[section separator="true"]
[section-item 9]
[row]
[column 12]
[toc-this]
This page applies to all [a-glossary term="Statement%20of%20Assurance"]statement of assurance[/a-glossary]
audits (annual reports and specific annual reports) unless specified otherwise. It applies to other compliance and financial audits by analogy, unless their specific nature requires alternative arrangements.
Principles
Errors found as the result of tests in the statement of assurance work are recorded in the form of findings.
Findings likely to figure in an audit report are communicated back to the auditee in order to obtain feedback on their accuracy. This helps ensure that our reports are factually correct, evidence-based, fair and balanced.
Short, focused clearing documents that clearly identify the findings to be confirmed are likely to be easier, and therefore quicker, for the auditee to respond to. They should include information relevant to the addressee only.
Clearing documents must comply with the data protection rules in respect of personal data.
To ensure a minimum level of security, the clearing documents should be sent via CLEAR.
It is important for both auditor and auditee to apply the '[link title="no%20surprises%20approach" link="%2Faware%2FGAP%2FPages%2FCommunication-in-audit.aspx" /]
', each knowing what is expected of them in their respective roles, in order to promote an open, respectful and professional dialogue.
Instructions
Content and form
Include in the clearing document only those findings that may partially, or in whole, contribute to observations to be included in the draft annual report. This helps keep the clearing document as short and focused as possible.
The standardised form for documenting findings in Assyst includes all essential elements needed to provide sufficient information about a finding to allow the auditee to identify, check and confirm the accuracy of the facts supporting it.
Follow Chamber V practical guidance on reporting of findings for regularity as well as for reliability audits of the EU accounts. Clearing documents for these audits should include only findings reviewed by Chamber V.
Do not disclose personal data in the clearing document, such as:
- names of the ECA auditors, or staff from other organisations who accompanied the audit visit, as this information is not an essential part of the process; or
- names of the auditees or beneficiaries to which facts are related. Instead, clearing document should use initials or some other form of code that does not identify the person directly.
Include in the clearing document only the information necessary for the addressee to identify, understand and analyse the finding and to confirm its accuracy. For example, never disclose information collected from one recipient of EU funds to another recipient of EU funds. However, an EU body or a national authority responsible for managing EU funds can receive information collected from the final recipients of EU funds under that responsibility.
Include in the cover note, or accompanying e-mail, instructions to the recipient on when and how to reply to the clearing document. The [link title="standard%20letter%20template" link="%23Resources" /]
serves as a basis to ensure that the cover note includes all relevant elements. Cover letters should be always signed (digital where relevant) and dated. This includes the translated versions, as they constitute the principal communication.
Addressee
Address the clearing document to those holding direct responsibility for the audited matter (for example, in case of the Commission it is either the Commissioner and/or the Director General, in case of an Agency/JU it is the executive director), with a corresponding level of at the ECA.
Where a [link title="supreme%20audit%20institution%20(SAI)" link="%2Faware%2FGAP%2FPages%2FNotification.aspx%23Notify-the-bodies-concerned" /]
indicates a preference to distribute clearing documents to the national authorities and to coordinate the replies, address the clearing document formally to the head of the SAI. At the same time send copies of relevant documents to the national authorities concerned.
Where SAIs decide not to play a coordinating role, ask a national authority to coordinate the clearing procedure, including the distribution of our clearing documents and the coordination of the replies. Copy the SAI liaison officer to all relevant communications to the national authority concerned. It is possible to consult the SAIs for help in identifying the authority to be given the coordination role.
In the case of an audit of EU funds in a member state where a national authority is not involved in managing those funds (eg, directly managed expenditure), do not send a copy of the clearing document to the SAI. If the SAI requests a copy of the clearing document related to such a visit (or for any other audit of directly managed expenditure where it does not itself have the audit rights), it is up to the auditee to decide if they agree, and if so to provide the document. Such cases need to be handled carefully and sensitively.
Similarly, replies obtained from member state authorities cannot be shared with the national SAI, unless the authority itself decides to share it with them directly. Only SAIs coordinating the reply process for shared management audits have direct access to the replies. We encourage member state authorities to share their replies with the SAI through a dedicated mention in the [link title="standard%20cover%20note" link="%23Resources" /]
of the clearing document.
Send a copy of clearing documents sent to member states to the responsible DG of the Commission.
When the Commission is an auditee share clearing documents, the corresponding replies and analysis (both in the working language and the translated version) with DG BUDG. This applies to all management types and also bodies where the Commission acts as an accounting officer. The file sharing process is automated: when uploading the document to CLEAR, ensure that the button “Notify DG Budg” is ticked.
All the addressees (including in copy) should be clearly listed in the cover note of the clearing document.
Send the [link title="analysis%20of%20reply" link="%23Analysis-of-reply" /]
to the same addressees (e.g. auditee, Supreme Audit Institution, Commission, Agency or other EU body) as the original clearing document.
Deadlines and language
Prepare the clearing documents in the language of the member state concerned. For clearing with the Commission, or other EU body, use one of the ECA working languages (English or French).
To ensure timely progress of audit tasks, deadlines have been established for different parts of the clearing process as detailed in the following paragraphs.
It is a requirement to send the clearing documents within [link title="eight%20weeks" link="%2Faware%2FGAP%2FPages%2FStandard-timeframes.aspx" /]
of the completion of the physical audit visit (including time for translation). When no physical audit visit takes place, the eight-week deadline will apply from the date at which sufficient documentation has been received to enable the related audit work to take place.
Where agreed with the national authorities, it is possible to communicate the results of several missions carried out in a member state related to the same audit exercise in one clearing document. In such cases, the eight-week rule applies after the completion of the last audit mission concerned. However, in the case of particularly significant findings, it is recommended to communicate them immediately rather than waiting to complete ongoing or planned missions.
The aim is to complete all communication with auditees to obtain their feedback before the first chamber reading of the related annual report chapter (or specific annual report).
We ask the auditee to respond to clearing documents within [link title="four%20weeks" link="%2Faware%2FGAP%2FPages%2FStandard-timeframes.aspx" /]
of the date that the letter is sent to the auditee (in the language of the member state concerned in case of national authorities). You should [link title="remind" link="%23Resources" /]
the auditee of an approaching deadline if no reply has been received.
Prepare and send an [link title="analysis%20of%20reply" link="%23Analysis-of-reply" /]
in the language of the auditee within [link title="four%20weeks" link="%2Faware%2FGAP%2FPages%2FStandard-timeframes.aspx" /]
of its receipt (including time for translation).
It may be necessary in certain situations to deviate from the standard clearing approach (in terms of timing and/or practical arrangements). In such cases set out the specific arrangements in the [link title="task%20plan" link="%2Faware%2FGAP%2FPages%2FCA-FA%2FPlanning%2Ftask-plan-audit-programme.aspx" /]
.
Transmission
Send clearing documents and all related correspondence using secure electronic transmission. The primary tool for the transmission and storage of clearing documents is CLEAR. It generates emails with Ecafiles links and gives the sender the possibility to edit the message. It is not sufficiently secure to send clearing documents by simple email.
For this reason ask the auditees to transmit their replies and other documents electronically in a secure manner (eg, through Ecafiles).
It is a good practice to provide the text of clearing documents in an editable format, to facilitate auditee [link title="analysis%20of%20reply" link="%23Analysis-of-reply" /]
.
Contact the CLEAR support team for assistance in using CLEAR, and the Information Security Officer for advice on transmitting documents containing sensitive or classified information.
Analysis of reply
Analyse auditee responses and identify valid issues to be taken into account in the documentation of the evidence and when drafting the final report.
Communicate the results of this analysis to the auditee, notably regarding our position on the explanations they provided and any additional information they submitted to us. Use the analysis of reply template available in Eurolook as a basis for this process, which can take the form of a letter attached to an email, or directly in the body of an email.
Resources
[icons-list icon-size="2" separator="line" icon-vertical-alignment="middle" vertical-alignment="middle"]
[icon-list-item title="Use%20Eurolook%20to%20prepare%20your%20audit%20correspondence" description="All%20templates%20for%20notifying%20on-the-spot%20visits%2C%20clearing%20of%20audit%20findings%2C%20reminder%20of%20delay%20in%20reply%20and%20analysis%20of%20reply%20are%20available%20in%20Eurolook%20under%20the%20folder%20Standard%20Audit%20Letters." icon="fa-exclamation-triangle" /]
[/icons-list]
[/toc-this]
[/column]
[/row]
[/section-item]
[section-item 3]
[row]
[column 12]
[panel panel-style="boxed" title="Related%20documents" icon="book" class="ref-panel"]
[standards]
[link new-window title="ISSAI%20100%2F49" link="https%3a%2f%2fwww.issai.org%2fwp-content%2fuploads%2f2019%2f08%2fISSAI-100-Fundamental-Principles-of-Public-Sector-Auditing.pdf%23page%3D26" /]
[link new-window title="ISA%20260%2F9c" link="https%3a%2f%2fwww.ifac.org%2fsystem%2ffiles%2fpublications%2ffiles%2fIAASB-2020-Handbook-Volume-1.pdf%23INTERNATIONAL%2520STANDARD%2520ON%2520AUDITING%2520260%2520(REVISED)%23page%3D4" /]
[link new-window title="ISA%20260%2F16" link="https%3a%2f%2fwww.ifac.org%2fsystem%2ffiles%2fpublications%2ffiles%2fIAASB-2020-Handbook-Volume-1.pdf%23INTERNATIONAL%2520STANDARD%2520ON%2520AUDITING%2520260%2520(REVISED)%23page%3D5" /]
[link new-window title="ISA%20265%2F9-10" link="https%3a%2f%2fwww.ifac.org%2fsystem%2ffiles%2fpublications%2ffiles%2fIAASB-2020-Handbook-Volume-1.pdf%23INTERNATIONAL%2520STANDARD%2520ON%2520AUDITING%2520265%23page%3D3" /]
[link new-window title="ISSAI%20400%2F59" link="https%3a%2f%2fwww.issai.org%2fwp-content%2fuploads%2f2019%2f08%2fISSAI-400-Compliance-Audit-Principles-1.pdf%23page%3D27" /]
[/standards]
[rules]
[link new-window title="Art%201(5)%20ECA-IR" link="https%3A%2F%2Fwww.eca.europa.eu%2FLists%2FECADocuments%2FIMPLEMENTING_RULES_2021%2FIMPLEMENTING_RULES_2021_EN.pdf%23page%3D6" /]
[/rules]
[/panel]
[/column]
[/row]
[row]
[column 12][/column]
[/row]
[row]
[column 12]
[toc fixed="true" selectors="h2%2Ch3" class="basic-toc" /]
[/column]
[/row]
[/section-item]
[/section]
