Frequently Asked Questions

In 2020 PSAA commissioned independent research from Touchstone Renard to review the sustainability of the local government audit market.

During the summer of 2021 we considered the feedback provided by the market and confirmed our approach to support the drive towards a more sustainable market for local public audit services. We summarised the outcome of the market engagement in a report that we published in autumn 2021.

Our procurement strategy 2022 supported the drive towards a long term competitive and more sustainable market for local public audit services and recognised the need to encourage new entrants alongside existing suppliers. For example, we created different sized contract lots to reflect the range of capacity available within different firms.

Public Sector Audit Appointments Limited (PSAA) has been specified as an appointing person under the Local Audit and Accountability Act 2014 and the Local Audit (Appointing Person) Regulations 2015. It has had the power to make auditor appointments for audits of the accounts from 2018/19 onwards on behalf of eligible principal local government bodies that opt in.

Eligible bodies are those in the principal local government body types listed in schedule 2 of the Local Audit and Accountability Act 2014 with annual income or expenditure in excess of £6.5m. This includes county councils, district councils, London borough councils, unitary authorities, metropolitan councils, local police bodies, fire and rescue authorities, combined authorities (covering elected regional mayors), national park authorities, conservation boards, passenger transport executives, waste authorities, functional bodies, and other specified bodies.

Authorities with income and expenditure of less than £6.5m (such as parish councils) are smaller authorities and do not require a full audit. Smaller authorities can choose to be treated as full audit authorities in which case they are eligible to opt in as principal authorities.

NHS bodies are not eligible to opt into our scheme.

The list of the local government bodies opted into the 2018 appointing person scheme is available.

The list of the local government bodies opted into the 2023 appointing person scheme is available.

We continue to work closely with a range of local audit stakeholders including DLUHC, the FRC, the NAO, CIPFA, ICAEW and the LGA to help identify and develop further initiatives to strengthen the local audit. Our e-bulletins provide details of recent developments.

We know that there is a long way to go before something approaching a complete whole-system solution is crafted which must involve more local auditors and/or less audit work – preferably both. PSAA is ready to do everything we can as part of a collective systemwide effort to deliver the critical changes required.

Since 2018 PSAA has taken several initiatives to support improvements in local audit including:

• proactively and constructively engaging with the numerous high-profile industry reviews, including the significant Redmond Review into Local Authority Financial Reporting and External Audit;
• commissioning an independent review undertaken by Cardiff Business School of the design and implementation of our appointing person role to help shape our thinking about future arrangements;
• commissioning an independent review by consultancy firm Touchstone Renard of the sustainability of the local government audit market, which identified a number of distinctive challenges in the current local audit market. We published the report to inform debate and support ongoing work to strengthen the system and help to deliver long term sustainability;
• working with DLUHC to identify ways to address concerns about fees by developing a new approach to fee variations. This would seek wherever possible to determine additional fees at a national level where changes in audit work apply to all or most opted-in bodies;
• establishing of a Local Audit Quality Forum, which holds in-person events and webinars that are free for opted-in bodies to discuss relevant topics;
• using our Advisory Panel and attending meetings of the various Treasurers’ Societies and S151 officer meetings to share updates on our work, discuss audit-related developments, and listen to feedback;
• maintaining contact with those registered audit firms that are not currently contracted with us, to build relationships and understand their thinking on working within the local audit market;
• undertaking research to enable a better understanding of the outcomes of electors’ objections and statements of reasons; and
• sharing our experiences with, and learning from, other organisations that commission local audit services such as Audit Scotland, the NAO, and Crown Commercial Services.

The mechanism for allocating the costs of individual firm bids is the scale fee, which allocates the total costs of all firms’ tenders and PSAA total costs (approximately 2%) in a proportionate way across all bodies.

The scale fee does not vary in relation to which firm is appointed as auditor. Contingencies are not built into the fees and where additional audit work is required after the scale fee has been set, this results in a fee variation in line with the statutory framework. These may result in a permanent adjustment to the scale fee (for example group accounts are now required) or maybe for a single year only (for example a change of a key financial system). The scale fee is linked to the relative risk and cost of a particular body’s audit.

PSAA has a duty to make appointments to all bodies that opt into the schemes. We have published our approach to auditor appointments for the two five-year appointing periods from 2023/24 to 2027/28 and from 2018/19 to 2022/23.

When we make auditor appointments we consider any formal joint working or shared service arrangements where these are relevant to the auditor’s responsibilities. Providing there are no independence considerations or other constraints, we will look to appoint the same firm as for another opted-in body where this is requested. Auditors must be independent of the bodies they audit, as required by the Ethical Standards issued by the Financial Reporting Council and in accordance with PSAA’s obligations under the Regulations.

If you have a specific enquiry about either of the appointing period schemes, please contact us at generalenquiries@psaa.co.uk.

PSAA has a clear process for managing complaints, which sets out those areas that it covers. It does not cover matters of professional judgement. We have a Memorandum of Understanding with professional regulators (The Institute of Chartered Accountants England and Wales (ICAEW) as the Recognised Supervisory Body (RSB) and the Financial Reporting Council (FRC)), such that complaints are dealt with by the most appropriate body.

PSAA undertakes contract monitoring of the firms it appoints. Each year PSAA carries out an annual survey that is designed to obtain views from opted-in bodies on the delivery of their audit. This forms part of its engagement with the sector as the feedback received informs discussions with the firms, DLUHC, the FRC, the NAO, the LGA, CIPFA, ICAEW and other key stakeholders involved in local audit in England.

Issues with the timeliness of audit opinion delivery are caused by a variety of factors. In common with all stakeholders in the local audit system, we want to see the earliest possible return to a position in which virtually all local bodies can publish their audited accounts by the target date specified in the Accounts and Audit Regulations.

There are several significant obstacles which need to be overcome before that goal can be realised. They include:

• a backlog of delayed prior year audit opinions which are still outstanding;
• a shortage of audit staff with the requisite skills and experience;
• more demanding regulatory requirements which increase the time and resources needed to complete each audit; and
• local bodies entering more frequently into innovative transactions which require detailed examination by auditors, and capacity shortages in finance and other staff to deal with the volume and complexity of local government accounts.

In January 2023, the NAO published a progress update on the timeliness of local auditor reporting in England. This was an update on their original report issued in March 2021.

The 2020 NAO Code of Audit Practice requires auditors to report on a timely basis, clearly, concisely, and objectively without fear or favour. Timely reporting includes producing audit reports in time, insofar as the auditor can do so under auditing standards, to allow local bodies to comply with the requirements placed on them to publish their audited financial statements.

We have amended our expectation of firms within the 2021 Terms of Appointment. This states that where in the auditor’s view it would not be possible to issue an audit report in compliance with the auditing standards and the guidance issued by the NAO by the publishing date, the audited body must be consulted on an alternative target date. The auditor must notify the audited body promptly of any delays to the agreed timetable, and reissue the timetable having regard to those delays after further consultation.

The local audit system working together as a whole is the most effective way to drive the timely delivery of audits. It is important to recognise that any improvements will take time to materialise given the nature of retrospective audits and the significant number of delayed audits. There are no easy solutions which we or any other parties can simply action. The reality is that returning to a more predictable and stable position is going to take some time and will be a gradual process. Our e-bulletins provide updates on developments across the local audit system to seek to address the well-documented challenges.

Technical audit quality is a measure for the FRC as regulator. The Ethical Standard precludes contracts that contain fees that vary according to a pre-determined measure (for example specifying a date by which an audit opinion must be given).

We monitor the quality of audit services using a package of measures. We work with firms to improve matters where service has been poor, but our contractual options are limited. Our aim is to get to a position where we can replace auditors who do not meet the quality measures within our contracts and are not able to resolve the issues. However, the current shortage makes this very challenging, and is another reason for wanting to strengthen the supplier options available to us in the future.

Our audit contracts from 2023/24 contain a range of new provisions designed to improve service delivery which are summarised below, as per our webinar in March 2022 in which we explained the new features of the contract.

We are currently developing the practical arrangements for contract monitoring aligned to these strengthened provisions.

The measures in the new contract include:

• Firms will be paid when they deliver four predefined audit milestones (each attracting 25% of the scale fee), rather than on a routine quarterly basis unlinked to on the ground delivery:
  • for audit year 2023/24 where the Supplier has not been the Appointed Auditor for the previous audit year not earlier than 1 October 2023, otherwise on the production of the auditor’s annual report for the previous audit year
  • production of the draft audit planning report to the audited body
  • 50% of the supplier’s planned hours in respect of the audited body have been completed
  • 75% of the supplier’s planned hours in respect of the audited body have been completed
• We have introduced KPIs linked to the audit delivery lifecycle and a quarterly contract monitoring review process
• There is a Review Procedure through which we can require a supplier at its own cost to amend its method statement, if the current one does not satisfy their obligations under the contract
• There is a Rectification Plan process which we may invoke if:
  • the supplier fails to comply with its method statement obligations and materially impacts delivery;
  • there is a supplier delay or is reasonably likely to be a delay;
  • the supplier fails to achieve any KPI measure; and/or
  • commits a default that has or may have an adverse effect on the provision of the Services.
• Once agreed by us, the Rectification Plan creates a supplier obligation to implement it, including rectification of past failures.

The fact remains that as now, our statutory sanction of being able to remove auditors from appointments (e.g. for performance or other issues) is largely moot as there is no surplus in the local audit market. As referenced in our press release, we had to go through several procurement stages to get enough capacity to make the appointments which is far from ideal, this would be a surplus of supply and increased competition. In this context neither we nor the system can offer any guarantees on service delivery as our contract management framework is undermined by this capacity issue. What we can guarantee is that PSAA will do all we can to help the system tackle the issues. DLUHC has publicly stated that local audit will take years to fix, and no single action will solve it.

The introduction of IFRS was a government decision in 2007 ‘to improve consistency and comparability’ and ‘to follow private sector best practice’. CIPFA recognises how complicated accounts have become and DLUHC has committed to looking at what can be done to make them more accessible.

Please note that the implementation of IFRS16 has been delayed until 2024, following the CIPFA/LASAAC emergency consultation in March 2022.

Auditors are required to deliver an audit that complies with the NAO Code of Audit Practice, and PSAA’s contracts are let on this basis. Regulation 17(2) of the Local Audit (Appointing Person) Regulations 2015 states that where it appears to PSAA (as the appointing person) that the work involved in a particular audit was substantially more than that envisaged by the scale fee, then a larger fee may be charged.

PSAA has a robust process for reviewing and approving fee variations involving consultation with the audited body, and reviews of firms’ work programmes and audit files to assess proposals for additional fees submitted by auditors.