• Foreword
• Author's Acknowledgement
• Introduction
• Overview

Foreword

As Chairman of the Asian Organisation of Supreme Audit Institutions (ASOSAI) and on behalf of the Board of Governors I would like to express my appreciation of the work done on this publication "Accountability and Control of Public Enterprises". It has taken over two years to complete this research program which I believe has been a rather difficult but rewarding task for the authors. The Governing Board of ASOSAI which has been very sensitive to the training needs of member countries and acknowledging the paucity of information available on public enterprises in the ASOSAI region on a comparative basis commissioned this research study to be undertaken.

I am confident that this publication will not only be particularly useful to practitioners in the public sector, but of great interest to researchers and academics. It will no doubt be of considerable value in the numerous training courses and seminars on public enterprises conducted by ASOSAI and by our colleagues in INTOSAI and other affiliated regional organisations. I am also confident that this publication will be a source document for legislators and administrators who hold public accountability sacred.

I would like to thank all those particular country SAIs who responded to the questionnaires requesting information for this publication and the co-operation they have extended to the authors. Information pertaining to some countries is not complete and could not be included in this edition but it is hoped they may be included in an ensuing publication.

This publication would not have been possible but for the efforts of the authors, Mr D.J. Hill Deputy Auditor-General of Australia, Mr C.P. Mittal, Deputy Comptroller and Auditor-General of India and Mr L.T. Kulasingham, Deputy Auditor-General of Malaysia who were commissioned to undertake this assignment. I must also express my gratitude to Mr S. Sethuraman retired Deputy Comptroller and Auditor-General of India who was originally associated with this research project prior to his retirement in November 1986. My grateful thanks also go to the Auditors-General of Australia, India and Malaysia for making available their Deputies in addition to their normal duties for this project and meeting the associated costs involved.

On behalf of ASOSAI I would like to thank Mr D.J. Hardman, Associate Professor, School of Accounting, University of Technology, Sydney, who acted as adviser and technical consultant to the authors.

It is not possible for me to mention by name all of the others who assisted the authors in one way or another.

In conclusion I would like to say that I am proud that ASOSAI has been able to make such a significant contribution to the ever expanding store of knowledge in regard to public enterprises generally and to public accountability in particular.

Keiichi Tsuji
President of the Board of Audit of Japan and Chairman of ASOSAI (1985 -1988)

April 1988

This book originally started as a monograph but with the wealth of information that came to hand, the authors saw the opportunity of developing the source material into a more complete text.

Fifteen chapters of this book were finalised during the term of my predecessor Mr. Keiichi Tsuji and were to be published as Volume 1. However, the Governing Board of ASOSAI in June 1988 decided to commission the authors to continue their research to cover other Asian countries not included in the earlier study. The authors completed their assignment in December 1988 and decided to incorporate the additional country profiles with the earlier research in a single edition. The resulting book provides a remarkable scenario of public enterprises in the Asian region from a different perspective to most books written on this subject.

I would like to thank all those associated with this project and particularly those heads of SAIs who responded freely to requests by the authors for information in compiling the additional chapters to the text.

M. Jusuf
Chairman Supreme Audit Board of Indonesia
and Chairman of ASOSAI (1988 -1991)

April 1989

AUTHORS' ACKNOWLEDGEMENT

The authors express their personal appreciation of the valuable assistance given them in their research by the heads of Supreme Audit Institutions who are constituent members of ASOSAI. Without their co-operation the extensive work involved in compiling background information and preparing the text for publication would have been well nigh impossible.

We would also like to place on record our appreciation of the assistance rendered to each of us by members of our respective staffs. Mr D.J. Hardman M.Ec (Syd), B.Com (Qld) AAUQ, FASA, CPA, Associate Professor, School of Accounting, University of Technology, Sydney also rendered valuable advice and guidance in bringing this research study to completion and in reviewing the text for publication.

D.J. Hill AM B.Comm (Melb) FASA CPA
Deputy Auditor-General of Australia

C.P. Mittal MA (Delhi) IAAS
Deputy Comptroller and Auditor-General of India

L.T. Kulasingham BA (Hons) (Adel.), JSM
Deputy Auditor-General of Malaysia

INTRODUCTION

The Asian Organisation of Supreme Audit Institutions (ASOSAI), established in 1978, is a regional grouping of government audit institutions. It is affiliated to the International Organisation of Supreme Audit Institutions (INTO-SAI) and has a membership of 23 countries. It is run by a Governing Board of 7 members elected every 3 years at the Assembly.

The objectives of ASOSAI include the following:

1.    To promote understanding and cooperation among member-institutions through exchange of ideas and experiences in the field of Public Audit.

2.    To provide facilities for training and continuing education for government auditors with a view to improving the quality of their performance.

3.    To serve as a centre of information and as a regional link with organisations and institutions in other parts of the world in the field of Public Audit.

4.    To promote closer collaboration and brotherhood among auditors in the service of the government of the respective member-institutions and among regional groups.

The functions of ASOSAI are:

1.    To organise conferences and seminars for the exchange of ideas and experiences in the field of Public Audit.

2.    To encourage and to promote research and to undertake publication of research papers and professional articles in auditing and related fields.

In the furtherance of its objectives and functions ASOSAI has held four Assemblies, three International Seminars and 38 training courses since 1979. It also produces a Journal called the 'Asian Journal of Government Audit' which contains professional articles in auditing and related fields and is issued annually.

The audit of public enterprises was a much discussed topic at both the International Seminars and several training courses. Supreme Audit Institutions (SAIs) have stressed the need for greater audit attention in this area as public enterprises have become important instruments in carrying out government policies and programmes. Their financial impact on the economy and growth in importance and numbers has materially affected the Gross Domestic Product in most countries. They range from departmental undertakings to companies and their roles extend from the traditional public utilities to commercial and financial institutions.

The Governing Board of ASOSAI noted the concerns expressed by SAIs over the complexity of the audit of public enterprises, accountability issues, and questions of government control over them. In 1985, the Board recommended to the Assembly that the Secretary General arrange for a research program to be undertaken on this subject for publication. The purpose of the publication was to develop background material on public enterprises in the various ASOSAI countries and auditing practices relating to them which would provide practitioners, academics and other interested parties with useful information for future training, research and other purposes. The Deputy Auditors-General of Australia, India and Malaysia were commissioned to carry out this project.

Work commenced in March 1986 with the gathering of material on the subject that was already available in ASOSAI and from other sources. Questionnaires were developed covering a wide range of issues which were considered of primary concern. Individual questionnaires were distributed to all member SAIs for their responses. Some difficulties were encountered in the replies because of language problems as it was felt that some of the clarity of the responses may have been lost in translation. Some caution was therefore exercised in documenting information which was not entirely clear. Situations, perceptions and laws differ in each country and information was reported without comment. In no way is this publication intended to be critical of systems or practices in individual countries. The effectiveness of the accountability process is relative to the political and government institutions in the countries concerned.

Another problem that was encountered was the paucity of material and statistics available. The use of questionnaires meant that the answers to questions asked were not always adequate for the purposes resulting in unavoidable gaps in the information required for worthwhile conclusions to be reached.

The definitions on public enterprises given in the "Tokyo Declaration of Guidelines on Public Accountability" issued at the Third ASOSAI Assembly and Second International seminar held in Tokyo, Japan in May 1985 were used as the basis for the present publication. These 'Guidelines' and "The General Statement on the Performance Audit, Audit of Public Enterprises and Audit Quality" of the Twelfth International Congress of Supreme Audit Institutions held in Sydney in April 1986 are appended as important guideposts.

It would not have been possible to complete this project without the understanding and co-operation of member SAIs of ASOSAI who have been most helpful in providing information.

CHAPTER 1
OVERVIEW

Public enterprises in ASOSAI member and other regional countries have become important instruments in nation-building to carry out entrepreneurial functions associated with economic and social development. To some extent, public enterprises have assumed a part role of the State in accelerating economic development and maintaining political stability where sole dependence upon ministerial departments to implement government programmes have proved to be ineffective.

The growth in number of these bodies has increased materially and this is reflected in their contribution to the Gross Domestic Product (GDP) of a number of countries. For example in Malaysia, at federal and state levels, prior to 1955 there were 11 such enterprises which now number over 1345. In the Philippines, the number has increased from 65 to 303 in the last 15 years. India at central and state levels has about 1701 enterprises and they play a dominant and pace setting role in the national economy. Israel has 300 public commercial enterprises employing about 5% of the country's workforce. Their exports contribute about 15% of Israel's total exports and in monetary terms their imports equalled about 20% of GDP. In Papua New Guinea, the workforce of 22,000 in public enterprises is only slightly less than half of the total employment in the public service. Their capital and operating expenses are the equivalent of 64% of the central governments direct actual expenditure. In Sri Lanka, the energy sector is solely in the hands of public enterprises and about 42% of the agriculture and plantations are similarly conducted, contributing about 35% to GDP. In China there are approximately 800,000 public enterprises employing about 60 million workers. Profits and taxes from these enterprises constitute about 80% of the national revenues. These examples are by no means isolated as similar trends are discernible in many countries in the Asian region and elsewhere. An indication of the approximate number of public enterprises in the various countries is represented in Table 1.

Public enterprises are financed in a variety of ways. Generally, the initial investment capital is provided from the government as a launching grant. Thereafter, the enterprise may receive annual grants for operating and development expenditure depending on the nature of the enterprise and its activities. Statutory corporations and government owned companies are generally expected to generate their own income and operate profitably, are allowed to raise loans on the domestic and foreign markets and in a number of cases offer equity participation to government and private sector agencies. Characteristically more companies are created to undertake commercial or semi-commercial activities of the State as it is generally assumed that these provide greater operational flexibility than is normally possible through the traditional departmental form.

CONCEPTS OF PUBLIC ENTERPRISES IN ASOSAI MEMBER COUNTRIES

In the Tokyo Declaration of Guidelines on Public Accountability (1985) the following public enterprises were recognised:

(a)    departmental undertakings,

(b)    statutory corporations or autonomous bodies established by or under legislation,

(c)    autonomous bodies set up by government resolution or order, and

(d)    companies, nationalised or established under company law, where government has a controlling interest.

Departmental Undertakings

These are entities which organisationally are part of ministerial departments but operate in a commercial manner. They come within ministerial jurisdiction, receive direct appropriations for capital and operational purposes from the legislature, keep their accounts on an accrual basis and are staffed and managed by civil servants. General examples are railways, postal services, government printers, water boards, mints and such like bodies which are service rather than profit motivated. In some ASOSAI countries these bodies may even be established instead as statutory corporations depending on the amount of flexibility that is desired in carrying out their tasks. In general this form of public enterprise is not a legal entity in its own right.

Statutory Corporations, Bodies or Authorities

Statutory bodies are organisations which are established by or under legislation with their structure, powers and functions specifically prescribed. They are separate legal entities and can sue and be sued. They have far more autonomy than departmental undertakings and can in many cases invest, raise capital, borrow and lend within the terms of their statutes. Harbour boards, airlines, telecommunications, energy and banks are general examples. In this study, some countries have made a distinction between bodies established by separate laws which are labelled statutory corporations or statutory authorities and those established under omnibus legislation which are referred to as autonomous bodies. Whilst there may be some differences in autonomy and the powers they wield, these autonomous bodies should not be confused with the autonomous bodies established by government resolutions or orders.

Autonomous bodies established by Government Resolution or Order

These types of bodies are rare. They may be established by government order or Royal Decree for a public purpose. Examples of such entities are found in Thailand such as the National Housing Authority and the Bangkok Mass Transit Authority. In India they take the form of registered societies (under the Societies Registration Act) which receive government financial backing. Their powers and functions are as specified in the resolution or order establishing them.

Government Companies

These are bodies established under company law. They differ from other companies in as much as the State and/or public corporations hold the majority or all of their shares. Where equity in these companies is held jointly by public and private interests, they are generally referred to as 'mixed enterprises' or 'joint venture' companies.

RATIONALE OF PUBLIC ENTERPRISES

There are two qualitative dimensions to a public enterprise viz the 'public' and the 'enterprise' aspects. The 'public' aspect of the two dimensional concept envisages that an entity must serve a public purpose such as promoting industrial expansion, ensuring balanced regional development, and/or generally raising living standards. The 'enterprise' aspect connotes that the entity must function as a commercial organisation trying to achieve the normal commercial objectives expected of such a body. The weightage given to either dimension will determine whether the enterprise will operate in the nature of a nonprofit service organisation or a profit-orientated company.

In the ASOSAI Second Assembly and First International Seminar held in Seoul, Korea (1982) a paper presented on "State Audit Systems for Economic Development" outlined the phases of economic development which, theoretically at least, the various ASOSAI countries had reached or would experience. It referred to a first stage of 'maintenance' where production functions were limited and based on less advanced science and technology. In the second stage of 'mobilisation' the government mobilises society towards a 'take off' providing incentives for industrial expansion by providing access to raw materials, education and protective trade policies so that there is a commitment towards modernisation and industrial development. The third stage is one of 'guidance' of the economy in which modern technology and long range planning is prevalent with rapid urbanisation and changing class structures. The last stage is one of 'co-ordination' when the economy reaches the mature stage of a welfare oriented industrial society. At this stage the government tries to adopt a regulatory role co-ordinating the various aspects of the private sector in order to achieve the most equitable distribution of wealth and services. Member countries of ASOSAI are at various stages of development and generally fall within the stages of development described above. This is reflected in the types of enterprises that are established in each country; the diverse rationale postulated for establishing them, and the wide range of their activities. Arguably, when countries reach the 'mature' stage the governments concerned, depending on their political philosophies, begin to think in terms of privatising their enterprises, partly because they have become a burden on public coffers and/or because such enterprises are capable of functioning as private sector entities and still serve the public interests.

Public enterprises in ASOSAI countries grew out of necessity or were developed for political, economic, social and historical reasons. Governments had to fuel the engines of growth in the economy and had to provide the vehicles for achieving this purpose. There was a need to promote self-reliance in strategic sectors of the economy, provide infrastructural facilities for promoting a balanced and diversified economic structure in development, reduce racial and regional disparities, increase employment, bridge the gap in the investment participation as between the public and private sectors in the country and generate surpluses for reinvestment; also to enforce State control on trade and industry by ensuring an equitable distribution of goods and services. There was, in addition, a desire for creating prestigious or research-oriented institutions for discharging specialised functions. Further, it was also recognised that there was a need to bring outside expertise into management of the activity in ways which were not otherwise practicable in a departmental setting. It was also incumbent on governments to venture into and fill the void in those areas where the private sector was not prepared to invest. Governments also felt it necessary to intervene in those areas which they considered were being run inefficiently by the private sector. In some other cases entities which were poorly managed and required rehabilitation or the nature of the undertakings involved the public interest, 'nationalisation' or government take-over was warranted so as to prevent exploitation by the private sector. There were also certain types of enterprises, such as defence-oriented industries, which could not be left to the private sector for reasons of national security. Tied in with all these reasons was the desire to create infrastructural facilities to encourage economic growth by attracting domestic and foreign capital. In some situations there was a tendency to establish, 'mixed enterprises' or joint ventures with the private sector. There were additional 'spin offs' in this type of arrangement in that it facilitated transfer of technology, expertise and skills from the private sector to the public sector.

Most public enterprises in the ASOSAI region can be further classified according to sectoral or functional types including: public utilities, transport and communications, food and agriculture, development finance institutions, industrial, trading, manufacturing, regional development, oil, coal and gas and heavy engineering. In the various countries they may be grouped differently depending on how ministerial functions which determine ministerial responsibility, are allocated for particular enterprises. The number of enterprises within each sector may indicate the importance and priority each country places on these bodies for carrying out its policies, development plans and objectives. In Korea for example, there are more development finance institutions ie banks, insurance companies and the stock exchange, than any other types of public enterprise. In India on the other hand, commercial, manufacturing and industrial types predominate. In Malaysia the regional development and agricultural sectors are prominent reflecting the importance given to agricultural based industries and a commitment to improve the welfare of the rural population.

The range of activities is marked, touching on all aspects of the economy from the provision of basic amenities such as water and electricity, to tourist promotion, the management of ports, railways and airlines, to atomic energy. Public enterprises such as the manufacturing and industrial types are actively involved in production whilst other agencies such as development finance institutions, like banks and insurance companies, perform supportive functions providing technical and financial assistance to promote the development of both public and private enterprises. Many statutory corporations and companies have also established subsidiary companies to support their activities. For example, a housing authority may set up a construction company, a credit corporation and a cement factory help achieve its objectives. This sort of development has led to the creation of numerous subsidiary companies, many of which may provide similar services and perform overlapping functions. This proliferation of subsidiaries has resulted in a dilution of available expertise in those developing countries where staff are drawn from the public service. Of greater importance and concern however, is the potential for the weakening of controls exercised by the legislature and the executive over these bodies to the detriment of public accountability.

LEGISLATURAL AND GOVERNMENTAL CONTROLS

Public enterprises in the ASOSAI countries, other than the departmental form, generally enjoy considerable autonomy but they nevertheless are subject to legislatural and governmental controls because in many cases their funds are derived from the State. They are, then, publicly accountable. The nature and extent of controls vary between countries depending on the form and type of the enterprises and in some cases the extent of the investment. These controls are exercised directly by supervision and inspection, through committees of the legislature and institutions such as the SAI, or indirectly through government surveillance of performance. Generally, government controls over their policies, management and operations can be represented diagrammatically as follows:

The main instruments of legislatural controls in many of the ASOSAI countries are the budget debates, questions in the legislature, the annual accounts and reports of the enterprises tabled in the legislature, reports by the SAIs and examination by legislatural committees. The power of the government to exercise control stems primarily from the enabling statutes. Governments also supervise and control these bodies by ensuring that they comply with laws, rules and regulations issued by them and enforced by the central agencies such as the Treasury and public service personnel authorities. Controls are also exercised through pricing, lending and borrowing policies of the government. It is normal for most governments to appoint the boards of directors and also the chief executives. Apart from these organisational controls, procedural controls also exist. Systems for reporting on a regular basis and periodical review meetings between the Minister concerned and the managements of public enterprises are common. The SAIs discharge a different responsibility by sustaining public accountability through their annual and special reports.

Governments are conscious of maintaining a proper balance between autonomy and control. Excessive controls could be counter productive to the very purpose of establishing an enterprise whilst on the other hand, too much autonomy could put public funds at risk in the event of poor management. Although comprehensive legislatural and governmental controls exist, in practice some SAIs have found them to be ineffective. There is often a lack of performance criteria and properly developed monitoring and evaluation systems, compounded by a shortage of adequately trained staff in the enterprise to ensure compliance with prescribed procedures. This perceived weakness could put at risk public accountability and thus increase the burden of public enterprises on government budgets.

PUBLIC ACCOUNTABILITY AND STATE AUDITING

The Tokyo Declaration of Guidelines on Public Accountability defines public accountability as "the obligations of persons/authorities entrusted with public resources to report on the management of such resources and be answerable for the fiscal, managerial and programme responsibilities that are conferred." The external audit through the SAI is the most important and vital link in the process for determining such accountability.

The need for modern accounting systems and auditing practices in government has probably never been greater or more apparent than in recent times. Governments through their agencies and instrumentalities operate some of the largest and most complex business and service entities as evidenced amongst member countries. Many of these entities do not operate in a complete commercial environment and the traditional commercial bottom line 'profit and loss measures' are not always relevant as a guide to efficiency. Their performance cannot entirely be judged against the back-drop of financial results using criteria of financial viability such as net profitability or the rate of return on capital employed.

The role of the State audit system has to be continuously adjusted to the ever expanding tasks required of it as the country's economy moves along to higher stages of development. In response to these changes a number of the member countries has shifted to comprehensive audits covering considerations of economy, and efficiency, or, as has been described in the General Statement of Twelfth INCOSAI, performance audits.

Nonetheless, in a number of ASOSAI member countries, the main thrust of audit is still on financial and compliance audit. In so far as economy and efficiency audits are concerned these vary over a wide spectrum, in terms of scope, extent, methods and areas of audit concern. Thus at one end of the scale extensive performance audits are carried out by countries such as the Republic of Korea, Japan, Israel, Australia and India and at the other extreme there are some member countries where the SAIs have not yet embarked on performance audits to any great extent.

Systems evaluation is commonly conducted and wherever possible transactions testing on a sampling basis is carried out. The extent of testing varies depending upon a detailed assessment of the system of internal controls.

As regards performance auditing, the approach and methods employed vary amongst the different SAIs depending on the expertise, availability of qualified staff and the state of financial and other records of the public enterprises audited and their activities.

An important function of SAIs is not only to attest the financial statements of public enterprises but also to assist the government and the enterprise management to improve financial and administrative efficiency and performance. In this context, the emphasis throughout the audit process is to serve as instruments of both accountability and improved public administration. Audit findings and reports thus not only express opinions on the financial statements but also include comments on the propriety of transactions, management decisions, waste and extravagance. Thus, not only are the results and operations of public enterprises evaluated but suggestions are also given for corrective actions and improvements.

However, SAIs experience difficulty in evaluating the performance of public enterprises where the objectives of the enterprises are not clearly specified, or where multiple objectives are involved and there is no priority ranking to determine which objective takes precedence. It has been the experience of SAIs that, more often than not, the social and economic objectives are not expressed in such detail as to serve as performance indicators, nor are the standards of performance specified by the authorities approving the socio-economic development programmes.

To carry out the performance audit effectively, the SAI has to remain abreast of developments in different fields of human knowledge and develop the vision and the intuitive flair for a creative evaluation of performance against the overall framework of national objectives and policy. This requires constant thought and conscious efforts to improve the technical skills of the audit personnel at all levels. Many member countries have expressed that lack of experienced and multidisciplined staff is a major constraint in development of this important area of audit.

Table 2 summarises the mandate for audit of public enterprises by the SAIs. Audit arrangements in a number of member countries include provision for three levels of audit viz: internal audit, external audit carried out by commercial accountants appointed by the government on the advice of the SAI or by the SAI direct, and finally by the SAI itself. In discharging its responsibility to the legislature, the SAI reviews and comments on the performance of both internal auditors and the commercial auditor.

SAI Reports to the Legislature

The general practice is for the SAI to present both annual and special reports to the legislature in the interests of public accountability. It has been noted, however, that in some countries this is not the procedure in respect of government- owned companies not subject to SAI audit either as appointed external auditor or in the exercise of powers to review the audit carried out by the commercial auditor. This is a perceived weakness in the accountability process.

The process adopted by most legislatures is for SAI reports to be reviewed by a committee such as a Public Accounts Committee. Depending on practices followed as between the government and the legislature which vary as between countries, action is taken to correct deficiencies and weaknesses raised by the SAI.

Table 1.    Form of Public Enterprises

Countries	Departmental Undertaking	Public Corporation	Companies (Government / corporation Owned)	Autonomous	TOTAL
1. Australia	20	59	77	Nil	156#
2. China	-	-	-	-	800,000
3. Cyprus	Nil	25	6	Nil	31
4. Hong Kong	6	10	-	-	16
5. India	298	84	1079	240	1701
6. Indonesia	2	27	157	Nil	186 34*
7. Israel	n/a	n/a	n/a	Nil	300
8. Japan	17	81	13	96	207
9. Jordan	n/a	41	6	-	n/a
10. Korea	5	25	70	Nil	100
11. Kuwait	n/a	23	36	-	n.a
12. Malaysia	18	480	847+	Nil	1345
13. Nepal	-	25	32	-	57
14. New Zealand	14	7	18	26	65
15. Pakistan	41	124	120	12	297
16. Papua New Guinea	Nil	44	37	-	81
17. Saudi arabia	Nil	30	65	Nil	95
18. Singapura	-	41	505	-	546
19. Sri Lanka	77	207	43	Nil	327
20. Thailand	10	35	20	Nil	65
21. United Arab	n/a	26	n/a	-	n/a

#    At Federal level ie enterprises of the State governments are excluded.
*    Unclassified.
+    There are 1,133 companies but only 847 are considered active:
      Authors Note:
      Because of grey areas in classifying the various forms of public enterprises in some cases, the above figures are generally indicative of the broad distribution and approximate number of such bodies existing in the respective countries.

Table 2.    Mandate for Audit of Pubic Enterprises

Type of PE Countries	PUBLIC CORPORATIONS (STATUTORY BODIES)	COMPANIES (GOVERNMENT/ CORPORATION CONTROLLED)
Australia	Appointment under the legislation relating to each statutory authority	Appointment under the Companies Act and the Audit Act
China	Authorisation under Article 91 of the Constitution of the People's Republic of China and Article 2 of the Provisional Regulations on Audit Work issued by the State Council in 1985	Authorisation under Article 91 of the Constitution of the People's Republic of China and Article 2 of the Provisional Regulations on Audit Work issued by the State Council in 1985
Cyprus	Authorisation under the "Public Corporate Bodies (Audit of Accounts) Law	Audited by private firms of auditors
Hong Kong	Audited by private firms of auditors. However, SAI has access to books and records of statutory bodies
India	Authorisation under the provisions of the statute.	Authorisation under the Companies Act 1956 as "superimposed" auditor over private auditor
Indonesia	Authorisation under Act No.5 of 1973	Audited by private firms of auditors
Israel	Authorisation under the State Comptroller's Law 1958	Appointment under the Companies Law, 1975
Japan	Authorisation under the Board of Audit Law, 1947	Authorisation under the Board of Audit Law 1947
Jordan	Authorised by legislation	Audited by private firms of auditors
Korea	Authorisation under - The Board of Audit and Inspection Law 1963 - The Budget and Accounting Law 1962 - The respective laws establishing the corporation	Authorisation under - The Board of Audit and Inspection Law 1963 - The Budget and Accounting Law 1962
Kuwait	Authorisation under Law No. 30 of 1964 (Audit Bureau Legislation)	Authorisation under Law No.30 of 1964
Malaysia	Authorisation under provisions of the Constitution and the Audit Act 1957 Appointment under the legislation relating to each authority or the Statutory Bodies (Accounts and Annual Reports) Act 1980	Only on order by the King under the provisions of the Constitution and Audit Act 1957. So far none given
Nepal	Authorisation under the provisions of the Constitution and the Audit Act	Authorisation under the Constitution, Audit Act and Companies Act
New Zealand	Authorisation under the State Owned Enterprises Act or specific enabling legislation	No specific authority necessary. C&A-G is appointed under normal provisions of company legislation
Pakistan	Enacting order 1973	Audited by firms of chartered accountants. SAI authorised by Government in 1977 to evaluate performance of companies
Papua New Guinea	Authorisation under - the Constitution - the Public Bodies (Financial Administration) Act 1969	Audit by private auditors but SAI may carry out such audits under provisions of the Constitution under special circumstances.
Saudi Arabia	Authorisation under the Act Establishing the General Auditing Bureau	Authorisation under the Act establishing the General Auditing Bureau
Singapore	Appointment under the legislation relating to each authority	Audited by private firms of auditors
Sri Lanka	Authorisation under - the Constitution - the Finance Act No.38 of 1971 - enabling statutes	Authorisation under the Companies Law
Thailand	Authorisation under -the State Audit Act, 1979 - the Accounts and Finance Regulations issued by the Ministry of Finance	Audited by private auditors but SAI has inspection rights
United Arab Emirates	Authorisation under the provisions of the Constitution and Federal Law No. 7 of 1976	Authorisation under the provisions of the Constitution and Federal Law No. 7 of 1976