Fee Variations
- The Appointing Person legislation enables a firm to submit a fee variation proposal where they consider that additional work is required that is not provided for in the scale fee for an individual body.
- Firms are contractually obliged to have local discussions with individual opted-in bodies about any proposed fee variations. A description of our fee variation process is available online. We updated our process in response to the introduction of audit backstop dates.
- Based on the latest position available as of 31 July 2025 (the completion of our latest round of fee variation processing) we had received fee variation submissions for 485 out of 535 bodies (91%) for the 2023/24 audits, proposals for the remaining 9% are awaited. Of the submissions received, we have determined fee variations for 408 bodies (81%), with reviews ongoing for the remaining 77 (19%). We will provide further updates in our published quarterly monitoring data.
- Table 13 provides a detailed breakdown of the position at 31 July 2025. It shows the average level of fee variations approved, expressed as a percentage of scale fees.
Table 13: Summary of fee variations approved, being considered and firms’ proposals not yet received against scale fee at 31 July 2025
| Opinion type – description | Number of audits* | Audit scale fee £m | Total net value of fee variation requests approved (£m) | Total cost of audit £m | % total variations approved against scale fee |
| Disclaimed / Modified | 184 | 38.9 | -4.1 | 34.8 | -10.54% |
| Unmodified | 224 | 40.6 | 4.3 | 44.9 | 10.48% |
| Subtotal | 408 | 79.5 | 0.2 | 79.7 | 0.19% |
| Fee variations being considered | 77 | 14.4 | – | 14.4 | 0.00% |
| Firms’ proposals not yet received | 49 | 13.8 | – | 13.8 | 0.00% |
| Total | 534 | 107.7 | 0.2 | 107.9 | 0.14%** |
*Total includes pension funds as audits
**We will report this value once we have processed all fee variations for the 2023/24 audits
- Table 13 shows that for unmodified opinions the total value of approved fee variations as a percentage of scale fees is 10.48%, of which 5.17% relates to work required under ISA 315. We were unable to incorporate ISA 315 into the 2023/24 scale fees due to insufficient information at the time of setting them; however, it is incorporated in the 2024/25 scale fees.
- For disclaimed or modified opinions, the total value of approved fee variations is -10.54%. This comprises 34.45% negative fee variation for work included in the scale fees that firms were unable to complete, offset by an average 23.91% positive fee variation. The positive element mainly relates to ISA 315, planning and reporting disclaimer opinion, value for money additional risks, and quality and preparation issues at bodies.