Head

Auditor General (AG) or Comptroller General (CG)

President

President/First President

Organizational structure

Monocratic

General Audit Office or Comptrollers´ General

• All rights, powers, and responsibilities are grounded in the AG/CG
• Hierarchical structure

Collegiate

• Independent members with freedom to choose working methodologies and audit approaches
• Decisions are made by colleges, a board of members. or both.

Collegiate

Court of Auditors or Tribunals of Accounts

• Independent members are also judges who can impose sanctions.
• Most commonly, each judge is responsible for specific audited bodies because audit responsibilities are less centralized.

Accountability system

Parliamentary

• The SAI is auxiliary to parliament and cannot impose direct audit recommendations on the executive.
• The legislature authorizes expenditure; government offices spend and produce annual accounts. The SAI audits the implementation of the authorized expenditure, reporting back to the legislature or to the responsible parliamentary committee.

Parliamentary

• The SAI is auxiliary to parliament and cannot impose direct audit recommendations on the executive.
• The legislature authorizes expenditure; government offices spend and produce annual accounts. The SAI audits the implementation of the authorized expenditure, reporting back to the legislature or to the responsible parliamentary committee.

Judicial

• The SAI is a court of law endowed with quasi-judicial powers in administrative matters, enabling it to impose penalties or recommendations on audited officials.
• The legislature authorizes the annual budget; public accountants are responsible for proper expenditure and drawing up of annual financial statements, which the SAI then audits, reporting to parliament.

Relations with parliament

• Close ties with the responsible parliamentary committee, which holds government or public bodies accountable based on SAI reports

• Close ties with the responsible parliamentary committee, which holds government or public bodies accountable based on SAI reports

• Little or no relationship with Parliament. The SAI is part of the judicial system and operates independently from the executive and legislative branches.

Types of audit

• Mainly ex-post auditing
• Financial audits
• VFM/performance audits
• Regularity/compliance audits as well, although minor

• Financial audits
• VFM/performance audits
• Regularity/compliance audits as well

• Mainly regularity or compliance audits with sanctions
• Financial audits
• Minor VFM/performance audits (without enforcement powers)

Reporting

• Reports to parliament or responsible parliamentary committee

• Reports to parliament or responsible parliamentary committee

• Reports to parliament and/or head of state on the implementation of the state budget

Strengths

• Strong safeguards to ensure independence of the Auditor General/Comptroller General: not easily removed (dismissal requires an act of parliament, often from both chambers), ability to appoint own staff and decide on working program; submits budget and reports directly to parliament

• Balanced and inclusive audit system in which SAIs reflect multiple viewpoints and decisions are reached by consensus, thereby offering checks and balances that prevent misuse of authority by board members
• Board members have prerogative to freely decide on working methodologies.

• Strong safeguards to ensure independence of the members of the court: they are appointed for a non-time-limited period (fixed retirement age) and are independent from the legislative branch.
• Developing compliance audits effectively can be a strength in contexts in which other financial controls are weak.

Weaknesses

• Risk of abuse of power in the wrong hands: Ensuring integrity and credibility from the head of the SAI is important. Because power is considerably centralized, the institution´s reputation relies highly on this one individual´s capabilities and qualifications.
• Risks of susceptibility to undue political interference: Risks often are low, given that the SAI´s head is generally appointed by parliament and cannot be easily removed.

• Although inclusive, decision-making processes can be slow because of the need to reach consensus among board members.
• Given that board members share management responsibilities and can decide on diverse audit approaches, relationships with audited entities may become difficult and raise concerns regarding the quality of SAI work when members express no single view.
• Risks of susceptibility to undue political interference: This risk may develop when the term of board members matches general elections, and the risk increases if one political party holds a dominant position in parliament, given that the party may exercise influence over who is appointed to the SAI board.
• Appointment procedures by parliament and relatively short fixed terms may prevent board members from achieving high working standards, and that may even entail loss of corporate knowledge and strong leadership when mandates are simultaneously renewed.

• Risk of misuse of power and lack of independence when financial penalties flow to court (rather than back to central government budgets), especially in cases of lack of sufficient resources to meet SAI´s operational requirements.
• Lack of parliamentary involvement may lead to limited follow up of court´s reports and little public debate about their findings, thereby reducing openness of the accountability process.
• The main focus on compliance audit does not allow monitoring how well resources are being handled, although judicial SAI models have gradually begun to carry out VFM audits.

Examples

• Anglo-Saxon countries: United States, United Kingdom, Canada (most Commonwealth countries)
• European countries: Ireland, Denmark
• Latin American countries: Colombia, Mexico, Peru, Chile (an outlier case)

• Sweden, Germany, Netherlands
• Asian countries: Indonesia, Japan, Republic of Korea
• Latin American Countries: Argentina, Nicaragua

• European countries: France, Italy, Spain, Portugal, Romania, Moldova
• Latin American countries: Brazil, El Salvador
• Turkey
• Francophone countries in Africa and Asia