LGA response to consultation on Local audit reform: a strategy for overhauling the local audit system in England

1. The LGA is the National Voice of Local Government. We’re on the side of councils: promoting their work, supporting them to improve and helping them make a difference to people, places, and the planet. As the national membership body for local authorities, we provide the bridge between central and local government and we help councils deliver the best services to their local communities.

2. This response has been cleared by the lead members of the LGA’s Economy and Resources Board.

3. It is widely recognised that local audit is in crisis, and this is acknowledged in the consultation and the strategy. The LGA has been pressing for a long time for a timetable to be set by which timely audits will be restored. There is an urgent need to restore confidence in the local audit arrangements, restore timely audits permanently, and improve financial reporting. Taxpayers and residents should demand and be entitled to full confidence in local authority accounts. But it is also clear that the causes of the crisis are complex – there is no easy explanation nor an easy solution. Factors include:

• 3.1. insufficient audit resources. There are a limited number of audit firms within the market and a shortage of suitably qualified auditors working for them.
• 3. 2. Auditors have to do additional work due to tighter and stricter regulation of auditors following audit failures in the private sector.
• 3.3. Local authority accounts are complicated and hard to understand. These complexities add to the amount of audit work and the work for accounts preparers.

4. It is crucial that the strategy addresses these factors and that this is done with strong involvement from the local government sector. The strategy covers a large number of points, divided into several sections. We comment below on the proposals for each section and also respond to the detailed questions.

5. The detailed questions on the Local Audit Office (LAO) remit do not explore the overall proposal to set it up or consider its core functions – these are outlined in the Government’s “commitments” on page 23 of the consultation. Our members are ready to work with the Government on the proposal to set up a new local audit body but would need to be convinced that a new organisation would tackle the problems that exist in the sector. Structural change on its own will not be enough.

6. We note the statement that this is “not a return to a bloated Audit Commission. Lessons will be learnt, and the LAO will be proportionate and operate within its strategic objectives and the principles of this strategy.” It is crucial that this is borne out in the finalisation and implementation of the proposals. It is proposed that the new body will take on responsibilities currently undertaken by several bodies, and it is likely that it will be a body of a significant size, particularly if its responsibilities include the public provision of local audit.

7. The practical implications of this need to be worked though and confirmed as soon as possible. One of the bodies affected is Public Sector Audit Appointments (PSAA). PSAA was set up as an LGA initiative in response to the abolition of the Audit Commission. PSAA is a not-for-profit company limited by guarantee without share capital. The company’s sole member and guarantor is the Improvement and Development Agency (IDeA), which is under the control of the Local Government Association (LGA). PSAA operates independently of both the LGA and of IDeA. The impact on PSAA needs to be considered in full in consultation with PSAA and the LGA.

8. is not clear from the strategy document how the new body will be governed and how its independence and expertise will be assured. This is very important, particularly if it is given powers to alter councils’ accounts (see question 8). The body must not be seen as being politically influenced.

9. The published accounts of local authorities need to be as clear as they can be while reflecting a full and factual account of the council’s spending and financial position. Residents and taxpayers are the key audience, but also those responsible for governance and decision-makers within the council itself. However, most residents and taxpayers are unlikely to get assurance directly from the accounts that public money is being appropriately recorded and used for legitimate purposes. Instead, they will need to rely on those responsible for governance (especially statutory officers and elected members) and auditors to provide suitable assurance based on their commentary of those accounts. This places increased importance on the audit regime, but also means that audit reporting must be meaningful, intelligible and timely. There can be no doubt that timeliness has not been achieved recently.

10. Local government finance and the statutory framework within which it operates is inherently complex. The effort involved in producing and auditing the accounts has increased enormously over the years and continues to do so. Much, if not all of this added workload neither adds value to councils nor provides useful information to users of the accounts. In its submission of evidence to the Redmond review one firm of auditors drew attention to the increase in length and complexity of accounts by citing an example of a council where the length of the 2018/19 statement of accounts was 219 pages compared to 91 pages ten years earlier and the audit opinion was 12 pages compared to 3 pages ten years earlier. This was five years ago; since then, accounts, if they have been finalised at all, have become longer rather than shorter.

11. As outlined above, one of the main underlying causes of the current crisis in local audit is that there are a limited number of audit firms within the market and a shortage of suitably qualified auditors working for them, leading to insufficient audit resources. Apart from a few helpful points (eg the role of Responsible Individuals) the strategy does not include a great deal about building up additional audit capacity and resources. Instead, capacity building concentrates on actions to make local authority accounts more proportionate and so free up existing resources.

12. This is a step in the right direction, but it needs to go hand in hand with extending capacity in the audit market.

13. In addition, a second underlying cause of the current crisis is that auditors have to do additional work due to tighter and stricter regulation of auditors following audit failures in the private sector. Again the strategy does not address this directly – it is either picked up indirectly though measures to make the accounts more proportionate (which will impact on the amount of audit work) or through moving responsibility for regulation to the new LAO.

14. This misses the opportunity to consider the framework that governs the work that auditors do. There is no consideration of the auditing standards that auditors of local bodies have to follow (the International Standards on Auditing, UK) and whether they are suitable for local audits. This is an omission and is an area that could be usefully looked at in more detail. These auditing standards are designed for audits under the Companies Act and are long and complex (running to well in excess of 1,000 pages). Applying these overall standards to local audits does not recognise that local authorities are different and that a local authority will require a different audit to a large company. This is an area that should be considered further as the local audit strategy is developed, and could be a role for the new LAO, with a view to ensuring that auditing standards used in local audits are proportionate and appropriate.

15. This section includes proposals that councils’ audit committees should have at least one independent member and that a council’s accounts should be approved by full council. Neither of these are covered in the consultation questions.

16. It should be for local bodies to decide who sits on their committees. We agree that it is generally recognised as good practice for an independent member to sit on an audit committee, but there may be local circumstances that means this is not suitable for all councils. For example in some councils the role of the committee that performs the functions of the audit committee may be wider than just audit and this could mean that having an independent member may not be appropriate for those councils, or in some areas of the country there may be a lack of suitably qualified and experienced people willing to undertake the role for an appropriate remuneration. It would therefore be better and more practical if it were recommended as good practice that local bodies should have at least one independent member of the audit committee but that it was not mandated.

17. The proposal for the accounts to be approved by full council can be supported, provided that there is still scope for the accounts to be considered in more detail at the audit committee first and that the chair of the audit committee has a role in signing them off. The reality of full council meetings is that there is not always time to consider items in full detail, which is why councils have wider governance structures.

18. We have commented previously on the backstop arrangements, for example in our responses to the consultations on addressing the audit backlog, in early 2024.

19. The issue of fees and how they are to be funded remains to be resolved, both the fee variation to be implemented when auditors issue disclaimed opinions after having not completed audits by the backstop date, and also the potential additional costs of the audit work to be done on rebuilding assurance.

20. Calculation of the fee variation, and how it is to be funded, for the work done on a disclaimed opinion is a current issue with the first two backstops. It is crucial that fees are seen to be fair to both auditors and to audit bodies and that there is consistency of treatment between bodies. We have heard that claims for fees for work done have varied considerably between bodies and firms. This should have been dealt with by clear direction to auditors on how much work they needed to do before issuing a disclaimed opinion due to lack of time or capacity.

Question 1. Do you agree the LAO should become a new point of escalation for auditors with concerns?

21. It will be helpful to have a single point to which concerns can be escalated, both by auditors and about issues with auditors. If responsibilities are shared or not clear, then it is likely that issues will take longer to be resolved. An example of this recently was the valuation of infrastructure assets where no one body was able to take responsibility for a resolution or able to issue revised guidance that would be followed and so the issue had a major impact on increasing the audit backlog. A single point of escalation might have avoided this becoming the issue that it did.

Question 2. Do you agree relevant issues identified should be shared with auditors, government departments and inspectorates?

22. We agree that it should be helpful that issues are shared with auditors, government departments and inspectors. However, any sharing has to be done in an appropriate way. It is vital that any information that is shared is shared first with the council that is involved and that it is notified that the information is going to be shared more widely before that actually happens.

Question 3. Should the LAO also take on the appointment and contract management of auditors and for smaller bodies in the longer term? If so, when should responsibilities transfer from SAAA (Smaller Authorities Audit Appointments)?

23. There may be synergies from combining functions in this way. However, we understand that currently smaller bodies do not have the same problems with audit capacity as those that affect councils. It would therefore seem sensible at this stage to concentrate resources on the problems with local audit that need to be solved now.

Question 4. Should the LAO oversee a scheme for enforcement cases relating to local body accounts and audit?

24. It makes sense for the LAO to pick this up, reinforcing the point that a single point of contact and consistency across the sector would be helpful. As outlined in the introduction, above, tighter and stricter regulation of auditors, following audit failures in the private sector, has been one of the underlying causes of the current crisis. Whichever body picks up enforcement, it should be proportionate, only used as a last resort, and be mindful of unintended consequences.

Question 5. How could statutory reporting and Public Interest Reports be further strengthened to improve effectiveness?

25. Public Interest Reporting has been largely unchanged since before the 2011 Localism Act. It would be sensible to undertake a separate review of the role and operation of Public Interest Reports in the light of the changes in local powers and role brought about by the Act and assess whether changes need to be made.

Question 6. Should the scope of Advisory Notices be expanded beyond unlawful expenditure, or actions likely to cause a loss or deficiency, as defined by the Local Audit and Accountability Act, to include other high-risk concerns?

26. This is not supported. Under the Act, if an Advisory Notice is issued, then it is unlawful for the authority or officer to continue to take or implement the action that the advisory notice refers to while the advisory notice has effect. Expanding the scope of such notices to include other high-risk concerns that are not unlawful would fundamentally change the role of the auditor. Auditors would have the power to prevent local authorities from undertaking lawful expenditure. 27. The identification of high-risk concerns will include the exercise of subjective judgement on the part of the auditor in a different way from identifying unlawful expenditure. The response of a body to the identification of unlawful expenditure should be different to the identification of what may be a subjective opinion on a high-risk concern.

Question 7. Should the LAO own the register of firms qualified to conduct local audits?

28. This makes sense and reinforces the idea of a single point of contact and consistency across the sector.

Question 8. Should the LAO hold the power to require local bodies to make changes to their accounts, so that auditors could apply to the LAO for a change to be directed instead of needing to apply to the courts?

29. If this goes ahead, it is vital that the independence and expertise of the LAO are assured; this should be made clear before the body is set up. The ability to make such changes must be seen to be free from political influence and must also be compatible with the professional duties and responsibilities of the chief financial officer / section 151 officer of the local body. There must be a robust process in place for the LAO to assess such applications and this must include taking into account the views of the audited body including the ability of that body to be able to challenge such a ruling. And clearly the LAO must be set up to have suitable capacity and capability to conduct this role.

Question 9. What are the barriers to progressing accounts reform?

30. Legislation has established a finance system for local government which has its own unique set of rules The published accounts need to reflect both the IFRS rules (so the council can be compared with other entities) and the local government rules (so the accounts are usable by local authority decision makers). It is accepted that local authority accounts need to follow a set of recognised standards but the balance between compliance with International Financial Reporting Standards (IFRS) and the purpose of the accounts to report transparently on the use and stewardship of public resources appears to be wrong.

31. Local authority accounts have unique features that distinguish them from those laid down by international standards. One example is the separation of revenue and capital. This applies nowhere else and requires councils to account differently for each. Adherence to IFRS renders the accounts more complex, and it also means that every change in IFRS needs to be reflected by a further change in the local authority accounting code, which usually creates extra work for hard pressed accounting teams and auditors. There is a strong case for special treatment for local authority accounts to distinguish them from those laid down by international standards in the light of this.

32. The current balance between IFRS rules and the legislative framework underpinning local government means that the Accounting Code of Practice attempts to combine and consolidate two accounting rule books, one professionally based, the other based on legislation. As a result, accounts reform has fallen down, trying to reconcile two unreconcilable reporting requirements and the result, if a change has been made at all, has largely been either an unsatisfactory compromise or an additional layer of complication, rather than clarity and simplification.

33. To be clear, this is not a criticism of the standard of work by local authority accounts preparers who do a good job under very difficult circumstances. The accounts hold good financial information that can allow assessment of important issues such as use of reserves, financial resilience and capital health. However, to get to these, users firstly need access to timely audited statements and secondly, they need to find what they are looking for amongst pages of what may appear to be (particularly to users who are not specialist professionals) relatively meaningless detail.

Question 10. Are there structural or governance barriers to accounts reform that need to be addressed?

34. Until there is a clear recognition that local government accounts need to be significantly different from other sectors’ accounts, the bodies charged with setting the accounting rules are going to find it difficult to progress towards simplification. The need to shoehorn local authority accounts into any new International Financial Reporting Standard (IFRS) or to make a series of one-off exceptions or overrides means that there will always be new pressures that threaten to further complicate the published accounts that will cancel out other efforts at simplification. We have previously argued that adherence to IFRS renders the accounts more complex, and it also means that every change in IFRS needs to be reflected by a further change in the local authority accounting code, which usually creates extra work for hard pressed accounting teams and auditors. An alternative would be for the inclusion of IFRS considerations in the local authority accounting codes to be on an as needed basis. Adherence to the standard would no longer be by default. Instead IFRS would only be applied to the codes when it clearly improves the quality of financial information to aid decision making and makes a significant contribution to consistent reporting through whole of government accounts (WGA).

Question 11. Should any action to reform be prioritised ahead of the establishment of the LAO?

35. The timetable outlined in the annex to the strategy says that the LAO will be legally established by autumn 2026, and “fully resourced and begins contract management with other elements of its oversight” by 2027/28. Structural change in its own will not be enough and reform must not be held up by waiting for the new body to be established.

36. For example, we continue to endorse the long standing call by the Local Government Pension Scheme Advisory Board for the separation of the pension fund annual accounts in England from the administering authorities’ own accounts; this is already the case for the LGPS in Scotland and Wales. The problems with local audit have had an impact on the timely publication of finalised audited pension fund accounts and this has caused problems for the accounts of employers in the Local Government Pension Scheme (LGPS). There are over 18,000 separate employers in the scheme, far more than those that are directly affected by the local audit problems. So long as pension fund accounts remain part of the main local authority accounts, problems unrelated to the issuing of audit opinions on the pension fund itself will continue to impact on pension fund accounts.

Question 12. Are there particular areas of accounts which are disproportionately burdensome for the value added to the accounts?

37. There are several areas that have previously been highlighted that add burdens without adding value to the accounts, particularly relating to valuations of pensions, property, plant and equipment, and other non-investment assets generally.

38. As outlined in our answer to question 10, externally imposed changes to accounting standards that are then reflected with further changes in the local authority accounting code usually create extra work for hard pressed accounting teams and auditors.

Question 13. Do you agree that the current exemption to the usual accounting treatment of local authority infrastructure assets should be extended and if so, when should it expire?

39. The current exemption has been critical in unlocking the log jam that was caused by the issue of valuation of infrastructure assets. It needs to remain in place until a suitable and proportionate long-term solution has been agreed and implemented. It may be that the current exemption will work as a long-term solution. We have commented extensively on possible long-term solutions in our responses to HM Treasury's Thematic Review of non-investment asset valuations and to CIPFA's Survey on Reporting of Infrastructure Assets and also in our submission to the Public Accounts Committee enquiry into Whole of Government Accounts 2021/22.

Question 14a. Should the LAO adopt responsibility for CIPFA’s Code of Practice on Local Authority Accounting?

Question 14b. Are there other options relating to responsibility of CIPFA’s Code of Practice?

40. While the lack of progress over the past years towards simplification of the accounts has been frustrating, it is not clear that moving the responsibility of the Accounting Code would resolve the problem. As well as practical considerations such as sourcing the skills and expertise to manage the Accounting Code, and the impact on the devolved nations, there are also concerns about conflicts of interest given the other potential responsibilities of the LAO, and of the size of the new body, particularly if it undertakes public audit provision.

41. The LAO is not due to be fully up and running until 2027/28; progress on reforming the Accounting Code needs to be well advanced by that point.

Question 15. Should the Accounting Code be freely available if it is not transferred to the LAO?

42. We have long argued that it is a problem that although adherence to a number of financial codes is mandatory, the codes themselves are only available for a fee. Clearly this includes the Accounting Code, but the same also applies to other codes such as the Prudential Code for Capital Finance and the Treasury Management Code. Councils, and others who work with them, and others such as members of the public who wish to scrutinise their local council’s accounts, need to have access to these and similar mandatory codes and it is wrong that they are not freely available.

Question 16. What additional support should be provided to finance teams, audit committees and elected members to develop and strengthen financial governance?

43. MHCLG funds the Local Government Association to deliver a programme of improvement support which includes support to finance teams, audit committees and other elected representatives. Further support to audit committees and elected representatives is subject to negotiations currently underway in relation to the sector support programme for 2025/26. The LGA has worked with CIPFA to develop a local government finance workforce action plan and has shared with MHCLG a proposal for additional funding which would further develop the capability and capacity of the local government finance workforce to enable timely and good quality financial reporting. The LGA looks forward to discussing further with MHCLG how to implement and build on these programmes to support delivery of reforms to the local audit system.

Question 17. How should Key Audit Partner eligibility be extended further, should some categories of local audit be signed off by suitably experienced Responsible Individuals (and if so, which)?

44. It is important that councils have confidence in the skills and experience of their auditors. However, it is also clear that measures need to be taken to address the shortage of suitably skilled and qualified audit staff. If the proposed change to sign off is made, it must be clear that the quality of the audit work will not be diminished. 45. One area that may be suitable for this to be applied is the audit of pension funds and if so, this adds a further argument for the case for the separation of the funds from the administering authority’s accounts.

Question 18. Should the market include an element of public provision?

46. The current reliance on the market has been tested to the limits and it is only through the excellent efforts of PSAA that the last procurement exercise was brought to anything approaching a successful conclusion. Despite this, one or two councils are often without an auditor, and it continues to be hard to make new appointments to some bodies (for a variety of reasons). It would be helpful if there was an arrangement for an “auditor of last resort” who could be appointed to organisations where it has not proved possible to appoint an auditor through the usual process. Such an auditor of last resort would need to be in the public sector.

47. In order for such an auditor of last resort to have the necessary skills, experience and resources, and to keep up to date, they would have to take on a proportion of the local audit market, which would mean that the market would include an element of public provision.

Question 19. If yes, should public provision be a function of the LAO?

48. This needs careful consideration. It may make sense to bring all audit expertise together into one body. However, If the LAO were to take on audit work direct, this would be likely to increase the size of the organisation considerably and so change its balance and focus.

49. There are also potential conflicts of interest such as:

• 49.1. A conflict between the LAO undertaking the procurement exercise and appointing auditors but also providing audit services itself and so “appointing itself” to part of the market. 
• 49.2. The LAO regulating the work of auditors but also employing the auditors that are being regulated itself as well.

50. These issues would need to be resolved before such a function is taken on by the LAO and other options should be identified and evaluated as well.

Question 20. What should the initial aim be in relation to proportion of public and private provision?

51. As outlined above, the aim should be for the public provider to be able to act as an auditor of last resort when it proved impossible to appoint an auditor through the market. In order to be available to do this, the public provider must be able to employ sufficient staff with the necessary up to date skills, knowledge and experience and this means that they will need to have an ongoing audit workload which will be a “proportion” of the market. That proportion should be calculated as the minimum size to enable a viable team to be employed.

Question 21. Should the Secretary of State, in consultation with the LAO and for defined periods, set an envelope within which the body could determine the appropriate proportion of public provision for the market?

52. See answer to question 20 above. This would be one way of achieving a level of public provision that would be viable.

Question 22. Do you think that the Chair of an audit committee should be an independent member?

53. As mentioned in the introduction, the strategy commits to mandating bodies to appoint independent members of audit committees, although there is no consultation question on this.

54. While generally the opinion is that it should be for local authorities to decide if there should be independent membership of committees, if the government is minded to move to such a position there are some concerns which will require attention. There may be some areas or bodies where it is difficult to find and appoint an appropriate independent member with suitable skills and experience and for an appropriate level of remuneration. Councils may therefore be placed into a position of being required to appoint unsuitable candidates to comply with legislation. It would therefore be important that if, in the event that independent membership is mandated, consideration is given to formal guidance on what constitutes “independent”, appropriate skill requirements, renumeration levels and a solution for those authorities who are unable to recruit suitable local capacity, potentially through a national pool.

55. We do not agree that councils should be mandated to have an independent chair of their audit committee. Councils should be free to make the best appointment for the role. Best practice highlights that in well performing councils the audit committee and chair of the audit committee play a strong role in corporate governance. Adopting a mandated independent chair could carry a risk that corporate governance becomes separated from member responsibility and accountability. Audit committees also play a wider role in good council governance than the formal audit process, therefore given this and other circumstances, depending on the local terms of reference of the audit committee, it would be inappropriate for the chair to be an independent member.

Question 23. Do you have views on the need for a local public accounts committees or similar model, to be introduced in combined authority areas across England?

Question 24. Would such a model generate more oversight of spending public money locally?

Question 25. How would the creation of such a model impact the local audit system and the work of local auditor?

56. It is not clear what the role and purpose of a local public accounts committee is proposed to be, and what is expected to be achieved by it. If the idea is to create a local equivalent of the House of Commons Public Accounts Committee (PAC), it should be borne in mind that the PAC has access to the support and resources of the National Audit Office and there is no similar local equivalent resource to this.

57. It should also be considered that local auditors have a responsibility to work on the accounts of the body that they are appointed to audit. They do not have a remit to work more widely and across other bodies and, even if this could be resourced, this could signal a fundamental change (presumably requiring legislation) in the work being done and the role of the auditor. As previously stated, it is not clear what this would seek to achieve.

58. The current priority has to be to concentrate resources on the problems with local audit that need to be solved now; any move to a local public accounts committee model must not result in a delay in restoring timely audits for local bodies and restoring confidence in the local audit system.

59. An alternative role for a local public accounts committee would be to add transparency to central government spend locally and enable scrutiny across different central government departments and how they could be co-ordinated better with local bodies in an area. A local public accounts committee (or a regional select committee?) may add value if it means that locally elected leaders can hold government departments accountable for the quality of services they deliver locally. It may be worth experimenting with new models of accountability along these lines. However, any such move should be based on a local decision and not mandated from above and would be dependent on transparency relating to central government spend which does not currently exist.

Question 26. Do you agree that the MLA (Major Local Audit) threshold should be increased?

60. Yes, and it is important that inflation or a similar factor is introduced to be applied annually to the threshold so that more bodies do not become subject to MLA purely because of inflation or because a review of the threshold has not been carried out for several years.

Question 27. Do you agree that some local bodies should be declared exempt from the regulatory focus of an MLA? For example, should Integrated Care Boards be exempt?

61. We do not have a view on this.

Question 28. Do you agree that smaller authorities’ thresholds should be increased?

Question 29. Do you agree that the lower audit threshold of £25,000 should be increased broadly in line with inflation?

62. Yes, and as with the MLA it is important that an inflation or similar factor is introduced to be applied annually to the threshold. This is so that more bodies do not cease to count as smaller authorities and so face a significant change in audit regime (and, indeed, auditor) purely because of inflation, or because a review of the threshold has not been carried out for several years.

63. Further consideration needs to be given to the impact of Parish and Town Councils expanding their responsibilities and financial scale with a bigger portfolio of assets and liabilities on their balance sheets. When larger Parish and Town Councils exceed the smaller authorities’ threshold they will need a different type of audit. This will impact on overall local audit capacity and that needs to be taken account of in the overall capacity assessment of the local audit system. Consideration should also be given to how this will impact on overall governance and assurance of such bodies and whether existing models will still be appropriate.

Question 31. What additional support, guidance or advice do local bodies and/or auditors need for future statutory deadlines (including backstop dates) for the publication of audited accounts?

64. We acknowledge that there has been extensive communication by system partners to explain the reset process, the meaning of the different opinions and the impact on local bodies. This needs to be continually reinforced for each backstop date. We have had some feedback from some of our member councils that some of the communication has been quite technical. In particular, some of the accepted technical terminology (including widely used terms like “modified opinions” and “disclaimed opinions”) are unlikely to be understood by members of the public. It would be helpful if further consideration could be given to how the situation can be better explained to the general public.

65. As noted in our general comments, above, the fees to be paid for the reset period and the accounts affected by the backstops need urgent consideration, including how they are funded. It is crucial that fees are seen to be fair to both auditors and to audit bodies and that there is consistency of treatment between bodies. There needs to be clear direction to auditors on how much work they need to do before issuing a disclaimed opinion due to lack of time and capacity and what it is acceptable to claim as a fee.

Question 32. Do you think that financial reporting and/or auditing requirements should be amended for a limited period after the backlog has been cleared and as assurance is being rebuilt, to ensure workload and cost are proportionate?

66. Where suitable amendments to financial reporting and auditing requirements are identified, these should be introduced on a permanent basis, as outlined in our comments on financial reporting (above) and in answers to questions 9 – 15 above. It is not clear what temporary changes would achieve over permanent changes.

Bevis Ingram, Senior Adviser Finance

Email: [email protected]

Local audit reform: a strategy for overhauling the local audit system in England