Independent Supervisory Bodies


Does there exist an independent and effective audit office?

There exists an effective and independent audit office.
Under the Auditor-General Act 1997, the auditor-general is responsible for providing auditing services to parliament and other public sector entities. The Australian National Audit Office (ANAO) supports the auditor-general, who is an independent officer of parliament. The ANAO’s purpose is to provide parliament with an independent assessment of selected areas of the public administration, and to provide assurance regarding public sector financial reporting, administration and accountability. This task is undertaken primarily by conducting performance and financial statement audits.
The Austrian Court of Audit (Rechnungshof) is an instrument of parliament. Its president is elected by parliament for a period of 12 years, without the possibility of re-election, which gives the president a certain degree of independence.

The Court of Audit reports regularly to parliament and parliament can order it to perform specific tasks. Consequently, the parliamentary majority determines how to handle audit reports and, in cases of doubt, the majority backs the cabinet. Thus, the main vehicle to force the government to react in a positive way to audit reports is public opinion. The Court of Audit enjoys an impeccable public reputation, which affords it a powerful role in constitutional practice.

One problem is the insufficient funding of the Court of Audit, while, at the same time, an increasing number of tasks are delegated to the court by the governing majority. There are also areas in which the court cannot make inquiries. It may be seen as a compliment that, in 2019, the majority in parliament denied the Court of Audit direct access to party finances, to which the court reacted in 2021 by providing its own suggestions for a reform of the party finance law. The court also criticized the government’s “chaotic” handling of its coronavirus policies, which had undermined public trust and limited the effectiveness of some measures.
The auditor general is appointed by parliament on the advice of the prime minister for a 10-year term. Once in place, however, auditor generals have virtually a free hand in deciding who to audit and when. The Office of the Auditor General is accountable to parliament, and the removal of an auditor general requires the approval of both the House of Commons and Senate. Reports of the auditor general are reviewed by the Public Accounts Committee of the House of Commons.
Reports of the auditor general – including the Office of the Commissioner of the Enviornment and Sustainable Development – span a broad range of topics. Recent reports have included audits on IT solutions, shipbuilding programs, the Canada Child Benefit, procurement of personal protective equipment, safe drinking water, and of course rollout of the emergency benefits launched during the pandemic. Government departments in turn respond to the Audits with planned action measures for addressing concerns. The OAG is a highly effective institution in its undertakings.
Office of the Auditor General of Canada.
The national audit office, Rigsrevisionen, is an independent institution under the authority of parliament. It examines the soundness of state accounts and assesses whether institutions have applied funds in the best possible ways. The Rigsrevisionen may initiate investigations on its own initiative, and at the request of the State Auditors (Statsrevisionerne), the parliamentary audit office. The work is made public via various reports, some of which also attract quite a lot of media attention. Its work is highly respected and can lead to policy action. This was seen recently, for instance, with the report on the principles for the valuation of housing underlying the tax levied on housing values (ejendomsværdiskatten). The issue of valuation of real estate for tax purposes remain a political issue in connection with the government’s 2025 plan.
Hentik Zahle, Dansk forfatningsret, 2.

Website of national audit office: (accessed 20 October 2020).
Legislative accountability is advanced by the audit office, which is accountable to parliament. Formerly, parliamentary oversight of government finances was performed by parliamentary state auditors. However, this institution has been abolished. In its place is the parliamentary Audit Committee, which was created by combining the tasks performed by the parliamentary state auditors with the related functions of the administrative and audit section of the Finance Committee. The office of the parliamentary state auditors has also been replaced by the National Audit Office of Finland, which is an independent expert body affiliated to parliament. The role and duties of the National Audit Office of Finland (NAOF) are defined in the country’s constitution. The NAOF audits central government finances, monitors fiscal policy, and oversees political party and election campaign funding (National Audit Office of Finland 2020).
It is also tasked with auditing the legality and propriety of the state’s financial arrangements, and reviewing compliance with the state budget. Specifically, the office is expected to promote the exercise of parliament’s budgetary power and the effectiveness of the body’s administration. It also oversees election and party funding. The office is directed by the auditor general, who is elected by parliament. With about 150 employees, the office has four impact areas: sustainable general government finances; sustainable governance and public administration; a safe, healthy and affluent society; and information governance. However, in 2021, the audit office was caught up in a scandal which undermined its operative capacity. Parliament ultimately decided to fire the body’s general director.
National Audit Office of Finland, 2020. Accessed, 28.12. 2020.

“National Audit Office”;;

“The Audit Committee,”

“Scandal in 2021”:
The Federal Court of Audit (FCA) is a supreme federal authority and an independent public body. FCA members enjoy the same degree of independence as the members of the judiciary. Its task is to monitor the budget and the efficiency of state’s financial practices. It submits its annual report directly to the Bundestag, the government and the Bundesrat. The Bundestag and Bundesrat jointly elect the FCA’s president and vice-president, with candidates nominated by the federal government. According to the FCA’s website, around 1,300 court employees “audit the (state) account and determine whether public finances have been properly and efficiently administered,” while the FCA’s “authorized officers shall have access to any information they require” (Federal Budget Act Section 95 Para. 2). The reports regularly receive considerable media attention.
According to critics, however, the strong position of the FCA also leads to risk-averse behavior in ministries and authorities which discourages new approaches and ideas from taking off. In other words, strict control by audit offices may also function as a brake on innovation in public administration (Wiarda 2021, see also Chapter P5.1).

Wiarda, Jan-Martin (2021): Zu deutsch bei Innovationen, in: Der Tagesspiegel 11.07.2021, (accessed 13 February 2022)
New Zealand
The controller and auditor-general is appointed by the governor-general on the advice of parliament and is fully accountable to it. The Office of the Auditor-General consists of the following departments: Accounting and Auditing Policy, Legal Group, Local Government, Parliamentary Group, Performance Audit Group and Research and Development. It is empowered to survey the central government and local governments. The legal basis is the Public Audit Act 2001.
All about the Controller and Auditor General (Wellington: Office of the Auditor General 2012).
Norway has an independent statutory authority, the Office of the Auditor General, that is accountable to parliament. Its main task is to ensure that the central government’s resources and assets are used and managed according to sound financial principles and in compliance with parliamentary decisions. In recent years, evaluations of goal attainment of reforms and of the effectiveness of new laws, have become increasingly important. Also the operations of (fully and partially) state-owned companies are scrutinized. The audit office has 450 employees. Its governing council is a board of five directors, all selected by the parliament for four years. Decisions of the audit office have consistently been consensual.
In order to conform to international standards, such as the International Organization of Supreme Audit Institutions (INTOSAI), the Swedish National Accountability Office (NAO; Riksrevisionen) was established in 2003 after the adoption of an enabling constitutional amendment (Riksrevisionen 2021). For all intents and purposes, the audit office now reports to the parliament. The mandate and mission of the audit office is such that this represents the only chain of accountability. In this respect, the constitutional role and mandate of the audit office is now in harmony with INTOSAI standard.

The NAO assesses whether public agencies follow relevant directives, rules and statutes, and whether goals are reached in an effective way. If this proves not to be the case, it provides recommendations for the improvement of agency operations. From this perspective, the NAO has the ability to assess whether the budgetary measures adopted by the parliament have followed the existing regulatory framework. The NAO also audits the government, corporations and foundations.
Riksrevisionen. (The Swedish NAO). 2021. “Om Riksrevisionen.”
The National Audit Office (NAO) is an independent office funded directly by parliament. Its head, the comptroller and auditor general, is an officer of the House of Commons. The NAO works on behalf of parliament and the taxpayer to scrutinize public spending and is accountable to the Public Accounts Committee (PAC). The media will usually pick up on any NAO findings, especially if they uncover questionable practices.

In 2020, the NAO undertook an investigation into government procurement during the coronavirus pandemic following a number of media reports. It found that the government did not always have “a clear audit trail to support key procurement decisions,” and that £10.5 billion worth of contracts had been awarded without any competition, £6.7 billion through framework agreements and only £0.2 billion through a competitive tender or bidding process. It recommended that the Cabinet Office issue new rules to avoid conflicts of interest for public officeholders in the future – or “chumocracy,” as the press labeled numerous cases of firms with links to Conservative members of parliament being awarded lucrative contracts for testing and supplying personal protective equipment during the pandemic.
The General Accountability Office (GAO) is the independent non-partisan agency of the U.S. Congress charged with auditing activities. It is responsive to Congress alone. The GAO undertakes audits and investigations upon the request of congressional committees or subcommittees, or as mandated by public laws or committee reports. In addition to auditing agency operations, the GAO analyzes how well government programs and policies are meeting their objectives. It performs policy analyses and outlines options for congressional consideration. It also has a judicial function in deciding bid protests in federal procurement cases. In many ways, the GAO can be considered a policy-analysis arm of Congress.
Established by the constitution (Article 180), the Court of Audit (Cour des Comptes/Rekenhof) is a collateral body of the parliament. It exerts external controls on the budgetary, accounting and financial operations of the federal state, the communities, the regions, the public-service institutions that depend upon them, and the provinces. Some public firms, non-profit organizations and “private” (but largely state-funded) organizations such as some universities, are also subject to thorough review. The Court of Audit’s legal powers allow it considerable independence and broad autonomy to fulfill its mandate. The members of the Court of Audit are elected by parliament but then operate in a very autonomous manner. The court’s reports are public and presented to parliament along with the accounts of the state. The body regularly attracts media attention for its critical remarks regarding the management of public entities or services (such as over the roads in Wallonia or the roadwork procurement in the Brussels Capital region).

This happened to a lesser extent during the COVID-19 crisis: the Court of Audit occasionally warned of the costs of the crisis for the social security system (not unexpectedly), but did not try to stop the government from reacting as it did. It also promptly investigated the government’s failed policy of stockpiling surgical and FFP2 masks, but without being particularly critical.
More routinely, it tracked the procurement measures taken by the government during the crisis and commented on the likely public deficits of 2020 and 2021. It was also requested to perform occasional analyses, for example, on how to restructure Belgium’s security services or on how to modify the pricing of GP consultations.

While the Court of Audit appears sufficiently independent, the enforcement of its numerous recommendations remains limited, as can be seen with regard to the public management of roadworks in the Brussels Capital region. Here, it pointed out “major discrepancies between the services actually provided and the services to be provided at the time of the contracts” in 2003. This problem does not appear to be fully solved, as a 2021 report stated that the three major operators “do not always control the deadlines or the costs.”
The Office of the Comptroller and Auditor General (OCAG) reports to the lower house of parliament. The OCAG attends meetings of the lower house’s Public Accounts Committee (PAC) as a permanent witness. The results of the OCAG’s independent examinations are used for PAC enquiries.

The PAC’s effectiveness is enhanced by having the OCAG’s reports as a starting point, and in turn the OCAG’s scrutiny gains significantly in impact and effectiveness because its reports are considered by and used as a basis for action by the PAC. The PAC examines and reports to the lower house as a whole on its review of accounts audited by the OCAG. This process ensures that the parliament can rely on its own auditing processes and capacities.
The Chamber of Auditors was upgraded in 1999 to become the Court of Auditors, which today oversees the finances of the state administration. While keeping a low profile, the court effectively controls government spending, including that of ministries, public administration and other state services. It can audit the use of public funds and subsidies granted to public and private entities. The court essentially controls the effectiveness and efficiency of public spending, but it is not authorized to express its opinion on the political wisdom of public spending. Its scrutiny completes the ongoing work done by internal auditors in each ministry. Furthermore, the court’s main interlocutor is parliament, and it undertakes cases either voluntarily or upon parliamentary instruction.
“Rapports.” Cour des Comptes Luxembourg. Accessed 14 January 2022.
The National Audit Office is an independent institution reporting exclusively to parliament, and is charged with scrutinizing the fiscal performance of public administration. Both the auditor general and his or her deputy are appointed by a resolution of the House of Representatives, requires a majority vote of no less than two-thirds of the body’s members. The auditor general enjoys constitutional protection and works closely with the Public Accounts Committee. The NAO can open investigations without a prior request by parliament or the prime minister. The office audits all central government ministries, local governments and EU-funded projects, and publishes special reports on key and often sensitive policy areas. A 2019 report on constitutional reform by the Commissioner for Standards in Public Life recommended that the auditor general, as a designated officer of parliament, should not be additionally designated as a public officer, in order to emphasize his/her independence from the government. In 2020, the NAO proposed amendments to the constitution, which aim to strengthen the office. Among the articles recommended was Article 5a, “The Auditor General or any person authorized by him shall have the right to audit all the Ministries, departments and offices of the Government of Malta, including the Office of the President, the House of Representatives, and the Superior and Inferior Courts of Malta and (5)(d) The Auditor General or any person authorized by him shall have the right to obtain information from any recipients of public funds in relation to any audit being undertaken by the Office.”
Report by the Auditor General on the public accounts 2016
Annual Report on the working of local government 2016
Performance audit: outpatient waiting at Mater Dei hospital
Ombudsman annual report 2016
Commissioner for standards in public life; Toward Higher Standards in public life October 2019
National Audit Office (NAO) 2020 Proposed amendments to the Constitution: Strengthening of the National Audit Office’s Legal Framework
Switzerland’s Audit Office is an independent and autonomous body. It supports the Federal Assembly and the Federal Council through the production of analyses and reports. The chairman of the Audit Office is elected by the Federal Council; this election must be confirmed by the Federal Assembly. In administrative terms, the Audit Office falls under the authority of the Department of Finance.

The Audit Office acquired a very independent and self-confident role in the case of the politically controversial export of arms to war-prone regions (NZZ 4 September 2018). It has harshly criticized the Federal Administration as being insufficiently critical and working too closely with representatives from the arms industry.
NZZ 4. Sept. 2018

There exists an effective and independent audit office, but its role is slightly limited.
The Audit Office underwent complete overhauls in both 2014 and 2015 due to the adoption, in both years, of completely new Audit Office Acts, each of which involved a full restructuration of the office’s governance architecture. In both cases, the new laws served as an excuse for the early termination of the mandates of the existing Audit Office leadership. While the present governance structure, established with the act of 2015, has made the office more professional than in the past, the repeated changes have undermined the independence and credibility of the Audit Office.

Since 2015, the Audit Office has performed its tasks in a clear and professional manner with a high degree of openness and has made its findings available to the general public. Under the present framework, the Audit Office’s capacity to contribute to the improvement of the effectiveness of government expenditures and assessment of the overall impact of different policies remains severely underutilized. Its effectiveness has also suffered from the fact that it is not vested with sufficient powers to act based on its findings. Such powers have been reserved for government bodies with dubious reputations, such as the prosecutor general or the anti-corruption agency.
Chile’s General Comptroller (Contraloría General de la República, CGR) has far-reaching competences, and is invested with strong political and legal independence. The officeholder is nominated by the president and must be approved by a three-fifths majority vote in the Senate. The comptroller has oversight power over all government acts and activities, and investigates specific issues at the request of members of the Chamber of Deputies. The office presents an annual report simultaneously to the National Congress and the president. The National Congress has the right to challenge the constitutionality of the comptroller’s work.
Comptroller General of the Reblic of Chile (Contraloría General de la República, CGR),, last accessed: 13 January 2022.
The Supreme Audit Office (Nejvyšší kontrolní úřad, NKÚ), which had 467 employees in 2020, audits the financial management of state entities and financial resources received from abroad. It expresses an opinion on the state’s final financial accounting statement and oversees the implementation of the state budget. The NKÚ is not authorized to audit the finances of municipalities, towns or regions, or to audit companies co-financed by the state or lower-level governments. The constitution regulates the functioning of the NKÚ; the body’s president and vice-president are appointed for terms of nine years by the county’s president, based on proposals made by the Chamber of Deputies. The Chamber of Deputies further elects the members of the NKÚ upon nomination by the president of the NKÚ. In 2020, NKÚ audited 152 institutions, the Chamber of Deputies’ Control Committee discussed 22 NKÚ audit reports and the government considered 24 audits. Reports were frequently critical, pointing to failures at varying levels of public administration to assess adequately whether money had been well spent in terms of achieving state objectives. This was exacerbated during the pandemic when many decisions were taken with more haste and, in the NKÚ’s view, the state gave up on efforts to find savings. The NKÚ concluded that the stability of public finances could come under threat and that there needed to be a decisive change in how the state operated.
NKÚ (2021): Annual Report 2020. Prague (
Parliament does not have its own audit office, except for a special body called the Office Parlementaire d’Évaluation des Choix Scientifiques et Technologiques, which is responsible for analyzing and evaluating the impact of technology. In practice, its role has been rather limited.

Instead, the Court of Accounts can now respond to any parliamentary request, and can act both as auditor and adviser. While much progress could be made to fully exploit this opportunity, it is noticeable that collaboration between the two institutions has improved since the Court’s presidency was offered to two prestigious former politicians, the last one from the opposition to the governing party and recently to a former minister and EU commissioner. The role of the Court has dramatically changed, from merely overseeing the government accounts to making a full evaluation of public policies. The body’s criticisms of past policies and forward-looking proposals are often a blessing for reformers. They can rely on these objective and usually tough evaluations when promoting their own agendas, and can point to the evaluations as a means of persuading the public. The last president of the Court (appointed in 2020) introduced an innovation: Aside from the traditional and extensive reports that might require several months or years of work, the body can now publish briefs about key issues on the governmental agenda, giving it a more active role in the ongoing reform debate.
Iceland’s National Audit Office (Ríkisendurskoðun) is fully accountable to parliament. Considering its substantial human and financial resource constraints, the National Audit Office performs its functions quite effectively. These constraints, however, mean that a vast majority of the agencies under its jurisdiction have never been audited. No significant strengthening of the office’s financial resources has occurred for several years, as its staff numbers were reduced from 49 in 2009 to 41 in 2015, a total of 16%. However, the number of staff has been restored to 50.
Ársskýrsla Ríkisendurskoðunar 2020 (Annual Report of National Audit Office 2020). Accessed 7 February 2022.
The National Audit Office is accountable to the parliament and the president. The auditor general is appointed by the parliament based on a nomination by the president. The parliament’s Committee on Audit considers financial-, compliance- and performance-audit reports submitted by the office, and prepares draft parliamentary decisions relating to the implementation of audit recommendations. The office also cooperates with other parliamentary committees. The leaders of the parliamentary Committee on Audit at one time used audit reports for political purposes, especially after an opposition-party member was appointed to head it. The National Audit Office also performs the functions of an independent fiscal institution, monitoring compliance with EU fiscal-policy norms. According to the OECD review released in 2019, this unique institutional setup, in which the independent fiscal institution (founded in 2015) is part of National Audit Office, results in several challenges; for instance, there is a lack of a clear public identity and a lack of operational independence, and the office has difficulties in recruiting and retaining senior staff members. On the other hand, the Budget Policy Monitoring Department (BPMD) was praised for having quickly established “a reputation for solid independent analysis,” contributing to fiscal transparency as well as parliamentary and public debates.

Over the last few years, the National Audit Office criticized the government’s draft budgets for their lack of compliance with fiscal-discipline provisions and poor allocation of government expenditure. While these criticisms are not always taken into account, there seems to have been progress over time. In its 2020 report to the parliament, the National Audit Office reported that 80% of its recommendations had been implemented, up from 60% in 2018. The National Audit Office was ranked as the best state institution in 2016 by the Lithuanian magazine Veidas due to its representation of state interests, competence and exceptional performance.
OECD Independent Fiscal Institutions Review, Lithuania’s Fiscal Independent Institution, 2019,
Poland’s Supreme Audit Office (Naczelna Izba Kontroli, NIK) is accountable exclusively to the Sejm. The NIK chairperson is elected by the Sejm for six years, ensuring that his or her term does not coincide with the term of the Sejm. The Senate has to approve the Sejm’s decision. The NIK has wide-ranging competencies and is entitled to audit all state institutions, government bodies and local-government administrative units, and corporate bodies and non-governmental organizations that pursue public contracts or receive government grants or guarantees. The NIK can initiate monitoring proceedings itself or do so at the request of the Sejm, its bodies or its representatives (e.g., the speaker of the Sejm, the national president or the prime minister). It is also responsible for auditing the state budget. Since August 2019, Marian Banaś, a former PiS minister of finance, has headed NIK.

Shortly after Banaś assumed office, accusations emerged that he had provided irregular information on his income and had contact with criminal circles in Craców. As no real evidence has been found as of today, he has stayed on. Under his leadership, the NIK has continued to behave professionally and independently (Wilczek 2021). Since 2020, the NIK has reported on several cases in which the government misspent money. This includes the unlawfully organized postal votes for the presidential election, which wasted PLN 130 million. A further PLN 280 million (€61 million) was misspent by the Justice Fund, which belongs to the Justice Ministry. Instead of helping crime victims, the funds were used for political purposes that benefited the government. The NIK has also played a major role in uncovering, and putting on the agenda, the government’s use of the Israeli Pegasus spyware (Wanat 2022). The governing coalition has responded to the NIK’s activities by increasing the pressure on Banaś. Various government members have asked Banaś to step down, Justice Minister Ziobro, in his function as prosecutor general, requested that legal immunity be lifted from Banaś, and Banaś and is family have frequently been the object of investigations by the Anti-Corruption Office (CBA).
Wilczek, M. (2021): ‘Armored Marian’ — the man who has Poland’s Law and Justice party in his sights, in: Politico, May 13 (

Wanat, Z. (2022): Poland’s Watergate: Ruling party leader admits country has Pegasus hacking software, in: Politico, January 7,
The Tribunal de Contas or Supreme Audit Office (SAO) is totally independent of the Assembly of the Republic and the executive. It is part of the judicial system, on an equal level with the rest of the judicial system.
The Court of Audits is largely able to conduct its audits effectively. However, it also frequently notes that there are insufficiencies in the publication and communication of information that limit its efficacy. Conversely, entities that are audited complain of the complex bureaucratic rules they must adhere to.
The Court of Accounts is an independent institution in charge of conducting external audits on the propriety of money management by state institutions. Parliament adopts the budget proposed by the court’s plenum and appoints the court’s members but cannot remove them. The court president is appointed by parliament for a nine-year term from among the counselors of account. Thus, while court presidents tend to be appointed on a partisan basis, they are not always representing the current parliamentary majority. The court submits to parliament annual and specific reports that are debated in the legislature after being published in the Official Gazette. The annual public report articulates the court’s observations and conclusions on the audited activities, identifies potential legal infringements and prescribes measures. The appointment of Mihai Busuioc, who has been close to PSD leader Dragnea, as new court president in mid-October 2017 has raised concerns about its independence. These concerns have been aggravated by parliamentary proposals to alter the Court’s remit and to render it more amenable to the will of the government.
The Audit Office (Court of Audit) is an institution formally independent of the government and parliament. It is both a court that intervenes to resolve disputes related to the implementation of administrative law (e.g., civil service pensions) and a high-ranking administrative institution supervising expenses incurred by ministries and public entities.

The staff of the Audit Office is composed of judges who enjoy the same tenure and follow a comparable career path to that of other judges. As in the case of selecting high-ranking judges, the government selects and appoints the Audit Office’s president and vice-presidents. Nonetheless, the Audit Office has detached itself from government control.

The Audit Office submits an annual financial statement and the state’s balance sheet to the parliament. In the past, there were delays in rolling out the financial statements of the Audit Office. Over time, the submission of financial statements has improved, as the financial statement for 2019 is available and the corresponding statement for 2020 is under preparation. Meanwhile, the Audit Office was very active in the period under review regarding “focused audits.” In 2021, it published eight “focused” audits concerning certain agencies or categories of expenses, including topical audits, such as public procurement processes related to the COVID-19 pandemic.
Information on the Greek audit office in English is available at
Ιnformation on targeted controls of the Audit Office is available at (in Greek)
For more information on Court of Audit competences and activities in English see
State audit functions in Israel are chiefly overseen by the State Comptroller. The State Comptroller is an independent agency that conducts audits of government ministries, local and municipal governments, and other independent, governmental organizations, including public universities, all military branches and government-funded corporations. The scope of audit powers is one of the broadest in the world, giving the comptroller jurisdiction over 1,400 organizations. The office receives its powers and authority from the Basic Law: The State Comptroller, which authorizes the comptroller to receive immediate information from the bodies undergoing audits. Additionally, the State Comptroller is tasked with auditing campaign and party finances, and reviewing the accounts and finances of party primary candidates and government ministers. The State Comptroller’s Office is under the oversight of the Knesset State Audit Committee (Comptroller 2021).

However, allegations of intimidation and suppression at the State Comptroller’s Office have swirled since the beginning of the current state comptroller’s tenure. In January 2020, reports about the whitewashing of official audits surfaced, including a coverup of the Finance Ministry fudging a Finance Ministry audit of Israel’s 2018 deficit figures in order that the official number met deficit reduction targets, concealing implications of Prime Minister Netanyahu’s corrupt interventions in audits and reports, and forbidding staff from airing concerns and speaking to the media (Magid 2020). While the State Comptroller’s Office reacted swiftly to the pandemic and issued several reports (as noted above), these allegations raise serious concerns and questions over the integrity, accuracy and quality of the State Comptroller’s audits.
Ministry of Justice (2021), “Amendments to Privacy Protection Act” Acceses 11 January 2021, Retrived from:

Israel Government. 2017. Government Decision 3019 on the Renaming the Technology and Information Law Authority in the Ministry of Justice (in Hebrew). Access 20 January 2020.

Israel Government. 2006. Government Decision 4660 on the Establishment of a Legal Authority for Information Technologies and Protection of Privacy in the Ministry of Justice (in Hebrew). Access 20 January 2020.

Israel Government. 2020. Government Decision 4897 on the Authorization of the General Security Service to assist in the national effort to reduce the spread of the new coronavirus (in Hebrew). Access 20 January 2020.

Israel Government. 2020. Government Decision 2916 on the Authorization of the General Security Service to assist in the national effort to reduce the spread of the new coronavirus (in Hebrew). Access 20 January, 2020.

European Commission. 2011. Commission Decision of 31 January 2011 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data by the State of Israel with regard to automated processing of personal data. Access 20 January, 2020.

The Privacy Protection Agency. Organizational structure. Access 20 January 2020.

The Privacy Protection Agency. 2020. First report in accordance to Act to Authorize the ISA to Assist in the National Effort to Contain the Spread of the Novel Coronavirus and to Promote Use of Civilian Technology to Locate Individuals who were in Close Contact with Patients (Temporary Provisions) 2020-5780 (in Hebrew). Access 20 January 2020.

The Privacy Protection Agency. 2020. Interim Summary: The Privacy Protection Agency’s Actions During the Corona Crisis (in Hebrew). Access 20 January 2020.

Ravia, Haim. 2020. The government has decided to freeze the law authorizing the GSS to help fight the Corona. Access 20 January 2020.

Sela Steinman, Ronit. 2020. Sharp letter to the Minister of Justice: The Privacy Protection Authority is silenced and not heard.
General auditing functions are conducted in Italy by the Court of Accounts (Corte dei Conti), which oversees all administrative activities. The court regularly reports its findings to the parliament, but cannot be said to be accountable to the parliament as it is an independent judicial body. The court can review ex ante the legitimacy of executive acts (although its decisions can be overruled by the government) and is responsible for the ex post review of the state budget. The court oversees the financial management of publicly funded bodies. It is protected from political influence; its judges remain in office until they are 70 years old and cannot be removed without cause. Judges are nominated through national competitive exams, and members of the court nominate the court president. The court has a highly skilled professional staff. Citizens may access court decisions via the internet, at no cost, shortly after decisions are rendered.

In April 2014, the parliament created the Parliament Budgetary Office (Ufficio parlamentare di bilancio), which is tasked with assessing the government’s macroeconomic and fiscal forecasts and monitoring compliance with national and European fiscal rules. This new body plays a particularly important role during the budgetary session and enables the parliament to have its own independent source of information in evaluating government proposals. Over the years, this office has demonstrated its increased independence by criticizing the budgetary policies of the government and in some cases (as in 2016 and 2018) openly contesting some of the government’s economic forecasts.
The Supreme Audit Office of the Slovak Republic (NKÚ) is an independent authority accountable exclusively to the National Council. The chairman and the two vice-chairmen are elected by the National Council for seven years each, and the office reports regularly and whenever requested by the council. There is an informal agreement that the chairman should be proposed by the opposition. Since 2019, the NKÚ has stepped up its control activities. The installation of a new planning board has increased the relevance and timeliness of its reviews, and the NKÚ has sought to expand its role in the legislative process and to widen its mandate with regard to local self-government. In October 2021, the NKÚ uncovered substantial flaws in the public procurement process of the construction of highways by the National Highway Company (Slovak Spectator 2021).
Slovak Spectator (2021): Slovakia was losing millions due to discrepancies in highway company, audit office says, in: Slovak Spectator, October 12 (
According to Article 150 of the Slovenian constitution, the Court of Audit is the supreme auditing authority in all matters of public spending. The Court of Audit is an independent authority accountable exclusively to parliament. The Court of Audit scrutinizes the performance of national and local governments and all legal persons established or owned by them. The chairman and the two vice-chairmen are elected by the parliament for nine years – on the basis of secret ballots – and the office reports regularly and whenever requested to the parliament.

The Court of Audit has far-reaching competencies, and still enjoys some reputation and public trust. However, after the Janša government took over, there was a lot of pressure on the court from both the coalition government and opposition to deliver their reports about COVID-19 protective equipment procurement in a way that would favor one or the other side. In addition, a number of political comments made by the chairman of the court during the period under review did not help the independence of the court.

The position of the court is somewhat limited by a lack of both financial and human resources, and by political pressures, which were evident during last term of office. While it can propose its own budget to the legislature, the ultimate decision regarding the Court’s resources rests with parliament.
The Netherlands’ General Audit Chamber is the independent organ that audits the legality, effectiveness and efficiency of the national government’s spending. The court reports to the States General and government, and its members are recommended by the States General and appointed by the Council of Ministers. Parliament frequently consults with this institution, and in many cases, this leads to investigations. Investigations may also be initiated by ministers or deputy ministers. However, such requests are not formal due to the independent status of the General Audit Chamber. Requests by citizens are also taken into account. Every year, the chamber checks the financial evaluations of the ministries. During the coronavirus crisis, the Audit Chamber periodically calculated total costs and reported on them. Chamber reports are publicly accessible and can be found online and as parliamentary publications (Kamerstuk). Through unfortunate timing in view of (more) important political developments, in recent years such evaluations played only a minor role in parliamentary debates and government accountability problems. By selecting key issues in each departmental domain, the General Audit Chamber hopes to improve its efficacy as instrumental advice. In addition, there is an evident trend within the chamber to shift the focus of audits and policy evaluations from “oversight” to “insight.” In other words, the chamber is shifting from ex post accountability to ongoing policy-oriented learning. Unfortunately, this has been accompanied by a substantial reduction in resources for the Audit Chamber, resulting in a loss of 40 full-time employees and the need to outsource research frequently. The childcare benefits affair caused the Audit Chamber chair to admit that, obviously, the Chamber and other oversight bodies had been unable to present their criticism in an effective and persuasive way.
NRC, 1 October 2021, Aharouay and Valke, Naar de drie toezichthouders wordt vaak niet geluisterd: ‘Het is teveel waan van de dag’

Algemene Rekenkamer, Coronarekening, Editie Prinsjesdag 202

P. Koning, Van toezicht naar inzicht, Beleidsonderzoek Online, July 2015
The Auditor General is elected by the parliament (Sabor) for an eight-year mandate and can be removed by the Sabor only if he or she is unable to conduct his or her work or is convicted for a criminal act. The Audit Office reports to the Sabor at the end of every fiscal year. It undertakes a broad range of audits (approximately 300 every year) and acts independently. Since 2019, it has also been able to review the operations of the Croatian National Bank (HNB) – an extension of its remit seen by the European Central Bank as compatible with central bank independence. Ivan Klesic, the auditor general, was reappointed for a further eight-year term in December 2018. The reports of the auditor general are carefully crafted, and often identify inefficiencies and irregularities in spending taxpayers’ money. The auditor general can inform the State Attorney’s Office about cases of fraud. In 2018, however, one-third of all 258 recommendations or decrees issued by the auditor general were ignored by the public entities concerned. Since 2019, the auditor general can impose fines on recalcitrant and non-compliant public entities. However, these fines remain too small to significantly alter existing behavior patterns and processes. The recent scandal involving former Minister of Regional Development Gabrijela Žalac, who was charged with serious misconduct relating to projects financed by European Structural and Investment Funds, has revealed the weakness of the State Attorney’s Office in investigating prominent political figures. Without the combination of work performed by investigative journalists and the active role of European Public Prosecutor’s Office, the investigation would certainly not have led to the point of indictment.
ECB (2018) Opinion of the European Central Bank of 26 October 2018 on the legal framework of the State Audit Office. European Central Bank, CON/2018/45, Frankfurt, M.
The auditor general is a constitutionally independent officer appointed by and reporting to the president, the highest authority in the republic. The terms of the auditor general’s removal are the same as those of a Supreme Court justice. The auditor general presents an annual report to the president, who “shall cause it to be laid” before the parliament. S/he also produces a multitude of reports on specific subjects and on entities of public law. Parliamentary committees invite the auditor general to their hearings. The constitution provides that the audit office shall review “all disbursements and receipts, and audit and inspect all accounts of moneys and other assets administered, and of liabilities incurred, by or under the authority of the republic.” This gives the office oversight authority over all three estates.

In 2020 and 2021, the auditor general faced a strong reaction to his work from the executive and was threatened with sanctions. Despite excessive media exposure and actions that damage the credibility of the institution, the auditor general exerts his powers in a rather efficient way, exposing abuses of power and non-compliance with laws.
1. Government accuses audit boss of overstepping his powers, Cyprus Mail, 30 December 2020,
The National Audit Office (NAO) is an independent institution defined by the national constitution. According to the constitution, the NAO is not a part of any branch of power, rather it must remain independent. Although the reports of the NAO are aimed at the national parliament, the government and the public, the parliament remains the first client. The auditor general annually reports to the parliament on the use of public funds and on government budgetary discipline and spending.
In recent years, the NAO and the auditor general have become more active in communicating their work to the public. As a result, several shortcomings and problems in the work of government were publicly debated, which eventually contributed to an improvement in the quality of policy implementation.
The Board of Audit of Japan is considered to be independent of the executive, legislative and judiciary. Its yearly reports to the cabinet are forwarded to the Diet along with the cabinet’s own financial statements. The board is free to direct its own activities but parliament can request audits on special topics. The Board can also present opinions, reports and recommendations in between its annual audit reports. In these reports, the board frequently criticizes improper expenditures or inefficiencies, fulfilling its independent watchdog function.
Colin Jones, Japan’s Board of Audit: unlikely guardians of the Constitution?, The Japan Times, 4 December 2016,
The State Audit Office is Latvia’s independent and collegial supreme audit institution. The office is constitutionally independent of parliament and the executive. It primarily audits the executive and local governments, and reports to parliament, which has full access to all audit findings.

In order to promote the responsibility of officials and company managers for their decisions, the State Audit Office has frequently called for amendments to the law, which would enable the State Audit Office to impose financial penalties on officials who have wasted state funds. The law has been under discussion in the parliament since 2015, with repeated calls from the State Audit Office to solve the issue.

In addition, in 2019, the State Audit office made an announcement emphasizing the urgent need to marshal the state guarantee and debt discharge accounting. It was noted that if the ministries were unable to cooperate, the State Audit Office would refuse to give an opinion on the state’s annual report for the financial year and call on the respective officials to take responsibility for the consequences.
1. State Audit Office (2019) The Reluctance of Ministries Can Lead to the State Audit Office Refusing to Express an Opinion on the Annual Report of the State for Financial Year 2019, Available at:, Last assessed: 05.11.2019.

2. OECD (2009), Review on Budgeting in Latvia, p. 204 and 223, Available at:, Last assessed: 05.11.2019

3., Last assessed: 05.11.2019
The federal Superior Audit Office (ASF) was set up in 2001 to help the Chamber of Deputies, the lower house of the National Congress, and it has technical and managerial autonomy. In practice, the audit office shows a high degree of independence, but little sanctioning power. The audit office is accountable to parliament exclusively. Over the last decade, the audit office has become stronger in technical terms, but remains incapable of fully covering all relevant topics. A central problem remains impunity, a challenge which has become more and more severe over the last decade, and undermines the authority of the institution.
In general, President López Obrador intends to reform the constitution to limit the number and competences of independent and autonomous bodies, with the goal of concentrating competences in the executive. The debates over the issue and the stated intention to bring about the change have already limited the oversight function exerted by independent bodies.
OECD 2017: Mexico’s National Auditing System. Strengthening Accountable Governance,
The Court of Auditors is the audit office body charged with auditing the state’s accounts, electoral and party funding, and the financial management of the entire public sector. In addition, most autonomous communities have also established courts of audit tasked with monitoring their devolved competences. The national Audit Office is empowered to undertake investigations on its own initiative following the submission of a complaint, and has authority to impose substantial penalties for the misuse of public funds. Although there have been certain improvements, the office suffers from a lack of resources and political independence, since its members are appointed by the parties themselves. In recent years, it has also been accused of nepotism.
Deadlines for submitting accounts and other financial information to the Court of Auditors were suspended during the first nationwide state of alarm. Moreover, the Coordination Committee of the Court of Auditors on several occasions pointed out that the fight against COVID-19 has had a substantial impact on public spending and auditing. In 2021, the Court of Auditors started to revise all emergency contracts between government ministries, the autonomous communities, town councils and publicly owned businesses. However, in 2021, the Court restructured its departments, and the final report on emergency contracts was postponed. The Court’s decision to implement embargoes and charges against Catalan secessionists was criticized by the Council of Europe. In November 2021, all but one of the members of the Court of Auditors were replaced.
There exists an independent audit office, but its role is considerably limited.
The Hungarian State Audit Office (ÁSZ) is accountable only to the parliament. The Orbán government has used its parliamentary majority to take control of this body by appointing a former Fidesz parliamentarian to head the institution, and also by replacing other top officials. In its campaign for the 2018 and 2019 elections, the government instrumentalized the ÁSZ by bringing it to investigate the finances of some opposition parties, so as to decrease their campaign capacity. The ÁSZ has done little to monitor the government’s often opaque financial activities and has not protested the channeling of state funds to oligarchs close to Fidesz. Compared to other state institutions, however, the ÁSZ still has a relatively large amount of independence.
South Korea
The Board of Audit and Inspection is a national-level organization tasked with auditing and inspecting the accounts of state and administrative bodies. It is a constitutional agency that is accountable to the president. It regularly reports to the parliament. The National Assembly regularly investigates the affairs of the audit office, as it does with other ministries. Demands to place the audit office under the leadership of the National Assembly, thus strengthening the institution’s autonomy, have gained parliamentary support. However, tired of repeated political gridlocks and political confrontations, civil society organizations have instead proposed making the audit office independent. In its stalled constitutional-reform bill, the Moon government too proposed making the audit office independent.
According to Article 160 of the constitution, the Turkish Court of Accounts (TCA) is charged on behalf of the Grand National Assembly with auditing all accounts related to revenues, expenditures, and properties of government departments that are financed by the general or subsidiary budgets. The court’s auditing capacity was limited by Law 6085 in 2010, but the Constitutional Court annulled Article 79 regulating how the TCA would audit the accounts of public institutions. In December 2012, the Constitutional Court also annulled the provision limiting performance auditing. Currently, the TCA has three functions: auditing, financial trials, and reporting. It conducts regulatory audits and performance audits. It provides for an exhaustive audit mandate and gives the TCA full discretion in discharging its responsibilities. As of February 2020, the TCA had 1,874 staff members including 830 auditors.

The TCA’s 2019-2023 Strategic Plan foresees the development of greater risk-based audit and human resources capacities. The TCA reports to – but is not accountable to – parliament. Four audit reports are sent to the parliament each year, including the External Audit General Evaluation Report, the Accountability General Evaluation Report, the Financial Statistics Evaluation Report, and the Report on State, which was considered only during budget deliberations in the parliament. The reports of the TCA are considered only by the parliament. Parliament elects the TCA president and its members. Candidates must be graduates of universities or higher education institutions of law, political science, economics or administrative sciences who have served at least 16 years in public service.

Auditors are selected from a pool of university graduates in the same fields through a series of written and oral examinations. If a criminal act is found during the audits and investigations, the relevant auditor notifies the president of the TCA immediately. If a public criminal case is required, the chief prosecutor of the TCA sends the documents either to the relevant public authority or to the chief public prosecutor of the republic (the country’s top prosecutors). A TCA report can be taken as the basis for a trial, but is shared only with those involved, and is not disclosed to the public.

There are credible concerns concerning the fiscal discipline, transparency and accountability of the Turkey Wealth Fund (TWF), which is now directly affiliated with the president and is not fully subject to direct audit by the TCA. The law allows only a limited number of the companies within the TWF to be audited by the TCA. What is more worrisome is that the audit is conducted by auditors appointed by the president, who is also the chairman of the TWF. Moreover, the transition to the presidential system further undermined the accountability of agencies, as well as internal control and auditing, since various institutions’ roles and responsibilities have not yet been clarified. Finally, given that TCA reports are only considered by the parliament during the deliberations on the budget in December, the TCA was not in a position to monitor the government’s financial actions during the pandemic.
Sayıştay. 2020.

European Commission. “Turkey Report 2021. Commission Staff Working Document.” October 19, 2021.
There does not exist an independent and effective audit office.
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