Budget Legislation in Selected Countries: Accounting, Financial Reporting, and Audit
|Country||Monitoring of Accounts||Accounting Rules||Internal Audit||External Audit|
|Australia||Secretaries (heads of department) are responsible under their ministers for financial management and accounting. The Minister of Finance coordinates and issues regulations (CFMH 6.1-6.6, 8.208.3). 1/||The budget management law covers only basic principles on accounting classification of public money. Detailed regulations and instructions are issued by the Ministry of Finance (FMAB 42-43).||Under Finance Directions, Secretaries of Departments are responsible for internal audit (CFMH 6.35, 6.36).||External auditing is performed by the Auditor General, Director of the National Audit Office. The Auditor General is required to prepare audit financial statements on accounts and records of all departments and agencies’ business, and report to Parliament annually (CMFH). In the new legislation audit provisions are to be covered in the FMAB (Part 14) and in a separate Act, the Auditor General Act. 1/|
|France||The Treasury is responsible (LDF 108-111).||Covered in the Comptabilité Publique Decree 1962 (LDF 100-107)||The spending ministries are responsible for internal audit but this is closely overseen by the Inspection General of the Ministry of Finance (LDF 115-116).||External auditing is performed by the Cour des Comptes, which audits government transactions. Reports every year to Parliament end to the President (LDF 19-124).|
|Germany||The Federal Minister of Finance is primarily responsible for accounting, collection, and disbursement through Federal Cash Offices (FBC 75-79).||The (Federal) Minister of Finance regulates details concerning the establishment and arrangements of accounts, and supporting documents, with the agreement of the Federal Audit Office. The laws cover the establishment and arrangement of accounts and supporting documents (FBC 71-79, 84).||Internal audit is carried out by departmental and agency internal audit units. In agreement with the Federal Audit Office, the responsible minister determines the arrangements for internal audit (LBP 56; FBC 100).||The Federal Audit Office is responsible for all external auditing. The Auditor General is required to report to the Parliament and inform the Minister of Finance and heads of ministries once a year. Audit provisions are given in the LBP (Chap. 5), the FBC (Part V), and the LFA|
|New Zealand||The Minister of Finance (Treasury) reports on overall government operations half-yearly and annually (PFA 27-29). Chief executives of departments and agencies are responsible for reporting on departmental operations (PFA 33-40).||Regulations and instructions are issued by the Treasury. Accounting conventions are adopted from standard private sector accounting practice (PFA 35; FRA 5).||Departmental and agency heads are responsible for internal audit subject to treasury instructions. (PFA 33)||The Audit Office is responsible for external auditing and is required to prepare a report on the annual and half-yearly public accounts prepared by Treasury and departments for Parliament (PFA 30, 38, 43). Agencies may use private sector auditors or the Audit Office.|
|Portugal||Monitoring is performed by the responsible entity under the authority of the Government and supervision of the Audit Court (FNB 21).||The law covers general accounting principles (FNB 19, 24-27; DL, Section II). 1/||Departments and agencies are responsible for internal audit (DL 53).||The Audit Court is responsible for external audit of the public accounts (FNB 21, 24).|
|Sweden||The Minister of Finance, National Audit Office, heads of departments and agencies; and the National Debt Authority (Treasury) are responsible (C Chap. 9).||Regulations and instructions are issued by the MF.||Departments and agencies are responsible for internal audit. The Minister of Finance is responsible for establishing audit procedures within the Government, in agreement with the National Audit Office (EAP).||The National Audit Office and the Parliamentary Auditors are responsible for all external auditing (C).|
|United Kingdom||The Treasury and Accounting Officers (departmental heads) at departments and agencies are responsible for reporting on departmental operations.||The Government Accounting Guidelines provide an extensive manual for government accounting (GAG).||Heads of departments and agencies are designated as Accounting Officers (AO) responsible to Parliament for good management, including internal audit. The AO is responsible for signing the appropriated accounts each year. The Internal Audit Development Branch of Treasury provides guidance and assistance to departments (GAG C, D).||The National Audit Office is the main external auditor for the Government. It certifies the accounts of nearly 500 departments and agencies and prepares value-for-money reports for Parliament. The Audit Commission audits the Health Service and appoints auditors for local governments (NAO, AC).|
|United States||The OMB monitors budget execution, Treasury maintains a central summary accounting system and agencies maintain detailed accounts. The Treasury and heads of departments are responsible in agreement with the General Accounting Office (CBP 503).||GAO prescribes government accounting standards. Efforts to standardize agency accounting systems have been promoted by the JFMIP. 2/||Federal agencies are responsible for internal audit and most have an Inspector General appointed by the President (approved by Congress).||The GAO, an agency of Congress, is the external auditor of the executive branch of government. There is not at present a requirement for presentation of a comprehensive audited financial statement by the executive branch.|
See Appendix for all abbreviations.
The Joint Financial Management Improvement Program, coordinated by the heads of OMB, Treasury, CBO and GAO. OMB has been given specific responsibilities for improving financial management systems under the Chief Financial Officers (CFO) Act of 1990.