Overview of countries’ supreme audit institutions with surcharging powers

Published on 9 October 2017 as a TI Helpdesk answer
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.

Author(s): Krista Lee-Jones, Transparency International,

Reviewed by: Roberto Martinez B. Kukutschka, Transparency International tihelpdesk@transparency.org
Publication date: 9 October 2017
Number: 0

Download full answer

Country / Territory - Brazil   |   France   |   Gambia   |   Ghana   |   Japan   |   Latvia   |   Malta   |   New Zealand   |   Sri Lanka   |   Zimbabwe   
Region - Global   
Language(s) - English   
Topic - Accountability   
Tags - Ghana   |   Supreme Audit Institutions (SAIs)   |   Brazil   |   France   |   Zimbabwe   |   Sri Lanka   |   Audit   |   Malta   |   surcharging   |   The Gambia   |   Latvia   |   New Zealand   |   Japan   

Contact the Anti-Corruption Helpdesk

If you work for one of our supporting partner organisations, submit your query to the Helpdesk:

More Helpdesk answers


Influencing governments on anti-corruption using non-aid means

What are the methods of influencing governments in anti-corruption strategies using non-aid means (e.g. diplomatic, reputational, economic)? Where ...

See the answer


Overview of corruption and anti-corruption in Chad

Can you provide an overview of corruption and anti-corruption in Chad? We would be particularly interested to have information on the health sector, ...

See the answer