The Review of the INTOSAI Framework of Professional Pronouncements (Component I)

The development of the Strategic Development Plan (SDP) for 2020-2022, based on inputs from a wide consultation and a technical review of the current documents, identified the need for further analysis of the IFPP to better define, scope and plan its future development.

This project aims to look at the clarity (of concepts and drafting) and presentation of the framework. The review will neither question the formal requirements nor make proposals for factual changes to the substance of those requirements (and therefore the way audits are done). Development of new pronouncement material (components 2 and 3 of the SDP) can continue in parallel, but be cognizant of the outcome of this project.

The project has been divided into the following phases:

First phase: Desk review

The PSC secretariat and the Technical Support Function analysed the pronouncements concerning the audit of performance and compliance objectives. INTOSAI bodies involved in the standard-setting process were asked to provide feedback. The full set of documents concerned – analysis and feedback received – is available for consultation at this web page’s end.

Second phase: Online discussions to further explore specific issues

To make the process as open and collaborative as possible, the PSC secretariat included views and feedback from across the INTOSAI community. In this phase, we also invited users of the framework from the recently established ISLO network. Discussions focused on key issues identified in the previous phase as needing further reflection. Each session focused on a different subject and was primarily guided by questions covering different aspects of the issue (see the table below).

23 November (12h00 CET)

 

What is the purpose of the standards framework (IFPP), and how can the needs of different user
groups be accommodated?

See minutes here

  • Is the IFPP intended to be an infrequently accessed reference framework or a useful and
    practical resource?
  • Is it aimed at methodology departments, auditors or both? Do these major (potential) users have
    different requirements?
  • Should the content of the framework, as far as possible, reflect current practice, or does it
    establish an acceptable minimum? Who decides on the minimum?
  • Should the framework cover every type of work an SAI may do or is it more about the principles
    that should be applied whatever the mandate/objective/output?
  • What do developing SAIs need: dedicated (simplified) standards? simplify current standards?
    include dedicated country perspective to all material, where appropriate? more support?
  • Should the framework provide a ‘ready-made’ audit manual that can be taken over and applied
    directly?
  • What difference – if any – should there be between the hundred- and thousand-series ISSAIs?
1 December (12h00 CET)

 

What is guidance and how do we ensure it is soundly-based, useful and available?

 

What possibilities do new ways of working bring?

See minutes here

  • Can a distinction be made between guidance intended to make the meaning of concepts and
    requirements clearer on the one hand, and suggestions and examples on how to put them into
    practice, on the other?
  • Should some elements of guidance be compulsory? If so is this a different concept and should it
    be given a different name?
  • Can a distinction be made between guidance that needs to be part of the framework and follow the
    lengthy due process, and guidance outside it that could be provided in quicker and more flexible
    format? If so, how should this distinction be defined?
  • Does guidance provided outside the framework need formal ‘approval’? If so, who should provide
    it?
  • Should guidance only flow from a requirement in the framework, or can it be of ‘independent’
    issues that some SAIs could find useful?
  • When guidance flows from a requirement, is it sufficiently clear from the requirement that it
    exists, and can be found easily?
  • Practical examples provided by individual SAIs can be a useful element of guidance. Do they need
    vetting, and by whom?
  • Do online collaborative websites give new possibilities for practitioners to post and discuss
    examples and other elements of guidance?

If so, could direct feedback be used to assess the relevance and utility of guidance?

15 December (12h00 CET)

 

Do the concepts of ‘principles’ and ‘standards’ refer to documents, or elements of their content,
and what do they mean in practice?

See minutes here

  • Are principles an abstract concept or an element of content?
  • In the case of the former, does this mean everything in a document entitled as such are
    considered principles? In the case of the latter, can the individual principles be identified?
  • ‘Principles-based’ has a number of different meanings, what are they?
  • Which meaning of ‘principles-based’ is the one the framework is or should be based on, and what
    implications could this have?
  • Are standards an abstract concept or an element of content?
  • In the case of the former, does this mean everything in a document entitled as such are
    considered standards? In the case of the latter, can individual standards be identified?
19 January (12h00 CET)

 

Compliance audit is ‘generally conducted’ in cooperation with one of the two other audit types:
should this have an impact on how the material (standards and guidance) in the framework is
sorted and presented?

See minutes here

  • Is the reality in practice that compliance audit is ‘generally conducted’ with one of the two
    other audit types? Or are they more likely to be standalone tasks, reported separately?
  • ISSAI 400 suggests that when compliance and performance audit are performed in combination, the
    standards that apply can be one, or the other, or both. What normally happens in practice? What
    challenges arise from following two sets of standards at the same time?
  • Are SAI mandates defined around the audit types?
  • Is SAI training organised around these audit types?
02 February (12h00 CET)

Financial audit: impact and implications of relationship with the ISAs.

INTOSAI’s financial auditing standards are based on the International Standards on Auditing (ISAs)
developed by the International Auditing and Assurance Standards Board (IAASB). While the principles
are set out in ISSAIs 100 and 200, the standards in the form of ISSAIs 2200 – 2810 are simply
renumbered ISAs.

Guidance on applying ISAs in the public sector context is given with the ISAs themselves,
supplemented by GUID 2900 currently being finalised. More information, including the specific
arrangements concerning ethics and quality control, can be found in the recently adopted ISSAI 2000.

See minutes here

  • Do you find the situation clear, or can there be confusion as to what applies in practice?
    When carrying out financial audit work in accordance with international auditing standards,
    do you refer in your audit report to the audit as having been performed in accordance with
    the ISAs or the financial audit ISSAIs?
  • Is there scope to further simplify the IFPP in respect of financial audit, for example by
    removing from the IFPP those documents that are simply renumbered ISAs (knowing that INTOSAI
    has no responsibility for the content thereof) ?
  • Do you find difficulties in accessing the ISAs, and what could help in this respect?
  • What do you see as the challenges for INTOSAI’s financial audit standard-setting
    strategy?  Are there particular issues you would like to see addressed in the future?
23 February (13h30 CET)

Are pronouncements on performance auditing sufficiently clear to do the work?

See minutes here

  • Do you find the current performance audit content of the IFPP clear, sufficient and useful? How
    would you like to see it develop in the future, such as topics that need covering or where
    further guidance would be useful?
  • Do you find the 3Es too restrictive when scoping performance audits, or do they represent a
    sufficiently flexible guide for all performance audit work?
  • Is evaluation fundamentally different from performance audit? Does performance audit have
    lessons to learn from evaluation?

 

In order to support Auditing in complex and challenging contexts (ACCC), SAI Sweden organised a meeting in 2021 to hear SAIs in these contexts about their views on the INTOSAI Framework of Professional Pronouncements (IFPP). It happened through the CBC workstream.

Third phase: Survey to identify the needs of the INTOSAI community

We carried out an Intosai-wide survey (third phase) in 2021, addressed to all Intosai members, to ensure the best possible input and identify the needs of the Intosai community. Please see the here.

Fourth phase: Data analyses of the Survey

We will discuss the preliminary results in meetings with Intosai stakeholders. They will happen as shown in the table below:

Goal Committee Chairs 03/06
Afrosai, Carosai Minutes
ISLO Minutes
FAAS Minutes
Subcom Chairs Minutes
Olacefs 12/05
Eurosai 13/05
Arabosai Minutes
ICS 18/05
Asosai, Pasai 19/05
CAS 19/05
PAS 19/05
IDI+GS 20/05

 

You can download the preparatory documentation in English, Spanish, French and Arabic

Documents

Phase 1

01. Letter regarding Component I Review – August 2020
02. Component I of the Strategic Development Plan: Analysis of the framework and next steps
03. ISSAI Comparisson Spreadheet
04. Feedback: FAAS
05. Feedback: PAS
06. Feedback: ICS
07. Feedback: CAS
07. Feedback: CAS – Comments from the representatives
08. Feedback: FIPP
09. Feedback: CBC
09. Feedback: CBC Swedish NAO
09. Feedback: Swedish NAO answers and general comments
10. Feedback: KSC
10. Feedback: WGVBS (SAI Ecuador)
10. Feedback: WGVBS (SAI Mexico)
10. Feedback: WGVBS (SAI Turkey)
11. Feedback: WGEA (SAI Finland)
12. Feedback: SAI Iraq

Phase 2 Discussion sessions

01. The purpose of the standards framework (IFPP), and how can the needs of different user groups be accommodated? 23.11.2020
02. What is guidance and how do we ensure it is soundly-based, useful and available? What possibilities do new ways of working bring? 01.12.2020
03. Do the concepts of ‘principles’ and ‘standards’ refer to documents, or elements of their content, and what do they mean in practice? 15.12.2020
04. Compliance audit is ‘generally conducted’ in cooperation with one of the two other audit types: should this have an impact on how the material (standards and guidance) in the framework is sorted and presented? 19.01.2021
05. Financial audit: impact and implications of relationship with the ISAs. 02.02.2021
06. Performance audit: Are pronouncements on performance auditing sufficiently clear to do the work? 23.02.2021

Phase 3: Feedback

Afrosais_Carosai_Discussion Summary _Comp1 workshop-02.05.2022
Arabosai_Discussion Summary _Comp1 workshop_16May2022
ISLO_Discussion Summary _Comp1 workshop_05.05.2022
PSCSubcommittee_Chairs_Discussion Summary _Comp1 workshop_12May2022
[FAAS]Comp1_discussion_summary workshop_11May2022