Appointing support for PFMA completeness reviews and control remediation is an advisory commissioning workflow defining scope for population reviews and control remediation.
When a public institution governed by the Public Finance Management Act 1 of 1999 (PFMA) engages external technical support to evaluate expenditure completeness, establishing a precise commissioning brief is essential. Accounting officers of departments and accounting authorities of public entities listed in Schedules 2 and 3 to the PFMA hold statutory obligations under Sections 38 and 51 to prevent unauthorised expenditure where applicable, and irregular and fruitless and wasteful expenditure. Advisory engagements provide technical diagnostic methodologies rather than statutory legal determinations.
National Treasury Instruction No. 4 of 2022/2023 sets the national statutory compliance framework for managing non-compliant expenditure, including 30-day supplier invoice payment tracking. In contrast, Western Cape Treasury Circular 7 of 2026 (issued on 16 April 2026) provides provincial guidance for Western Cape institutions on quarterly reporting schedules, serving as a provincial circular rather than universal national procedure. Distinguishing national statutory instructions from provincial guidance ensures commissioning briefs remain legally aligned.
Defining the population review scope and system boundaries
safeguard assets and manage revenue, expenditure and liabilities of the public entity
— National Treasury Instruction No. 4 of 2022/2023, paragraph 2.4, p. 2
A commissioning brief for completeness support must define the exact transaction populations and system boundaries under review. Completeness reviews assess whether all expenditure transactions across financial years have been identified, categorised, and recorded in official registers. The scope should encompass general ledger transaction files, payment sub-ledgers, supply chain databases, and contract variation records.
Advisers require read-only system access to extract transaction data and evaluate sub-ledger completeness. Under Section 51(1)(c) of the PFMA, accounting authorities must "safeguard assets and manage revenue, expenditure and liabilities of the public entity" (National Treasury Instruction No. 4 of 2022/2023, page 2 of 4). Establishing read-only access boundaries protects live financial records while allowing advisers to perform empirical population matching across financial data sets.
To structure population testing effectively, the commissioning brief should mandate specific diagnostic steps across financial systems:
- Reconciling general ledger expenditure line items against payment batch sub-ledgers.
- Cross-referencing supply chain contract registers with actual payment voucher records.
- Matching historical non-compliant expenditure registers against current general ledger files.
- Verifying supplier invoice receipt logs against the 30-day payment tracking register.
- Indexing primary source documentation bundles to support transaction completeness.
Case register to ledger reconciliation and sample limitations
A core objective of completeness support is reconciling the institution's case register for non-compliant expenditure against general ledger balances. The Western Cape circular requires separate registers for historical unauthorised expenditure where applicable, and irregular and fruitless and wasteful expenditure. Advisers perform automated and manual data matching to identify unrecorded expenditure cases and eliminate duplicate register entries.
The brief must distinguish sample-based testing from a 100 per cent census review. While advisers deploy statistical and risk-based sampling to test transaction populations, sample testing inherently contains sample limitations. Identifying an exception within a sample does not automatically establish systemic loss or criminal misconduct. Furthermore, an advisory completeness review provides diagnostic analysis rather than an audit assurance opinion or legal investigation.
When evaluating transaction samples, advisers encounter unresolved cases where primary evidence is incomplete. The brief should specify that unresolved cases are logged in a diagnostic exception file for management investigation rather than subjected to speculative accounting entries. Preserving unresolved case status ensures that data gaps are resolved through systematic evidence retrieval rather than arbitrary ledger write-offs.
Retaining statutory authority and decision ownership
Commissioning external support for completeness reviews does not transfer statutory accountability away from institutional leadership. Under the PFMA, accounting officers and accounting authorities must identify the competent authority for each decision on condonation, loss recovery or write-off; the relevant treasury or other authorised body may hold the power. External advisers provide technical analysis and control recommendations, but cannot condone non-compliance or make executive determinations.
Similarly, technical completeness reviews must remain separate from formal forensic investigations or criminal proceedings. External advisers evaluate control performance and record completeness; they do not establish criminal guilt, make legal findings, or replace statutory law enforcement functions. Maintaining clear functional boundaries ensures that advisory reviews support administrative governance without exceeding legal mandates.
Remediation design, retesting and the commissioning matrix
Following completeness diagnostics, advisers must formulate root-cause control remediation designs to prevent recurring non-compliance. Remediation workflows re-engineer daily processing controls, update delegation frameworks, and establish supervisory review protocols. The commissioning brief should require advisers to retest modified controls within a pilot environment to verify operating effectiveness before institutional rollout.
The table below presents an advisory commissioning matrix detailing review workstreams, key technical deliverables, acceptance evidence requirements, and retained owner decision rights.
| Review workstream | Key technical deliverable | Acceptance evidence requirement | Retained owner decision right |
|---|---|---|---|
| Population Scoping | Population review report & system boundary map | Reconciled general ledger & sub-ledger extract file | Accounting Officer approval of review scope |
| Register Reconciliation | Case-register-to-ledger reconciliation matrix | Verified quarterly UIFWE register alignment file | Accounting Authority sign-off on case register |
| Control Remediation | Root-cause control fix & retest protocol | Documented SOPs & retest evaluation log | Line manager approval of modified controls |
| Unresolved Cases | Diagnostic exception log & retrieval plan | Indexed missing document tracking register | Executive decision on case investigation |
What good looks like
A well-commissioned PFMA completeness review establishes a transparent diagnostic framework that strengthens institutional internal controls. By defining clear population boundaries, maintaining read-only access, reconciling case registers against ledgers, designing root-cause control fixes, and preserving retained statutory authority, accounting officers and accounting authorities protect public resources, enhance financial reporting credibility, and provide evidence for management to assess the remediation effort.
Sources
- National Treasury Instruction No. 4 of 2022/2023, pp. 1–2 — National Treasury
- Western Cape Treasury Circular 7 of 2026, sections 3–5 and Appendices A–C — Western Cape
Frequently Asked Questions
What population boundaries should a PFMA completeness review define?
Identify the institutions, systems, transaction types and financial periods covered. Reconcile source extracts to control totals and record exclusions, missing data and whether testing covers a sample or the complete defined population.
What is the distinction between a completeness review and an assurance audit opinion?
A completeness review is an advisory diagnostic workflow that evaluates transaction populations and identifies data gaps to support internal management reviews . An assurance engagement has its own agreed or statutory criteria, responsibilities and reporting basis; the advisory review should not imply it supplies such an opinion .
Can an external adviser condone irregular expenditure or write off financial losses?
No, external advisers function strictly in an advisory capacity and possess no statutory authority . Statutory powers to condone non-compliance, recover losses, or write off expenditure must be exercised by the competent authority under the applicable law and lawful delegations .
How should an institution manage unresolved cases identified during population testing?
Unresolved cases where primary documentation is missing should be logged in a diagnostic exception register for targeted evidence retrieval . Institutions should avoid making speculative accounting entries or arbitrary write-offs until evidence retrieval or formal investigation is concluded .
Why must control remediation include a retesting phase before full rollout?
Retesting provides evidence about the design and operation of modified controls over the tested period and population . Retesting identifies operational friction early, and can reveal whether further changes are needed before wider use .
Read the wider context in expenditure accountability and control.