Strengthening the Independence of Supreme Audit Institutions

Annex B. Models of supreme audit institutions (SAIs)

SAIs can be categorised according to several criteria, including their mandates and powers, the branch of government to which they report, and their organisational structure. The literature commonly distinguishes between two main SAI models, the legislative model and the jurisdictional model, along with the board model, which is often considered a derivative of the other two (Table A ‎B.1).

Regardless of the model, the powers and structure of SAIs usually reflect an effort to address the institutional priorities that existed at the time of their creation. These priorities often include implicit considerations about the balance of power among branches of government, the accountability of public officials and the extent to which auditing and jurisdictional functions should be institutionally fragmented or consolidated.

Table A ‎B.1. SAI models

Legislative model	Jurisdictional model	Board model
The legislative model refers to SAIs that are primarily designed to support the role of the legislature (parliament) in holding the executive accountable. Some of these SAIs are even part of the legislative branch itself. Accountability is exercised through frequent interaction between the SAI and a legislative committee, often the Public Accounts Committee, which receives and reviews the SAI’s audit results. In this model, the SAI is commonly considered accountable to the legislature through the presentation of a performance report and the submission of its financial statements, which usually are audited by a private firm appointed by the legislature. The institutional relationship typically includes strong engagement in the process of making audit results public; in some cases, publication is subject to a formal tabling process in the legislature. Additionally, follow-up on audit recommendations and findings is often accompanied by scrutiny from the legislature. While SAIs following this model often have a single head, some operate under a board or collegiate governance structure in which an audit board approves audit reports and submits them to the legislature.	Under this model, SAIs have the authority to impose personal liability on public officials responsible for managing public resources. Such liability may arise when irregularities are detected in the management of these resources, or when losses occur as a result of those irregularities. The jurisdictional process may be initiated either on the basis of audit findings or following the referral of irregularities by a third party. SAIs operating under the jurisdictional model are typically not part of the legislative branch; in some cases, they are integrated into the judiciary. Their organisational structure generally separates auditing functions from jurisdictional functions.	SAIs with a board or collegiate decision-making structure have traditionally been classified in the literature as a third model, known as the “board model.” This model shares some features with the legislative model, particularly the fact that these SAIs report to the legislature, but differs in that decision making is undertaken collectively by a board rather than being concentrated in a single head of the institution

Source: Based on (IDI, 2019[1]).

When elements of a SAI’s design are adopted from abroad, countries often retain those features even after the source country has reformed them. For example, in the United Kingdom, the Comptroller and Auditor General traditionally served a permanent term until retirement. In 2011, however, the United Kingdom shifted to a single, non-renewable 10-year term. One of the SAIs included in the data collection initially adopted the UK model and has kept the original lifetime-until-retirement arrangement, even though the United Kingdom itself has transitioned to a different system. Box A ‎B.1 provides the example of the Court of Account of France.

Box A ‎B.1. Case of the Cour des comptes (Court of Accounts) of France

Established in the early nineteenth century, the Cour des comptes of France has played a formative role in the development of Supreme Audit Institution models internationally. Over time, the institution has accompanied and implemented substantial reforms to adapt its mandate and tools to evolving public financial management and governance practices.

The Cour des comptes has seen its framework evolved to enhance clarity, coherence and effectiveness in holding public actors accountable. In 2023 a major reform introduced by law a unified regime of financial liability for public managers, replacing previous sanctioning arrangements with a single streamlined system addressing serious financial misconduct, with proportionate penalties. Cases are now examined by a dedicated Litigation Chamber (chambre du contentieux) within the Cour des comptes, and a Financial Court of Appeal has been established. This reform aimed to strengthen accountability while aligning enforcement mechanisms with contemporary standards of public administration.

Source: Compiled by OECD and IDI based on interviews.

References

[1] IDI (2019), What are Supreme Audit Institutions?, IDI SAI Independence Resource Centre, https://sirc.idi.no/about/what-are-sais? (accessed on 20 February 2026).