Planning for Independence
SAI independence does not happen by chance but will often require a concentrated effort over many years to progress.
This means it is important for a SAI seeking greater independence to develop a realistic plan on how to achieve it. A useful article on the approach a SAI could adopt to achieve greater independence is Making SAI independence a reality – Some lessons from across the Commonwealth.
There is also detailed guidance on developing and implementing an independence strategy in IDI’s 2017 draft Towards Greater Independence: A guidance for Supreme Audit Institutions (Part 2, chapters 4 and 5). The guidance describes an analytical process whereby a SAI assesses its current state of independence, undertakes a comparison against the Mexico Declaration principles (INTOSAI-P 10), identifies its own priorities, then drafts a strategy and implementation plan to achieve greater independence.
The guidance has a useful section on identifying priorities (pages 70–71). It notes it may be unrealistic to expect the SAI can achieve independence across all the matters contemplated by the Mexico Declaration. Therefore, a SAI may need to prioritise those independence matters that are the most important to it and target its effort on those matters. It might also be possible to enhance independence in the practical sense without the need for a lengthy process of seeking constitutional change. This is covered at item 2 in the SAI independence checklist of issues a SAI should consider when seeking to broaden its independence.
The guidance also deals with:
the implementation of an independence strategy, including advocacy with key stakeholders and how to argue the case (pages 76–80); and
some of the practical issues that can arise with legislative reform (page 85).
Independence action plan
The IDI guidance notes it is important to have a plan for implementing an independence strategy and provides a comprehensive template (page 74).
Where a SAI has completed a PMF review it will have completed some of the template content already (such as the content ‘about the SAI’ and the assessment of the SAI’s independence against the eight principles of the Mexico Declaration). For those SAIs, one option would be to use the independence related gaps identified in the PMF review to list constitutional and legislative enhancements to remedy those gaps, and then prioritise the most important/achievable.
A SAI could also list any practical enhancements of independence that do not require legislative change. The SAI could then complete the rest of the implementation strategy template for the priority actions, including who it needs to consult/work with, timing, threats and risks, and the impact on resources and personnel.
Where a SAI has not completed a PMF review, it could use the template in the guidance.
We have developed an editable SAI Independence Strategy template for SAIs to use. It contains a SWOT analysis table, a letter seeking legislative support and makes a compelling case for pursuing greater SAI independence.
There is also a Legislative reform policy paper template and Drafting instructions that a consultant used in the Solomon Islands.
