Strengthening the Independence of Supreme Audit Institutions

2. How other actors shape the independence of supreme audit institutions

Abstract

Supreme audit institutions operate within a broader ecosystem of public accountability, where their independence is inseparable from the environment in which they operate. Their work relies on, and influences other actors, including the legislative, executive, judiciary, donors, other oversight institutions, media and civil society organisations. While formal rules define roles and responsibilities, the behaviour of these actors, the quality of their interactions with the SAI, and the informal norms that guide relationships are equally critical in shaping independent oversight.

2.1. The supreme audit institution as part of a country’s accountability ecosystem

Supreme audit institutions (SAIs) do not operate in isolation. They are core institutions of a broader accountability ecosystem consisting of multiple actors of the legislative, the executive and the judiciary as well as external actors such as civil society organisations (CSOs) or donors. Each of them plays a distinct role in shaping how public resources are managed, overseen and ultimately held to account.

In this ecosystem, the independence of a SAI is inseparable from the environment in which it operates. The behaviour of other actors, the quality of their interactions with the SAI and the informal norms that govern their relationships can be just as important as the constitutional or statutory provisions enshrining the independence of a SAI. Indeed, a legislature that is engaged and knowledgeable, an executive that respects boundaries, a judiciary that enforces accountability, and civil society organisations that leverage and amplify audit findings all contribute to an enabling environment for SAI independence. Conversely, weak or politically constrained actors, including SAIs, can undermine even the strongest legal framework.

Heads of SAIs consulted in the context of the Global Project see advocacy for independence as a game changer when facing threats. Understanding and support from the other actors in the accountability ecosystem are necessary to strengthen the independence of SAIs. In addition, recognising and respecting the complementarity between the actors of the accountability ecosystem reinforces their value and may strengthen their independence. This chapter explores how the actions, incentives, and capacities of other accountability actors can contribute to the independence of SAIs.

Although the recommendations in the following sections are organised by actor, they reflect that SAI independence is shaped not only by the actions of individual institutions but also by the relationships among them. Each actor interacts with the SAI in different ways throughout the audit process, and these interactions collectively define the enabling conditions for SAI independence within the broader accountability ecosystem. Viewing the recommendations through a relationship‑based lens highlights that independence is not exercised in isolation. Instead, it emerges from the quality of exchanges, formal and informal, between SAIs and the executive, legislature, judiciary, other oversight bodies, civil society, media, and development partners. These interactions occur at different stages of the audit process, and each stage involves distinct roles, expectations and information flows.

Table ‎2.1 illustrates this dynamic perspective. The same actors engage with the SAI in different capacities depending on the audit stage. For example, the executive provides essential inputs during audit planning through accounting systems and internal control information, while becoming the primary recipient of audit recommendations during follow‑up. Similarly, the legislature may initiate an audit through a formal request but later uses the audit report to inform budgetary deliberations or legislative oversight. Other actors, such as internal audit bodies, regulators, CSOs, media, and academia, also contribute inputs or make use of outputs at different points in the process. The actor‑specific recommendations do not discard the idea that strengthening independence requires co-ordinated action, mutual understanding of roles, and predictable practices among all actors engaged in the accountability system.

Table ‎2.1. Interaction of SAIs with other actors throughout the audit process

Stages of the audit process	Interactions with other actors
Planning the audit	Executive (audited entity): accounting systems, internal controls, policy and regulatory information Internal audit bodies: risk assessments, prior audit results Other oversight bodies: sector-specific guidance, prior findings Legislature: budgetary priorities, statutory mandate CSOs: citizen feedback, service delivery concerns Media: public debates and reporting on service delivery Regulators: sectoral data, compliance reports Academia: technical expertise, research on relevant topics
Conducting the audit	Executive (audited entity): detailed operational data, financial statements, internal reports CSOs: citizen perspectives, complaints, testimonies Academia: subject-matter expertise relevant to audit objectives
Reporting	Executive (audited entity): recommendations to improve decision making, internal controls, and compliance Internal audit bodies: insights to refine audit plans Other oversight bodies & regulators: information to guide reforms, compliance actions, and operational improvements Legislature: evidence to inform budget allocation, policy design, and legal reforms CSOs: information to support advocacy and dialogue with government Media: findings to enhance public awareness and reporting Academia: data to support research and policy studies Citizens: transparency to support informed engagement and electoral decisions Judiciary: in cases of disputes or legal review
Follow-up	Executive (audited entity): monitor implementation of recommendations and improve internal processes Internal audit bodies: lessons learned for future audits Other oversight bodies & regulators: track impact of reforms and compliance Legislature: oversight of reform implementation and budgetary decisions CSOs: track progress and hold authorities accountable Media: follow-up reporting to enhance transparency Academia: analysis of reform outcomes and systemic trends Citizens: information on reform progress to support accountability culture Judiciary: review outcomes if disputes arise

Source: OECD-IDI elaboration.

2.2. The role of the executive

The executive branch of government is responsible for implementing and enforcing laws, administering public affairs and managing public resources. In fulfilling these functions, it plays a central role in ensuring that public institutions operate effectively and in accordance with established legal and policy frameworks. The executive is also responsible for acting on the recommendations issued by the SAI (IDI, 2025[1]).

Stakeholder interviews indicate, however, that significant risks to SAI independence are linked to executive involvement in areas that should remain free from political influence. Concerns were raised around the executive’s role in the SAI’s budget-setting process and in shaping its work programme. Given that the executive is itself subject to audit, excessive or inappropriate involvement in these areas creates a risk of conflicts of interest and may undermine the SAI’s operational and functional independence.

At the same time, the executive has an essential responsibility to uphold and protect SAI independence. This includes refraining from political interference in the SAI’s work, ensuring that adequate legal and institutional safeguards are in place, and demonstrating commitment to accountability by implementing audit recommendations and sanctions. By clearly defining its responsibilities, in particular, in relation to internal control, fiscal policy and the follow-up of audit findings, the executive can mitigate risks of undue influence and reinforce a governance framework in which SAI independence and public accountability are safeguarded.

2.2.1. To limit undue involvement in external audit functions, the executive could clarify and strengthen its responsibility for internal control and audit, accounting systems, and policymaking powers on public integrity and broader public governance performance

A clear separation of responsibilities between the executive and the SAI is a fundamental principle of independence and public sector accountability. The executive is responsible for establishing and maintaining effective accounting systems, internal control frameworks, internal audit arrangements, and related policymaking and implementation functions in areas such as anti-corruption, public integrity, and overall public sector performance, including efficiency and effectiveness in the use of public resources. This separation is essential to safeguarding the independence of external audit and ensuring that SAIs are able to provide objective and credible oversight of government activities without assuming roles that could compromise the required arm’s-length relationship.

Effective internal control and internal audit systems within the executive branch also contribute to sound public financial management and broader government performance objectives, including efficiency, effectiveness, and value for money, by enabling the timely identification and remediation of risks and weaknesses. To enhance audit readiness, accounting reforms should be explicitly aligned with audit requirements. This includes adopting coherent accounting standards, consolidating charts of accounts, preparing timely financial statements, and ensuring transparency in reporting. Well-designed and maintained accounting systems provide SAIs with reliable, auditable information, strengthening their capacity to deliver credible and timely assurance. Likewise, clear executive ownership of public integrity and performance management policies helps ensure that SAIs are not drawn into operational or policy responsibilities that they may later be required to audit. Where these systems function effectively, external audit can focus on providing independent assurance and systemic insights, rather than compensating for shortcomings in executive accountability or auditing its own policy influence.

However, evidence from stakeholder interviews suggests that responsibilities related to accounting, internal control, and internal audit within the executive are not always fully assumed in practice. As a result, the SAI is at times expected, formally or informally, to address weaknesses that fall within the executive’s management responsibilities.

At the same time, the executive retains influence over key aspects of the SAI’s functioning, including elements of budget determination and work programme planning. Given that the executive is also the primary auditee, this situation creates risks to the SAI’s independence and blurs the boundary between internal management functions and external oversight. Strengthening executive ownership of internal accountability mechanisms would help to reduce these risks and reinforce institutional separation, while also improving overall government performance, accountability, and efficiency in public resource management.

Therefore, the executive branch could take clearer and more comprehensive responsibility for accounting systems, internal control processes and internal audit functions, as well as for policymaking and implementation mandates related to anti-corruption, public integrity and broader governance performance objectives, including effectiveness, efficiency, and value for money. This clarity of the respective roles of the executive and SAIs would contribute to strengthening internal governance and safeguarding the independence of SAIs. This could be achieved by reaffirming, through legislation, regulations or authoritative guidance, that these functions fall squarely within executive accountability, and by ensuring that internal audit arrangements are adequately resourced, professionally staffed and able to operate with sufficient functional independence within the administration to fulfil their mandates effectively.

In addition, the executive could strengthen frameworks that support effective interaction between internal audit and external audit, allowing the SAI to rely on internal audit work where appropriate without substituting for executive responsibilities and reducing audit duplication (OECD, 2024[2]). By fully assuming its role in internal assurance, internal control, and related policy ownership, the executive would reduce the need for involvement in external audit processes and help safeguard the SAI’s operational and institutional independence, while also strengthening the effectiveness and efficiency of broader public sector governance systems. An example of how clear executive ownership of accounting, internal control, and audit functions can support external audit independence is illustrated in Box ‎2.1 below.

Box ‎2.1. Public accounting and control framework in Estonia

Estonia provides a recent example of public sector accounting reform focused on accrual accounting, consolidation, and shared service arrangements. All public sector entities apply a unified chart of accounts and report into a central system on a regular basis, enabling timely consolidation of whole-of-government financial statements. Internal controls are reinforced through standardised rules, automated reconciliations, and centralised support functions. This comprehensive framework ensures that internal control and internal audit responsibilities are fully assumed by the executive, allowing the SAI to focus on external audit and independent oversight, rather than compensating for weaknesses in internal management. Estonia’s experience demonstrates the practical benefits of clarifying and strengthening executive responsibility to protect the independence and effectiveness of external audit.

Source: (Estonian Ministry of Finance, 2025[3])

2.2.2. To strengthen fiscal transparency, the executive could clarify policy priorities underpinning fiscal rules and their application

Fiscal transparency refers to the information available to the public about government’s fiscal policymaking process (IMF, 2018[4]). Clear and transparent fiscal rules are a key element of sound public financial management and fiscal integrity. They should be clearly defined, well understood and transparently applied to support accountability and informed public scrutiny (OECD, 2014[5]). The International Monetary Fund (IMF)’s Fiscal Transparency Code (IMF, 2019[6]) and Fiscal Transparency Handbook (IMF, 2018[4]) highlight the importance of reliable, comprehensive, and timely fiscal information, noting the role of independent SAIs in validating financial statements and ensuring that fiscal information is trusted by all stakeholders.

Stakeholders’ testimonies consistently referred to the relevance of fiscal transparency in relation to work of SAIs and other oversight institutions across four dimensions:

• First, fiscal transparency strengthens checks and balances between the executive and the legislative. When fiscal information is clear and accessible, the legislature is better equipped to scrutinise budget proposals and to use SAI findings effectively during budget deliberations. This contributes to a more balanced budget process and strengthens the use of audit findings in fiscal decision making.

• Second, SAIs noted that a robust fiscal transparency framework supports the selection of audit topics and strengthens risk assessments, as reliable fiscal information allows auditors to identify vulnerability and priority areas more effectively.

• Third, the exercise of the SAIs foresight role, particularly related to public finance and identifying fiscal vulnerabilities, depends to a large extent on the availability, quality and consistency of transparent fiscal information.

• Fourth, consulted oversight institutions, and SAIs, highlighted the importance of having a clear and transparent justification for their own budget trends, especially where budgets are constrained or reduced in the context of fiscal rule implementation, as this can affect the operational independence of oversight institutions. This is related to principle 8 of the Mexico Declaration principle, in the case of SAIs.

While fiscal transparency frameworks and fiscal rules are usually formally established and play an important role in guiding budgetary policy, evidence from document analysis and stakeholder interviews suggests that the policy priorities underpinning individual fiscal rules are not always clearly articulated or communicated. As a result, it may be difficult for stakeholders to assess how rules are applied in practice, how trade-offs are managed when multiple rules operate simultaneously, and how these decisions affect oversight institutions, including SAIs, particularly in relation to their resourcing and ability to conduct independent oversight.

Therefore, the executive could consider strengthening the fiscal transparency framework to better support the independence of SAIs and the broader accountability ecosystem. This includes clearly articulating the policy priorities associated with each fiscal rule and explaining how these priorities guide their application in practice. Explicitly documenting the objectives, scope and intended use of each rule, as well as clarifying how tensions between rules are resolved, would promote greater predictability and consistency and reduce the risk that fiscal rule implementation inadvertently constrains oversight institutions. This could be guided by the IMF’s four-pillar fiscal transparency framework, which covers fiscal reporting, forecasting and budgeting, fiscal risk analysis and management, and resource revenue management, ensuring that each pillar supports accessible, reliable, and policy-linked information for oversight institutions (IMF, 2019[6]).

The executive could also systematically communicate how fiscal rules are implemented in practice and how policy orientations are reflected in the budgets of SAIs and other oversight bodies. By making the policy rationale underpinning fiscal rules more explicit, the executive would facilitate more effective legislative scrutiny, strengthen external oversight, and help ensure that the resources of SAIs and other accountability institutions are determined in a transparent and predictable manner consistent with their independent mandates.

2.2.3. To strengthen accountability and support SAI independence, the executive could improve the follow-up of audit recommendations through structured engagement with the SAI and the legislature

Effective follow-up on audit recommendations is a core component of public sector accountability and performance. Audit and control mechanisms only contribute to improved governance when findings and recommendations are acted upon by the executive and subject to appropriate legislative scrutiny. INTOSAI’s Principles on the Value and Benefits of Supreme Audit Institutions (INTOSAI-P 12) emphasise that SAIs add value when their recommendations lead to tangible improvements, while implementation responsibility remains clearly with the executive.

Well-functioning follow-up arrangements also help preserve the institutional balance between the executive, the SAI and the legislature. By ensuring that the executive is accountable for corrective action, while the legislature exercises oversight and the SAI retains its independent assurance role, follow-up mechanisms contribute to both effective public management and the protection of SAI independence (OECD, 2020[7]).

The interviews conducted for this report indicate that there are examples of constructive engagement, both de jure and de facto, among SAIs, executives and legislatures. This provides a foundation for accountability and follow-up. However, the evidence collected also suggests that follow-up on SAI recommendations is not always systematic or consistent across government entities. In some cases, responsibilities for implementing recommendations are unclear, progress reporting is uneven, and timelines for follow-up are not well defined.

These shortcomings can limit the impact of audit work and may create expectations for the SAI to engage more extensively in the implementation of recommendations, which goes beyond its core mandate. At the same time, limited or ad hoc interaction between the executive and the legislature on audit follow-up can weaken legislative oversight by reducing the timely flow of information and incentives for the executive to act on audit findings. Sporadic engagement can fragment oversight efforts, limit the practical impact of SAI work, and erode institutional memory, making it harder for the legislature to track recurring issues or outstanding recommendations. Strengthening and formalising these interactions ensures audit findings are systematically considered, reinforcing both legislative oversight and the independence of the SAI. Box ‎2.2 provides two practical examples of ways that engagement between the SAI and executive has been strengthened.

Box ‎2.2. Strengthening relationships between the SAI and the executive in the follow-up of audit recommendations

Georgia – Realtime follow-up through a digital platform

The State Audit Office of Georgia (SAO) has developed a digital system, the Audit Recommendation Implementation System (ARIS), that enables real-time monitoring of how public entities implement audit recommendations. Through ARIS, audited institutions submit action plans, evidence, and progress updates directly to the SAO, while the system tracks deadlines, compliance status and supporting documentation. This structured, IT based communication channel allows both auditors and audited entities to share information transparently and continuously, reduces delays in follow-up, and helps target corrective actions more effectively. The platform also provides tailored access for Parliament and audited entities.

Colombia – Institutionalised follow-up through a mandatory improvement plan

In Colombia, audited entities must prepare a Plan de Mejoramiento (Improvement Plan) when the SAI, the Contraloría General de la República, identifies audit findings. Entities are legally required to design corrective actions, document responsibilities and timelines, and upload progress reports through the national electronic reporting system (SIRECI). The SAI conducts systematic monitoring of each plan, reviewing evidence submitted by entities and verifying whether corrective actions are completed, partially implemented or pending. Internal control offices also play a formal role by validating the evidence before it is submitted. This structured, recurrent monitoring process helps maintain active dialogue between the SAI and the audited entity.

Source: (State Audit Office of Georgia, 2022[8]; Superintendencia de Servicios Públicos Domiciliarios, 2025[9])

The executive could consider strengthening the follow-up of audit recommendations by establishing clearer and more structured processes for responding to, implementing and reporting on recommendations issued by the SAI. This could include formally assigning responsibility within the executive for co-ordinating follow-up, setting clear expectations for timelines and progress reporting, and ensuring that comprehensive and timely information is provided to the legislature to support its oversight role.

In addition, the executive could enhance structured engagement with both the SAI and the legislature by using follow-up mechanisms, such as written action plans or progress reports, to clarify recommendations, communicate implementation challenges and demonstrate corrective action, while fully respecting the independence of external audit i.e. ensuring that engagement does not influence the SAI’s audit work, findings, or reporting. Strengthening these arrangements could improve the effectiveness of audit follow-up, reinforce accountability to the legislature and enhance the credibility and institutional authority of the SAI, thereby supporting its independent role within the broader public accountability system.

2.2.4. To reinforce the independence of SAIs, in jurisdictions where the executive has a constitutionally defined role in the nomination or appointment process of the head of the SAI, robust safeguards should be applied to ensure that this role is exercised in a transparent and merit-based manner, consistent with the principle of SAI independence

In many countries, constitutional or legal frameworks assign the executive branch a formal role in the appointment of the head of the SAI, such as through nomination or participation in the selection process. Even where the legislature makes the final appointment, the executive may exert influence through political majorities in the legislature. These arrangements can give rise to perceptions of political alignment or undue influence, particularly when procedures are opaque or discretionary. 

Such perceptions can undermine confidence in the independence and impartiality of the head of the SAI, especially given the institution’s role in auditing government entities. Ensuring that appointment processes are transparent, rule-based, and anchored in professional qualifications is therefore critical to maintaining the credibility and legitimacy of the SAI. 

Interviews with SAI officials and members of the legislature highlighted the importance of transparent and well-defined appointment procedures in strengthening the legitimacy of the selected candidate. Interviewees emphasised that clear criteria, open processes, and visible adherence to merit-based standards can help reinforce confidence in the independence of the SAI’s leadership, particularly in systems where the executive participates in the appointment process. 

Where the legal framework grants the executive a role in nominating or appointing the head of the SAI, additional safeguards could be introduced to strengthen transparency and protect the perceived independence of the institution. In such cases, the executive could ensure that the selection and nomination process is conducted in a transparent and merit-based manner. 

This may include publicly outlining the criteria used in selecting the nominee, explaining how the candidate meets these criteria, and demonstrating how the nominee’s professional qualifications and experience align with the requirements of the role. The involvement of an independent selection panel in the appointment process could further reinforce transparency and impartiality. Greater openness around the selection process can help reinforce confidence that the appointment is based on competence and professional merit rather than political considerations. 

These practices can be aligned with international public-governance standards that emphasise merit, integrity, transparency, and protection from undue political influence in leadership appointments (Gerson, 2020[10]). 

2.2.5. The executive could carefully consider potential unintended consequences related to legal reforms proposals affecting the mandate and functions of the SAI and other accountability actors

Informal challenges often arise through incremental, incoherent, or fragmented legal and regulatory developments.

• First, new laws, regulations or amendments in related policy areas may unintentionally affect the SAI’s mandate, access to information, reporting lines, or resources. Without systematic legal coherence, inconsistencies and ambiguities can emerge, creating space for restrictive interpretations that gradually weaken independence, even when the core audit law remains unchanged.

• Second, reforms aimed at strengthening oversight, such as expanding the SAI’s mandate, can have unintended consequences if not aligned with the broader accountability ecosystem and available resources. Assigning new responsibilities without adequate capacity, co-ordination, or alignment with other actors may create pressures that indirectly affect independence and effectiveness.

As the primary actor responsible for drafting and proposing legislation, the executive has a primary responsibility to ensure that draft laws and regulations are coherent, evidence-based, and consistent with the broader legal framework. This includes assessing whether proposed reforms are aligned with the SAI’s constitutional mandate and existing audit laws, and whether potential implications for other accountability actors have been considered. Recognised principles of good public administration, such as the OECD Principles of Public Administration (OECD, 2023[11]), emphasise that policies and legislation should be developed on the basis of sound analysis, clear internal procedures, systematic use of regulatory impact assessments, and inclusive consultation processes.

Legal reforms should be designed to mitigate system-level risks by promoting legal coherence and by considering the wider institutional framework, the operational requirements of SAIs, and the resources needed to uphold independence in practice. Coherence is particularly critical where sector-specific laws intersect with audit mandates, data protection regulations, or access-to-information provisions that may inadvertently constrain oversight.

Ensure legal coherence of new and existing legislation

A clear, coherent and consistent legal framework is essential for enabling SAIs and other accountability actors to carry out their mandates effectively and without undue interference. In practice, however, legal frameworks governing public auditing are not always internally consistent. Fragmentation across primary and secondary legislation, or misalignment between constitutional provisions and sector-specific laws, can create ambiguities regarding the SAI’s mandate, access to information and audit scope. These inconsistencies may, over time, constrain the SAI’s operational independence, even where strong formal guarantees exist.

SAI independence extends beyond constitutional recognition and depends on the alignment of ordinary legislation governing audit scope, access to information and relationships with audited entities. Where legal frameworks are fragmented or inconsistent, SAIs may face practical obstacles that undermine their effectiveness and independence, even when strong constitutional guarantees formally exist.

In some countries, the SAI’s constitutional mandate is constrained in practice by a lack of legal coherence across the broader legal framework. Although the constitution often grants the SAI authority to follow the flow of public funds, certain sector-specific laws introduce limitations that restrict the full exercise of this mandate. For example, in cases brought forward to IDI’s SIRAM and during interviews conducted in the context of the Global Project, stakeholders noted inconsistencies between constitutional provisions and secondary legislation. These include restrictions related to national security classifications, data protection frameworks, personal data regulations, and requirements for auditing state-owned enterprises, which in some cases must be audited by private firms instead of the SAI. Such inconsistencies can create legal ambiguities regarding the SAI’s oversight powers and increase the risk of legal challenges to audit activities.

Existing legal frameworks are not always systematically aligned with the SAI’s constitutional powers, and mechanisms within the executive to identify and resolve such inconsistencies are not always well established. In addition, when draft laws or regulations maintain or introduce constraints affecting the SAI, the underlying rationale is not always clearly articulated or supported by publicly available legal analysis. Opportunities to incorporate the perspectives of legal experts, civil society organisations, academia and international partners in the preparation of legislation affecting the SAI may also remain limited.

Therefore, the executive could consider reinforcing legal coherence as a means of safeguarding the SAI’s independence and effectiveness. This could include introducing structured review mechanisms within the policy development and legislative drafting process to assess whether proposed laws and regulations in areas relevant to public financial management, audit, and government accountability are consistent with the SAI’s constitutional mandate and audit law or jurisdictional framework. Such processes could be supported by independent legal expertise and embedded within internal government procedures. This approach would help identify and address contradictions at an early stage, particularly in proposals that may affect the SAI’s mandate, access to information, or audit scope. Box ‎2.3 provides an example in practice of a structured and sequenced reform process supporting legal coherence.

Box ‎2.3. Sequenced legal consistency reform in France

France undertook a major reform of its public financial accountability framework, culminating in the introduction of the Unified Regime of Public Manager Responsibility (Régime de responsabilité des gestionnaires publics – RGP), which entered into force on 1 January 2023. Rather than being adopted as a standalone measure, the reform resulted from a sequenced and co-ordinated legislative process designed to ensure coherence between financial liability rules, public management reforms and internal control systems.

The process unfolded through clearly defined milestones: recommendations issued in June 2018 by the Comité Action Publique 2022; a political decision to proceed with reform during the 5th Interministerial Committee for Public Transformation in February 2021; legislative authorisation granted through the 2022 Budget Law in December 2021; and the adoption of Ordonnance n° 2022-408 in March 2022, which formally established the unified regime.

The reform replaced a fragmented and category-based liability system with a single, coherent regime of responsibility applicable to all public managers in cases of serious financial misconduct. Importantly, the new framework aligns sanctioning mechanisms with the functioning of internal control systems, thereby modernising and harmonising the broader accountability architecture.

This sequenced and structured approach illustrates how systematic legal coherence, embedded in executive-led policy development and supported by co-ordinated reform processes, can enhance consistency across accountability frameworks. By reducing fragmentation and clarifying responsibilities, such reforms can strengthen the overall legal environment within which supreme audit institutions operate, thereby contributing indirectly to the safeguarding of their independence and effectiveness.

Source: (Légifrance – Service public de la diffusion du droit, 2022[12]; Légifrance – Service public de la diffusion du droit, 2022[13]).

In parallel, the executive could institutionalise regular and structured dialogue with the SAI and other relevant stakeholders during the preparation of draft legislation and regulatory reforms. Such engagement can help identify legal ambiguities and their operational implications at an early stage, support a shared understanding of institutional mandates, and reduce the risk that reforms unintentionally weaken the SAI or create overlaps or gaps in oversight responsibilities.

To strengthen transparency and accountability, the executive could also clearly communicate the legal and policy reasoning underpinning draft laws and regulations that may affect the SAI’s mandate. Publishing supporting analyses, including assessments of legal consistency and potential impacts, would reduce uncertainty for the SAI and audited entities, while reinforcing trust in the reform process. More systematic stakeholder engagement, including with civil society, academia and international partners, could further support alignment with international standards and good practices.

Legal reforms should consider threats to independence, the broader accountability ecosystem, and required resources

Legal reforms aimed at strengthening the mandate of SAIs play a central role in reinforcing public accountability and integrity. Expanding or modifying the responsibilities of SAIs without due consideration of their impact on the SAI’s core mandate, institutional interactions and implementation capacity, however, may unintentionally undermine their independence or effectiveness.

In some countries, legal reforms related to the SAI have sought to expand the institution’s roles and responsibilities to cover, for example, auditing of donor funded development projects, auditing political parties, or designing or implementing internal control, internal audit or integrity policies. In particular, given the challenges in effectively controlling corruption, SAIs are increasingly asked to play a more explicit and active role in controlling corruption (United Nations, 2019[14]). Such expanding mandates reflect the trust placed in the SAIs, a strong commitment to strengthening external audit and recognises the SAIs as a key pillar of the accountability system.

However, the design and implementation of such reforms have not always fully considered their implications for the core mandate of the SAI, the wider accountability ecosystem, or the resources required to carry out the expanded mandate effectively.

• First, while SAIs play an important role in assessing and strengthening the overall internal control system, there is a risk to independence when they become responsible for designing or implementing internal control, internal audit or integrity policies. Assigning these responsibilities may directly undermine the SAI’s capability to independently provide oversight in these areas. In addition, it may lead to challenges related to ensuring the ownership of the executive in implementing controls and integrity measures as public managers may perceive that this has become the task of the SAI. To play an effective role in promoting public integrity, SAIs should focus on their core mandate of providing oversight and assurance, supervising the use of public resources and the application of laws, regulations and policies, as well as providing relevant evidence and insights on the performance of such policies and on emerging systemic and structural risks that can inform policymaking.

• Second, expanding the mandate of SAIs may come along with expectations by citizens and stakeholders that are difficult to meet as the success of such a reform may also depend on the performance of other accountability actors. In some cases, evidence gathered through the Global Project indicates that new responsibilities have been introduced without a clear assessment of how such interdependencies, capacity constraints or co-ordination challenges may affect the SAI’s ability to implement reforms as intended. Weaknesses or gaps in the accountability chain then can place additional burdens on the SAI and create expectations that exceed its core mandate. Reforms affecting SAIs should therefore consider how other actors within the accountability ecosystem, such as the executive, the legislature, internal control bodies or anti-corruption bodies, may influence the successful implementation of such reforms.

• Third, expanded roles of SAIs have not always been accompanied by a systematic analysis of the financial, human and technical resources required for a successful implementation. As a result, the SAI may be expected to deliver additional functions without proportionate increases in budget or staffing, potentially increasing dependence on external decision makers for resources and, in turn, posing risks to institutional independence. Principle 8 of the Mexico Declaration on SAI Independence emphasises that SAIs must have access to adequate and stable resources; new mandates that are not matched by appropriate funding and capacity can weaken institutional independence and expose SAIs to external pressures. The executive could therefore ensure that draft laws and reform proposals are systematically accompanied by an assessment of their resource implications, including budgetary needs, staffing, skills and infrastructure. Where resource constraints exist, the executive could consider phased implementation or alternative institutional arrangements to mitigate risks to independence.

In light of the challenges outlined above, the executive could consider adopting a more holistic approach to legal reforms affecting the SAI’s mandate, to ensure that potential challenges are identified and addressed at an early stage. When drafting laws or regulations that propose changes to the roles and responsibilities of the SAI, the executive could systematically assess the risks and implications outlined above. Such analysis would help ensure that reforms are realistic, complementary and do not inadvertently shift responsibilities to the SAI that properly belong to other actors or undermine their independence.

To support this, the executive should consider establishing transparent and structured reform processes, grounded in sound analysis and supported by tools such as regulatory impact assessments. It should also ensure early and meaningful consultation with the SAI and other relevant stakeholders within the accountability ecosystem. This consultation could take place even when not legally required, reflecting a commitment to transparency and reinforcing trust among oversight institutions. Such engagement can help identify legal ambiguities, capacity constraints and institutional interdependencies at an early stage, while promoting more balanced and coherent reform design. In doing so, the executive could further strengthen openness, predictability and trust in reform processes, helping to ensure that changes are aligned with the SAI’s functional needs, institutional role and contribution to public sector integrity.

2.3. The role of the legislature

Through its lawmaking function, as well as the control and regulation of the national finances, the legislature shapes the governance landscape and oversees the executive. The oversight of the executive is usually done through committees of the legislature such as the public accounts committee in the legislative model and the finance committee in the jurisdictional model (IDI, 2025[1]).

In many countries, however, oversight of government finances and operations by legislatures is constrained due to lack of resources, capacity and leverage, and a non-responsive executive (Morgner and Chêne, 2015[15]). Much like with SAIs, while the individual strength of the legislature itself cannot ensure overall accountability, having a legislature operating under significant constraints makes accountability nearly impossible (Krafchik, 2025[16]).

In relation to the SAI, the legislature plays multiple, interconnected roles:

• First, the legislature has the authority to establish and amend the legal framework governing the SAI. Consequently, any reforms aimed at strengthening the SAI’s mandate, independence, or powers require the approval and support of legislators. In this context, the legislature also contributes to the interpretation and implementation of the legal framework in practice.

• Second, the legislature is often responsible for appointing or approving the heads and members of the SAI and, in many systems, retains the power to dismiss them. These functions are critical in shaping the leadership, independence, and credibility of the institution.

• Third, in line with good practices, the legislature plays a key role in determining and approving the SAI’s budget, thereby directly influencing its financial autonomy and operational capacity.

• Fourth, to carry out their oversight function, legislators can rely on SAI audit reports as a key tool for holding the executive accountable. Through debates, committee hearings, particularly within public accounts or budget committees, and formal inquiries, legislators can use SAI findings to scrutinise government spending, assess compliance with laws and policies and evaluate performance. This oversight function is further reinforced by the legislature’s responsibility to ensure that the executive follows up on the SAI’s audit recommendations. Effective follow-up mechanisms, such as requiring formal government responses, setting deadlines for corrective action and monitoring implementation progress are essential to ensure that audit findings translate into concrete improvements in public financial management and governance. To perform this role effectively, two complementary dimensions are essential: (1) strengthening the legislature’s internal capacity, through specialised committees, technical expertise, and structured procedures, to analyse and use audit findings; and (2) engaging constructively in the SAI process in a manner that supports, rather than compromises, the SAI’s independence.

The following recommendations are therefore directed at the legislature and address both the formal and informal dimensions of its engagement with the SAI. While some proposals concern formal, codified elements, such as legislative amendments or procedural reforms, these are often intended to respond to informal challenges that shape how oversight functions in practice. As formal rules do not automatically determine behaviour, strengthening the legal framework alone may be insufficient if unwritten norms, political incentives or organisational practices undermine their implementation. The recommendations thus recognise the interplay between de jure arrangements and “rules in use,” seeking not only to improve formal structures but also to mitigate informal constraints that impact the effective exercise of legislative oversight and the SAI’s operational independence.

2.3.1. Through their lawmaking, the legislature can support SAI independence by strengthening laws and regulations that underpin the institutional architecture of SAIs and protect their mandate

The structural design and composition of the SAIs are central to safeguarding their independence. The Mexico Declaration sets out key principles relating to the formal, de jure dimensions of SAI structure, including constitutional recognition, appointment mechanisms, tenure, and protection from undue interference. However, the effectiveness of these formal safeguards is often shaped by informal dynamics that influence how structural arrangements operate in practice.

Legislators bear primary institutional responsibility for establishing and maintaining a robust SAI structure. While many structural features are entrenched in constitutional or statutory provisions, independence is not secured by legal design alone. The transparency, integrity and good-faith implementation of these arrangements, particularly in areas such as appointments, removals and organisational governance, often extend beyond the written framework. It is at this intersection between formal safeguards and informal practices that structural independence may either be reinforced or undermined, underscoring the need for careful legislative attention.

To enhance the long-term independence and operational sustainability of the SAI, the legislature could strengthen the SAI’s institutional architecture by ensuring that legal requirements of internal structures and leadership arrangements are designed to minimise political influence, preserve institutional knowledge and support continuity

A robust institutional structure is essential for SAIs to fulfil their mandates, including jurisdictional activities, with independence, continuity and professionalism. The sustainability of a SAI depends not only on its formal, legal guarantees but also on the stability of its internal architecture, specifically, its human resources framework and the composition and functioning of its collegial bodies.

SAIs must be insulated from political influence in both their decision making and operational management. Ensuring a stable, professional workforce and a balanced, well-designed collegial body is therefore critical to safeguarding independence, preserving institutional memory, and ensuring objective audit outcomes over time.

Workforce and staff structure

Testimonies from interviews and consultations with SAI staff highlighted that stability within the SAI workforce is perceived as closely linked to its independence. According to interviewees, uncertainty around staffing arises from both internal and external dynamics. Internally, several consulted stakeholders noted that tensions may arise if the professional career of SAI employees depends too much on the institution’s leadership. Informally, the SAI employees then may orient their behaviour towards satisfying the leaderships’ interest, which may not always coincide with the interest of the institution. Externally, staff reported that recruitment and career progression can be influenced by broader public administration policies, ad hoc executive decisions, or informal networks linked to political actors.

In countries where SAI personnel belong to the general civil service pool, the testimonies emphasised that the SAI’s limited control over hiring, remuneration and career development further contributes to this uncertainty. Where SAIs are part of the general civil service, ensuring their operational independence requires that they retain full autonomy over hiring, career development and remuneration, testimonies suggest that this is often not the case in practice. It was noted that recruitment is often shaped by regulations set by the executive, and in practice, civil service systems may operate through informal hierarchies and discretionary authority within bodies such as ministries of public administration. Testimonies indicated that even when formal frameworks appear neutral, their implementation may be affected by informal bargaining, cross-institutional dependencies or expectations of loyalty, creating openings for external influence in staffing decisions. Several consulted stakeholders also observed that legislatures may undervalue the need for a stable, technically qualified SAI workforce, sometimes assuming that SAIs can be staffed like other public institutions without considering the specific auditing or jurisdictional expertise required. Together, these accounts describe a context in which both formal constraints and informal norms shape staffing outcomes in ways that may not align with the operational needs of the SAI.

Collegial bodies

In several SAIs, governance is entrusted to collegial bodies composed of several members who collectively assume strategic leadership, adopt key decisions, and safeguard the institution’s independence. This model aims to promote balanced deliberation, shared responsibility and continuity through collective decision making. While collegial arrangements can strengthen institutional resilience, their effectiveness depends heavily on the design of appointment procedures, mandate structures and internal decision-making rules. Where these safeguards are insufficiently defined or implemented, collegial systems may become vulnerable to politicisation, informal bargaining or instability, with potential implications for the SAI’s perceived and actual independence.

There have been instances where the renewal of members of collegial bodies occurs simultaneously, creating windows of opportunity for the prevalence of informal practices that lead to quota-based negotiations. This situation undermines Principle 2 of the Mexico Declaration by weakening safeguards against political cycles and reducing stability within the leadership structure.

Beyond timing, the appointment processes of collegial bodies themselves are often perceived by stakeholders interviewed in the context of the Global Project as being driven exclusively by political considerations. While the appointment of SAI leadership inherently involved political actors in many governance systems, limited transparency and weakly defined selection criteria amplify perceptions of bias, affecting confidence in the neutrality and independence of the institution. Where appointment procedures lack openness of clear merit-based standards, some consulted stakeholders pointed out that the credibility of leadership decisions may be questioned both internally and externally.

Additionally, some testimonies perceived that the size and composition of collegial bodies sometimes allow for informal bargaining or politicisation. Undefined or unbalanced voting rights for politically appointed members brings about informal arrangements that can further distort deliberations, hinder collective decision making and reduce the credibility and independence of the SAI.

Therefore, to address the vulnerabilities identified above and enhance the long-term independence and operational sustainability of the SAI, the legislature could strengthen the SAI’s institutional architecture by ensuring that internal structures and leadership arrangements are designed to minimise political influence, preserve institutional knowledge and support continuity.

First, the legislature could consider reinforcing the stability and professional development of the SAI’s workforce through measures that formalise a long-term approach to human-resources management. This would allow the alignment of staff incentives with the objective of independence. Depending on the national administrative context, this could involve establishing a more autonomous career framework for staff, ensuring that recruitment and promotion processes are based on merit, and safeguarding key HR decisions from undue involvement of executive bodies responsible for broader civil service management. Box ‎2.4 provides two examples of this in the contexts of South Africa and Spain. These steps can help reduce the influence of informal expectations, networks, and discretionary practices that sometimes shape appointments and mobility.

Box ‎2.4. Examples of independent SAI staffing structures

South Africa

The Auditor-General of South Africa (AGSA) is subject only to the Constitution and the law, which require it to perform its functions “without fear, favour or prejudice.” This constitutional guarantee of independence extends beyond audit decision making to the AGSA’s internal organisation and staffing. Recruitment profiles, job requirements, and hiring decisions are determined by the AGSA itself rather than by general public-service rules or executive-branch regulations.

This institutional autonomy enables the AGSA to attract and retain professionals with the specialised competencies required for modern public-sector auditing.

To sustain this independence in practice, the AGSA has established dedicated talent-management and human-resource programmes, including structured pathways for graduates and early-career auditors. These initiatives support long-term workforce planning, strengthen technical capacity, and promote continuous professional development, thereby reinforcing the institution’s operational effectiveness and resilience.

Spain

The employment model of the Tribunal de Cuentas is grounded in a stable, merit-based civil‑service corps. Career staff enter through competitive public examinations for the main professional corps, (auditors, legal officers, and technical audit staff), ensuring a consistently high level of technical expertise and professionalism across the institution. This structure provides strong continuity, as career officials enjoy employment safeguards and cannot be removed by the institution’s leadership except on serious and legally established grounds. 

Source: Interviews with the Auditor-General of South Africa; (Letsebe, 2025[17]); and Fact-finding mission.

Second, the legislature could review and strengthen the leadership and governance arrangements of the SAI to ensure that decision-making structures operate predictably and are safeguarded against both formal institutional changes (such as shifts in legislative majority affecting appointments) and informal political dynamics, including bargaining or personalised influence. This may include adopting mechanisms that ensure staggered or phased transitions within the collegial leadership structures, thereby preventing simultaneous turnover that can expose the institution to political negotiation or informal quota-based arrangements. Furthermore, clarifying the size, composition and operating rules of leadership structures can contribute to effective deliberation and minimise opportunities for informal political trade-offs or personalised influence. In some systems, these objectives are achieved by establishing clear internal rules for collegial decision making, distributing responsibilities across members, defining quorum and deliberation procedures, and implementing staggered appointments or phased transitions to limit the space for both formal and informal dominance by any single actor. Box ‎2.5 provides an example of staggered appointments.

Box ‎2.5. European Court of Auditors (ECA) – Staggered terms by design

The European Court of Auditors appoints 27 members for fixed six‑year terms, and not all terms coincide; when the Court was established, initial appointments were made with different term lengths so that future renewals would not occur all at once. This effectively creates a de‑facto staggered renewal cycle, helping avoid complete turnover in the same political moment and reducing opportunities for co-ordinated political influence within the Court.

Source: (Official Journal of the European Communities (OJEC), 1977[18]).

To strengthen the independence and credibility of a SAI, the legislature could enhance the transparency of the appointment, the tenure and dismissal frameworks of heads of SAIs

Ensure a transparent and merit-based appointment of heads of SAI

Transparent and merit-based appointment processes for heads of SAIs are a cornerstone of institutional independence, legitimacy, and can also support broader confidence in the institution’s oversight role. The OECD Recommendation on Public Service Leadership and Capability explicitly recommends adherents to consider merit-based criteria and transparent procedures in the appointment of senior level public servants (Gerson, 2020[10]). The OECD Integrity Handbook further underlines that transparency in appointments reduces perceptions of undue influence and strengthens accountability, particularly for institutions with oversight and control functions (OECD, 2020[7]).

Public accountability systems require not only formal guarantees of independence but also processes that foster public confidence in decision-making and leadership selection. Where appointment procedures are perceived as opaque or politically driven, even strong legal safeguards may be insufficient to ensure trust in the institution’s independence. Box ‎2.6 provides an example of the benefits of non-political appointments.

Box ‎2.6. Non-political background of the President of the Audit Bureau of Jordan

The current Head of the Audit Bureau of Jordan comes from an academic background rather than a political or partisan career. While this is not a rule in Jordan, his non-political professional background is widely perceived by consulted stakeholders as a reputational asset, as it signals technical expertise, methodological rigour, and a commitment to professional standards. As a result, his leadership is viewed as less susceptible to political influence or favouritism. This perception strengthens confidence in the Bureau’s objectivity and reinforces the view that the institution operates with a high degree of independence, particularly in its oversight and accountability functions.

Source: Fact-finding mission.

Stakeholders consulted during the data collection process consistently emphasised that the initial credibility of the head of the SAI at the moment of appointment plays a decisive role in shaping the institution’s reputation and perceived independence. It was noted that this credibility depends not only on the formal legal framework but also on how the appointment process operates in practice. In addition, several practices were highlighted that undermine transparency, such as appointments made in closed legislative sessions, limited public information on candidates’ backgrounds and the absence of documentation supporting selection decisions.

At the same time, consulted stakeholders acknowledged positive elements within existing frameworks, including the presence of a legal basis for appointments and clearly defined roles for the legislature. It was also recognised that some degree of political involvement is inherent given legislatures’ constitutional responsibilities.

Despite this, consulted stakeholders identified important challenges, particularly where the legal framework is broad or allows significant discretion. In such cases, transparency mechanisms beyond the law remain weak. Criteria for selection, procedures for identifying and nominating candidates and the rationale for final decisions are not systematically disclosed. According to consulted stakeholders, this contributes to a perception that appointments are influenced by political considerations or informal quotas, which in turn affects the perceived independence and credibility of appointees.

Concerns were also raised about the professional profile of heads of SAI. In several countries, consulted stakeholders observed that individuals appointed to lead the SAI often lack long-standing institutional experience, which can reinforce perceptions that political considerations are prioritised over professional expertise and institutional knowledge. This may affect both the credibility of leadership and confidence in the SAI’s independence.

Some SAIs additionally pointed to the importance of safeguarding the independence of appointments to other key institutional positions beyond the head, including deputy heads and members of boards, and members of advisory bodies. In jurisdictional SAIs, testimonies underscored the need to extend the same guarantees and independence conditions applicable to the appointment of the head or members of the jurisdictional body to other roles linked to the jurisdictional function.

Therefore, to safeguard independence and legitimacy the legislature could strengthen the transparency and clarity of the appointment process for the head of the SAI through complementary measures that go beyond minimum legal requirements. Where the legal framework permits a significant degree of discretion, the legislature could supplement it with publicly accessible transparency measures (see Box ‎2.7 for an example). These could include the clear definition and disclosure of appointment criteria, such as professional qualifications, integrity standards and relevant experience, as well as the institutional responsibilities at each stage of the process. The main steps of the appointment process, including the identification, nomination, and selection of candidates, could be systematically documented and made publicly available, together with an explanation of the rationale for the final decision.

Box ‎2.7. Transparency in the Paraguayan Head of SAI appointment process

The appointment of the Comptroller General in Paraguay incorporates several key elements of a transparent selection process as outlined in Article 281 of the Constitution and Law No. 276/94 (Organic and Functional Law of the Comptroller General). The Constitution requires the Senate to publicly propose a shortlist of candidates with defined eligibility criteria, and the Chamber of Deputies to elect the Comptroller by absolute majority from that shortlist, with recorded votes in open session.

The process is conducted in open legislative sessions, which are broadcast live through the Congress’ television channel and covered extensively by national media. Candidates’ names, professional qualifications, and voting outcomes are publicly known, and deliberations occur in formal plenary sittings rather than closed executive procedures. In addition, eligibility criteria, including age, professional background, and incompatibility provisions, are established in the legislation, providing ex-ante clarity regarding qualification requirements and grounds for disqualification.

Together, these features generate an initial bonus of credibility, an early presumption of legitimacy and competence, stemming from the openness and procedural safeguards of the appointment. The durability of that credibility, however, ultimately depends on the Comptroller’s performance and continued independence in office.

Source: Fact-finding mission; (Senado de la República del Paraguay, 2021[19]).

In addition, the legislature could promote more visibly merit-based and inclusive leadership profiles by explicitly recognising the value of professional audit or jurisdictional experience, including experience gained within the SAI, alongside other relevant qualifications. Procedural safeguards, such as structured hearings, cross-party involvement, or staggered appointments in the case of collegial bodies, could further reduce perceptions of political bias. Moreover, establishing appointment procedures that require a qualified majority can provide an additional layer of formal protection: although procedural in nature, such thresholds encourage broader political consensus, limit unilateral influence, and help reinforce the legitimacy and perceived neutrality of the selected candidate. Taken together, these measures would help generate a credibility bonus for the head of the SAI and strengthen the institutional reputation and perceived independence of the SAI as a whole.

The aforementioned considerations may also apply to the appointment and profiles of deputy heads of SAIs, members of jurisdictional bodies, and members of boards, including advisory boards, as well as, where applicable, prosecutors and rapporteurs in the case of jurisdictional SAIs.

Strengthen the tenure and dismissal framework of the head of the SAI to minimise fear of retaliation in the exercise of legal duties, political pressure and perceptions of influence

The tenure arrangements for the head of the SAI are a key determinant of the institution’s ability to operate independently. Tenure length, reappointment possibilities and the clarity of legal protection and dismissal procedures directly affect the security and autonomy of the head of SAI and, by extension, the independence of the SAI.

Where these arrangements are well-designed, they can protect the SAI from undue influence stemming from the heads of SAI’s fear of retaliation when carrying out their mandates. Strengthening these elements is therefore essential to ensuring that the SAI can perform its oversight role free from both explicit and implicit political interference.

However, findings from the Global Project indicate that the independence and effectiveness of the head of the SAI is shaped not only by formal rules but also by the informal dynamics surrounding them. For example, several consulted heads of SAIs noted that, following appointment, appointing authorities may establish a tacit expectation of loyalty. Such informal loyalty obligations can influence how the mandate is exercised.

In this context, tenure length affects vulnerability to informal influence. Short or flexible terms may create expectations of early replacement or political bargaining, increasing susceptibility to informal pressure from the executive or the legislature. Similarly, ambiguous dismissal procedures create openings for informal manipulation, particularly where heads of SAIs do not enjoy legal immunity. When grounds for removal are not clearly defined, political actors may exploit legal grey areas or threaten dismissal informally to shape the SAI’s behaviour.

Testimonies also converged on the view that reappointment possibilities generate strong informal incentives, including the creation of loyalty obligations aimed at securing renewal. The prospect of reappointment may encourage officeholders to seek favour with decision makers, potentially compromising impartiality and undermining the practical effectiveness of formal independence safeguards. Even the perception that reappointment is politically influenced can damage public confidence in, and the credibility of, the head of the SAI.

To counteract informal incentives for political alignment or favour-seeking, the legislature could consider adopting a sufficiently long and fixed term for the head of the SAI, designed not only to provide formal insulation from the executive and legislative branches but also to discourage informal factors generating expectations of early replacement or implicit bargaining. In this context, it is also important that the term of office does not coincide with electoral cycles to reduce risks of political alignment and reinforce institutional independence. Box ‎2.8 provides a country example of this.

Box ‎2.8. The term of the Auditor-General of New Zealand

Under the Public Audit Act 2001, the Auditor‑General is appointed for a single, non‑renewable term of seven years, with statutory protections modelled on those that apply to senior judges. This non‑renewable fixed term is intended to reduce incentives for the incumbent to curry favour with appointing authorities and to minimise the risk of retaliation or undue political influence in the exercise of official duties; removal is only permitted through a process that safeguards independence from executive interference.

This arrangement combines a sufficiently long period in office to allow meaningful institutional leadership with a non‑renewable term that removes dependence on reappointment, supporting the SAI’s autonomy in audit planning, reporting, and interaction with other branches of government.

Source: (OAG, New Zealand, 2016[20]).

Recognising that informal practices often exploit ambiguities in legal texts, the legislature could codify clear, tightly framed dismissal provisions, ensuring that grounds for removal cannot be informally negotiated, interpreted flexibly, or used as leverage to shape audit priorities or constrain critical oversight.

Furthermore, acknowledging that reappointment processes can create strong informal incentives for the officeholder to act in ways perceived as politically accommodating, the legislature could consider prohibiting the re-election or renewal of the SAI head’s mandate. A non-renewable term can reduce opportunities for political actors to signal support or opposition in ways that influence behaviour and helps avoid perceptions that the SAI’s leadership is informally beholden to those controlling reappointment decisions.

These steps would strengthen not only the formal structure of SAI independence but also its resilience to informal pressures that can compromise oversight and accountability in practice.

The legislature should carefully consider the implications of legal reforms for SAI independence, the accountability ecosystem, and resource requirements

While the executive is typically responsible for drafting and submitting legal reforms, the legislature plays a central and complementary role in scrutinising, amending, and ultimately adopting these proposals. The exercise of this responsibility is critical to safeguarding the independence of SAIs and ensuring that the broader accountability ecosystem functions effectively. Without careful legislative review, reforms intended to strengthen oversight may inadvertently create ambiguities, constrain SAI mandates, or place unrealistic expectations on institutions, undermining independence and effectiveness.

Legal and regulatory reforms often intersect with multiple areas of public administration, including audit laws, sector-specific regulations, data protection, and access to information. Incoherent, fragmented, or inconsistent legal frameworks can limit the operational scope of SAIs, create risks of restrictive interpretations, and generate opportunities for informal influence by other actors. Legislative scrutiny is therefore essential to identify and resolve potential conflicts, ambiguities, or gaps before reforms are enacted, ensuring that laws are applied consistently and do not undermine oversight responsibilities.

The legislature could institutionalise a structured process for reviewing proposed reforms affecting the SAI, ensuring that all relevant dimensions are considered. Such a process may include:

• Systematic assessment of consistency with constitutional and legal frameworks: Legislators could evaluate whether draft laws align with the SAI’s constitutional mandate, existing audit laws, and sector-specific regulations, identifying potential contradictions that could limit the SAI’s independence or oversight capacity.

• Evaluation of operational and resource implications: Legislative review should consider whether reforms impose additional responsibilities without corresponding adjustments to budget, staffing, or technical capacity, which could create dependence on external actors and erode institutional autonomy.

• Consultation with relevant stakeholders: The legislature could seek input from the SAI, independent legal experts, civil society organisations, academia, and international partners, ensuring that proposed reforms are evidence-based, technically sound, and informed by best practices in public financial management and audit.

• Assessment of systemic risks: Legislators could examine the potential impact of reforms on other oversight institutions and the wider accountability ecosystem, including internal control bodies, anti-corruption agencies, and sector regulators, to ensure that responsibilities are appropriately allocated and complementary.

Adopting such a structured approach enables the legislature to exercise its oversight role not only in approving reforms but also in proactively safeguarding legal coherence. By systematically analysing the potential consequences of reforms, legislators can prevent situations where oversight responsibilities are either missing, duplicated, or weakened, and can reduce the likelihood of unintended pressures on the SAI or other accountability actors.

Legislative scrutiny can also reinforce transparency and public trust. By clearly communicating the legal and policy reasoning underpinning decisions to adopt, amend, or retain provisions affecting the SAI, the legislature provides predictability and clarity for the SAI, audited entities, and other stakeholders. Publicly documenting the analysis, consultations, and rationale for decisions ensures that the legislative process is seen as evidence-based and impartial, enhancing confidence in the accountability framework and the integrity of audit institutions.

Ultimately, the legislature’s proactive and structured engagement in reviewing proposed legal reforms complements the executive’s drafting responsibilities. By ensuring that reforms are coherent, evidence-based, and operationally feasible, the legislature strengthens the institutional and legal environment in which SAIs operate, safeguards their independence, and supports the broader accountability ecosystem. This dual approach, executive drafting combined with careful legislative scrutiny, helps ensure that legal reforms enhance, rather than inadvertently weaken, the capacity of SAIs to perform their oversight role effectively.

2.3.2. Strengthening their own internal institutional arrangements and capacities could improve the effectiveness and credibility of the legislature’s oversight role

Safeguarding SAI independence relies not only on the SAI’s own institutional design, but also on the internal arrangements within the legislature itself. While constitutional and statutory provisions may formally assign oversight responsibilities to the legislature the extent to which these functions are exercised credibly and autonomously is shaped by the legislative body’s internal structures, resources and organisational capacity. Formal rules may designate committees, reporting lines and budgetary powers, yet these de jure arrangements do not automatically guarantee rigorous or sustained scrutiny in practice.

The legislature therefore bears responsibility for ensuring that its own institutional framework supports its oversight role and enables effective engagement with the SAI. This includes establishing appropriate support structures, safeguarding transparent and credible budgetary processes, as well as building the technical capacity necessary to interpret and act upon audit findings.

To strengthen credible and autonomous oversight, the legislature could consider establishing an independent budget management office to help ensure robust checks and balances, clear division of powers, and sound fiscal transparency practices are applied, thereby creating positive institutional conditions for the independence of the SAI

The legislature plays a central role in shaping the institutional environment that supports credible and autonomous oversight, including the independence of the SAI. By operating with strong internal capacity, clear procedures, and robust analytical support, the legislature can ensure that checks and balances between branches of government are effectively maintained, responsibilities are clearly delineated, and fiscal transparency practices are consistently applied. Such institutional conditions help create a stable and predictable framework in which the SAI can exercise its mandate without undue influence, enhancing the credibility, objectivity, and impact of public audits. Conversely, weak legislative capacity, opaque decision making, or unclear divisions of authority can undermine both oversight institutions and broader accountability arrangements.

Testimonies indicated that a key informal factor affecting the independence of SAIs is the imbalance of power between the executive and the legislature. Even in systems where laws appear balanced and formal rules assign decision-making authority to the legislature, consulted stakeholders observed that the executive often wields greater influence and resources, which can affect SAIs’ budgetary independence and the institutional environment which the SAI operates. This influence is particularly evident in the appointment of heads of SAIs, legislative scrutiny of audit findings and the determination of SAIs’ budgets.

Strengthening power parity between the legislature and the executive is widely viewed as a critical step in addressing this imbalance. In particular, enhancing the legislature’s access to independent information and analytical capacity for budgetary decision making can have a direct and positive impact on SAIs, notably by supporting greater budgetary autonomy.

In this regard, the OECD’s Best Practices for Parliaments in Budgeting (OECD, 2023[21]) recommends that the legislature establish specialist analytical support in the form of an in-house research or scrutiny unit, or an independent parliamentary budget office, with resources allocated commensurate to their mandate, and full, timely access to all relevant information, including the assumptions and methodologies underlying budget and other fiscal proposals. These practices align with the OECD’s 2014 Recommendation of the Council on Principles for Independent Fiscal Institutions (OECD, 2014[5]), which emphasises that these bodies should operate according to independence, non-partisanship, transparency, and accountability.

Legislative budget offices are publicly funded bodies established under the statutory authority of the legislature or, in some cases, the executive. Their mandate is to provide technical, expert, and non-partisan analysis of fiscal policy and the budget, and in some systems, they also provide advice to support legislative scrutiny.

By providing legislators with impartial analysis and advice, budget offices help ensure that budget decisions are evidence-based, address structural biases toward higher spending or deficits, and promote transparency and accountability in public finance management. This enhanced analytical capacity strengthens the legislature’s oversight role and can also support the independence of SAIs by contributing to a more balanced institutional equilibrium between the legislature and the executive. This includes executive interference in key areas such as appointments, the tabling of audit reports, follow-up of recommendations, and the budgetary autonomy of SAIs.

Therefore, to strengthen credible and autonomous oversight, legislatures could consider establishing an independent budget office to support transparent, evidence-based budgetary decision making for the SAI. Such an institution could help the legislature exercise its budgetary authority in a manner that reinforces SAI independence while maintaining fiscal discipline and accountability. See Box ‎2.9 for a practical example from Australia.

Box ‎2.9. Australia’s Parliamentary Budget Office

In 2012, Australia established the Parliamentary Budget Office (PBO) by the Parliamentary Service Act 1999 (Section 64B), which is an independent and non-partisan department of the Parliament.

The PBO has three main functions:

1. Responding to requests made by Senators and Members for costings of policy proposals or for analysis of matters relating to the budget.

2. Publishing and presenting information to enhance the public understanding of budget and fiscal policy settings.

3. Publishing a report after every general election that provides transparency around the fiscal impact of the election commitments of major parties, and minor parties and independents that choose to be included.

Source: (Parliamentary Budget Office, Australia, n.d.[22]).

Legislatures could also consider using an independent fiscal analysis function, such as a parliamentary budget office or similar body, to provide impartial assessments of the SAI’s budget proposals. These assessments can help determine whether proposed allocations are adequate, predictable, and aligned with the SAI’s constitutional mandate and workload. By grounding deliberations in objective fiscal information, this approach may reduce reliance on executive-provided data and support more transparent and informed decision making, contributing indirectly to the financial autonomy and effectiveness of the SAI.

These measures can enable legislatures to exercise their budgetary authority more independently and credibly, reduce executive dominance in fiscal decision making, and help safeguard the financial autonomy and effectiveness of the SAI.

To strengthen legislative oversight, the legislature could enhance its capacity and institutional capability to engage effectively with the SAIs and maintain institutional memory

A capable and well-resourced legislature is a critical component of an effective accountability ecosystem. Oversight institutions must be able to not only to receive information but also understand, interpret and act upon the information. The effectiveness of SAIs therefore depends not only on their formal independence and technical quality, but also on the ability of the legislature to use audit findings to hold the executive to account and to support corrective action.

The legislature has a responsibility to review and make use of audit reports. According to a joint (Inter-Parliamentary Union/UNDP[23]) questionnaire for parliaments, data indicates that the vast majority (90%) of parliaments surveyed (100 parliamentary chambers) received reports from audit institutions, however only 66% report having clearly established procedures for reviewing the reports. This tendency was also noted by Transparency International in their 2023 report, Strengthening parliamentary oversight: Key findings and recommendations from multi-country assessment (Transparency International, 2023[24]).

Legislatures with specialised expertise, continuity of knowledge and dedicated support structures are significantly better positioned to follow up on audit recommendations and ensure their implementation. Without sufficient institutional capacity and memory, even high-quality audit reports risk having limited practical impact.

Multiple stakeholders consulted raised concerns that limited capacity and capability within the legislature constrain the impact of audit reports. While the legal framework provides the legislature with a formal role in scrutinising audit findings, in practice there appears to be insufficient human and technical resources to systematically analyse reports and follow up on audit recommendations. This capacity gap could sometimes be seen as affecting the legislature’s ability to exercise its oversight role independence, as limited analytical resources can increase reliance on political narratives rather than evidence-based assessments.

Consulted stakeholders noted that legislative committees often lack specialised expertise required to engage in depth with complex audit findings, particularly in budgetary and financial management areas. As a result, follow-up on audit recommendations is uneven and frequently depends on individual interest rather than institutionalised processes.

Concerns were also expressed regarding institutional memory and staff capability. Existing legislative staff were described as needing additional training to effectively work with audit reports and to understand audit methodologies and public financial management issues. High staff turnover and limited opportunities for structured knowledge transfer further weaken the legislature’s ability to engage consistently and effectively with the work of the SAIs.

Therefore, to enhance the effectiveness of legislative oversight and maximise the impact of audit work, the legislature could strengthen its internal capacity and institutional arrangements for engaging with audit findings.

• The legislature could consider investing in dedicated resources and specialised support structures to analyse SAI reports and track the implementation of audit recommendations over time. This could include strengthening committee secretariats or establishing dedicated units with expertise in auditing, public financial management and performance evaluation. Box ‎2.10 below provides the example of Germany.

• In parallel, targeted and continuous training for legislative staff could be introduced to improve understanding of audit processes, financial oversight, and the effective use of SAI reports in legislative scrutiny.

• To address challenges related to institutional memory, the legislature could consider formal mechanisms to retain and transfer knowledge, such as standardised procedures for handling audit reports, documentation of follow-up actions, and structured handover processes for staff and committee members.

• The legislature could also consider strengthening structured and informal engagement with the SAI, including regular briefings, technical exchanges and dialogue on audit planning and findings. Such practices can help build mutual understanding, improve the relevance and uptake of audit work, and reinforce co-ordination mechanisms between both institutions. Box ‎2.11 below provides the example of Indonesia.

• Independent parliamentary budget offices can also strengthen the capacities of the legislature to engage with SAIs and audit reports.

Together, these measures would enable the legislature to engage more effectively with the SAI, reinforce accountability in practice and support the long-term impact of audit and oversight functions. Stronger technical capabilities could help ground discussions in evidence, thereby softening potential political positions and reinforcing the legislature’s role as an independent and credible oversight body.

Box ‎2.10. Parliamentary technical expertise at the Bundestag, Germany

Within the federal Parliament of Germany (the Bundestag), the Budget Committee and its Auditing Subcommittee, play a key role in analysing audit findings and integrating them into budget oversight. Members (rapporteurs) develop in-depth expertise in specific budget areas over a full legislative term, which enhances the legislature’s capacity to understand complex fiscal information and moderates purely partisan interpretation of technical audit results. This co-operative structure supports continuous scrutiny and helps introduce audit findings systematically into parliamentary decision making.

Source: (Deutscher Bundestag, n.d.[25]).

Box ‎2.11. Mechanisms to strengthen co-ordination between the SAI of Indonesia (BPK) and the House of Representatives (DPR)

The SAI of Indonesia (BPK) and the House of Representatives (DPR) have established mechanisms to define the scope, expectations and processes governing their interaction in two key areas: (i) the determination of BPK’s budget, and (ii) the submission, clarification and follow-up of audit reports, including DPR’s audit requests.

These arrangements are grounded in the legal framework governing BPK. In addition, both institutions have developed complementary co-ordination practices to clarify areas of discretion and better align their respective objectives beyond minimum legal requirements.

For the budget process, BPK and DPR follow an agreed procedure that structures the preparation, review and approval of BPK’s budget within DPR, contributing to greater transparency and predictability.

Furthermore, BPK and DPR have signed a Memorandum of Understanding setting out procedures for the submission and publication of financial audit reports, as well as the summary of semester audit results. The Memorandum also specifies how DPR may request clarification of audit findings and propose the undertaking of performance or special purpose audits by BPK.

Taken together, these mechanisms complement the formal legal provisions and provide greater clarity, structure and predictability to the working relationship between BPK and DPR.

Source: Fact-finding mission.

2.3.3. By engaging with the SAI through transparent and well-defined procedures, the legislature can balance effective oversight with respect for the SAI’s autonomy, reinforcing both accountability and independence

Legislatures are the primary recipients of SAI reports and the institutions responsible for holding the executive to account based on audit findings. As such, the way legislatures engage in the SAI process can either reinforce or inadvertently undermine SAI independence.

Effective legislative engagement requires a careful balance. On the one hand, legislatures should actively use audit work to inform oversight, budget scrutiny and policy debate. On the other, their involvement must respect the SAI’s autonomy in determining its audit programme, methodologies and conclusions. Clear frameworks, transparent procedures and well-defined roles are therefore essential to ensure that legislative interaction strengthens, rather than compromises, institutional independence. The recommendations under this section focus on safeguarding that balance.

To promote effective legislative oversight while safeguarding audit independence, countries could consider establishing agreed procedures for legislative audit requests to SAIs through clear agreements defining scope, criteria and follow-up arrangements

Effective public accountability systems rely on strong, independent external audit institutions and meaningful legislative oversight, as reflected in the OECD Recommendation on Public Integrity, notably the principles on accountability, checks and balances, and organisational autonomy. SAIs play a critical role in providing objective assurance on the use of public resources, while legislatures are responsible for scrutinising audit findings and ensuring appropriate follow-up.

Legislatures equipped with clear procedures, institutional capacity and stable working arrangements with SAIs are better positioned to use audit work strategically without undermining audit independence. Box ‎2.12 provides an example from the United States. Conversely, ad hoc or informal audit requests risk weakening the effectiveness of audits by diverting resources from risk-based audit planning and creating perceptions of political influence, thereby limiting the practical impact of audit work.

Box ‎2.12. Example from the United States – Protocols in place for audit request from the legislature

The United States Government Accountability Office (GAO) provides a clear example of a structured process for legislative audit requests. Congressional committees, subcommittees, and individual Members of Congress may submit written requests for audit work via the office’s Congressional Relations office. Requests from committee chairs or ranking members are given priority, and the subject matter must fall within the jurisdiction of the requesting body. Once a request is received, GAO acknowledges it and, if accepted, provides the requester with a contact point and an expected start date of the audit work.

GAO then assembles an audit team, and initiates work according to staff availability, keeping the original requester informed of progress. The audit design phase involves engagement with stakeholders and planning a fact-based methodology, typically taking several months. Requesters may receive briefings on status or preliminary findings at any stage, and GAO limits shared information to questions, scope and methodology to safeguard the integrity of the audit process. After draft findings are provided to the audited agency for comment, the final report is issued and published, with original requesters having a limited opportunity to delay public release for briefing preparation.

GAO’s protocol demonstrates several good practice features for managing legislative audit requests: a formal entry point and request format, transparent criteria for prioritising and accepting work, structured communication and briefing opportunities, and clear procedures for proceeding from request to publication of results. These elements help ensure that audit requests support legislative oversight while respecting the independence and professional standards of the audit institution.

Source: (GAO, n.d.[26]).

In several countries, there is a growing demand from legislatures for SAIs to conduct audits at legislative request, beyond their regular, risk-based audit programmes. In some cases, this trend reflects increased interest by legislatures in using audit tools to support their oversight role, which is a positive development for accountability.

At the same time, the absence of clear, formalised procedures governing such requests creates several challenges:

• Responding to legislative requests may require SAIs to reallocate staff and financial resources, potentially affecting the delivery of planned audits.

• Without transparent criteria and safeguards, some staff members of SAIs, perceive these audit requests as a potential interference on the independence of SAIs, either where they are made in good faith aiming at improving public accountability or when they are made as part of a strategy to affect the image of political opponents.

• The lack of agreed criteria or timelines also reduces predictability and makes it difficult to assess which requests can be accommodated and under what conditions.

• Finally, limited clarity regarding how legislatures are expected to use and follow up on audits conducted at their request can reduce their overall impact.

These challenges generally do not stem from weaknesses in the legal mandates of SAIs but rather from gaps in the operational interface between legislatures and audit institutions regarding audit requests.

Therefore, countries could consider establishing an agreed-upon framework governing legislative audit requests to SAIs to strengthen legislative oversight while preserving audit independence and effective resource management. Such a framework could clarify the process and criteria for submitting and assessing audit requests, including which legislative bodies may initiate requests, the types of issues that may be covered, and how relevance, materiality, and alignment with risk-based audit planning are assessed.

The framework could also define safeguards to protect audit independence and ensure transparent resource allocation by explicitly confirming the discretion of SAIs to accept, prioritise, defer, or decline requests based on professional judgement and available resources. This may include integrating accepted requests into annual or multiannual audit plans, establishing expectations regarding volume or timing of requests, or clarifying how requests outside strategic priorities are handled.

In addition, clear, documented arrangements could strengthen mutual expectations regarding communication and follow-up by clarifying timelines and modalities for responding to requests, how audit results are communicated to legislatures, and how legislative bodies are expected to follow up on findings and recommendations.

By clarifying roles, procedures, and expectations, these arrangements can help legislatures make more strategic use of audit work, enhance the impact of audit findings, and reduce risks, real or perceived, of interference in audit planning and execution.

To strengthen public accountability, the legislature could consider reinforcing the follow-up of audit recommendations through a systematic, committee-based mechanism that complements the SAI’s follow-up process

Effective public integrity systems depend on strong and mutually reinforcing oversight by SAIs and legislatures. While SAIs are responsible for issuing independent audit findings and recommendations, legislatures play a critical role in scrutinising executive action and ensuring that audit recommendations are acted upon.

Follow-up from the legislature is a key driver of the implementation of audit recommendations. Scrutiny by the legislature, particularly when exercised through specialised committees, can strengthen political and administrative incentives for the executive to address audit findings, pursue financial recoveries where warranted, and remedy systemic weaknesses. Where engagement from the legislature is weak or unclear, even high-quality audit recommendations risk having limited practical impact.

Stakeholders interviewed expressed concerns that audit recommendations issued by the SAIs are often not acted upon by the executive, highlighting the relevance for legislatures, which have a constitutional and political mandate to scrutinise executive action and ensure that audit findings are translated into accountability and improvements. In some cases, recommendations are perceived to receive limited attention from the legislature or executive bodies, reducing their effectiveness as tools for accountability and improvement.

Uncertainties remain regarding the precise role of the legislature in the follow-up process and how it complements the follow-up activities of the SAI. Stakeholders noted a lack of clarity on procedures, expectations and consequences when recommendations are not implemented, resulting in uneven follow-up and continued reliance on political context or media attention rather than consistent institutional mechanisms. For other stakeholders, such as CSOs and media, there can be confusion on the scope and outcomes between the political scrutiny of the legislature and the follow-up process between the SAI and the audited entity.

Interviews with consulted stakeholders suggested that, in some cases, legislative engagement with audit findings tends to be most visible at the time reports are made public, particularly through public statements or media coverage. Several interviewees noted that once public attention shifts to other issues, incentives for the legislature to follow-up on and make use of the audit findings may diminish. This dynamic can limit the extent to which audit results are systematically discussed or used in subsequent oversight activities.

Therefore, the legislature could consider strengthening its role in the follow-up of audit recommendations by establishing a systematic, committee-based follow-up mechanism that complements the SAI’s processes and is insulated from undue political influence. In particular, audit findings could systematically trigger legislative scrutiny through the responsible committee, with clear procedures for reviewing executive responses, monitoring implementation, and requesting corrective action where necessary. Box ‎2.13 provides an example of this in the context of Kenya.

Box ‎2.13. Parliamentary follow-up process in Kenya

Kenya offers a strong example of parliamentary engagement with SAI reports through a structured, timebound review process. The Constitution requires Parliament to examine Auditor-General reports within three months of receipt, creating a predictable oversight cycle. This review is primarily carried out by specialised committees such as the Public Accounts Committee (PAC), which routinely examines the Auditor-General’s reports on national ministries and agencies and tables follow-up reports accordingly.

A notable innovation in Kenya’s parliamentary oversight system is the dedicated Committee on Implementation, which is mandated to monitor whether resolutions adopted by the National Assembly, including those arising from audit inquiries, are acted upon by the Executive. This committee examines whether implementation has occurred, the extent of progress made, and whether action was taken within a reasonable timeframe. Importantly, it publishes its reports on the Parliament’s website.

Source: (Transparency International, 2023[24]).

Such a mechanism could clarify roles and responsibilities between the SAI and the legislature, ensuring that follow-up is not duplicated but reinforced. The responsible legislative committee could be mandated to track the status of audit recommendations over time, require formal responses from the executive within defined timeframes, and report publicly on progress and persistent non-compliance. Where appropriate, the framework could also enable the legislature to support the pursuit of financial recoveries and other remedial actions identified through audits. In addition, organising legislative hearings with the concerned auditees can further strengthen accountability, as such sessions provide a structured forum for reviewing implementation efforts, questioning delays, and encouraging corrective action.

By embedding follow-up of audit recommendations within regular legislative oversight processes, rather than relying on ad hoc political pressure, the legislature can enhance the credibility, consistency, and impact of external audit, thereby strengthening public accountability.

To safeguard audit independence and timely legislative scrutiny, the legislature could consider establishing binding procedures for the tabling of audit reports that ensure automatic and non-discretionary submission to the legislature

Timely and independent reporting by SAIs is a cornerstone of effective public accountability. For audit findings to inform legislative scrutiny and executive accountability, audit reports must be submitted to the legislature without undue delay or political filtering.

The value of audit work depends not only on its quality but also on the timeliness and integrity of its reporting process. Where the submission or tabling of audit reports is subject to discretionary decisions by political actors, there is a risk that oversight is weakened, perceptions of interference arise, and public trust in both the audit function and legislative scrutiny is undermined.

From the fact-finding undertaken for this report, testimonies point out that, in some cases, the process for submitting audit reports to the legislature does not consistently ensure timely and automatic tabling. While the SAI can finalise and present its reports, these reports are not automatically tabled in the legislature upon completion.

As a result, the timing of the legislature’s access to audit reports can be delayed, creating gaps between the completion of audits and their consideration by the legislature. Stakeholders noted that this arrangement leaves space for discretionary decision making and may expose the audit reporting process to political considerations, even if this is not the intent. At the same time, the ability of the SAI to present reports directly to the legislature reflects a positive foundation for transparency and engagement, which could be strengthened through clearer procedural safeguards.

Therefore, the legislature could consider establishing clear, binding procedures governing the tabling of audit reports in the legislature to ensure that submission is timely, automatic, and non-discretionary. Such procedures could specify that audit reports are tabled within a defined timeframe following their finalisation, without requiring approval or action by political actors beyond formal transmission. See Box ‎2.14 below regarding Canada as an example. The tabling of audit reports does not in itself result in making them public.

Box ‎2.14. Legal and procedural tabling requirements in Canada

In Canada, the Auditor General’s reports (both performance and annual audit reports) must be submitted to Parliament and tabled in the House of Commons via the Speaker. By law, the Speaker must table these reports forthwith upon receipt, or within 15 sitting days if the House is not in session, ensuring that tabling is automatic and non-discretionary rather than subject to government control over timing.

Once tabled, Auditor General reports are automatically referred to the House of Commons Standing Committee on Public Accounts for review. This committee has a specific mandate to examine all reports of the Auditor General and is traditionally chaired by a member of the opposition, which helps anchor scrutiny in evidence rather than partisan discretion.

Source: (Canadian House of Commons, 2025[27]).

In parallel, the SAI and the legislature could agree on practical mechanisms that promote timely reporting while safeguarding audit quality and independence. This may include shared expectations regarding reporting timelines, advance communication on upcoming reports, and procedural distinctions between the formal submission of reports and their subsequent legislative debate or publication. By clarifying these processes, the legislature can strengthen its oversight role while ensuring that the audit function remains protected from real or perceived political interference.

Embedding these safeguards in law or legislative rules of procedure would help ensure that audit reporting supports consistent accountability regardless of political context.

2.4. The role of other actors beyond the executive and the legislature

2.4.1. The judiciary could be engaged with the SAIs through structured mechanisms and supported by clear legal and operational safeguards to reinforce SAI independence

The judiciary is notably absent from the principles outlined in the Mexico Declaration as an actor that can interfere with independence. However, the Lima Declaration states that SAIs shall be guaranteed adequate legal protection by a supreme court against any interference with their independence and legal mandate. Evidence gathered through the data collection indicates that the judiciary has increasingly emerged as a key actor in this landscape.

Judicial decisions, particularly those addressing constitutional disputes or legal inconsistencies affecting the mandate, operation or independence of SAIs, are critical to ensuring legal certainty. Legal certainty is a fundamental element underpinning SAI independence, as it constitutes the practical, or de facto, expression of constitutional and legal safeguards designed to protect SAIs from undue influence. In this regard, the judiciary plays a decisive role in interpreting and enforcing these safeguards.

While fully respecting the rule of law, confidentiality requirements and independence, judiciaries and SAIs could be systematically included in structured dialogue mechanisms aimed at clarifying procedures, facilitating the exchange of experiences, and enabling institutional feedback. Depending on national contexts, such mechanisms could take the form of working groups, joint workshops, or memoranda of understanding (MoUs).

These structured exchanges could be designed to strengthen mutual understanding of respective mandates and expectations, and to promote good practices for safeguarding the independence of both SAIs and the judiciary. In particular, dialogue could address internal safeguards, such as integrity frameworks, ethical standards, and conflict-of-interest controls, as well as external safeguards, including interactions with other public authorities and stakeholders.

In institutional models where SAIs are structurally linked to, or embedded within, the judiciary, specific legal and operational safeguards should be clearly established to prevent external interference and protect audit independence. These may include:

• explicit legal provisions separating judicial and audit functions

• protection of the audit process from external influence

• guarantees of adequate, stable and autonomous budgetary and human resource arrangements

Such safeguards should ensure that, even within a judicial framework, the SAI enjoys protections comparable to those afforded to oversight institutions operating under legislative or executive models.

2.4.2. Donors could provide co-ordinated and systemic support to SAIs, aligned with national priorities and the broader accountability ecosystem

For a significant number of SAIs around the world, support from donors constitutes a critical factor in their institutional development. Financial and technical assistance provided by donors often compensates for constraints in domestic budgetary resources, enabling SAIs to strengthen core audit functions, invest in capacity development and modernise organisational practices. Such support is most effective when it recognises SAIs as integral components of a wider public accountability ecosystem, including legislatures, executive bodies, judicial institutions, and civil society, rather than as standalone institutions. In many contexts, the support from donors complements national funding and contributes to sustaining reform momentum, particularly where fiscal space is limited.

However, the evidence gathered for this report emphasised the importance of donor co-ordination to avoid overlapping interventions and to enhance the efficiency and coherence of support at the country level. Improved co-ordination mechanisms were seen as essential to maximising impact, reducing administrative burdens on SAIs, and ensuring that support addresses priority needs. Stakeholders also noted that financial support may be affected by global financial constraints, potentially limiting the predictability and sustainability of external assistance in the medium to long term.

Also, the Paris Declaration on Aid Effectiveness and the Accra Agenda for Action emphasise that donors should avoid parallel systems and fragmented reform support and that this support should be anchored in country-led reform strategies and diagnostics (OECD, 2005[28]; OECD, 2008[29]). Donors are encouraged to channel support through country systems, even where capacity is uneven, and to accept a calibrated level of fiduciary risk consistent with long-term system strengthening. Strengthening the accountability ecosystem, and in particular SAIs, is therefore key. Donors can support such efforts by supporting accounting, internal control and audit reforms and by supporting and strengthening the independence and credibility of SAIs.

Therefore, donors could make greater use of existing co-ordination platforms, such as the INTOSAI–Donor Co-operation, to align strategies, share information and promote complementarities in support to SAIs. Support decisions could be more systematically informed by recommendations, standards and good practices developed by INTOSAI and the OECD, helping donors to identify priority areas and ensure consistency with internationally recognised principles of public sector auditing and governance.

Donors could also adopt a more systemic approach to supporting SAIs and consider the broader institutional and legal environment in which they operate. This includes ensuring coherence with legal frameworks, strengthening institutional co-ordination with key accountability actors, and recognising the role of informal factors, such as political economy dynamics and organisational culture, that may affect the implementation and effectiveness of reforms. Box ‎2.15 provides an example of this.

Box ‎2.15. International engagement: The case of the Court of Accounts of São Tomé and Príncipe

In August 2023, the National Assembly of São Tomé and Príncipe approved a reform of the Organic Law of the Court of Accounts by 35 votes in favour and 19 against. The reform was subsequently promulgated by the Executive on 8 September 2023 as Law No. 01/23. The revised legal framework introduced changes with potential implications for the mandate and independence of the Court of Accounts.

Throughout the legislative process, the INTOSAI Development Initiative (IDI), together with development partners and international financial institutions, followed the reform closely and engaged in exchanges regarding its potential impact on the independence of the SAI. As part of this engagement, IDI collaborated with the IMF to conduct an assessment of the 2023 Organic Law, focusing on its implications for the independence and functioning of the Court of Accounts.

The assessment contributed to inform new conditionality under the IMF-supported programme for São Tomé and Príncipe. It provided an analytical basis for IMF engagement on issues related to SAI independence, including: (i) developing a deeper understanding of how the legal framework is applied in practice, notably with regard to pre-audit, concurrent audit, ex-post audit and jurisdictional functions; and (ii) examining the alignment between the mandate of the Court of Accounts and other relevant legislative frameworks, such as public procurement legislation.

This collaboration illustrates how international and professional organisations can combine technical expertise and policy dialogue to support reforms that contribute to SAI independence, while strengthening national legal processes and institutional mandates. It highlights the role of co-ordinated global engagement in promoting effective and independent public oversight institutions.

Source: Compiled by OECD and IDI based on interviews and documents review.

2.4.3. SAI independence can benefit from, and contribute to, the strengthened independence of other oversight institutions

SAIs operate within a broader network of public oversight institutions, including public and private organisations whose outputs are interdependent and regulated by law. Alongside regulators, central banks, ombudspersons, anti-corruption agencies and other autonomous oversight bodies, SAIs share core operational principles: decisions grounded in technical criteria, mandates oriented towards the public interest rather than political or private priorities, and the need for stability and protection from external interference. An accountability ecosystem approach recognises that the effectiveness and independence of SAIs are interlinked with the independence and credibility of these peer institutions, and that co-ordinated oversight strengthens the overall accountability system.

Across these institutions, independence relies on similar foundational conditions, including a clear and legally secure mandate, guaranteed access to information and adequate financial, human, and material resources. While these needs are broadly shared, independence challenges vary by institutional context. Regulators, for example, face heightened risks of influence from regulated entities (OECD, 2016[30]), while internal audit bodies must safeguard objective judgement and ensure appropriate reporting lines to maintain credibility. The forms and intensity of pressure exerted by political, economic or managerial actors differ depending on organisational arrangements and governance frameworks.

In turn, interaction among autonomous institutions is key to ensuring public accountability. For example, SAIs typically audit regulators, while regulators use audit findings to inform risk identification and mitigation. Public internal audit bodies could co-ordinate with SAIs to avoid duplication and promote consistent quality standards, and private-sector internal audit functions operate within regulatory frameworks defined by sectoral authorities. Despite these interconnections, institutions apply different approaches to measuring impact and demonstrating the value of their work.

Stakeholders and SAIs consulted during the data collection process emphasised that SAI independence should be assessed as part of a broader system of oversight institutions, aligned with the independence conditions of peer bodies such as regulators, anti-corruption agencies, and prosecutors. Effective relationships with these institutions were seen as essential to fulfilling mandates and reinforcing credibility. Consulted stakeholders also highlighted opportunities for mutual learning, particularly in strategies to advocate for and protect institutional independence.

During the exchanges with stakeholders in the context of the Global Project, other oversight institutions noted the value of structured mechanisms to exchange good practices and highlighted the absence, at the global level, of reference frameworks comparable to INTOSAI for many peer institutions.

Therefore, at the international level, INTOSAI could share its experience in developing standards, assessment tools and co-operation mechanisms, such as the SAI Performance Measurement Framework (SAI PMF), SIRAM, and the INTOSAI–Donor Co-operation, with other oversight institutions to support capacity development and independence advocacy. In addition, OECD standards and its Public Integrity Indicators (PIIs) provide complementary insights into the effectiveness of accountability actors across the public sector, including external oversight, internal audit, and the judiciary. The forthcoming external oversight indicator will further enhance the ability to assess these actors collectively, enabling a more integrated understanding of oversight effectiveness and the broader accountability ecosystem.

At the country level, explicit and structured co-ordination among SAIs and other oversight institutions could be promoted as part of a whole accountability ecosystem approach, while fully respecting each institution’s mandate, decision-making autonomy, and institutional independence. This co-ordination could be fostered through clearly defined arrangements, particularly where co-ordination is not established in legal frameworks, such as inter-institutional working groups, information-sharing arrangements, or joint workshops, that clarify roles, support regular dialogue and enable the timely exchange of information on systemic risks, emerging integrity issues, and cross-cutting accountability challenges. Such arrangements should be designed to reinforce complementarity among institutions, facilitate mutual learning on safeguarding independence, and reduce existing overlap while avoiding duplication or encroachment on decision-making responsibilities.

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