily undermined its operational capacity. Parliament ultimately decided to fire the body’s general director and appoint a new, independent general director. The decision was made in parliament without consultation with the judiciary. However, the person at the center of the scandal was later convicted in court (YLE, 2021).
With about 150 staff members, the financial and personnel resources align with the requirements of the Audit Office to effectively carry out its mandate.
The Audit Office also conducts follow-up investigations to determine if its recommendations have been implemented. The findings of both the original and follow-up reports are reported in the media and used by the legislature.
Citations:
National Audit Office of Finland. 2023. https://www.vtv.fi/en/ (Accessed 22 December 2023)
YLE. 2021. “Court fines former auditor general for abuse of office.” https://yle.fi/news/3-12292381
National Audit Office of Finland. 2023. https://www.vtv.fi/en/ (Accessed 22 December 2023)
YLE. 2021. “Court fines former auditor general for abuse of office.” https://yle.fi/news/3-12292381
Germany
The Basic Law assigns the Federal Court of Audit (Bundesrechnungshof) the responsibility for public auditing in Germany, specifically auditing accounts and ensuring the federation properly and efficiently administers public finances. To carry out these duties, members of the court enjoy judicial independence (Article 114, Paragraph 2, Basic Law). As an independent body, the Federal Court of Audit is subject only to the law and holds the same status as the federal ministries, the Office of the Federal President, and the Federal Chancellery. It is autonomous and independent in its choice of audit methods, the depth of the audit, and has the legal authority to decide on the content of the audit (Seyfried, 2021).
During an audit, relevant bodies are required to provide information and cooperate, including sharing confidential or secret data. The Federal Court of Audit must simply state that the information is essential to fulfilling its mandate to obtain the necessary information (Article 28 Prüfungsordnung des Bundesrechnungshofes).
The president of the Federal Court of Audit is elected by parliament (Bundestag) and the Federal Council (Bundesrat) based on the federal government’s suggestion. After the election, the president is appointed by the federal president. There is no debate prior to the election, and the Bundestag vote is conducted in secret, requiring a majority of its members. This process ensures the independence of the court’s president, and reelection is not permitted (Article 5 Bundesrechnungshofgesetz). Given that the court’s members, including the president, enjoy judicial independence, the potential removal of the president adheres to Article 97 of the Basic Law, which outlines judicial independence. Thus, dismissal, whether permanent or temporary, is only possible through a judicial decision based on the law.
As a federal authority, the Federal Court of Audit’s financial and personnel resources are funded by the federal budget. The court submits its budget request, including estimates of the resources required to fulfill its mandate, to the federal government, where the final budget is then subject to political negotiations. Currently, the court has a staff of around 1,050 employees and an annual budget of €187 million (Bundesrechnungshof, 2023a). While these costs are low compared to the size of the federal budget (below 0.1%), the resources should be sufficient to effectively monitor the federal budget given the size of the institution.
According to the Open Budget Survey (2021), Germany’s budget oversight, comprising audit and legislative oversight, scores an impressive 91 out of 100 points, ranking it first in global budget oversight. The audit oversight alone is awarded a score of 95. Additionally, the survey rates public access to budgetary information at 73 out of 100, and the audit report – which examines the soundness and completeness of the government’s year-end accounts – at 67 points. Since these scores exceed 61 points, they indicate that Germany publishes sufficient information about the use of public resources to facilitate effective public debate.
Nevertheless, the Federal Court of Audit only examines, criticizes, or recommends cost-saving measures and does not have the authority to issue legally binding judgments. For media access, the Court publishes press releases, statements, and background information on its website. The Court further encourages the media to contact the designated press officer with any questions or requests for additional information (Bundesrechnungshof, 2023b). The legislature reviews the Court’s reports and regularly invites Court representatives to public hearings. If federal ministries receive critical remarks or suggestions for changes from the Court, they must adhere to the “comply or explain” principle. They may diverge from the Court’s guidance but must provide arguments to justify their disagreement with a particular view or suggestion.
During an audit, relevant bodies are required to provide information and cooperate, including sharing confidential or secret data. The Federal Court of Audit must simply state that the information is essential to fulfilling its mandate to obtain the necessary information (Article 28 Prüfungsordnung des Bundesrechnungshofes).
The president of the Federal Court of Audit is elected by parliament (Bundestag) and the Federal Council (Bundesrat) based on the federal government’s suggestion. After the election, the president is appointed by the federal president. There is no debate prior to the election, and the Bundestag vote is conducted in secret, requiring a majority of its members. This process ensures the independence of the court’s president, and reelection is not permitted (Article 5 Bundesrechnungshofgesetz). Given that the court’s members, including the president, enjoy judicial independence, the potential removal of the president adheres to Article 97 of the Basic Law, which outlines judicial independence. Thus, dismissal, whether permanent or temporary, is only possible through a judicial decision based on the law.
As a federal authority, the Federal Court of Audit’s financial and personnel resources are funded by the federal budget. The court submits its budget request, including estimates of the resources required to fulfill its mandate, to the federal government, where the final budget is then subject to political negotiations. Currently, the court has a staff of around 1,050 employees and an annual budget of €187 million (Bundesrechnungshof, 2023a). While these costs are low compared to the size of the federal budget (below 0.1%), the resources should be sufficient to effectively monitor the federal budget given the size of the institution.
According to the Open Budget Survey (2021), Germany’s budget oversight, comprising audit and legislative oversight, scores an impressive 91 out of 100 points, ranking it first in global budget oversight. The audit oversight alone is awarded a score of 95. Additionally, the survey rates public access to budgetary information at 73 out of 100, and the audit report – which examines the soundness and completeness of the government’s year-end accounts – at 67 points. Since these scores exceed 61 points, they indicate that Germany publishes sufficient information about the use of public resources to facilitate effective public debate.
Nevertheless, the Federal Court of Audit only examines, criticizes, or recommends cost-saving measures and does not have the authority to issue legally binding judgments. For media access, the Court publishes press releases, statements, and background information on its website. The Court further encourages the media to contact the designated press officer with any questions or requests for additional information (Bundesrechnungshof, 2023b). The legislature reviews the Court’s reports and regularly invites Court representatives to public hearings. If federal ministries receive critical remarks or suggestions for changes from the Court, they must adhere to the “comply or explain” principle. They may diverge from the Court’s guidance but must provide arguments to justify their disagreement with a particular view or suggestion.
Citations:
Bundesrechnungshof. 2023a. “https://www.bundesrechnungshof.de/DE/5_ueber_uns/1_wer_wir_sind/wer_wir_sind_node.html”
Bundesrechnungshof. 2023b. “https://www.bundesrechnungshof.de/DE/7_presse/presse_node.html” (accessed: 13.11.23)
International Budget Partnership. 2021. “Open Budget Survey 2021.” https://internationalbudget.org/sites/default/files/country-surveys-pdfs/2021/open-budget-survey-germany-2021-en.pdf
International Budget Partnership. 2021. “Open Budget Survey 2021. 8th Edition.” https://internationalbudget.org/wp-content/uploads/Open-budget-survey-2021-1.pdf
Seyfried, M. 2021. “Bundesrechnungshof.” In Handwörterbuch des politischen Systems der Bundesrepublik Deutschland, eds. Andersen, U., Bogumil, J., Marschall, S., and Woyke, W. Wiesbaden: Springer VS.
Bundesrechnungshof. 2023a. “https://www.bundesrechnungshof.de/DE/5_ueber_uns/1_wer_wir_sind/wer_wir_sind_node.html”
Bundesrechnungshof. 2023b. “https://www.bundesrechnungshof.de/DE/7_presse/presse_node.html” (accessed: 13.11.23)
International Budget Partnership. 2021. “Open Budget Survey 2021.” https://internationalbudget.org/sites/default/files/country-surveys-pdfs/2021/open-budget-survey-germany-2021-en.pdf
International Budget Partnership. 2021. “Open Budget Survey 2021. 8th Edition.” https://internationalbudget.org/wp-content/uploads/Open-budget-survey-2021-1.pdf
Seyfried, M. 2021. “Bundesrechnungshof.” In Handwörterbuch des politischen Systems der Bundesrepublik Deutschland, eds. Andersen, U., Bogumil, J., Marschall, S., and Woyke, W. Wiesbaden: Springer VS.
New Zealand
New Zealand has an independent audit office known as the Office of the Auditor-General (OAG). The OAG operates independently from the government and is responsible for auditing the public sector, including government departments, local authorities, state-owned enterprises and other public entities.
The Office of the Auditor-General conducts various audits to ensure effective oversight of public entities. These include financial audits, performance audits, and compliance audits (Controller and Auditor-General n.d.).
A much-publicized intervention by the OAG in 2023 was the audit of the Labour government’s handling of $640 million in the Provincial Growth Fund (PGF). The OAG found that applications to the PGF were assessed “inconsistently” and that there was a lack of risk management functions. However, the OAG also stressed that it might take years before the economic, social, cultural or environmental impacts of any of the PGF-funded projects could be properly assessed (Cheng 2023).
The Office of the Auditor-General conducts various audits to ensure effective oversight of public entities. These include financial audits, performance audits, and compliance audits (Controller and Auditor-General n.d.).
A much-publicized intervention by the OAG in 2023 was the audit of the Labour government’s handling of $640 million in the Provincial Growth Fund (PGF). The OAG found that applications to the PGF were assessed “inconsistently” and that there was a lack of risk management functions. However, the OAG also stressed that it might take years before the economic, social, cultural or environmental impacts of any of the PGF-funded projects could be properly assessed (Cheng 2023).
Citations:
Cheng, D. 2023. “Auditor-General’s Office says no visibility on whether $640m in PGF funds is value for money.” Stuff, 22 June. https://www.nzherald.co.nz/nz/politics/auditor-generals-office-says-no-visibility-on-whether-640m-in-pgf-money-is-value-for-money/RXZ36ZCDP5BOHPZIVOM6GNF6I4/
Controller and Auditor-General. n.d. “What we do.” https://oag.parliament.nz/about-us/what-we-do
Cheng, D. 2023. “Auditor-General’s Office says no visibility on whether $640m in PGF funds is value for money.” Stuff, 22 June. https://www.nzherald.co.nz/nz/politics/auditor-generals-office-says-no-visibility-on-whether-640m-in-pgf-money-is-value-for-money/RXZ36ZCDP5BOHPZIVOM6GNF6I4/
Controller and Auditor-General. n.d. “What we do.” https://oag.parliament.nz/about-us/what-we-do
Norway
Norway’s independent statutory authority, the Office of the Auditor General (OAG), is named in the constitution and is accountable to parliament. Its main task is to ensure that the central government’s resources and assets are used and managed according to sound financial principles and in compliance with parliamentary decisions. In recent years, evaluations of the attainment of reform goals and the effectiveness of new laws have become increasingly important. The operations of fully and partially state-owned companies are also scrutinized. The OAG has 450 employees and is governed by a board of five directors, all selected by parliament for four years. The auditor general, appointed by parliament for a four-year term, leads the OAG. Decisions of the OAG have consistently been consensual. The government is required to follow up on all OAG reports. Failure to do so may result in a vote of no confidence in parliament.
Since 1962, Norway has had a Parliamentary Ombud appointed by parliament. This office investigates complaints from citizens regarding injustices, abuses, or errors by central or local public administrations. Additionally, the Ombud ensures that human rights are respected and conducts independent investigations. Every year, the Ombud’s office submits a report to parliament documenting its activities. Generally, the Ombud is active and trusted.
However, the Ombud has recently expressed concerns about the risk of losing funding and popular legitimacy because too few of its recommendations are taken seriously and implemented. Since 1962, the Ombud institution has been extended to other policy areas. The Ombudsperson for Children was established in 1981, followed by the Ombudsperson for Nondiscrimination in 2006, and the Ombudsperson for Older People in 2021.
Since 2017, all ministries have been required to formally assess the impacts of their policies on civil protection and emergency preparedness. The purpose of these written instructions was “to reinforce society’s capacity to prevent crises and to deal with serious incidents by means of comprehensive and coordinated work with civil protection and emergency preparedness” (Norwegian Ministry of Justice and Public Security, 2017). Although this instrument is not implemented or assessed by an independent body, it serves as an example of horizontal coordination. However, the OAG might, on its own initiative, assess whether ministries comply with the regulation.
Since 1962, Norway has had a Parliamentary Ombud appointed by parliament. This office investigates complaints from citizens regarding injustices, abuses, or errors by central or local public administrations. Additionally, the Ombud ensures that human rights are respected and conducts independent investigations. Every year, the Ombud’s office submits a report to parliament documenting its activities. Generally, the Ombud is active and trusted.
However, the Ombud has recently expressed concerns about the risk of losing funding and popular legitimacy because too few of its recommendations are taken seriously and implemented. Since 1962, the Ombud institution has been extended to other policy areas. The Ombudsperson for Children was established in 1981, followed by the Ombudsperson for Nondiscrimination in 2006, and the Ombudsperson for Older People in 2021.
Since 2017, all ministries have been required to formally assess the impacts of their policies on civil protection and emergency preparedness. The purpose of these written instructions was “to reinforce society’s capacity to prevent crises and to deal with serious incidents by means of comprehensive and coordinated work with civil protection and emergency preparedness” (Norwegian Ministry of Justice and Public Security, 2017). Although this instrument is not implemented or assessed by an independent body, it serves as an example of horizontal coordination. However, the OAG might, on its own initiative, assess whether ministries comply with the regulation.
Citations:
Riksrevisjonen. 2024. Annual Report 2023. Document 2 (2023-2024). https://www.riksrevisjonen.no/contentassets/9e1061c5f7fe4678b4b93e5d1e5bb611/annual-report-2023.pdf
Norwegian Ministry of Justice and Public Security. 2017. “Instructions for the Ministries’ Work with Civil Protection and Emergency Preparedness.” https://www.regjeringen.no/en/dokumenter/instructions-for-the-ministries-work-with-civil-protection-and-emergency-preparedness/id2569693/
Riksrevisjonen. 2024. Annual Report 2023. Document 2 (2023-2024). https://www.riksrevisjonen.no/contentassets/9e1061c5f7fe4678b4b93e5d1e5bb611/annual-report-2023.pdf
Norwegian Ministry of Justice and Public Security. 2017. “Instructions for the Ministries’ Work with Civil Protection and Emergency Preparedness.” https://www.regjeringen.no/en/dokumenter/instructions-for-the-ministries-work-with-civil-protection-and-emergency-preparedness/id2569693/
Sweden
Riksrevisionen, the Swedish National Audit Office (Swedish NAO), is the independent auditing body.
It is an independent public agency under the Riksdag charged with auditing public agencies and operations. Established after a 2003 reform, its purpose is to oversee the financial operations of Swedish public agencies and ensure that resources are used according to the decisions made in the Riksdag.
It is the only body with the authority to audit all state finances. The Swedish NAO also has significant international operations, with a mandate to help developing countries build better auditing practices (Riskrevisionen, n.d.,a; n.d.,b). It issues numerous audit reports available on its website, many also in English. A search in the Retriever database (covering print and digital media, radio, and TV) conducted in January 2023, with the keyword “Riskrevisionen,” returned 13,671 hits for the two-year period 2022 – 2023. The amount, diversity, and relevance of the reports result in considerable media attention.
It is an independent public agency under the Riksdag charged with auditing public agencies and operations. Established after a 2003 reform, its purpose is to oversee the financial operations of Swedish public agencies and ensure that resources are used according to the decisions made in the Riksdag.
It is the only body with the authority to audit all state finances. The Swedish NAO also has significant international operations, with a mandate to help developing countries build better auditing practices (Riskrevisionen, n.d.,a; n.d.,b). It issues numerous audit reports available on its website, many also in English. A search in the Retriever database (covering print and digital media, radio, and TV) conducted in January 2023, with the keyword “Riskrevisionen,” returned 13,671 hits for the two-year period 2022 – 2023. The amount, diversity, and relevance of the reports result in considerable media attention.
Citations:
Riskrevisionen. (n.d.a). “About the Swedish NAO.” https://www.riksrevisionen.se/en/about-the-swedish-nao.html
Riskrevisionen. n.d., b. “International Operations.” https://www.riksrevisionen.se/en/international-operations.html
Riskrevisionen. (n.d.a). “About the Swedish NAO.” https://www.riksrevisionen.se/en/about-the-swedish-nao.html
Riskrevisionen. n.d., b. “International Operations.” https://www.riksrevisionen.se/en/international-operations.html
Switzerland
“Within the scope of legal and constitutional provisions, the Swiss Federal Audit Office (SFAO) is independent and autonomous. It determines its own audit program annually based on risk analysis and on criteria contained in Article 5 of the Federal Auditing Act. The Federal Council and the Joint Committee on Finance of the Federal Assembly are notified of this program. For administrative purposes, the Swiss Federal Audit Office is assigned to the Federal Department of Finance, but is not subordinate to it” (SFAO 224a).
Switzerland’s Audit Office supports the Federal Assembly and the Federal Council through the production of analyses and reports. The chairman of the Audit Office is elected by the Federal Council; this election must be confirmed by the Federal Assembly. The Audit Office acquired a very independent and self-confident role in the case of the politically controversial export of arms to war-prone regions (NZZ 4 September 2018). It has harshly criticized the federal administration for being insufficiently critical of and for working too closely with representatives of the arms industry.
The power and salience of the Audit Office have been further strengthened by the new rules on political-party financing transparency (SFAO 2024b). The Audit Office has substantial inquiry powers and means. Although it is affiliated with the Department of Finance, its mandate extends beyond strictly financial audits, and include the implementation and impact of laws. The Audit Office now has a dedicated line of action regarding whistleblowing.
Switzerland’s Audit Office supports the Federal Assembly and the Federal Council through the production of analyses and reports. The chairman of the Audit Office is elected by the Federal Council; this election must be confirmed by the Federal Assembly. The Audit Office acquired a very independent and self-confident role in the case of the politically controversial export of arms to war-prone regions (NZZ 4 September 2018). It has harshly criticized the federal administration for being insufficiently critical of and for working too closely with representatives of the arms industry.
The power and salience of the Audit Office have been further strengthened by the new rules on political-party financing transparency (SFAO 2024b). The Audit Office has substantial inquiry powers and means. Although it is affiliated with the Department of Finance, its mandate extends beyond strictly financial audits, and include the implementation and impact of laws. The Audit Office now has a dedicated line of action regarding whistleblowing.
Citations:
SFAO (Swiss Federal Audit Office, Eidgenössische Finanzkonrolle). 2024. “Legal mandate.” https://www.efk.admin.ch/en/about-us/act.html
SFAO (Swiss Federal Audit Office, Eidgenössische Finanzkonrolle). 2024. “How does transparency in political funding work in Switzerland?” https://www.efk.admin.ch/en/political-funding/background/how-does-transparency-in-political-funding-work-in-switzerland.html
SFAO (Swiss Federal Audit Office, Eidgenössische Finanzkonrolle). 2024. “Legal mandate.” https://www.efk.admin.ch/en/about-us/act.html
SFAO (Swiss Federal Audit Office, Eidgenössische Finanzkonrolle). 2024. “How does transparency in political funding work in Switzerland?” https://www.efk.admin.ch/en/political-funding/background/how-does-transparency-in-political-funding-work-in-switzerland.html
UK
The National Audit Office (NAO) is independent of both the government and the civil service, and it is overseen by the Public Accounts Committee (PAC) of the House of Commons. The NAO examines government departments, executive agencies, and arm’s-length bodies, focusing on assessing the value for money of public spending. It also provides guides on good practice and distills lessons learned on cross-cutting issues important to the government. The NAO is led by the Comptroller and Auditor General, an officer of the House of Commons with statutory authority. By working closely with the PAC, which had 41 active inquiries at the end of 2023, the NAO can both select its investigations and influence public debate. However, the NAO clarifies that its purpose is to investigate whether public money has been well used, not to question government policy objectives.
The NAO conducts over 400 financial audits annually, including audits of all government departments, executive agencies, arm’s-length bodies, companies audited under statute or on a voluntary basis, and some charities. Additionally, the NAO publishes around 60 value-for-money reports each year, making recommendations for more efficient and effective spending. It also issues lessons learned reports and good practice guides. The NAO has some international activities, serving as the external auditor for certain international organizations and providing technical assistance to audit institutions in countries receiving UK aid.
NAO reports, often discussed in the PAC, receive extensive media coverage and frequently highlight issues for public authorities. For example, a 2021 report on COVID-19 criticized the procurement of personal protective equipment (PPE) and other goods and services through emergency direct awards instead of established procurement procedures. In the same year, the NAO found that the government was too slow in disbursing compensation to victims of the Windrush scandal. In 2023, the NAO drew attention to delays in auditing local authorities in England, several of which subsequently admitted to insolvency risks.
Each devolved parliament and government has its own audit office, conducting equivalent research and audit functions. These offices are essential for scrutinizing devolved public services. However, issues such as COVID-19 policy, where both UK and devolved governments funded initiatives, highlight the limitations of these offices in auditing the full range of activities in each country.
The NAO conducts over 400 financial audits annually, including audits of all government departments, executive agencies, arm’s-length bodies, companies audited under statute or on a voluntary basis, and some charities. Additionally, the NAO publishes around 60 value-for-money reports each year, making recommendations for more efficient and effective spending. It also issues lessons learned reports and good practice guides. The NAO has some international activities, serving as the external auditor for certain international organizations and providing technical assistance to audit institutions in countries receiving UK aid.
NAO reports, often discussed in the PAC, receive extensive media coverage and frequently highlight issues for public authorities. For example, a 2021 report on COVID-19 criticized the procurement of personal protective equipment (PPE) and other goods and services through emergency direct awards instead of established procurement procedures. In the same year, the NAO found that the government was too slow in disbursing compensation to victims of the Windrush scandal. In 2023, the NAO drew attention to delays in auditing local authorities in England, several of which subsequently admitted to insolvency risks.
Each devolved parliament and government has its own audit office, conducting equivalent research and audit functions. These offices are essential for scrutinizing devolved public services. However, issues such as COVID-19 policy, where both UK and devolved governments funded initiatives, highlight the limitations of these offices in auditing the full range of activities in each country.
9
Australia
Australia has well-resourced audit offices at federal and state levels, ensuring effectiveness in this area. The Australian National Audit Office (ANAO), led by the Auditor-General, audits Commonwealth agencies’ financial statements and conducts performance assessments. Parallel institutions exist at the state level to monitor state agencies’ activities. While there is little evidence of corruption or extreme maladministration in the public sector, commentary suggests some areas of weakness, including procurement, cybersecurity, and grants administration (Macdonald 2022). Furthermore, it has been observed that on a few occasions there have been efforts by an Australian government to obstruct the oversight activities of the Auditor-General by resorting to the doctrine of cabinet confidentiality (Patrick 2023). However, this practice and line of argument is unusual.
Citations:
Macdonald, A. 2022. “ANAO Auditor-General Says Public Sector Regularly Falls Short in Three Areas.” The Mandarin August 26. https://www.themandarin.com.au/198283-anao-auditor-general-says-public-sector-regularly-falls-short-in-three-areas/
Patrick, R. 2023. “If the Premier Won’t Be Transparent, the Auditor-General Should Take Action.” In Daily October 9. https://indaily.com.au/opinion/2023/10/09/if-the-premier-wont-be-transparent-the-auditor-general-should-take-action
Macdonald, A. 2022. “ANAO Auditor-General Says Public Sector Regularly Falls Short in Three Areas.” The Mandarin August 26. https://www.themandarin.com.au/198283-anao-auditor-general-says-public-sector-regularly-falls-short-in-three-areas/
Patrick, R. 2023. “If the Premier Won’t Be Transparent, the Auditor-General Should Take Action.” In Daily October 9. https://indaily.com.au/opinion/2023/10/09/if-the-premier-wont-be-transparent-the-auditor-general-should-take-action
Belgium
Established by the constitution (Article 180), the Court of Audit (Cour des Comptes/Rekenhof) is a collateral body of parliament. It exerts external control over the budgetary, accounting, and financial operations of the federal state, the communities, the regions, public-service institutions that depend on them, and the provinces. Some public firms and nonprofit organizations are also subject to review, such as the Flemish public-transportation firm De Lijn, which was audited in 2013.
The Court of Audit’s legal powers grant it considerable independence and broad autonomy to fulfill its mandate. Members of the Court of Audit are elected by parliament. The court’s reports are public and presented to parliament along with the state accounts. The body regularly attracts media attention for its critical remarks regarding the management of public entities or services, such as roads in Wallonia or so-called Economic Activity Zones. However, its recommendations and criticisms are seldom followed up with concrete political actions.
The Court of Audit’s legal powers grant it considerable independence and broad autonomy to fulfill its mandate. Members of the Court of Audit are elected by parliament. The court’s reports are public and presented to parliament along with the state accounts. The body regularly attracts media attention for its critical remarks regarding the management of public entities or services, such as roads in Wallonia or so-called Economic Activity Zones. However, its recommendations and criticisms are seldom followed up with concrete political actions.
Citations:
https://www.rtbf.be/article/la-cour-des-comptes-dezingue-la-gestion-des-parcs-d-activites-economiques-en-wallonie-11171356
https://www.ccrek.be/EN/Presentation/Presentation.html
https://www.courdescomptes.be/EN/
https://www.rtbf.be/article/la-cour-des-comptes-dezingue-la-gestion-des-parcs-d-activites-economiques-en-wallonie-11171356
https://www.ccrek.be/EN/Presentation/Presentation.html
https://www.courdescomptes.be/EN/
Czechia
The Supreme Audit Office (Nejvyšší kontrolní úřad, NKÚ) was established in 1993 (law 166/1993) as an independent audit institution. It oversees public spending and budgeting, evaluating the effectiveness, economy, and efficiency of public resource utilization and identifying weaknesses in their expenditure.
The NKÚ provides independent and impartial reports to the government, the Chamber of Deputies, the Senate, experts, and the public. These reports assess whether national resources have been used effectively, economically, and efficiently, and whether all binding legal regulations have been observed. NKÚ officers face no term limits but must retire at age 65. The president of the Czech Republic nominates the leadership, and all nominations are confirmed by the parliament. On average, the NKÚ audits CZK 230 billion per year, completing 33 control actions in 2022, investigating 167 individuals, and making 19 recommendations.
The NKÚ’s annual report for 2022 emphasized the need for substantial changes to achieve sustainable budgets. This commentary mirrored the government’s analysis justifying its 2023 package of measures and was implicitly controversial both politically and economically, as discussed under Sustainable Budget Policies.
The report also conducted several investigations into individual government expenditures, uncovering various weaknesses and irregularities. For example, goals for digitalization had not been met and relied heavily on one-off funding from the EU, raising concerns about the lack of guaranteed long-term funding. The use of EU funds during 2016-2017 (the most recent period investigated) was often improperly planned and controlled. Allocations frequently did not follow stated rules, despite contemporary reports suggesting compliance. In practice, allocated sums were often higher than those specified in the bidding process, with inadequate recording of spending and evaluation of impacts. Moreover, assistance intended for smaller enterprises frequently benefited large firms.
While effective auditing is in place, it remains up to public bodies to address the issues raised by the audit office. Past experience shows that media attention is sometimes drawn to these findings.
The NKÚ provides independent and impartial reports to the government, the Chamber of Deputies, the Senate, experts, and the public. These reports assess whether national resources have been used effectively, economically, and efficiently, and whether all binding legal regulations have been observed. NKÚ officers face no term limits but must retire at age 65. The president of the Czech Republic nominates the leadership, and all nominations are confirmed by the parliament. On average, the NKÚ audits CZK 230 billion per year, completing 33 control actions in 2022, investigating 167 individuals, and making 19 recommendations.
The NKÚ’s annual report for 2022 emphasized the need for substantial changes to achieve sustainable budgets. This commentary mirrored the government’s analysis justifying its 2023 package of measures and was implicitly controversial both politically and economically, as discussed under Sustainable Budget Policies.
The report also conducted several investigations into individual government expenditures, uncovering various weaknesses and irregularities. For example, goals for digitalization had not been met and relied heavily on one-off funding from the EU, raising concerns about the lack of guaranteed long-term funding. The use of EU funds during 2016-2017 (the most recent period investigated) was often improperly planned and controlled. Allocations frequently did not follow stated rules, despite contemporary reports suggesting compliance. In practice, allocated sums were often higher than those specified in the bidding process, with inadequate recording of spending and evaluation of impacts. Moreover, assistance intended for smaller enterprises frequently benefited large firms.
While effective auditing is in place, it remains up to public bodies to address the issues raised by the audit office. Past experience shows that media attention is sometimes drawn to these findings.
Citations:
Supreme Audit Office. https://www.nku.cz/cz/o-nas/
Annual Report from the Supreme Audit Office. 2022. https://www.nku.cz/assets/publikace-a-dokumenty/vyrocni-zprava/vyrocni-zprava-nku-2022.pdf
Supreme Audit Office. https://www.nku.cz/cz/o-nas/
Annual Report from the Supreme Audit Office. 2022. https://www.nku.cz/assets/publikace-a-dokumenty/vyrocni-zprava/vyrocni-zprava-nku-2022.pdf
Estonia
The National Audit Office (NAO) is an independent institution defined by the Estonian constitution. According to the constitution, the NAO is not a part of any branch of power, and it must remain independent. The scope, functions and competences of the NAO are defined in the National Audit Office Act. The primary purpose of the NAO is to exercise economic oversight over the funds of the public sector. Although the reports of the NAO are aimed at the national parliament, the government and the public, the parliament remains the foremost client. The auditor general annually reports to the parliament on the use of public funds and on government budgetary discipline and spending.
Besides providing the annual audit report to the Riigikogu, the NAO conducts performance audits across various policy domains, focusing on strategies and specific pressing issues. No external entity can mandate the NAO to perform audit functions. The NAO independently determines what, when and how to audit. The NAO Act grants the office the legal authority to obtain all necessary information to conduct its work.
The auditor general (AG) is appointed to office by the Riigikogu for a term of five years, with candidates proposed by the president. A candidate for the position of AG must pass a security check by the Estonian Internal Security Service. Removal of the AG is determined under conditions specified in the NAO Act. The Supreme Court makes relevant decisions in cases of extended incapacity to work or entry into force of a judgment of conviction for a criminal offense.
The activities of the NAO are financed from the state budget. Since the budget is drafted by the Ministry of Finance, a certain breach of financial independence exists for the NAO – that is, the Ministry of Finance, which is audited by the NAO, effectively decides on the extent and manner of financing of the entity auditing it. The NAO employs approximately 100 people. Three-fourths of them are engaged in auditing, while the remaining one-fourth perform support and administrative tasks.
In recent years, the National Audit Office (NAO) and the auditor general have become more active in communicating their work to the public. As a result, a number of shortcomings and problems in the work of government have been brought into public debate, eventually contributing to the quality of policy implementation. The findings of the NAO are widely reported in the media and are publicly available on the NAO’s website.
Besides providing the annual audit report to the Riigikogu, the NAO conducts performance audits across various policy domains, focusing on strategies and specific pressing issues. No external entity can mandate the NAO to perform audit functions. The NAO independently determines what, when and how to audit. The NAO Act grants the office the legal authority to obtain all necessary information to conduct its work.
The auditor general (AG) is appointed to office by the Riigikogu for a term of five years, with candidates proposed by the president. A candidate for the position of AG must pass a security check by the Estonian Internal Security Service. Removal of the AG is determined under conditions specified in the NAO Act. The Supreme Court makes relevant decisions in cases of extended incapacity to work or entry into force of a judgment of conviction for a criminal offense.
The activities of the NAO are financed from the state budget. Since the budget is drafted by the Ministry of Finance, a certain breach of financial independence exists for the NAO – that is, the Ministry of Finance, which is audited by the NAO, effectively decides on the extent and manner of financing of the entity auditing it. The NAO employs approximately 100 people. Three-fourths of them are engaged in auditing, while the remaining one-fourth perform support and administrative tasks.
In recent years, the National Audit Office (NAO) and the auditor general have become more active in communicating their work to the public. As a result, a number of shortcomings and problems in the work of government have been brought into public debate, eventually contributing to the quality of policy implementation. The findings of the NAO are widely reported in the media and are publicly available on the NAO’s website.
France
The national Court of Auditors (Cour des Comptes) is a powerful and independent institution. It monitors the accounts of any institution that spends public money. The court is independent in the choice of the audits it undertakes. Since 2008, the institution being monitored can “contradict” or corrected the audit. A decree-law from March 2023 creates an “appeal court of auditors,” with the Conseil d’Etat – the administrative high court – acting as the final appeal court.
The institution appears to possess the means necessary to exercise its powers. It is a very prestigious institution, representing one of the most preferred posts in French administration, especially for the best students leaving the elitist National School of Administration (ENA, now INSP).
The president of the court is named by the Council of Ministers (the president and the government). It is thus usually a rather visible political figure who fulfills the necessary credentials, such as some past linkage to the court, ideally being a member of that administration. Since 2020, the position has been held by Pierre Moscovici, a former minister of the economy under the Hollande presidency, and a European commissioner. Once named, the court president cannot be removed, granting the officeholder substantial autonomy. Typically, the fact that the president is a leading politician gives the court some public visibility. However, to date, no president of the court has attempted to return to politics afterward.
The institution appears to possess the means necessary to exercise its powers. It is a very prestigious institution, representing one of the most preferred posts in French administration, especially for the best students leaving the elitist National School of Administration (ENA, now INSP).
The president of the court is named by the Council of Ministers (the president and the government). It is thus usually a rather visible political figure who fulfills the necessary credentials, such as some past linkage to the court, ideally being a member of that administration. Since 2020, the position has been held by Pierre Moscovici, a former minister of the economy under the Hollande presidency, and a European commissioner. Once named, the court president cannot be removed, granting the officeholder substantial autonomy. Typically, the fact that the president is a leading politician gives the court some public visibility. However, to date, no president of the court has attempted to return to politics afterward.
Latvia
The State Audit Office is an independent and collegial supreme audit institution. It operates independently of parliament and the government (State Audit Office Law).
The auditor general is appointed to office by the Saeima for four years. The current auditor general was approved in December 2023.
The State Audit Office conducts financial, compliance, and performance audits of executive and local authorities. Both the parliament and the government have full access to the audit findings and conclusions. The State Audit Office also has complete access to the information and evidence required for its audits.
In 2022, it had a 93.1% implementation rate for its recommendations. The highest number of recommendations was for the Ministry of Education and Science and the Ministry of Welfare – both responsible for sectors with major reforms expected (Valsts kontrole, 2024).
The 2022 – 2025 Strategy of the State Audit Office focuses on strengthening the effectiveness of public expenditure, building trust in the public sector, enhancing the impact of the Supreme Audit Office for the public good, and increasing the capacity and professionalism of auditors (Valsts kontrole, 2023).
The audits are extensively reported in the media. The State Audit Office’s Public Council also supports these publicity efforts. Several audits have attracted significant press and public interest – huge financial problems at Rezekne city municipality, public procurement for the military, and the malfunctioning healthcare system in the sphere of oncology.
The auditor general is appointed to office by the Saeima for four years. The current auditor general was approved in December 2023.
The State Audit Office conducts financial, compliance, and performance audits of executive and local authorities. Both the parliament and the government have full access to the audit findings and conclusions. The State Audit Office also has complete access to the information and evidence required for its audits.
In 2022, it had a 93.1% implementation rate for its recommendations. The highest number of recommendations was for the Ministry of Education and Science and the Ministry of Welfare – both responsible for sectors with major reforms expected (Valsts kontrole, 2024).
The 2022 – 2025 Strategy of the State Audit Office focuses on strengthening the effectiveness of public expenditure, building trust in the public sector, enhancing the impact of the Supreme Audit Office for the public good, and increasing the capacity and professionalism of auditors (Valsts kontrole, 2023).
The audits are extensively reported in the media. The State Audit Office’s Public Council also supports these publicity efforts. Several audits have attracted significant press and public interest – huge financial problems at Rezekne city municipality, public procurement for the military, and the malfunctioning healthcare system in the sphere of oncology.
Citations:
State Audit Office Law. https://likumi.lv/ta/en/en/id/62538-state-audit-office-law
European Court of Auditors. 2023. “Latvia.” https://op.europa.eu/webpub/eca/book-state-audit/en/#h-17
Valsts kontrole. 2023. Latvijas Republikas Valsts kontroles 2022. gada publiskais pārskats. Rīga. https://lrvk.gov.lv/uploads/files/Dokumenti/Par%20mums/Gadap%C4%81rskati/Valsts%20kontroles%202022.%20gada%20publiskais%20p%C4%81rskats.pdf
Valsts kontrole. 2023. “Valsts kontroles darbības stratēģija 2022.-2025.gadam.” https://www.lrvk.gov.lv/lv/par-mums/valsts-kontrole/strategija
5. Valsts kontrole. 2024. “Noslēgtās revīzijas (in Latvian).” https://lrvk.gov.lv/lv/revizijas/revizijas/noslegtas-revizijas
State Audit Office Law. https://likumi.lv/ta/en/en/id/62538-state-audit-office-law
European Court of Auditors. 2023. “Latvia.” https://op.europa.eu/webpub/eca/book-state-audit/en/#h-17
Valsts kontrole. 2023. Latvijas Republikas Valsts kontroles 2022. gada publiskais pārskats. Rīga. https://lrvk.gov.lv/uploads/files/Dokumenti/Par%20mums/Gadap%C4%81rskati/Valsts%20kontroles%202022.%20gada%20publiskais%20p%C4%81rskats.pdf
Valsts kontrole. 2023. “Valsts kontroles darbības stratēģija 2022.-2025.gadam.” https://www.lrvk.gov.lv/lv/par-mums/valsts-kontrole/strategija
5. Valsts kontrole. 2024. “Noslēgtās revīzijas (in Latvian).” https://lrvk.gov.lv/lv/revizijas/revizijas/noslegtas-revizijas
Lithuania
Lithuania has an independent National Audit Office whose autonomy is guaranteed by both the appointment process and its accountability mechanisms. The parliament appoints the auditor general based on a nomination by the president. The National Audit Office is accountable to both the parliament and the president. The parliament’s Committee on Audit reviews financial, compliance and performance audit reports submitted by the office and prepares draft parliamentary decisions concerning the implementation of audit recommendations. Traditionally, the position of the head of the Committee on Audit is allocated to a member of the Seimas opposition. The National Audit Office also collaborates with other parliamentary committees.
In practice, the National Audit Office consults political institutions, stakeholders and society on the question of which audits to undertake. However, it retains the discretion to make the final decisions regarding the audits, which are planned in advance every year. The Seimas has the right to request a particular audit by adopting a resolution. According to the National Audit Office, it determines which audits to undertake based on priority areas, in addition to those audits it is legally required to perform, such as the audits of draft annual state budgets and EU investments.
The National Audit Office serves as an independent fiscal institution, monitoring compliance with EU fiscal-policy norms. According to an OECD review released in 2019, this unique institutional setup, in which the independent fiscal institution (founded in 2015) is part of the National Audit Office, presents several challenges. These include a lack of clear public identity and operational independence, as well as difficulties in recruiting and retaining senior staff members. However, the Budget Policy Monitoring Department (BPMD) was praised for quickly establishing “a reputation for solid independent analysis,” contributing to fiscal transparency and enhancing parliamentary and public debates.
In the past, the National Audit Office has criticized the government’s draft budgets for their lack of compliance with fiscal-discipline provisions and poor allocation of government expenditures. While these criticisms are not always taken into account, there seems to have been progress over time. The Office monitors the implementation of its recommendations and provides up-to-date data on their implementation on its web page. It has also undertaken initiatives to inform the general public about the importance of the efficient and effective use of taxpayers’ money, as well as the challenges to the sustainable development of the state in addressing the most important issues.
In practice, the National Audit Office consults political institutions, stakeholders and society on the question of which audits to undertake. However, it retains the discretion to make the final decisions regarding the audits, which are planned in advance every year. The Seimas has the right to request a particular audit by adopting a resolution. According to the National Audit Office, it determines which audits to undertake based on priority areas, in addition to those audits it is legally required to perform, such as the audits of draft annual state budgets and EU investments.
The National Audit Office serves as an independent fiscal institution, monitoring compliance with EU fiscal-policy norms. According to an OECD review released in 2019, this unique institutional setup, in which the independent fiscal institution (founded in 2015) is part of the National Audit Office, presents several challenges. These include a lack of clear public identity and operational independence, as well as difficulties in recruiting and retaining senior staff members. However, the Budget Policy Monitoring Department (BPMD) was praised for quickly establishing “a reputation for solid independent analysis,” contributing to fiscal transparency and enhancing parliamentary and public debates.
In the past, the National Audit Office has criticized the government’s draft budgets for their lack of compliance with fiscal-discipline provisions and poor allocation of government expenditures. While these criticisms are not always taken into account, there seems to have been progress over time. The Office monitors the implementation of its recommendations and provides up-to-date data on their implementation on its web page. It has also undertaken initiatives to inform the general public about the importance of the efficient and effective use of taxpayers’ money, as well as the challenges to the sustainable development of the state in addressing the most important issues.
Citations:
National Audit Office. https://www.valstybeskontrole.lt/EN
OECD Independent Fiscal Institutions Review. 2019. “Lithuania’s Fiscal Independent Institution.” https://www.oecd.org/gov/budgeting/lithuania-independent-fiscal-institutions-review-2019-en.pdf
National Audit Office. https://www.valstybeskontrole.lt/EN
OECD Independent Fiscal Institutions Review. 2019. “Lithuania’s Fiscal Independent Institution.” https://www.oecd.org/gov/budgeting/lithuania-independent-fiscal-institutions-review-2019-en.pdf
Slovenia
The Court of Audit, which was established in 1991 and has been operational since 1995, is an independent state body tasked with monitoring and ensuring the transparent and efficient use of public funds in Slovenia. It audits all public institutions that receive public or European funds. Financially independent, it presents a financial plan to the National Assembly, which authorizes funds, making it an autonomous budget user. While mandated to conduct certain audits, no entity can delegate tasks or issue instructions. However, the National Assembly and the government can propose specific audits, with the court selecting at least five proposals from the National Assembly, including two from opposition MPs. Additionally, it can initiate audits based on initiatives from individuals and civil society organizations. The National Assembly appoints the president and two deputies of the court for nine-year terms.
The highly trusted Court of Audit regularly conducts effective and independent audits, prompting remedial actions for identified irregularities. From 2020 to 2022, it faced pressures from both the government and the opposition, including internal conflicts over audit reports, notably regarding the procurement of COVID-19 protective equipment.
During the same government’s tenure, Prime Minister Janša initially refused to nominate two Slovenian prosecutors proposed by the Judicial Council to the EU Public Prosecutor’s Office (EPPO). After negotiations and EU intervention, the government finally informed the EPPO about the candidates in November 2021, leading to their nomination for a five-year term.
Under Robert Golob’s new government, a new president of the Court of Audit was appointed in July 2022, following changes in the deputy president position in 2021. In 2022, the court issued numerous audit reports, summary reports, and post-audit reports covering 94 audited entities. The National Assembly committee overseeing public finances reviews these reports regularly, and the media frequently covers the court’s findings.
The highly trusted Court of Audit regularly conducts effective and independent audits, prompting remedial actions for identified irregularities. From 2020 to 2022, it faced pressures from both the government and the opposition, including internal conflicts over audit reports, notably regarding the procurement of COVID-19 protective equipment.
During the same government’s tenure, Prime Minister Janša initially refused to nominate two Slovenian prosecutors proposed by the Judicial Council to the EU Public Prosecutor’s Office (EPPO). After negotiations and EU intervention, the government finally informed the EPPO about the candidates in November 2021, leading to their nomination for a five-year term.
Under Robert Golob’s new government, a new president of the Court of Audit was appointed in July 2022, following changes in the deputy president position in 2021. In 2022, the court issued numerous audit reports, summary reports, and post-audit reports covering 94 audited entities. The National Assembly committee overseeing public finances reviews these reports regularly, and the media frequently covers the court’s findings.
Citations:
Računsko sodišče. 2023. “Poročilo o delu 2022.” https://www.rs-rs.si/o-racunskem-sodiscu/o-racunskem-sodiscu/o-nas/
Delo. 2023. “Evropska delegirana tožilca.” https://www.delo.si/tag/evropska-delegirana-tozilca/
Dnevnik. 2021. “Po izvolitvi Frank Elerjeve in Oštirja za delegirana tožilca Dikaučič želi spremeniti zakonodajo.” https://www.dnevnik.si/1042977756
Računsko sodišče. 2023. “Poročilo o delu 2022.” https://www.rs-rs.si/o-racunskem-sodiscu/o-racunskem-sodiscu/o-nas/
Delo. 2023. “Evropska delegirana tožilca.” https://www.delo.si/tag/evropska-delegirana-tozilca/
Dnevnik. 2021. “Po izvolitvi Frank Elerjeve in Oštirja za delegirana tožilca Dikaučič želi spremeniti zakonodajo.” https://www.dnevnik.si/1042977756
There exists an effective and independent audit office, but its role is somewhat limited.
8
Greece
Greece’s Hellenic Court of Audit (ElSyn 2024) is a highly respected and independent institution with nearly 200 years of history, having been established in 1833 and modeled on the French “Cour des Comptes.” The Greek constitution guarantees its organization and operation (Article 98).
The Hellenic Court of Audit plays a crucial role in auditing public finances and acts as a high-level court for disputes related to public pensions and the financial responsibilities of public servants. Among its most significant tasks are controlling government expenditures and supervising public procurement, especially concerning high-cost public tenders.
The audit office has unrestricted access to information, documents, and premises during its audits. It is well-equipped with the financial and human resources necessary to fulfill its duties. The executive branch cannot interfere with the decisions made by the audit office, and these decisions carry the weight of court rulings, which the government and public administration are obliged to follow.
The audit office is held in high regard, on par with Greece’s highest courts, such as the Supreme Criminal and Civil Court (Areios Pagos) and the Supreme Administrative Court (Symvoulio tis Epikrateias). Accordingly, the head (president) of the audit office is appointed in the same manner as the heads of these courts, as specified in the constitution (Article 90, paragraph 5). This process involves the ranking of candidates by the supreme courts, followed by the cabinet selecting appointees from among the highest-ranking judges and submitting a list of candidates to a parliamentary committee composed of the speaker, vice presidents, and other heads of parliamentary committees (the “Conference of Parliamentary Chairmen”). This committee votes by reinforced majority on the new head, who is then officially appointed by the Minister of Justice.
While the appointment process allows for some political discretion, it generally ensures the independence of the audit office’s head.
The audit office publishes an annual report, which it submits to parliament. Although these reports are not frequently covered in the media or widely utilized by the legislature, they are an essential part of parliamentary debates.
The Hellenic Court of Audit plays a crucial role in auditing public finances and acts as a high-level court for disputes related to public pensions and the financial responsibilities of public servants. Among its most significant tasks are controlling government expenditures and supervising public procurement, especially concerning high-cost public tenders.
The audit office has unrestricted access to information, documents, and premises during its audits. It is well-equipped with the financial and human resources necessary to fulfill its duties. The executive branch cannot interfere with the decisions made by the audit office, and these decisions carry the weight of court rulings, which the government and public administration are obliged to follow.
The audit office is held in high regard, on par with Greece’s highest courts, such as the Supreme Criminal and Civil Court (Areios Pagos) and the Supreme Administrative Court (Symvoulio tis Epikrateias). Accordingly, the head (president) of the audit office is appointed in the same manner as the heads of these courts, as specified in the constitution (Article 90, paragraph 5). This process involves the ranking of candidates by the supreme courts, followed by the cabinet selecting appointees from among the highest-ranking judges and submitting a list of candidates to a parliamentary committee composed of the speaker, vice presidents, and other heads of parliamentary committees (the “Conference of Parliamentary Chairmen”). This committee votes by reinforced majority on the new head, who is then officially appointed by the Minister of Justice.
While the appointment process allows for some political discretion, it generally ensures the independence of the audit office’s head.
The audit office publishes an annual report, which it submits to parliament. Although these reports are not frequently covered in the media or widely utilized by the legislature, they are an essential part of parliamentary debates.
Citations:
ElSyn. 2024. “Hellenic Court of Audit.” https://www.elsyn.gr/en
ElSyn. 2024. “Hellenic Court of Audit.” https://www.elsyn.gr/en
Portugal
The primary national audit institution in Portugal is the Tribunal de Contas, which operates as a Supreme Audit Institution following the court model. According to the Portuguese constitution and the law, the Court of Auditors is a sovereign body and a Supreme Court with unique jurisdiction. Its primary mission is to externally and independently control public financial activities and enforce financial responsibilities, serving as a cornerstone of the country’s financial governance.
This audit office operates independently from the government while remaining an integral part of the judicial system, as mandated by Lei n.º 98/97. The head of the audit office is appointed by the president of the republic, upon a proposal from the government, ensuring the preservation of its independence.
Additionally, the Tribunal de Contas possesses jurisdiction and financial control powers that enable it to make independent and autonomous decisions regarding the audit processes it undertakes. This court conducts its audits effectively despite encountering persistent challenges, notably the issue of workforce rejuvenation, characterized by a low percentage of employees under the age of 40.
The Organizational and Procedural Law specifies that the Court of Auditors is responsible for evaluating the legality and the economy, effectiveness, and efficiency, based on technical criteria, of the financial management of public entities, including the organization, functioning, and reliability of internal control systems. Article 11(2) also states that the court cooperates with other sovereign bodies – primarily through its support services – to disseminate necessary information for preventing and combating waste, illegality, fraud, and corruption concerning public funds and values at both the national and community levels.
This audit office operates independently from the government while remaining an integral part of the judicial system, as mandated by Lei n.º 98/97. The head of the audit office is appointed by the president of the republic, upon a proposal from the government, ensuring the preservation of its independence.
Additionally, the Tribunal de Contas possesses jurisdiction and financial control powers that enable it to make independent and autonomous decisions regarding the audit processes it undertakes. This court conducts its audits effectively despite encountering persistent challenges, notably the issue of workforce rejuvenation, characterized by a low percentage of employees under the age of 40.
The Organizational and Procedural Law specifies that the Court of Auditors is responsible for evaluating the legality and the economy, effectiveness, and efficiency, based on technical criteria, of the financial management of public entities, including the organization, functioning, and reliability of internal control systems. Article 11(2) also states that the court cooperates with other sovereign bodies – primarily through its support services – to disseminate necessary information for preventing and combating waste, illegality, fraud, and corruption concerning public funds and values at both the national and community levels.
Citations:
Law on Organisation and Procedural Law of the Court of Auditors (LOPTC) (Lei de Organização e Processo do Tribunal de Contas). 1997. https://diariodarepublica.pt/dr/detalhe/lei/98-1997-193663?_ts=1703762058332
Law on Organisation and Procedural Law of the Court of Auditors (LOPTC) (Lei de Organização e Processo do Tribunal de Contas). 1997. https://diariodarepublica.pt/dr/detalhe/lei/98-1997-193663?_ts=1703762058332
Slovakia
The Supreme Audit Office of the Slovak Republic (NKÚ) is an independent body established by law. It has nearly 300 employees and a budget of €13.9 million in 2022, determined annually by the State Budget Law. NKÚ conducts financial, compliance, and performance audits with full discretion over the scope of its audits. It is authorized to obtain necessary information and question officials and witnesses. The president and two vice presidents of NKÚ are elected by the National Council of the Slovak Republic via secret ballot (Law 39/1993).
Since its inception in 1993, NKÚ’s ability to perform high-quality audits has improved, and its reports have received significant media coverage. However, a key limitation is the follow-up on its recommendations, with implementation details often only available in control protocols (Nemec, 2022). The Open Budget Survey (OBS 2021) rates NKÚ as competent and efficient but suggests improvements in auditing a larger percentage of budgeted and extra-budgetary funds. The OBS also recommends that NKÚ report on executive actions taken in response to its findings and that the executive publicly disclose the steps taken to address these recommendations.
Since its inception in 1993, NKÚ’s ability to perform high-quality audits has improved, and its reports have received significant media coverage. However, a key limitation is the follow-up on its recommendations, with implementation details often only available in control protocols (Nemec, 2022). The Open Budget Survey (OBS 2021) rates NKÚ as competent and efficient but suggests improvements in auditing a larger percentage of budgeted and extra-budgetary funds. The OBS also recommends that NKÚ report on executive actions taken in response to its findings and that the executive publicly disclose the steps taken to address these recommendations.
Citations:
Nemec, J. 2022. Public Administration and Governance: Slovakia. Brussels: European Union.
Zákon 39/1993 o Najvyššom kontrolnom úrade SR. https://www.slov-lex.sk/pravne-predpisy/SK/ZZ/1993/39/vyhlasene_znenie.html
Open Budget Survey. 2021. “Slovakia.” https://internationalbudget.org/open-budget-survey/country-results/2021/slovakia or https://internationalbudget.org/sites/default/files/country-surveys-pdfs/2021/open-budget-survey-slovakia-2021-en.pdf
www.nku.gov.sk
Nemec, J. 2022. Public Administration and Governance: Slovakia. Brussels: European Union.
Zákon 39/1993 o Najvyššom kontrolnom úrade SR. https://www.slov-lex.sk/pravne-predpisy/SK/ZZ/1993/39/vyhlasene_znenie.html
Open Budget Survey. 2021. “Slovakia.” https://internationalbudget.org/open-budget-survey/country-results/2021/slovakia or https://internationalbudget.org/sites/default/files/country-surveys-pdfs/2021/open-budget-survey-slovakia-2021-en.pdf
www.nku.gov.sk
USA
In the 1970s, in response to the Watergate scandal, Congress created numerous regulatory agencies responsible for overseeing the executive branch, including those from within the executive branch itself (Roberts and Dull 2013). These independent agencies and auditors have collectively become known as the “accountability state” (Hilliard, 2017).
Inspectors general play an important role in the federal government, regularly monitoring for unlawful or inefficient behavior by the agencies (Potter 2019). They are generally regarded with a high level of respect and seen as having mostly avoided the partisan politicization that characterizes much of the U.S. government (Spence 2019).
Some concerns have been raised about a chilling effect caused by U.S. presidents dismissing inspectors general who seem to frustrate or embarrass their administration (Dodds 2020). Various presidents have entered office and tried to remove inspectors general. Ronald Reagan removed more than a dozen in his first few weeks in office. His successor, George H. W. Bush, tried to remove all of them but came under intense political pressure and relented. More recently, Donald Trump was known for removing inspectors general whom he found troublesome (Thompson et al. 2020).
Congress can insist on the reinstatement of inspectors general, and this sometimes happens, but generally the president’s party in Congress tends to side more with the president of their own party than with government bureaucrats in such disputes (Michaels 1997).
Inspectors general play an important role in the federal government, regularly monitoring for unlawful or inefficient behavior by the agencies (Potter 2019). They are generally regarded with a high level of respect and seen as having mostly avoided the partisan politicization that characterizes much of the U.S. government (Spence 2019).
Some concerns have been raised about a chilling effect caused by U.S. presidents dismissing inspectors general who seem to frustrate or embarrass their administration (Dodds 2020). Various presidents have entered office and tried to remove inspectors general. Ronald Reagan removed more than a dozen in his first few weeks in office. His successor, George H. W. Bush, tried to remove all of them but came under intense political pressure and relented. More recently, Donald Trump was known for removing inspectors general whom he found troublesome (Thompson et al. 2020).
Congress can insist on the reinstatement of inspectors general, and this sometimes happens, but generally the president’s party in Congress tends to side more with the president of their own party than with government bureaucrats in such disputes (Michaels 1997).
Citations:
Nadia Hilliard. 2017. The Accountability State. Lawrence: University Press of Kansas.
Patrick Roberts and Matthew Dull. 2013. “Guarding the Guardians: Oversight Appointees and the Search for Accountability in US Federal Agencies.” Journal of Policy History.
Joel Aberbach and Bert Rockman. 2009. “The Appointments Process and the Administrative Presidency.” Presidential Studies Quarterly.
Judith Michaels. 1997. The President’s Call. Pittsburgh: Pittsburgh University Press.
Frank Thompson, Kenneth Wong, and Barry Rabe. 2020. Trump, the Administrative Presidency, and Federalism. Brookings.
Graham Dodds. 2020. The Unitary Presidency. New York: Routledge.
Rachel Potter. 2019. Bending the Rules: Procedural Politicking in the Bureaucracy. Chicago: University of Chicago Press.
David Spence. 2019. “The Effects of Partisan Polarization on the Bureaucracy.” In Can America Govern Itself?, eds. F. Lee and N. McCarty. Cambridge: Cambridge University Press.
Nadia Hilliard. 2017. The Accountability State. Lawrence: University Press of Kansas.
Patrick Roberts and Matthew Dull. 2013. “Guarding the Guardians: Oversight Appointees and the Search for Accountability in US Federal Agencies.” Journal of Policy History.
Joel Aberbach and Bert Rockman. 2009. “The Appointments Process and the Administrative Presidency.” Presidential Studies Quarterly.
Judith Michaels. 1997. The President’s Call. Pittsburgh: Pittsburgh University Press.
Frank Thompson, Kenneth Wong, and Barry Rabe. 2020. Trump, the Administrative Presidency, and Federalism. Brookings.
Graham Dodds. 2020. The Unitary Presidency. New York: Routledge.
Rachel Potter. 2019. Bending the Rules: Procedural Politicking in the Bureaucracy. Chicago: University of Chicago Press.
David Spence. 2019. “The Effects of Partisan Polarization on the Bureaucracy.” In Can America Govern Itself?, eds. F. Lee and N. McCarty. Cambridge: Cambridge University Press.
7
Ireland
Ireland has increasingly adopted an “evidence-informed approach” to policymaking, favoring it over an evidence-based one. Ruane (2021) highlights the significant role of the central statistics office in integrating high-quality datasets into policy formulation. More recently, following the Troika, the Irish Government Economic and Evaluation Service (IGEES) has been supporting departmental-level audits and developing capacity to address future data challenges. An OECD review of IGEES found it made a “significant difference in strengthening the analytical capacity of the Civil Service in Ireland.”
To further improve the quality of policy analysis and challenge government economic and budgetary proposals, several other institutional innovations have been introduced. These include the creation of the independent Irish Fiscal Advisory Council (IFAC) and the Parliamentary Budget Office (PBO). An Official Statistics Board, chaired by former Assistant Secretary to the Department of Social Protection Anne Vaughan, provides oversight and coordination. Additionally, the Oireachtas Library Service, Department of Finance, Department of Public Expenditure and Reform, Central Bank, Fiscal Advisory Council and various sub-sectoral Ombudsman offices (policing, media, children etc.) perform watchdog functions, reviewing fiscal issues and debt sustainability.
The Office of the Comptroller and Auditor General (C&AG) derives its remit from Article 33 of the 1937 constitution of Ireland, although it was established in 1923 and had its powers substantially revised in 1993. These revisions included the assessment of value for money and special assessments of economy, effectiveness and efficacy in specific aspects of public administration. The latest published example is the review of NAMA (C&AG 2022). The independent C&AG is appointed by the president, based on the nomination of Dáil Éireann, and operates under a strong culture aligned with constitutional and legislative provisions to act independently of the government and report to parliament.
The C&AG’s remit includes the state and state bodies, including specified agencies or bodies receiving state funds. It publishes annual reports on the Accounts of the Public Services, the latest being for 2022 (published in 2023), addressing issues arising from audits of government departments and offices, including the accounts of the Revenue Commissioners. These reports are examined in detail by the Dáil Committee of Public Accounts. The latest general report publicly available is a 2021 evaluation of the National Asset Management Agency (C&AG 2022), and a 2023 audit of the Irish Advisory Council on 25 reports undertaken in 2022.
Scott’s (2021) assessment views the development of the C&AG office as consistent with international trends of arms-length regulation. However, he identifies significant weaknesses in Ireland’s regulatory capacity, effectiveness and accountability. While the C&AG has strong formal independence, including protection from removal from office, its capacity for formal regulation or enforcement is limited.
To further improve the quality of policy analysis and challenge government economic and budgetary proposals, several other institutional innovations have been introduced. These include the creation of the independent Irish Fiscal Advisory Council (IFAC) and the Parliamentary Budget Office (PBO). An Official Statistics Board, chaired by former Assistant Secretary to the Department of Social Protection Anne Vaughan, provides oversight and coordination. Additionally, the Oireachtas Library Service, Department of Finance, Department of Public Expenditure and Reform, Central Bank, Fiscal Advisory Council and various sub-sectoral Ombudsman offices (policing, media, children etc.) perform watchdog functions, reviewing fiscal issues and debt sustainability.
The Office of the Comptroller and Auditor General (C&AG) derives its remit from Article 33 of the 1937 constitution of Ireland, although it was established in 1923 and had its powers substantially revised in 1993. These revisions included the assessment of value for money and special assessments of economy, effectiveness and efficacy in specific aspects of public administration. The latest published example is the review of NAMA (C&AG 2022). The independent C&AG is appointed by the president, based on the nomination of Dáil Éireann, and operates under a strong culture aligned with constitutional and legislative provisions to act independently of the government and report to parliament.
The C&AG’s remit includes the state and state bodies, including specified agencies or bodies receiving state funds. It publishes annual reports on the Accounts of the Public Services, the latest being for 2022 (published in 2023), addressing issues arising from audits of government departments and offices, including the accounts of the Revenue Commissioners. These reports are examined in detail by the Dáil Committee of Public Accounts. The latest general report publicly available is a 2021 evaluation of the National Asset Management Agency (C&AG 2022), and a 2023 audit of the Irish Advisory Council on 25 reports undertaken in 2022.
Scott’s (2021) assessment views the development of the C&AG office as consistent with international trends of arms-length regulation. However, he identifies significant weaknesses in Ireland’s regulatory capacity, effectiveness and accountability. While the C&AG has strong formal independence, including protection from removal from office, its capacity for formal regulation or enforcement is limited.
Citations:
C&AG. 2023. “https://www.audit.gov.ie/en/find-report/publications/2023/25-irish-fiscal-advisory-council.pdf”
C&AG. 2022. “National Asset Management Agency: Progress on Achievement of Objectives as at End 2021.” https://www.audit.gov.ie/en/find-report/publications/2023/special-report-116-nama-progress-on-achievement-of-objectives-as-at-end-2021.pdf
Coakley. 2021. “The Politics of the Presidency.” In The Oxford Handbook of Irish Politics, eds. Farrell D. and N. Hardiman, 366-382. Oxford: OUP.
Daly, P. 2021. “The Irish Courts and the Administrative State.” In The Oxford Handbook of Irish Politics, eds. D. M. Farrell and N. Hardiman, 264-280. Oxford: Oxford University Press.
Reidy, T., and F. Buckley. 2017. “Democratic Revolution? Evaluating the Political and Administrative Reform Landscape After the Economic Crises.” Administration 65 (2): 1-12.
Ruane, F. 2021. “Introducing Evidence into Policy Making in Ireland.” In Policy Analysis in Ireland, eds. J. Hogan and M. P. Murphy, 63-76. Bristol: Policy Press.
Scott. 2021. “Politics of Regulation in Ireland.” In The Oxford Handbook of Irish Politics, eds. Farrell D and N Hardiman, 647-668. Oxford: OUP
C&AG. 2023. “https://www.audit.gov.ie/en/find-report/publications/2023/25-irish-fiscal-advisory-council.pdf”
C&AG. 2022. “National Asset Management Agency: Progress on Achievement of Objectives as at End 2021.” https://www.audit.gov.ie/en/find-report/publications/2023/special-report-116-nama-progress-on-achievement-of-objectives-as-at-end-2021.pdf
Coakley. 2021. “The Politics of the Presidency.” In The Oxford Handbook of Irish Politics, eds. Farrell D. and N. Hardiman, 366-382. Oxford: OUP.
Daly, P. 2021. “The Irish Courts and the Administrative State.” In The Oxford Handbook of Irish Politics, eds. D. M. Farrell and N. Hardiman, 264-280. Oxford: Oxford University Press.
Reidy, T., and F. Buckley. 2017. “Democratic Revolution? Evaluating the Political and Administrative Reform Landscape After the Economic Crises.” Administration 65 (2): 1-12.
Ruane, F. 2021. “Introducing Evidence into Policy Making in Ireland.” In Policy Analysis in Ireland, eds. J. Hogan and M. P. Murphy, 63-76. Bristol: Policy Press.
Scott. 2021. “Politics of Regulation in Ireland.” In The Oxford Handbook of Irish Politics, eds. Farrell D and N Hardiman, 647-668. Oxford: OUP
Italy
The Italian Court of Audit (Corte dei Conti) is a constitutional body responsible for oversight and judicial functions in public accounting and related legal matters. It also offers expert advice to the government, parliament, and local authorities when requested.
Article 100 of the Italian constitution mandates that the Court of Audit conduct a preventive evaluation of the legality of government actions and assess subsequent state budget management. In jurisdictional matters, the Court has the authority to adjudicate cases involving accountants, administrators, and public officials for all aspects of public resource management.
The leadership of the Court of Audit consists of a board of presidency, which includes a president, four members selected by parliament, four members elected from among the Court’s magistrates, and the Court’s general prosecutor. The president is appointed by decree of the president of the republic on the recommendation of the president of the Council of Ministers. The board’s elected members serve four-year terms and are ineligible for reelection for eight years after their term ends. The Court regularly reports its findings to parliament but is not accountable to it, as it stands as an independent judicial body.
Recently, the Court of Audit has been at the center of public debate due to its oversight responsibilities associated with the implementation of the National Recovery and Resilience Plan (NRRP). The Court’s 2023 report on public finance coordination emphasized that Italy is significantly lagging in spending European funds. This finding prompted a strong response from the Meloni government, which deemed the Court’s attitude counterproductive. These remarks were followed by the approval of Decree Law 44/2023, which reduces the Court’s concurrent control function. The role of the Court in implementing the NRRP, as clarified in a government declaration, is thus successive.
Article 100 of the Italian constitution mandates that the Court of Audit conduct a preventive evaluation of the legality of government actions and assess subsequent state budget management. In jurisdictional matters, the Court has the authority to adjudicate cases involving accountants, administrators, and public officials for all aspects of public resource management.
The leadership of the Court of Audit consists of a board of presidency, which includes a president, four members selected by parliament, four members elected from among the Court’s magistrates, and the Court’s general prosecutor. The president is appointed by decree of the president of the republic on the recommendation of the president of the Council of Ministers. The board’s elected members serve four-year terms and are ineligible for reelection for eight years after their term ends. The Court regularly reports its findings to parliament but is not accountable to it, as it stands as an independent judicial body.
Recently, the Court of Audit has been at the center of public debate due to its oversight responsibilities associated with the implementation of the National Recovery and Resilience Plan (NRRP). The Court’s 2023 report on public finance coordination emphasized that Italy is significantly lagging in spending European funds. This finding prompted a strong response from the Meloni government, which deemed the Court’s attitude counterproductive. These remarks were followed by the approval of Decree Law 44/2023, which reduces the Court’s concurrent control function. The role of the Court in implementing the NRRP, as clarified in a government declaration, is thus successive.
Citations:
Report on public finance coordination: https://www.corteconti.it/Download?id=ddfd70d1-1d57-46c6-b12c-6c0001670bb7
REV: A public statement of the government clarified the role of the Corte dei Conti re NRRP:
www.governo.it/it/articolo/norme-riguardanti-la-corte-dei-conti-e-i-controlli-sul-pnrr-nota-di-palazzo-chigi/22788
Report on public finance coordination: https://www.corteconti.it/Download?id=ddfd70d1-1d57-46c6-b12c-6c0001670bb7
REV: A public statement of the government clarified the role of the Corte dei Conti re NRRP:
www.governo.it/it/articolo/norme-riguardanti-la-corte-dei-conti-e-i-controlli-sul-pnrr-nota-di-palazzo-chigi/22788
Spain
The Court of Audit, recognized by the Spanish constitution, is an external audit body responsible for auditing the state’s accounts, electoral and party funding, and the financial management of the entire public sector. In addition, most autonomous communities have established regional courts of audit to monitor their devolved competences. The national audit office is empowered to undertake investigations on its own initiative following the submission of a complaint and has the authority to impose substantial penalties for the misuse of public funds.
The head of the audit office is appointed by the King based on a proposal from the plenary, for a term of three years. The election is conducted by secret ballot. Members of the plenary and the head of the Court can be removed from office only after completing their term, upon resignation accepted by the parliament, due to incapacity or incompatibility, or for serious failure to perform their duties (Court of Audit 2023).
After a contentious period when the political autonomy of the Court was questioned, the major parties reached an agreement in 2021 to renew its members.
Although there have been certain improvements (the budget for 2023 was €78 million; 2020 €63 million), the office suffers from a lack of financial resources, personnel, and independence from politicians, since members of the plenary are appointed by the parties themselves. The Court of Audit legally has budgetary autonomy and draws up its own budget, which is approved by parliament.
The Court of Audit actively exchanges information on improved methods as a member of several international organizations of supreme audit institutions, such as EUROSAI, INTOSAI, and OLACEFS. It also maintains relations with the European Court of Auditors and participates in auditing various international organizations.
The head of the audit office is appointed by the King based on a proposal from the plenary, for a term of three years. The election is conducted by secret ballot. Members of the plenary and the head of the Court can be removed from office only after completing their term, upon resignation accepted by the parliament, due to incapacity or incompatibility, or for serious failure to perform their duties (Court of Audit 2023).
After a contentious period when the political autonomy of the Court was questioned, the major parties reached an agreement in 2021 to renew its members.
Although there have been certain improvements (the budget for 2023 was €78 million; 2020 €63 million), the office suffers from a lack of financial resources, personnel, and independence from politicians, since members of the plenary are appointed by the parties themselves. The Court of Audit legally has budgetary autonomy and draws up its own budget, which is approved by parliament.
The Court of Audit actively exchanges information on improved methods as a member of several international organizations of supreme audit institutions, such as EUROSAI, INTOSAI, and OLACEFS. It also maintains relations with the European Court of Auditors and participates in auditing various international organizations.
Citations:
Court of Audit. 2023. “Website.” https://www.tcu.es/en/
Court of Audit. 2023. “Website.” https://www.tcu.es/en/
Netherlands
The General Audit Chamber (Algemene Rekenkamer) annually scrutinizes annual reports and ex post policy evaluations by ministerial departments. In 2012, the government introduced the Regulation for Regular Evaluation Studies, which specifies criteria for assessing policy efficiency, goal achievement, evidence-based policymaking and subsidy-based policies. The Chamber chooses its own research agenda formally independently, but informally in consultation and coordination with the government and its departments. In line with the general trend toward more instrumental advice, the General Audit Chamber has focused its attention on specific points in departmental agendas. Multiyear research programs focus on policy areas and themes of significant financial and societal importance. Accountability research consists of examination of departmental annual reports, with the goal of doing more than simply approving the national accounts and giving an opinion on the quality of operational management. In the coming years, the focus will be on data management and the use of (machine learning) algorithms.
Since evaluation findings are just one factor in designing new or adjusting existing policies, it is not clear how much policy learning actually occurs. A recent study commissioned by the minister of finance assessed past evaluations and their use. The study confirmed that although “no other country evaluates so many of its policies,” policymaking civil servants and members of parliament are less sensitive to the outcomes of previous policies than to images and incidents (as reported in the press). One thing is very clear though: If learning occurs, it becomes evident only years after a seriously problematic situation is first signaled.
One cause of this delay may be political interference in the functioning of inspectorates and monitoring agencies. State inspectorates are currently part of a ministry. As such, they are embedded in terms of finances, external communication and press relations, and research programming. Even the assessment of its performance depends on the ministry. A minister has far-reaching powers to issue instructions. These sometimes involve the omission of serious inspection in certain policy aspects or areas, and sometimes the intensification of such activity. Ministries may also influence the effectivenss of inspectorates by withholding research budgets. One inspector has described the swing of the pendulum: “After every disaster there is criticism: The government is lax, supervision is inadequate. But if things go well for a while, the opposite is heard: The government must take a step back. The Netherlands can do with less supervision, because the administrative burden is too high.”
Studies show that the selection of cases to be investigated by the auditors (Rekenkamers) – especially at the local level – seems to be rather random, and methods used for evaluation are not always very convincing. At the same time, there is much more scrutiny than elsewhere, and it is relatively independent, with serious criticisms resulting. Yet again, much of this critique is often ignored for years, and always draws almost immediate denials by those in power.
Since evaluation findings are just one factor in designing new or adjusting existing policies, it is not clear how much policy learning actually occurs. A recent study commissioned by the minister of finance assessed past evaluations and their use. The study confirmed that although “no other country evaluates so many of its policies,” policymaking civil servants and members of parliament are less sensitive to the outcomes of previous policies than to images and incidents (as reported in the press). One thing is very clear though: If learning occurs, it becomes evident only years after a seriously problematic situation is first signaled.
One cause of this delay may be political interference in the functioning of inspectorates and monitoring agencies. State inspectorates are currently part of a ministry. As such, they are embedded in terms of finances, external communication and press relations, and research programming. Even the assessment of its performance depends on the ministry. A minister has far-reaching powers to issue instructions. These sometimes involve the omission of serious inspection in certain policy aspects or areas, and sometimes the intensification of such activity. Ministries may also influence the effectivenss of inspectorates by withholding research budgets. One inspector has described the swing of the pendulum: “After every disaster there is criticism: The government is lax, supervision is inadequate. But if things go well for a while, the opposite is heard: The government must take a step back. The Netherlands can do with less supervision, because the administrative burden is too high.”
Studies show that the selection of cases to be investigated by the auditors (Rekenkamers) – especially at the local level – seems to be rather random, and methods used for evaluation are not always very convincing. At the same time, there is much more scrutiny than elsewhere, and it is relatively independent, with serious criticisms resulting. Yet again, much of this critique is often ignored for years, and always draws almost immediate denials by those in power.
Citations:
P. Omtzigt. “Concept Verslag Notaoverleg, Tweede Kamer, Initiatiefnota van het lid Omtzigt ‘Voorstellen ter versterking van de onafhankelijkheid van rijksinspecties’ (36149).”
Algemene Rekenkamer. 2021. Vertrouwen in verantwoording, Strategie 2021-2025.
Toezine. “Toezichthouders kunnen meer hun rol als evaluator pakken.”
02 november 2021
NRC, Karlijn Kuijpers, Derk Stokmans. 2023. “Houd de politiek buiten het toezicht, zeggen de inspecteurs.” NRC June 11.
F. Mertens. 2023. De minister en de inspecteur-generaal. Fragmenten uit de geschiedenis van het onderwijstoezicht. Delft: Eburon.
P. Omtzigt. “Concept Verslag Notaoverleg, Tweede Kamer, Initiatiefnota van het lid Omtzigt ‘Voorstellen ter versterking van de onafhankelijkheid van rijksinspecties’ (36149).”
Algemene Rekenkamer. 2021. Vertrouwen in verantwoording, Strategie 2021-2025.
Toezine. “Toezichthouders kunnen meer hun rol als evaluator pakken.”
02 november 2021
NRC, Karlijn Kuijpers, Derk Stokmans. 2023. “Houd de politiek buiten het toezicht, zeggen de inspecteurs.” NRC June 11.
F. Mertens. 2023. De minister en de inspecteur-generaal. Fragmenten uit de geschiedenis van het onderwijstoezicht. Delft: Eburon.
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Israel
The State Comptroller’s Office is an independent audit office that audits government ministries, local and municipal governments, and other independent governmental organizations, including public universities, all military branches and government-funded corporations. The scope of its audit powers is one of the broadest in the world, giving the comptroller jurisdiction over 1,400 organizations. The office derives its authority from the Basic Law: The State Comptroller, which authorizes it to receive immediate information from bodies being audited.
Additionally, the state comptroller is responsible for auditing campaign and party finances, and reviewing the accounts and finances of party candidates and government ministers. The office also serves as the State Ombudsman, responding to complaints from the public regarding the organizations under its jurisdiction. The State Comptroller’s Office acts independent, and its reports and conclusions are widely covered in the media and public discourse.
The comptroller reports on government ministries and local authorities. The decision on which issues and departments to investigate lies with the comptroller. The reports are also presented in parliamentary committees. Each agency examined must collaborate with the comptroller. Additionally, each agency must provide a response to the comptroller’s reports and findings, explaining their activities and the corrections being made. The comptroller, however, has no legal authority to force an agency to make the necessary amendments.
The state comptroller is elected in a secret vote by the Knesset for a period of seven years. The budget of the State Comptroller’s Office is determined by the Knesset Finance Committee to ensure its independence from the executive branch. The Knesset also decides the state comptroller’s salary and holds the power to remove them from office, although no state comptroller has ever been removed from office in Israel.
The State Comptroller’s Office publishes various types of reports, most of which are discussed by the Knesset. The media discusses the major annual report as well as reports it believes are of public interest. For example, the reports on the fire in Carmel in 2008, housing expenses of Prime Minister Netanyahu and issues that could lead to criminal charges have been discussed in the media.
The current state comptroller was appointed in 2019. Upon entering office, the state comptroller announced several changes to how the State Comptroller’s Office would function, including issuing positive reports in addition to negative ones. Furthermore, the state comptroller closed the department responsible for examining corruption issues and made it more difficult for whistleblowers. Because the state comptroller lacks legal authority to enforce his recommendations, his power derives from his personal influence and the media coverage his reports receive. As the present state comptroller has repeatedly expressed a desire to limit his critique of government activities, it appears that the power of the State Comptroller’s Office has diminished.
Additionally, the state comptroller is responsible for auditing campaign and party finances, and reviewing the accounts and finances of party candidates and government ministers. The office also serves as the State Ombudsman, responding to complaints from the public regarding the organizations under its jurisdiction. The State Comptroller’s Office acts independent, and its reports and conclusions are widely covered in the media and public discourse.
The comptroller reports on government ministries and local authorities. The decision on which issues and departments to investigate lies with the comptroller. The reports are also presented in parliamentary committees. Each agency examined must collaborate with the comptroller. Additionally, each agency must provide a response to the comptroller’s reports and findings, explaining their activities and the corrections being made. The comptroller, however, has no legal authority to force an agency to make the necessary amendments.
The state comptroller is elected in a secret vote by the Knesset for a period of seven years. The budget of the State Comptroller’s Office is determined by the Knesset Finance Committee to ensure its independence from the executive branch. The Knesset also decides the state comptroller’s salary and holds the power to remove them from office, although no state comptroller has ever been removed from office in Israel.
The State Comptroller’s Office publishes various types of reports, most of which are discussed by the Knesset. The media discusses the major annual report as well as reports it believes are of public interest. For example, the reports on the fire in Carmel in 2008, housing expenses of Prime Minister Netanyahu and issues that could lead to criminal charges have been discussed in the media.
The current state comptroller was appointed in 2019. Upon entering office, the state comptroller announced several changes to how the State Comptroller’s Office would function, including issuing positive reports in addition to negative ones. Furthermore, the state comptroller closed the department responsible for examining corruption issues and made it more difficult for whistleblowers. Because the state comptroller lacks legal authority to enforce his recommendations, his power derives from his personal influence and the media coverage his reports receive. As the present state comptroller has repeatedly expressed a desire to limit his critique of government activities, it appears that the power of the State Comptroller’s Office has diminished.
Citations:
The State Comptroller https://www.mevaker.gov.il/he/Pages/default.aspx
The State Comptroller https://www.mevaker.gov.il/he/Pages/default.aspx
Japan
According to the constitution, state revenues and expenditures are audited annually by the Board of Audit. The Board of Audit Act clarifies the organization and mandate of the board. The board is independent of the cabinet. It is composed of commissioners appointed for five-year terms by the cabinet with the consent of both houses of parliament. Commissioners can be removed from office only if they are sentenced to imprisonment or retire upon reaching the age of 70. While judges were previously appointed from among high-ranking bureaucrats, especially Ministry of Finance officials, at present they are recruited either from academia or from among the Board of Audit bureaucrats, which reduces the risk of collusion with different ministries.
The Board of Audit has the obligation to audit the revenues and expenditures of all state institutions and all juridical persons whose stated capital is based 50% or more on funds provided by the state. If it finds it necessary or is requested by the cabinet, it can audit the financial management of other entities (e.g., those that receive state subsidies). All entities are obliged to accept field audits and provide the requested documents. The board may request the head of a ministry or agency to take disciplinary action against an official who has caused substantial damage to the state. Any crimes must be reported to the Public Prosecutor’s Office. Audit reports have to be submitted to, but need not be approved by, the Diet.
Japan ranked average among OECD countries in the Open Budget Survey 2021. A notable weakness of Japan’s Board of Audit is the lack of formal mechanisms for public assistance in audit investigations. Annual audit reports occasionally capture public attention. For example, the November 2023 report revealed 344 instances of wasteful spending or inappropriate accounting, amounting to JPY 58 billion (about €360 million). The board also indicated that unsecured financial assistance from government-affiliated financial institutions aimed at countering the effects of the COVID-19 pandemic amounting to JPY 69.7 billion (about $463 million) had become irrecoverable.
The Board of Audit has the obligation to audit the revenues and expenditures of all state institutions and all juridical persons whose stated capital is based 50% or more on funds provided by the state. If it finds it necessary or is requested by the cabinet, it can audit the financial management of other entities (e.g., those that receive state subsidies). All entities are obliged to accept field audits and provide the requested documents. The board may request the head of a ministry or agency to take disciplinary action against an official who has caused substantial damage to the state. Any crimes must be reported to the Public Prosecutor’s Office. Audit reports have to be submitted to, but need not be approved by, the Diet.
Japan ranked average among OECD countries in the Open Budget Survey 2021. A notable weakness of Japan’s Board of Audit is the lack of formal mechanisms for public assistance in audit investigations. Annual audit reports occasionally capture public attention. For example, the November 2023 report revealed 344 instances of wasteful spending or inappropriate accounting, amounting to JPY 58 billion (about €360 million). The board also indicated that unsecured financial assistance from government-affiliated financial institutions aimed at countering the effects of the COVID-19 pandemic amounting to JPY 69.7 billion (about $463 million) had become irrecoverable.
Citations:
Board of Audit of Japan. 1947, amended 2021. “The Board of Audit Act.” https://www.jbaudit.go.jp/english/jbaudit/law.html
International Budget Partnership. 2022. “Open Budget Survey 2021, Japan.” https://internationalbudget.org/sites/default/files/country-surveys-pdfs/2021/open-budget-survey-japan-2021-en.pdf
Prime Minister of Japan and His Cabinet. 1946. “The Constitution of Japan.” https://japan.kantei.go.jp/constitution_and_government_of_japan/constitution_e.html
Watanabe, Toru. 2023. “$463 mil. in unsecured COVID loans in Japan irrecoverable, total may hit $6.64 bil.” The Mainichi, November 8. https://mainichi.jp/english/articles/20231108/p2a/00m/0na/012000c
Board of Audit of Japan. 1947, amended 2021. “The Board of Audit Act.” https://www.jbaudit.go.jp/english/jbaudit/law.html
International Budget Partnership. 2022. “Open Budget Survey 2021, Japan.” https://internationalbudget.org/sites/default/files/country-surveys-pdfs/2021/open-budget-survey-japan-2021-en.pdf
Prime Minister of Japan and His Cabinet. 1946. “The Constitution of Japan.” https://japan.kantei.go.jp/constitution_and_government_of_japan/constitution_e.html
Watanabe, Toru. 2023. “$463 mil. in unsecured COVID loans in Japan irrecoverable, total may hit $6.64 bil.” The Mainichi, November 8. https://mainichi.jp/english/articles/20231108/p2a/00m/0na/012000c
Poland
The Supreme Audit Office (Naczelna Izba Kontroli, NIK) serves as Poland’s highest audit authority, operating under the principles of collegiality and accountable to the Sejm (parliament). It oversees various entities, including government administration bodies, the National Bank of Poland, state legal entities and other state organizational units. Furthermore, the NIK is empowered to audit the activities of local government bodies, legal entities of local self-government and other organizational units of local self-government. It broadens its examination to different entities and economic entities (entrepreneurs) to the extent that they use state or municipal assets or funds and fulfill financial obligations to the state. The budget implementation is also within the purview of the NIK’s audit responsibilities. The office can obtain all necessary information and question officials and staff during its audits.
The president of the Supreme Audit Office is appointed by the Sejm upon the request of the marshal of the Sejm or a group of at least 35 deputies, requiring an absolute majority vote with Senate consent. The dismissal of the president is subject to stringent conditions, including a Tribunal of State verdict or severe illness, making the termination of a six-year term challenging. The approval of the budget law by the Polish Sejm concurrently approves the NIK’s financial plan.
The NIK has a central bureau in Warsaw and 16 local branches, with the president wielding powers akin to the minister responsible for budget matters. The release of the NIK’s findings to the media is contingent on the nature and significance of the matter. Depending on the situation, the NIK may opt to make its findings public through interviews with journalists, press conferences, or statements and information published on its website.
Marian Banaś has been the head of Poland’s Supreme Audit Office since 2019. Initially associated with the Law and Justice administration, Banaś became a leading opponent following a Central Anti-Corruption Bureau investigation into alleged links to a criminal group. In 2023, before the parliamentary elections, Banaś threw his support behind the far-right party Konfederacja, citing its advocacy for the independence of the NIK (Notes from Poland 2023).
The president of the Supreme Audit Office is appointed by the Sejm upon the request of the marshal of the Sejm or a group of at least 35 deputies, requiring an absolute majority vote with Senate consent. The dismissal of the president is subject to stringent conditions, including a Tribunal of State verdict or severe illness, making the termination of a six-year term challenging. The approval of the budget law by the Polish Sejm concurrently approves the NIK’s financial plan.
The NIK has a central bureau in Warsaw and 16 local branches, with the president wielding powers akin to the minister responsible for budget matters. The release of the NIK’s findings to the media is contingent on the nature and significance of the matter. Depending on the situation, the NIK may opt to make its findings public through interviews with journalists, press conferences, or statements and information published on its website.
Marian Banaś has been the head of Poland’s Supreme Audit Office since 2019. Initially associated with the Law and Justice administration, Banaś became a leading opponent following a Central Anti-Corruption Bureau investigation into alleged links to a criminal group. In 2023, before the parliamentary elections, Banaś threw his support behind the far-right party Konfederacja, citing its advocacy for the independence of the NIK (Notes from Poland 2023).
Citations:
Notes from Poland. 2023. “Head of Polish State Audit Office Holds Press Conference with Far-Right Leader.” https://notesfrompoland.com/2023/07/27/head-of-polish-state-audit-office-holds-press-conference-with-far-right-leader/
Notes from Poland. 2023. “Head of Polish State Audit Office Holds Press Conference with Far-Right Leader.” https://notesfrompoland.com/2023/07/27/head-of-polish-state-audit-office-holds-press-conference-with-far-right-leader/
There exists an independent audit office, but its role is considerably limited.
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Hungary
The criticism faced by the Hungarian State Audit Office (ÁSZ) centers on the issues of administrative expertise, political bias, lack of transparency and potential conflicts of interest. Concerns have arisen that the office targets opposition parties and organizations with more rigorous audits while allegedly being more lenient with those aligned with the government. Additionally, there are transparency issues related to the publication of audit reports and the methodologies used in conducting audits. These criticisms highlight the challenges that independent institutions face in maintaining autonomy and public trust in a politically charged environment. For example, the Democratic Coalition (DK) and the Együtt parties were each fined HUF 16 million for renting office space below market rates. The Politics Can Be Different party (LMP) faced a similar fine of HUF 8.8 million for the same reason. These fines have raised concerns about selective enforcement, as there is no similar scrutiny of the ruling Fidesz party’s activities.
Furthermore, the government urged the Audit Office to fine several NGOs critical of the government under the new anti-NGO legislation. After a field trip to Hungary in 2023, the European Parliament’s budget control committee was particularly critical of the quality of the ÁSZ’s leadership and performance. Overall, the Audit Office is more of a complementary government body than one that oversees the government. In February 2024, just a few months before the European Parliament and municipal elections, the State Audit Office levied a record-breaking HUF 520 million (approximately €1.34 million) fine on opposition parties for allegedly using foreign funds during the 2022 general election campaign. This action put the opposition parties in a difficult position ahead of the next campaign period and further tilted the playing field in favor of Fidesz (Bloomberg 2024).
Furthermore, the government urged the Audit Office to fine several NGOs critical of the government under the new anti-NGO legislation. After a field trip to Hungary in 2023, the European Parliament’s budget control committee was particularly critical of the quality of the ÁSZ’s leadership and performance. Overall, the Audit Office is more of a complementary government body than one that oversees the government. In February 2024, just a few months before the European Parliament and municipal elections, the State Audit Office levied a record-breaking HUF 520 million (approximately €1.34 million) fine on opposition parties for allegedly using foreign funds during the 2022 general election campaign. This action put the opposition parties in a difficult position ahead of the next campaign period and further tilted the playing field in favor of Fidesz (Bloomberg 2024).
Citations:
Bloomberg. 2024. “Hungary Clamps Down on Orban’s Opponents With Hefty Fine.” 20 February. https://www.bloomberg.com/news/articles/2024-02-20/opposition-deprived-of-funding-as-orban-clamps-down-with-hefty-fine
Bloomberg. 2024. “Hungary Clamps Down on Orban’s Opponents With Hefty Fine.” 20 February. https://www.bloomberg.com/news/articles/2024-02-20/opposition-deprived-of-funding-as-orban-clamps-down-with-hefty-fine
There is no independent and effective audit office.
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