Transparency International

This Anti-Corruption Helpdesk brief was produced in response to a query from one of Transparency International’s national chapters. The Anti-Corruption Helpdesk is operated by Transparency International and funded by the European Union


I am researching the surcharging power (the power to require a person to pay back monies lost to state bodies due to corruption, fraud or misappropriation) of auditor generals/supreme audit institutions. Which countries have this power and what are the legal provisions governing it?


  1. The role of supreme audit institutions
  2. Westminster model
  3. Board model
  4. Court of auditors
  5. References


Many supreme audit institutions (SAIs) rely on external accountability mechanisms to enforce the outcomes of their audit findings. However, some SAIs have the power to disallow public expenditures where they are deemed to be unauthorised or unlawful due to negligence or misconduct, and require such amounts to be refunded by those responsible. This is known as the power of surcharge. This paper provides a brief overview of 10 jurisdictions with some form of surcharging power granted to its SAI.


Krista Lee-Jones,


Roberto Martinez B. Kukutschka, Transparency International, [email protected]


Roberto Martinez B. Kukutschka, Transparency International
[email protected]




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