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Internal Audit and Counter Fraud Summary of Activities

Argyll and Bute Council · 16 December 2025
Back to Audit and Scrutiny Committee — 16 December 2025 and its agenda

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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  16 DECEMBER 2025  
INTERNAL AUDIT AND COUNTER FRAUD SUMMARY OF ACTIVITIES 
1. SUMMARY  
1.1 The objective of the report is to provide the Audit and Scrutiny Committee (the
Committee) with a summary of Internal Audit activity and progress during quarter 3
of 2025/26.  
1.2 Core activities together with a progress update statement are shown below: 
• 2025/26 Individual Audits undertaken: Eight audits have been completed
during the period, 4 have been assessed as providing high assurance, one
substantial assurance, 2 reasonable assurance and one limited assurance.
(Where HSCP and LiveArgyll Audits are included, these are provided for
information only). 
• 2025/26 Audit Plan progress: The plan is currently on track. In the event that
this position was to change, we will flag it to the Committee as part of the
quarterly updates. 
• Scrutiny: Planned work for 2025/26 has been agreed by the Committee along
with those who will serve on the Panel, and work on this will commence in
January 2026. 
• Counter Fraud: The Counter Fraud Team (CFT) is continuing to rebill council
tax accounts and recovery of funds is underway.  All other aspects and
referrals are being considered, investigated and evaluated and the Counter
Fraud Team remain vigilant to protect our public purse. All CFT team
members have completed the accredited CIPFA Fraud Specialist Course. The
team lead is currently progressing toward the completion of year 4 of a Master
in Accountancy course.   
• Continuous Monitoring Programme Testing: A number of auditable units
are subject to continuous testing. There has been one new issue identified this
quarter. 
• Performance indicators: Current status is green / on track.   
2. RECOMMENDATIONS  
2.1 To review and endorse the Summary of Activities report.

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3. DETAIL  
3.1 Eight audits have been completed since the previous Committee in September
2025. 
Audits Completed 
• Oban Airport 
• ICT Disaster Recovery 
• School Residential Trips
• Self-Directed Support
• Building Cleaning 
• HSCP Governance Arrangements -for information only
• HSCP Partnership Working – for information only
• HSCP Workforce Planning  – for information only 
Verification Audit Work Completed 
• N/A 
Audits in Planning / in Progress
reported to a future meeting of the Committee. 
• Capital Programme – Management and Monitoring (awaiting management
response to draft report)
• Payroll – iTrent
• Performance Management Arrangements and Reporting
• Project Management 
• Street Lighting 
3.2 In addition to those already in progress, indicative audits planned for 2025/26
are: 
• Eclipse
• Rural Growth Deal
• Whistleblowing
• LiveArgyll Building/Property Maintenance   
2025/26 Audit Plan  
3.3 Work is ongoing and is currently on track at this point in time. Only one
amendment to the plan should be noted and that relates to the strategic
Procurement review which has been postponed to another audit plan when the
work will be more appropriate to be undertaken.   
Scrutiny  
3.4 It was agreed by the Committee that the chosen subject area for the 2025/26
scrutiny review would be on the Council’s preparedness for the Bio-Municipal

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Waste (BMW) Landfill Ban.  A background and scoping document will be prepared
and issued to the Panel members for agreement in due course. We anticipate that
this will commence early in January 2026.   
Counter Fraud  
3.5 The CFT is progressing well with both team members fully CIPFA accredited fraud
investigators. The team now consists of 2 full time staff after completing
secondments.  Both team members are fully trained under the accredited CIPFA
fraud course. 
3.6 Routine work continues and is progressing to track the full income due and to be
recovered as part of this ongoing work. Based on the amount of additional billing,
even accounting for a degree of non-recovery, the indications are that the team are
anticipating exceeding their annual target. In addition, the team are raising
awareness of the Council’s zero tolerance to fraud and this will help act as a
deterrent to fraud being perpetrated in the first place.  
3.7 Visits continue to play a vital role in the CFTs proactive and reactive work.  Recent
visits have taken place in Mull, Campbeltown and Tarbert. Work is still underway
for Helensburgh. Further efforts toward Coll had to be delayed due to Storm Amy.
Travel to the outer islands will commence spring 2026. Both officers continue to be
proactive and make visits when information is received via the online portal and
other islands will soon be visited.  
3.8 The CFT continue to link in with Internal Audit and Debt Recovery, and where
necessary to assist, trace persons and open communication to long term debts for
recovery. Several cases have resulted in large scale rebilling.  
3.9 Second homes and Non-Domestic Rates are playing larger roles in the CFT’s 
investigations with several claims already adjusted.  These will remain proactive
areas.  
3.10 The CFT continue to work closely with the empty homes team to support each
other in our remits.  Work and communication between each department is key in
identifying and finding appropriate solutions to enable empty homes to return to
residency or open market.  
3.11 The NFI exercise continues to be a routine work area for the CFT.  The 2024/2025
exercise had extra data uploaded this September and work on this element will
commence when this has been matched and results released.  The initial part of
the matching exercise is coming to a close.  Any remedial or conclusive work will
be completed when and where appropriate.  The system is reviewed periodically
for any updates.  
3.12 Since the inception of the CFT a total of £1,553,043,262 has been rebilled and
£1,048,213 has been recovered. A recovery percentage of 68% has been
achieved at the last review of the figures. Recent large rebilling has been passed
to other agencies, and this takes time to process and progress payment plans.   
Additional Updates from Quarter Three  
3.13 The Council has entered a ten-year programme to deliver the Rural Growth Deal
(RGD) for Argyll and Bute.  The Council, as the accountable body for this

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programme is required to allocate and account for distribution of the funding to
partners, third parties and other bodies in accordance with the approved
governance arrangements.  The Council’s Chief Internal Auditor has been
appointed to coordinate audit activity throughout the programme, this will include
liaison with partner auditors to obtain annual confirmation of regular and planned
reviews of grant funded activities and a specific review of RGD within the
Council’s Annual Audit Plan at least every two years.  Discussions regarding the
audit input required have taken place and the first review will be included within
the 2025/26 Internal Audit Plan. We will closely monitor the additional work
associated with this appointment going forward and determine whether
additional resources may be required.  
3.14 Our work as the contracted Internal Auditors for the HSCP has been progressing
well and priority has been given in this area due to staff availability, therefore, we
have been able to complete our work for 2025/26. We will continue to monitor and
report progress to the HSCP’s Audit and Risk Committee in relation to the
implementation of recommendations made in previous reports. 
3.15 Internal Audit staff continue to increase their skills and ultimately aim to complete
appropriate professional qualifications at the end of their training programmes.
Internal Audit have two staff members who are undertaking formal professional
training; training is at differing stages but is progressing as expected at this time.
The aim is to develop and retain professional staff on the completion of the
qualifications and increase resilience within the service.   
Continuous Monitoring  
3.16 Our continuous monitoring programme is generally focused on transactional type
activity. Standard audit tests are applied which are relevant to each auditable unit.
Control design tests look at whether the controls in place adequately address the
potential risk event. There has been one new finding within the quarter that
requires to be reported. 
Table 1: Continuous Monitoring Findings 
Auditable
Area
Areas Tested Issues Identified Management comment /
action
Payroll  Expenses Five out of 37 expense
claims tested were
found to have been
authorised by
managers/appropriate
persons but receipts
were either missing or
did not align with the
claim period,
additionally, there was
no evidence of
Executive Director
approval for claims over
6 months old. 
The respective
Managers/authorisers were
notified of the findings via
email and advised that the
guidance on the HUB must
be adhered to and the
importance of this. 
Four responses were
received assuring that the
guidance would be followed
in future and despite
sending 3 emails, no
response was received for
the 5th claim tested.   
3.17 A process is in place whereby management are advised of continuous monitoring
findings and, where appropriate, requested to take remedial action.    Due to the

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volume of continuous monitoring tests carried out the decision was made to report
by exception only.     
National Reports  
3.18 A follow up process for national reports is in place whereby management are
advised of national reports published and asked to confirm what, if any, action is
planned as a result of the report.  Table 2 details the national reports issued during
quarter two of 2025/26 due to be reported in quarter three.  
Table 2: National Reports 
National Report Issued To Detail Management response/
Action taken
Delivering for
the future:
Responding to
the workforce
challenge
Executive
Director Kirsty
Flanagan
Scotland’s councils
urgently need to
make progress
with workforce
plans if they are to
protect services
and financial
sustainability.
‘Following publication of the
Workforce Challenges report in
August 2025, the Council has
been assessing our current
People Strategy and Strategic
Workforce Plan against the
Commission’s
recommendations.  This self-
assessment will be reported in
the first instance to the
Executive Leadership Team in
Spring 2026 and any
improvements identified for
inclusion in future iterations of
the Strategic workforce
documents.’
Flooding in
Communities: 
Moving towards
flood resilience
Executive
Director Kirsty
Flanagan
Flooding is getting
worse because of
changes to our
climate.  It’s likely
flooding will
happen more
often.
A request has been made to
schedule this report for
discussion at the next Scottish
Collaboration of Transportation
Specialists (SCOTS) meeting on
12 December, thereafter, a
report will be prepared for the
Council’s Environment,
Development and Infrastructure
(EDI) Committee.
The 2023/24
audit of Glasgow
City Council
Chief
Executive
The processes,
decisions and
actions that
enabled five senior
Glasgow city
Council officers to
take significant
early retirement
and redundancy
payouts fell short
of the behaviour
and standards
expected of public
servants.
A stand-alone report to be
submitted to a future meeting of
the Audit and Scrutiny
Committee.

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Cyber-attack
affecting
operations and
services:  The
2023/24 audit of
Comhairle nan
Eilan Siar
Executive
Director Kirsty
Flanagan
All Scottish
councils must learn
from the immediate
and ongoing
impacts of a
significant cyber-
attack on
Comhairle nan
Eilean Siar.
Argyll and Bute Council actively
manages cyber security risk
through its Strategic Risk
Register, regular reviews, and
robust IT protocols using
specialized software, while
acknowledging that absolute
prevention cannot be
guaranteed. The Council
collaborates with other
authorities, including Comhairle
nan Eilean Siar, for mutual
learning and recovery support,
and participates in the Scottish
Local Authority Information
Security Group (SLAISG) for
information sharing and best
practices. Cyber risk remains a
key focus, with efforts centred
on minimizing threats and
ensuring readiness and
preparation for potential attacks. 
National Fraud Initiative (NFI)  
3.19 NFI data matching involves comparing computer records held by one body against
other computer records held by the same or another body to identify potentially
fraudulent claims and payments to be identified.  Note though that the inclusion of
personal data within a data matching exercise does not mean that any specific
individual is under suspicion. Where a match is found it indicates that there may be
an inconsistency which requires further investigation. No assumption can be made
as to whether there is fraud, error or other explanation until an investigation is
carried out.  A reminder process is in place to ensure that matches are reviewed
on a timely basis.  
3.20 The previous NFI exercise has been completed and results published by Audit
Scotland.  This exercise was conducted by officers and matches checked and
closed accordingly.  NFI provided additional data releases over the course of the
exercise and matches were addressed when these became available.    
3.21 Existing users have been reviewed and new users added where requested, all
users have been and will continue to be informed that matches are available for
review.  Progress in investigating matches will be monitored monthly by the
Counter Fraud team and reported quarterly to the Audit and Scrutiny Committee.    
3.22 New HMRC data has been uploaded and released back to us, the respective
teams have been contacted to start matching this data.  
3.23 The NFI exercise for 2024/25 has commenced with the data uploads so far
submitted to the Cabinet office for review and therefore data matching when
released.  The new NFI matches will appear in the table below as and when they
have been released and checked. More uploads have been given to Cabinet office
during November 2025 and will be matched once released.

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Table 4: National Fraud Initiative Progress at 16/11/2025
Operational
Area
Total
Matches
Recommended/Very
High / High/ Medium
Risk Matches
Matches
Complete 
*
WIP
Match Description
CT to Elect
Register 
2422 0 2422 0 CT records to Electoral
Register/ other data sets to
ensure discount awarded
to only those living alone
aged over 18, taking into
account disregarded
occupants.  (CT to other
Datasets will not be
progressed further due to
poor quality data)
CT rising
18s 
85 0 85 0
CT to HMRC
Household
Composition
1106 0 1106 0
Housing
Benefits
13 9 11 0 HB records to records in
other authorities / other
datasets including student
loans, payroll and pensions
to identify undeclared
income and capital.
Payroll 300 107 61 0 Payroll records to other
datasets including other
payrolls and pensions to
ensure employee is not
receiving additional
income.
Blue Badges 200 200 200 0 Blue badge records to
DWP data to identify
deceased claimant with
valid badge.
Housing
Waiting list
262 258 227  0 Housing waiting list
records to other
organisations HBCTR and
tenant data to identify
undisclosed changes in
circs or false info.
Council Tax
Reduction
638 174  206 3 CTR records with records
in other authorities / other
datasets including; student
loans, payroll and pensions
to identify undeclared
income and capital
Creditors 2340 0 1126 0  Analyses Creditors data to
identify possible duplicate
vendors and payments,
VAT errors or fraud and
multiple vendors sharing a
bank account.
Procurement 67 0 14  0 Payroll records to
Companies House and
creditors’ data to identify
employees who appear to
have a personal interest in
a company that the
authority has traded with.
Business
Rates
154  0 154 0 Business rates records
within and between
authorities to identify
those fraudulently claiming
small business bonus
scheme and grants

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* Work in Progress
Overall Summary of Matches 
Matches
Complete
Work In
Progress
Cleared Frauds Errors Total
Value 
£
Recovering Recovering
Value 
£ 
5612  3 5532 0 80 62,726 0 0 
Internal Audit Development  
3.24 The table below details progress against the action points in our Internal Audit
development plan.  
Table 5: Internal Audit Development Key Actions: updated 18/11/25. 
Area For
Improvement
Agreed Action Progress
Update
Timescale
Review Continuous
Monitoring
Programme
The Continuous Monitoring
Programme will be reviewed to
assess value of existing tests carried
out and establish where these can be
enhanced with greater use of data
analytics.
In progress March2026
Follow-up
Performance
Reporting
Develop performance reporting
dashboard on Power BI
In progress March 2026 
3.25 Internal Audit scorecard data provided below are aligned to those for internal audit
in the Financial Services service plan.  All indicators are shown as currently being
on track.  
Table 6: Internal Audit Team Scorecard  
Internal Audit Team Scorecard 2025– 26 – FQ2 25/26 (as at September 2025)
BO115 We Are Efficient and Cost Effective    
Internal Audit Level of Satisfaction
Actual  100% G 
Target 80%
Review of Strategic Risk register
Status On Track G 
Target On Track
Percentage of audit plan completed
Status 100% G 
Target 80%
Percentage of audit recommendations accepted by
management
Actual  100%
G
Target 100%

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4 CONCLUSION  
4.1 The 2025/26 audit plan is progressing as anticipated at this stage in the year,
together with the Counter Fraud Team continuing with visits and pro-active work
throughout Argyll and Bute.  
5 IMPLICATIONS
5.1 Policy – Internal Audit continues to adopt a risk-based approach to activity
5.2 Financial – None
5.3 Legal – None
5.4 HR – None
5.5 Customer Service – None
5.6 Risk – None
5.7 Climate Change – None
5.8 Fairer Scotland Duty – None
5.9 Equalities – protected characteristics – None
5.10 Consumer Duty – None 
5.11 Island Communities – None
5.12 Children’s Rights and Wellbeing – None 
For further information please contact Internal Audit (01546 604108)
Paul Macaskill
Chief Internal Auditor
16 December 2025