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Argyll and Bute Council · 12 June 2025
Back to Audit and Scrutiny Committee — 12 June 2025 and its agenda

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Argyll and Bute Council
Comhairle Earra-Ghàidheal Agus Bhòid 
Customer  Services
Executive Director:  Douglas Hendry 
Kilmory, Lochgilphead, PA31 8RT
Tel:  01546 605522
DX 599700 LOCHGILPHEAD
5 June 2025 
NOTICE OF MEETING 
A meeting of the AUDIT AND SCRUTINY COMMITTEE will be held BY MICROSOFT TEAMS on
THURSDAY, 12 JUNE 2025 at 10:30 AM, which you are requested to attend. 
Douglas Hendry
Executive Director 
BUSINESS 
1. APOLOGIES FOR ABSENCE 
2. DECLARATIONS OF INTEREST 
3. MINUTES (Pages 3 - 8)  
Minutes of the Audit and Scrutiny Committee as held on 13 March 2025 
AUDIT ITEMS 
4. ANNUAL AUDIT PLAN FOR YEAR ENDING 31 MARCH 2025 (Pages 9 - 66)  
Report by Forvis Mazars 
5. INTERNAL AUDIT AND COUNTER FRAUD SUMMARY OF ACTIVITIES (Pages 67
- 76)  
Report by Chief Internal Auditor 
6. INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP REPORT 2024-2025
(Pages 77 - 88)  
Report by Chief Internal Auditor 
7. INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2025-26
(Pages 89 - 94)  
Report by Chief Internal Auditor 
(a) Short Term Lets (Pages 95 - 108) 
(b) Asbestos Management (Pages 109 - 126) 
(c) Bridges Asset Management Plan (Pages 127 - 142) 
Public Document Pack

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(d) Trading Standards (Pages 143 - 154) 
(e) External Placements (Pages 155 - 170) 
(f) IFRS 16 - Leasing (Pages 171 - 182) 
(g) Disclosure Checks - Live Argyll (Pages 183 - 196) 
8. INTERNAL AUDIT  ANNUAL REPORT 2024-2025 (Pages 197 - 220)  
Report by Chief Internal Auditor 
SCRUTINY ITEMS 
9. SCRUTINY REPORT ON THE MONITORING AND MANAGING OF COMPLAINTS
(Pages 221 - 240)  
Report by Chief Internal Auditor 
10. VERBAL UPDATE BY CHAIR OF SCRUTINY PANEL 
11. LOCAL GOVERNMENT IN SCOTLAND - FINANCIAL BULLETIN 2023-24 (Pages
241 - 286)  
Report by Section 95 Officer 
12. TREASURY MANAGEMENT ANNUAL REPORT 2024-25 
Report by Section 95 Officer (TO FOLLOW) 
13. LOCAL GOVERNMENT BENCHMARKING FRAMEWORK (LGBF): 2023/24
(Pages 287 - 296)  
Report by Executive Director with responsibility for Customer Support Services   
14. STATEMENT OF GOVERNANCE AND INTERNAL CONTROL (Pages 297 - 316)  
Report by Executive Director with responsibility for Legal and Regulatory Support 
REPORT FOR NOTING 
15. DRAFT AUDIT AND SCRUTINY COMMITTEE WORKPLAN (Pages 317 - 320) 
Audit and Scrutiny Committee 
Janice Wason Hall (Chair) Councillor Daniel Hampsey
Councillor Graham Hardie Councillor Fiona Howard
Councillor Reeni Kennedy-Boyle Councillor Gary Mulvaney (Vice-Chair)
Councillor Andrew Vennard   
Contact: Shona Barton, Governance Manager Tel: 01436 657605

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MINUTES of MEETING of AUDIT AND SCRUTINY COMMITTEE held BY MICROSOFT TEAMS 
on THURSDAY, 13 MARCH 2025 
Present: Janice Wason Hall (Chair) 
Councillor Graham Hardie
Councillor Fiona Howard
Councillor Reeni Kennedy-
Boyle 
Councillor Gary Mulvaney
Councillor Andrew Vennard 
Attending: Paul MacAskill, Chief Internal Auditor
Carolyn Earl, Interim Head of Financial Services
Shona Barton, Governance Manager
Mhairi Weldon, Senior Audit Assistant
Mark Outterside, Forvis Mazars 
The Chair asked the Committee to agreed that Item 7 (Audit Progress Report) of the Agenda be
taken after Item 3 (Minutes) to enable Mr Outterside from Forvis Mazars to attend another
meeting. 
The Chair also took the opportunity to congratulate Mhairi Weldon from the Internal Audit Team
who has recently passed her final examination and qualified as a Chartered Member of the
Institute of Internal Audit. Mhairi has been supported on the journey by Paul and his team and this
is an excellent example of the Council’s “Growing our Own” approach which encourages staff to
achieve their full potential. 
1. APOLOGIES FOR ABSENCE 
Apologies for absence was intimated on behalf of Councillor Daniel Hampsey. 
2. DECLARATIONS OF INTEREST 
There were no declarations of interest intimated. 
3. MINUTES 
The Minute of the previous meeting, held on 17 December 2024, were approved as a
correct record. 
4. AUDIT PROGRESS REPORT 
The Committee gave consideration to a report and a verbal update on the progress and
the current position of ongoing works in relation to the completion and delivery of the
Annual Audit for 2024-25. 
Decision 
The Audit and Scrutiny Committee noted the contents of the report and the verbal update
provided. 
(Reference: Report by Forvis Mazars dated 13 March 2025, submitted) 
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Councillor Fiona Howard joined the meeting during consideration of the following item of
business. 
5. INTERNAL AUDIT AND COUNTER FRAUD SUMMARY OF ACTIVITIES 
The Committee gave consideration to a report providing a summary of Internal Audit
activity and progress during quarter four of 2024/25 against the following areas:- 
Audits Completed
• Oban Airport
• Data Security & Information Security 
Audits in Planning/in Progress
• Short-Term Lets
• Bridges Asset Management Plan and Inspection Regime – In draft
• Asbestos Management – In draft
• External Placements
• Trading Standards
• Leasing – Estates
• Stores
• Disclosure Checks - protecting vulnerable groups 
The report also provided information on the work carried out on the 2024/25 Audit Plan
and by the Counter Fraud Team (CFT). 
Decision 
The Audit and Scrutiny Committee reviewed and endorsed the Summary of Activities
report. 
(Reference: Report by Chief Internal Auditor, dated 13 March 2025, submitted) 
6. INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2024-25 
Consideration was given to a report which provided an update on all open actions as at 31
December 2024. The report included information on actions where the agreed
implementation date had been rescheduled. 
Decision 
The Audit and Scrutiny Committee endorsed the contents of the report. 
(Reference: Report by Chief Internal Auditor dated 13 March 2025, submitted) 
7. INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE
2024/2025 
Consideration was given to a report containing the action plans in relation to the following
two audits:- 
Oban Airport
Data and Information Security – Data Platform 
Decision
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The Audit and Scrutiny Committee reviewed and endorsed the summary report and detail
within each individual report. 
(Reference: Report by Chief Internal Auditor dated 13 March 2025, submitted) 
8. VERBAL UPDATE BY CHAIR OF SCRUTINY PANEL 
The Chair provided information on the work of the Panel and noted that the final meeting
will be held on 28 March 2025. She advised that the Panel had been chaired by Martin
Caldwell and she was involved in a shadowing capacity. It was noted the scrutiny report
on the monitoring and managing of complaints will be submitted to the June Audit and
Scrutiny Committee for consideration. 
9. SCRUTINY FRAMEWORK AND MANUAL ANNUAL REVIEW 
The Committee gave consideration to a report which highlighted the conclusion of the
annual review to determine whether any changes are required to the Council’s Scrutiny
Framework and Manual. 
Decision 
The Audit and Scrutiny Committee noted the outcome of the annual review of the Scrutiny
Framework and Manual. 
(Reference: Report by the Chief Internal Auditor dated 13 March 2025, submitted) 
10. SCRUTINY - IDENTIFICATION OF A TOPIC 2025-2026 
The Committee gave consideration to a report which provided an update on the recent
engagement on potential scrutiny options in order to identify a topic to take forward in the
context of the Scrutiny Manual and Framework as part of the Committee’s scrutiny role for
2025-26.   
Decision 
The Audit and Scrutiny Committee:- 
1. agreed that the topic for 2025-26 will be a review of the Council’s readiness and
preparation for compliance with the ‘Biodegradable Municipal Waste Landfill Ban’
both based on the responses provided to the Chief Internal Auditor as part of the
recent communications with the Committee and the Committee’s previous wish to
maintain overview of progress in this area and, in accordance with the agreed
process of assessment which is detailed in the Scrutiny Framework and Manual. 
2. agreed to form a Scrutiny Panel that would take forward the review and that the
review would be scheduled to commence in the final quarter of 2025-2026; and 
3. appointed Janice Wason Hall as the Panel Chair and Councillors Reeni Kennedy-
Boyle and Gary Mulvaney as the two further Members. 
(Reference: Report by Chief Internal Auditor dated 13 March 2025, submitted) 
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11. TREASURY MANAGEMENT UPDATE QUARTER ENDED 31 DECEMBER
2024 
The Committee gave consideration to a report which provided an update on the Council’s
treasury management activity during the quarter 1 October to 31 December 2024 and the
overall position as at 31 December 2024. The report covered information on Economic
background; Interest rate forecasts; Borrowing; Investments and Compliance with treasury
and prudential limits. 
Decision 
The Audit and Scrutiny Committee noted the contents of the report and the treasury
activity during the period 1 October to 31 December 2024. 
(Reference: Report by Section 95 Officer dated 17 January 2025, submitted) 
12. TREASURY MANAGEMENT STRATEGY AND ANNUAL INVESTMENT
STRATEGY 
Consideration was given to a report which outlined the proposed Treasury Management
Strategy Statement and Annual Investment Strategy and set out the policy for the
repayment of loans fund advances for 2025-26.   
Decision 
The Audit and Scrutiny Committee:- 
1. noted that the report had been considered by the Policy and Resources
Committee on 20 February 2025 and approved by full Council on 27 February
2025. Any recommendations arising from further scrutiny by the Audit and Scrutiny
Committee will require to be presented to Council at the earliest opportunity; and 
2. endorsed the Treasury Management Strategy and Annual Investment Strategy for
2025-26, and the Prudential and Treasury Indicators for 2025.26 to 2027-28. 
(Reference: Report by Section 95 Officer dated 13 February 2025, submitted) 
13. 2024/2025 UNAUDITED ANNUAL ACCOUNTS PREPARATIONS 
Consideration was given to a report which outlined the plans in place for financial year end
31 March 2025 and the preparation of the Council’s Unaudited Accounts for 2024-25. 
Decision 
The Audit and Scrutiny Committee noted that plans are in place to prepare the Council’s
Annual Accounts for the year ending 31 March 2025, consistent with the proper
accounting practice and by the statutory deadline of 30 June 2025. 
(Reference:  Report by Section 95 Officer, dated 19 February 2025, submitted) 
14. INTERNAL AUDIT STRATEGY 2025-28 AND AUDIT PLAN 2025-26 
The Committee gave consideration to a report which introduced the new Internal Audit
Strategy covering 2025-28 and the Internal Audit Plan 2025-26. 
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Decision 
The Audit and Scrutiny Committee:- 
1. Approved the Internal Audit Strategy 2025-28, as attached at Appendix 1 to the report;
and 
2. Approved the Internal Audit Plan 2025-26, as attached at Appendix 2 to the report. 
(Reference:  Report by Chief Internal Auditor, dated 13 March 2025, submitted) 
15. INTERNAL AUDIT CHARTER AND INTERNAL AUDIT MANUAL 
Consideration was given to a report which outlined the proposed changes to the Internal
Audit Charter and Internal Audit Manual. 
Decision 
The Audit and Scrutiny Committee:- 
1. Approved the amended Internal Audit Charter, as attached at Appendix 1 to the
report; and 
2. Approved the amended Internal Audit Manual, as attached at Appendix 2 to the
report. 
(Reference:  Report by Chief Internal Auditor, dated 13 March 2025, submitted) 
16. INTERNAL AUDIT - GLOBAL INTERNAL AUDIT STANDARDS AND
APPLICATION NOTE FOR UK PUBLIC SECTOR 
The Committee considered a report which provided an update arising from the
introduction of the new Global Internal Audit Standards (GIAS) and the supplementary
Application Note. 
Decision 
The Audit and Scrutiny Committee:- 
1. noted the requirements of the new GIAS Standards as outlined in para 3.3 of the report and
also those contained within the Application Note which require the Council’s Internal Audit
section to comply with effect from the 1 April 2025;
2. noted the gaps outlined in paragraph 3.5 which require to be addressed in order to comply
and agree the action plan to address these requirements of the Standards; and 
3. noted the additional duties expected of the Audit and Scrutiny Committee in their roles as
‘those charged with governance duties’. 
(Reference: Report by Chief Internal Auditor dated 13 March 2025, submitted) 
17. RIPSA ANNUAL REPORT 
Having noted the legal requirements placed on the Council in relation to covert
surveillance, the Committee gave consideration to a report which advised that between 1
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January and 31 December 2024, the Council undertook no covert surveillance operations
and that training for Roads and Infrastructure and Regulatory Services was undertaken in
February and March 2024. 
Decision 
The Audit and Scrutiny Committee considered and noted the terms of the report. 
(Reference: Report by Executive Director with responsibility for Legal and Regulatory
Support dated 17 February 2025, submitted) 
18. DRAFT AUDIT AND SCRUTINY COMMITTEE WORKPLAN 
In order to facilitate forward planning of reports to the Audit and Scrutiny Committee,
Members considered the outline Audit and Scrutiny workplan. 
Decision 
The Audit and Scrutiny Committee agreed to note the outline workplan.   
(Reference:  Audit and Scrutiny Workplan, dated 13 March 2025, submitted) 
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Annual Audit Plan
Argyll and Bute Council – Year ending 31 March 2025
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Agenda Item
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Annual Audit Plan Letter
Audit and Scrutiny Committee
Argyll and Bute Council
Lochgilphead
Argyll
PA31 8RT
19th May 2025
Forvis Mazars
The Corner, Bank Chambers
26 Mosley Street
Newcastle upon Tyne
NE1 1DF
Dear Audit and Scrutiny Committee members,
Annual Audit Plan – Year ending 31 March 2025
We are pleased to present our Annual Audit Plan for Argyll and Bute Council for the year ending 31 March 2025. This report summarises our audit approach, including the significant audit
risks and areas of key judgement we have identified, and provides details of our audit team. In addition, as it is a fundamental requirement that an auditor is, and is seen to be, independent
of an audited entity, the section of the report titled ‘Confirmation of our independence’ summarises our considerations and conclusions on our independence as auditors.
Two-way communication with you is key to a successful audit and is important in:
• Reaching a mutual understanding of the scope of the audit and our respective responsibilities;
• Sharing information to assist each of us to fulfil our respective responsibilities;
• Providing you with constructive observations arising during the audit process; and
• Ensuring that we, as external auditors, gain an understanding of your attitude and views in respect of the internal and external operational, financial, compliance, and other risks
facing Argyll and Bute Council which may affect the audit, including the likelihood of those risks materialising and how they are monitored and managed.
With that in mind, this report, which has been prepared following our initial planning discussions with management, facilitates a discussion with you on our audit approach. We welcome
any questions, concerns, or input you may have on our approach or role as auditor.
www.forvismazars.com/uk
Forvis Mazars LLP – The Corner, Bank Chambers, 26 Mosley Street, Newcastle upon Tyne, NE1 1DF – Tel: 0191 383 6339 – www.forvismazars.com/uk
Forvis Mazars LLP is the UK firm of Forvis Mazars Global, a leading global professional services network. Forvis Mazars LLP is a limited liability partnership registered in England and
Wales with registered number OC308299 and with its registered office at 30 Old Bailey, London, EC4M 7AU. Registered to carry on audit work in the UK by the Institute of Chartered
Accountants in England and Wales. Details about our audit registration can be viewed at www.auditregister.org.uk under reference number C001139861. VAT number: GB 839 8356 73
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Annual Audit Plan Letter
Annual Audit Plan – Year ending 31 March 2025 (continued)
This report also contains appendices that outline our key communications with you during the audit, and forthcoming accounting issues and other issues that may be of interest to you.
Providing a high-quality service is extremely important to us and we strive to provide technical excellence with the highest level of service quality, together with continuous improvement to
exceed your expectations. If you have any concerns or comments about this report or our audit approach, please contact me.
This report has been prepared in accordance with the responsibilities set out within the Audit Scotland’s Code of Audit Practice (“the Code”) and for the sole benefit of the Audit and
Scrutiny Committee. Except where required by law or regulation, it should not be used, quoted or made available to any other parties without our prior written consent.
Yours faithfully,
Mark Outterside (Director)
Forvis Mazars
Forvis Mazars LLP – The Corner, Bank Chambers, 26 Mosley Street, Newcastle upon Tyne, NE1 1DF – Tel: 0191 383 6339 – www.forvismazars.com/uk
Forvis Mazars LLP is the UK firm of Forvis Mazars Global, a leading global professional services network. Forvis Mazars LLP is a limited liability partnership registered in England and
Wales with registered number OC308299 and with its registered office at 30 Old Bailey, London, EC4M 7AU. Registered to carry on audit work in the UK by the Institute of Chartered
Accountants in England and Wales. Details about our audit registration can be viewed at www.auditregister.org.uk under reference number C001139861. VAT number: GB 839 8356 73
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4
Contents
01 Engagement and responsibilities summary
02 Your audit engagement team
03 Audit scope, approach and timeline
04 Materiality and misstatements
05 Significant risks and other key judgement areas
06 Wider scope and Best Value
07 Audit fees and other services
08 Confirmation of our independence
Appendix A – Key communication points
Appendix B - Current year updates, forthcoming accounting and other issues
This document is to be regarded as confidential to Argyll and Bute Council. It has been prepared for the sole use of the Audit and Scrutiny Committee as the appropriate sub-committee
charged with governance. No responsibility is accepted to any other person in respect of the whole or part of its contents. Our written consent must first be obtained before this
document, or any part of it, is disclosed to a third party.
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01Engagement and responsibilities summary
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6
Engagement and responsibilities summary
We are appointed to perform the external audit of Argyll and Bute Council for the year to 31 March 2025. The scope of our engagement is set out in the Code of Audit Practice, issued by
the Auditor General and the Accounts Commission available from the Audit Scotland website: Code of audit practice | Audit Scotland (audit-scotland.gov.uk). Our responsibilities are
principally derived from the Local Government (Scotland) Act 1973 (the 1973 Act) and the Code of Audit Practice, as outlined below and overleaf.
Audit opinion
We are responsible for forming and expressing an opinion on whether the
financial statements are prepared, in all material respects, in accordance
with applicable law and UK adopted International Accounting Standards as
interpreted and adopted by the Code of Practice on Local Authority
Accounting in the United Kingdom 2024/25.
Our audit does not relieve management or Audit and Scrutiny Committee,
as Those Charged With Governance, of their responsibilities.
The Section 95 Officer is responsible for the assessment of the Council’s
ability to continue as a going concern. As auditors, we are required to
obtain sufficient, appropriate audit evidence regarding, and conclude on:
a) whether a material uncertainty related to going concern exists, and
b) the appropriateness of the Section 95 Officer’s use of the going concern
basis of accounting in the preparation of the financial statements.
Fraud
The responsibility for safeguarding assets and for the prevention and detection
of fraud, error, and non-compliance with law or regulations rests with both
those charged with governance, and management. This includes establishing
and maintaining internal controls over asset protection, compliance with
relevant laws and regulations, and the reliability of financial reporting.
As part of our audit procedures in relation to fraud, we are required to inquire of
those charged with governance, including key management and internal audit
on their knowledge of instances of fraud, and their views on the risks of fraud
and on internal controls that mitigate those risks. In accordance with
International Standards on Auditing (UK), we plan and perform our audit to
obtain reasonable assurance that the financial statements taken as a whole
are free from material misstatement, whether due to fraud or error. However,
our audit should not be relied upon to identify all such misstatements.
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7
Engagement and responsibilities summary (continued)
Internal control
Management is responsible for such internal control as management
determines is necessary to enable the preparation of financial statements that
are free from material misstatement, whether due to fraud or error.
We are responsible for obtaining an understanding of internal control relevant
to the audit in order to design audit procedures that are appropriate in the
circumstances, but not for the purpose of expressing an opinion on the
effectiveness of the Council’s internal control.
Wider reporting
We report to the National Audit Office on the consistency of the Council’s
financial statements with its Whole of Government Accounts (WGA)
submission. The level of auditor assurance required depends on monetary
thresholds set by HM Treasury.
Wider scope and Best Value
We are also responsible for reviewing and reporting on the wider scope
arrangements that the Council has in place and its arrangements to secure
Best Value. We discuss our approach to wider scope and Best Value work
further in the ‘Wider scope and Best Value’ section of this report.
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02Your audit engagement team
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Your audit team
9
Mark Outterside
Engagement Leader
mark.outterside@mazars.co.uk
07824 086 593
We will consider utilising internal experts/specialists on this engagement in the following areas:
1. The valuation of property, plant and equipment
2. The migration of payroll data to a new system
Engagement Manager
peter.hawkins@mazars.co.uk
07580 854 210
Peter Hawkins Aaron Rowell
Engagement Team Leader
aaron.rowell@mazars.co.uk 
07816 209 250
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03Audit scope, approach, and timeline
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11
Audit scope, approach, and timeline
Risk-based approach
Professional
scepticism
Understand the Council, its business, and
the environment in which it operates
(including IT environment)
Plan our audit, including determining
materiality and identifying significant
components
Perform our risk assessment to
identify risks of material
misstatement, including significant
risks
Respond to our identified risks by
designing appropriate and sufficient
audit procedures
Perform planned procedures and
evaluate findings and, where
necessary, review the appropriateness
and sufficiency of the scope of our audit
Form our audit conclusion based on
our audit findings
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Audit scope, approach, and timeline (continued)
Audit scope
Our audit approach is designed to provide an audit that complies with all professional requirements.
Our audit of the financial statements will be conducted in accordance with International Standards on Auditing (UK), relevant ethical and professional standards, our own audit
methodology, and in accordance with the terms of our engagement. Our work is focused on those aspects of your business which we consider to have a higher risk of material
misstatement, such as those impacted by management judgement and estimation, application of new accounting standards, changes of accounting policy, changes to operations, or areas
found to contain material errors in the past.
Audit approach
Our audit approach is risk-based, and the nature, extent, and timing of our audit procedures are primarily driven by the areas of the financial statements we consider to be more susceptible
to material misstatement. Following our risk assessment where we assess the inherent risk factors (subjectivity, complexity, uncertainty, change and susceptibility to misstatement due to
management bias or fraud) to aid in our risk assessment, we develop our audit strategy and design audit procedures to respond to the risks we have identified.
If we conclude that appropriately designed controls are in place, we may plan to test and rely on those controls. If we decide controls are not appropriately designed, or we decide that it
would be more efficient to do so, we may take a wholly substantive approach to our audit testing where, in our professional judgement, substantive procedures alone will provide sufficient
appropriate audit evidence. Substantive procedures are audit procedures designed to detect material misstatements at the assertion level and comprise tests of detail (of classes of
transaction, account balances, and disclosures), and substantive analytical procedures. Irrespective of our assessed risks of material misstatement, which takes account of our evaluation
of the operating effectiveness of controls, we are required to design and perform substantive procedures for each material class of transaction, account balance, and disclosure.
Our audit has been planned and will be performed to provide reasonable assurance that the financial statements are free from material misstatement and give a true and fair view. The
concept of materiality and how we define a misstatement is explained in the ‘Materiality and misstatements’ section of this report.
The diagram on the next page outlines the procedures we perform at the different stages of our audit. We have also provided, later in this report, a table setting out the procedures we
perform for the significant financial statement areas.
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Audit scope, approach, and timeline
13
Planning and risk
assessment
March to April 2025
• Planning our visit and
developing our
understanding of the entity
• Documenting systems and
control and performing
walkthroughs
• Risk identification and
assessment
• Considering proposed
accounting policies and
accounting treatments
• Developing our audit
strategy and planning the
audit work to be performed
• Agreeing timetable and
deadlines
• Preliminary analytical
review
• Determination of materiality
Interim
May 2025
• Documenting systems
and controls
• Performing walkthroughs
• IT general controls testing
• Reassessment of our
audit strategy (and
revising if necessary)
• Early substantive testing
of transactions
Fieldwork
July to September 2025
• Executing our strategy,
starting with significant
risks and other higher-risk
areas
• Use of data analytics
• Receiving and reviewing
the draft financial
statements
Completion
October 2025
• Final review of financial
statements, and
disclosure checklist
• Final director review
• Agreeing the content of
the letter of
representation
• Preparing our auditor’s
report
• Reporting to the Audit
and Scrutiny committee
• Subsequent events
procedures
• Signing our auditor’s
report
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Audit scope, approach, and timeline (continued)
Key developments
The below key developments have taken place in the year. We have set out below how we will approach these areas during our audit.
14
Implementation of new
payroll /HR system
In August 2024, a new payroll/HR
system was implemented (iTrent).
The Council previously used
ResourceLink.
The change in system directly impacts
our audit due to increased risk around
migration of data, as staff costs are a
significant balance within the accounts.
We plan to test staff costs at enhanced
risk (per the following page).
We will engage an internal IT specialist to
assess the migration process, and the
design and implementation of iTrent.
First year application of
IFRS 16
The 2024/25 code introduced the
mandatory application of IFRS 16 –
Leases.
It is expected that IFRS 16 will have a material
impact on the accounts in 2024/25, as the Council
will be required to recognise most of their
operational leases on the balance sheet. IFRS 16
will also impact the three Public Private
Partnership arrangements that the Council has.
We plan to test leases/Public Private Partnership
arrangements at enhanced risk (as set out on
page 29 of this report).
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15
Audit scope, approach, and timeline (continued)
Audit approach for significant financial statement areas
Our audit approach on significant financial statement areas is set out below.
Financial
statement area
Significant
risk
Key judgement
area or
enhanced risk
Testing of
controls
Substantive
procedures Comments
Valuation of land and
buildings Yes Yes No Yes See ‘Section 05 – Significant risks and other key judgement areas’ for further detail.
Valuation of net defined
pension liability/asset Yes Yes No No See ‘Section 05 – Significant risks and other key judgement areas’ for further detail.
Accounting for leases under
IFRS 16 No Yes No No See ‘Section 05 – Significant risks and other key judgement areas’ for further detail.
Accounting for Public
Private Partnerships under
IFRS 16
No Yes No Yes See ‘Section 05 – Significant risks and other key judgement areas’ for further detail.
Accounting for staff costs
under a new payroll/HR
system (iTrent)
No Yes No No See ‘Section 05 – Significant risks and other key judgement areas’ for further detail.
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Audit scope, approach, and timeline (continued)
Group audit approach
The preliminary scope of our group audit is based on our analysis of the risks we have identified at group level. When scoping our audit, we have considered quantitative criteria (the
contribution of each of the group’s consolidated components to the group financial statements); qualitative criteria (the risks of material misstatement of the group financial statements
that consolidated components may present individually at component level); and we have assessed the risk of material misstatement across the group’s consolidated components in
aggregate.
The nature and extent of audit work we plan to perform on the consolidated components is set out below.
Component name Identifier % Group
Expenditure Location Auditor Scope
Argyll and Bute Council Parent – local authority 98.05% Kilmory, Lochgilphead,
Argyll, PA31 8RT Forvis Mazars Full
Argyll and Bute Integration
Joint Board
Joint venture between the Council and NHS Highland with
responsibility for health and social care functions. 0.00% Campbeltown, PA28 6LE Forvis Mazars Specific
Dunbartonshire and Argyll
and Bute Valuation Joint
Board
Joint Board responsible for the maintenance of the electoral,
council tax and non-domestic rates registers for Argyll and Bute,
West Dunbartonshire and East Dunbartonshire Councils.
0.28%
Kilbrannan House, Bolgam
St, Campbeltown, PA28 6JY Forvis Mazars N/A
Live Argyll
100% owned subsidiary of the Council, which provides a wide
range of services within the area including libraries, leisure
facilities, halls, sports development and community centres.
1.67%
Campbeltown Aqualibrium.
Kinloch Road,
Campbeltown, Argyll, PA28
6EG
Forvis Mazars Specific
Common Good accounts The Council administers the Common Good Accounts for several
former Burghs. 0.00% Kilmory, Lochgilphead,
Argyll, PA31 8RT
Forvis Mazars N/A
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17
Audit scope, approach, and timeline (continued)
Follow up on deficiencies in internal control
Set out below are the significant deficiencies in internal control that we identified during our prior period audit. We request that you and management provide an update on the action taken
to address these deficiencies.
• We noted that there is scope for the Council to improve their property, plant and equipment valuation reconciliations, as there were instances where we struggled to agree details to
underlying records. We recommended that management prepare and maintain a reconciliation of the results of any revaluation exercises conducted with the fixed asset register/general
ledger and maintain summaries that agree back to supporting records (such as maps or architects’ plans).
• During our testing of property, plant and equipment valuations, we noted the asset records and floor areas held on the Concerto system were inconsistent with area inputs used in the
valuer calculations. We recommended management ensure there are clear controls and processes in place to ensure that information on Concerto is kept accurate and up to date.
• The Council administers numerous bank accounts, several of which were dormant during the period. It was not clear whether these accounts are actively monitored. We recommended
that a review of open bank accounts should be carried out periodically to identify dormant accounts. Any accounts which are no longer required should be closed.
• Related Parties testing identified one officer who was disclosed in the Senior Councillor Remuneration note in the accounts, but not on the Council’s website. We recommended that
management perform a regular exercise to ensure there is consistency between the two.
• During our testing of debtors, when considering the application of the Code/IFRS 9 Financial Instruments, we noted the Council had not done a detailed assessment of the expected
credit loss for 2023/24. We recommended that the Council ensure they perform an expected credit loss calculation which includes sufficient detail.
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18
Audit scope, approach, and timeline (continued)
Audit of trusts registered as Scottish charities
The Charities Accounts (Scotland) Regulations 2006 outline the accounting and auditing requirements for charitable bodies. The 2006 Regulations require charities to prepare annual
accounts and an auditor to prepare a report to the charity trustees where any legislation requires an audit.
The Local Government (Scotland) Act 1973 specifies the audit requirements for any trust fund where some or all members of a Council are the sole trustees. Therefore, a full and separate
audit and independent auditor’s report is required for each registered charity where members of the Council are sole trustees.
Members of the Council are the sole trustees for 7 trusts registered as Scottish charities, with total assets of circa £800,000. The preparation and audit of financial statements of registered
charities is regulated by the Charities and Trustee Investment (Scotland) Act 2005 and the Charities Accounts (Scotland) Regulations 2006.
We have not identified any significant risks, other than the risk of management override of controls which we have also identified as a risk for the Council’s annual accounts, for the financial
statements of the Council’s charitable trusts. Please see page 22 for disclosure of our planning materiality level. Page 26

Page 27

04Materiality and misstatements
Page 27

Page 28

Materiality and misstatements
20
Definitions
Materiality is an expression of the relative significance or importance of a particular matter
in the context of the  financial statements as a whole.
Misstatements in the financial statements are considered to be material if they could,
individually or in aggregate, reasonably be expected to influence the economic decisions
of users based on the financial statements.
Materiality
We determine materiality for the financial statements as a whole (overall materiality) using
a benchmark that, in our professional judgement, is most appropriate to the entity. We also
determine an amount less than materiality (performance materiality), which is applied
when we carry out our audit procedures and is designed to reduce to an appropriately low
level the probability that the aggregate of uncorrected and undetected misstatements
exceeds overall materiality. Further, we set a threshold above which all misstatements we
identify during our audit (adjusted and unadjusted) will be reported to the Audit and
Scrutiny Committee.
Judgements on materiality are made in light of surrounding circumstances and are affected
by the size and nature of a misstatement, or a combination of both. Judgements about
materiality are based on a consideration of the common financial information needs of
users as a group and not on specific individual users.
An assessment of what is material is a matter of professional judgement and is affected by
our perception of the financial information needs of the users of the financial statements. In
making our assessment we assume that users:
• Have a reasonable knowledge of business, economic activities, and accounts;
• Have a willingness to study the information in the financial statements with reasonable
diligence;
• Understand that financial statements are prepared, presented, and audited to levels of
materiality;
• Recognise the uncertainties inherent in the measurement of amounts based on the
use of estimates, judgement, and consideration of future events; and
• Will make reasonable economic decisions based on the information in the financial
statements.
We consider overall materiality and performance materiality while planning and performing
our audit based on quantitative and qualitative factors.
When planning our audit, we make judgements about the size of misstatements we
consider to be material. This provides a basis for our risk assessment procedures,
including identifying and assessing the risks of material misstatement, and determining the
nature, timing and extent of our responses to those risks.
The overall materiality and performance materiality that we determine does not necessarily
mean that uncorrected misstatements that are below materiality, individually or in
aggregate, will be considered immaterial.
We revise materiality as our audit progresses should we become aware of information that
would have caused us to determine a different amount had we been aware of that
information at the planning stage.
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Materiality and misstatements (continued)
21
Materiality (continued)
For the consolidated and single-entity Council financial statements, we consider that gross
revenue expenditure at surplus/deficit level is the key focus of users of the financial statements.
We have therefore determined our initial materiality levels using this as the benchmark.
We expect to set a materiality of 2% of gross revenue expenditure at surplus/deficit level for the
consolidated financial statements, and a materiality of 2% of gross revenue at surplus/deficit
level for the single-entity.
As set out in the tables alongside, based on currently available information (being the prior
period signed financial statements), we anticipate overall group materiality for the year ended
31 March 2025 to be in the region of £9.810m (£9.810m in the prior year), and performance
materiality to be in the region of £7.358m (£6.867m in the prior year).
For the single-entity, we anticipate overall materiality for the year ended 31 March 2025 to be in
the region of £9.697m (£9.697m in the prior year), and performance materiality to be in the
region of £7.273m (£6.788m in the prior year).
As set out in the tables overleaf, for the Argyll and Bute Charitable Trusts, we anticipate overall
materiality for the year ended 31 March 2025 to be in the region of £16,318 (£16,318 in the prior
year), and performance materiality to be in the region of £9,791 (£9,791 in the prior year).
We have selected gross revenue expenditure at surplus/deficit on provision of services level as
the benchmark for our materiality calculation. This is because the users of the financial
statements primarily focus on expenditure in the year and the implications of this on the funding
position of the authority.
We will continue to monitor materiality throughout our audit to ensure it is set at an appropriate
level.
Group financial statements
blank 2024/25
£’000s
2023/24
£’000s
Overall materiality £9,810 £9,810
Performance materiality £7,358 £6,867
Clearly trivial £294 £294
Specific materiality:
Remuneration Report
£1 for senior councillors and senior employees’
remuneration and pensions benefits.
1 banding for Employees’ remuneration.
1 banding for exit packages.
Council’s single-entity financial statements
blank 2024/25
£’000s
2023/24
£’000s
Overall materiality £9,697 £9,697
Performance materiality £7,273 £6,788
Clearly trivial £291 £291
Specific materiality:
Remuneration Report
£1 for senior councillors and senior employees’
remuneration and pensions benefits
1 banding for Employees’ remuneration.
1 banding for exit packages.
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Materiality and misstatements (continued)
22
Materiality (continued)
Argyll and Bute Charitable Trust
blank 2024/25 (TBC)
£
2023/24
£
Overall materiality £16,318 £16,318
Performance materiality £9,791 £9,791
Clearly trivial £490 £490
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Materiality and misstatements (continued)
Misstatements
We will accumulate misstatements identified during our audit that are above our
determined clearly trivial threshold. 
We have set a clearly trivial threshold for individual misstatements we identify (a reporting
threshold) for reporting to the Audit and Scrutiny Committee and management that is
consistent with a threshold where misstatements below that amount would not need to be
accumulated because we expect that the accumulation of such amounts would not have a
material effect on the financial statements. 
Based on our preliminary assessment of overall materiality, our proposed clearly trivial
threshold is £294k for the Group and £291k for the Council, based on 3% of overall
materiality. If you have any queries about this, please raise these with Mark Outterside.
Each misstatement above the reporting threshold that we identify will be classified as:
• Adjusted: Those misstatements that we identify and are corrected by management.
• Unadjusted: Those misstatements that we identify that are not corrected by
management.
We will report all misstatements above the reporting threshold to management and request
that they are corrected. If they are not corrected, we will report each misstatement to the
Audit and Scrutiny Committee as unadjusted misstatements and, if they remain
uncorrected, we will communicate the effect that they may have individually, or in
aggregate, on the financial statements and on our audit opinion.
Misstatements also cover qualitative misstatements and include quantitative and
qualitative misstatements and omissions relating to the notes of the financial statements.
Reporting
In summary, we will categorise and report misstatements above the reporting threshold to
the Audit and Scrutiny Committee as follows:
• Adjusted misstatements;
• Unadjusted misstatements; and
• Disclosure misstatements (adjusted and unadjusted).
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Page 32

05Significant risks and other key judgement
areas
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Page 33

Significant risks and other key judgement areas
Definitions
Following the risk assessment approach set out in the ‘Audit scope, approach, and timeline’ section, we have identified the risks of material misstatement in the financial statements. These
risks are categorised as significant, enhanced, or standard. The definitions of these risk ratings are set out below.
25
Risk
Level
Definition
Significant A risk that is assessed as being at or close to the upper end of the spectrum of inherent risk, based on a combination of
the likelihood of a misstatement occurring and the magnitude of any potential misstatement. A fraud risk is always
assessed as a significant risk (as required by auditing standards), including management override of controls and
revenue recognition.
Enhanced An area with an elevated risk of material misstatement at the assertion level, other than a significant risk, based on
factors/ information inherent to that area. Enhanced risks require additional consideration but do not rise to the level of a
significant risk. These include but are not limited to:
• Key areas of management judgement and estimation uncertainty, including accounting estimates related to material
classes of transaction, account balances, and disclosures but which are not considered to give rise to a significant
risk of material misstatement; and
• Risks relating to other assertions and arising from significant events or transactions that occurred during the period.
Standard A risk related to assertions over classes of transaction, account balances, and disclosures that are relatively routine,
non-complex, tend to be subject to systematic processing, and require little or no management judgement/ estimation.
Although it is considered that there is a risk of material misstatement, there are no elevated or special factors related to
the nature of the financial statement area, the likely magnitude of potential misstatements, or the likelihood of a risk
occurring.
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Significant risks and other key judgement areas (continued)
26
Audit risks and planned responses
In this section, we have set out the risks that we deem to be significant and enhanced, and our planned response. An audit is a dynamic process, and should we change our view of risk
and/ or our approach to address those risks during our audit, we will report this to the Audit and Scrutiny Committee.
Significant risks
Blank
Risk name Fraud Error Judgement Risk description Planned response
1 Management
override of
controls
Yes No Yes
Management at various levels within an organisation are in a
unique position to perpetrate fraud because of their ability to
manipulate accounting records and prepare fraudulent
financial statements by overriding controls that otherwise
appear to be operating effectively. Due to the unpredictable
way in which such override could occur there is a risk of
material misstatement due to fraud on all audits. You should
assess this risk as part of your oversight of the financial
reporting process.
We plan to address the management override of controls
risk through performing audit work over accounting
estimates, journal entries and significant transactions
outside the normal course of business or otherwise unusual.
We will address the risk through performing audit
procedures covering a range of areas including (but not
limited to):
• accounting estimates included in the financial statements
for evidence of management bias;
• any significant transactions outside the normal course of
business; and
• journals and other adjustments recorded in the general
ledger in preparing the financial statements.
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Significant risks and other key judgement areas (continued)
27
Significant risks (continued)
Blank
Risk name Fraud Error Judgement Risk description Planned response
2 Valuation of the
net defined
benefit
(liability)/surplus
No Yes Yes As at 31 March 2024, the net defined benefit liability
was £19.6m. The pension asset was nil. This is due
to the application of the asset ceiling applied in
accordance with IAS 19.
The valuation of the Council’s net liabilities/assets
includes use of discount rates, inflation rates,
mortality rates etc., all of which should reflect the
profile of the Council’s employees and other
appropriate data.
Due to the high degree of estimation uncertainty
associated with the valuations, we have determined
there is a significant risk in this area.
We will address this risk by reviewing the controls that the
Council has in place over the information sent to the
Scheme Actuary by the fund administrators (Strathclyde
Pension Fund).
We will:
• challenge the reasonableness of the Actuary’s
assumptions that underpin the relevant entries made in
the financial statements;
• critically assess the competency, objectivity and
independence of the Actuary;
• liaise with the auditors of the Pension Fund to gain
assurance that the overall IAS19 procedures and controls
in place at the Pension Fund are operating effectively;
• compare assumptions to expected ranges; and
• agree data in the Actuary’s valuation report for
accounting purposes to the relevant accounting entries
and disclosures in the Council’s financial statements.
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Significant risks and other key judgement areas (continued)
28
Significant risks (continued)
Blank
Risk name Fraud Error Judgement Risk description Planned response
3 Valuation
of
property,
plant and
equipment
No Yes Yes The Council held land and buildings
(including council dwellings) with a
net book value of £457 million at 31
March 2024. The Council has
adopted a rolling revaluation model
which sees other land and buildings
revalued over a five-year
cycle. This may result in individual
assets not being revalued for up to
5 years.
This creates a risk that the carrying
value of those assets that have
been revalued in year is materially
different from the year end fair
value.
Valuations are based on specialist
and management assumptions and
changes in these can result in
material changes to valuations. Due
to the high degree of estimation
uncertainty associated with
valuations, we have determined
there is a significant risk in this
area.
We will address this risk through:
• assessing the scope and terms of engagement with the in-house Valuer;
• assessing the competence, skills and objectivity of the in-house Valuer;
• assessing how management use the in-house Valuer’s report to value land and
buildings included in the financial statements;
• testing the accuracy of the data used in valuations;
• challenging the Council and in-house Valuer’s assumptions and judgements applied in
the valuations;
• reviewing the valuation methodology used, including the appropriateness of the
valuation basis;
• considering the reasonableness of the valuation by comparing the valuation output
with market intelligence;
• testing a sample of revaluations in the year, by agreeing the revaluations recorded in
the Annual Accounts to the in-house valuer’s reports. As part of this testing, we will
check whether the movements have been accounted for in accordance with the Code;
• challenging management’s assessment for those assets not subject to valuation in the
year;
• for those valued on Existing Use Value on a market comparable basis, we will check
market movements to assess the materiality of potential movement for 2024/25; and
• for those valued on a Depreciated Replacement Cost basis, which would be impacted
by changes in build costs during the year, we will test management’s analysis of
changes in the Build Costs Information Service (BCIS) index and assess any decisions
management make this regard.
We will engage the Forvis Mazars Real Estate Valuation Team to assist us with the
above.
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Significant risks and other key judgement areas (continued)
29
Other key areas of management judgement and enhanced risks
Blank
Risk name Fraud Error Judgement Risk description Planned response
1 Lease
liabilities
including
PPP (Public
Private
Partnership)
contracts
No Yes Yes Enhanced risk due to the implementation of a new accounting standard in 2024/25
(IFRS 16 Leases).
The Council has the following PPP contracts:
• Waste Management Public Private Partnership;
• Schools Non-Profit Distributing Organisation (NPDO) Public Private Partnership; and
• Schools Hub Design, Build, Finance and Maintain Contract (DBFM) Public Private
Partnership.
PPP liabilities as at 31 March 2024 totalled £122.38m.
IFRS 16 changes the definition of a lease compared to IAS 17 and IFRIC 4. The Council
will apply this definition to new leases only and will grandfather its assessments made
under the old standards of whether existing contracts contain a lease.
The new standard also applies to the Council’s PPP arrangements from 1 April 2024.
The Council has previously made disclosures in its financial statements; however, this is
a complex area, hence we have assessed it as an enhanced risk.
We will:
• critically review the accuracy
and completeness of the
Council’s assessment and
review the changes to the
PPP models;
• review the accounting
treatment;
• ensure the required
disclosures have been made;
and
• seek other evidence as
appropriate.
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Significant risks and other key judgement areas (continued)
30
Other key areas of management judgement and enhanced risks
Blank
Risk name Fraud Error Judgement Risk description Planned response
2 Accuracy and
completeness
of staff costs
following
change in
payroll/HR
system
No Yes No The Council have changed their payroll/HR system in-year (during August 2024), from
ResourceLink to iTrent. There is a risk relating to data migration, as this involves a
significant amount of payroll/HR data being migrated from one system to another, which
increases risks in relation to accuracy and completeness of this data.
We will:
• review the Council’s
arrangements for ensuring
the iTrent system is accurate
and complete;
• review import/export files to
ensure that these reconcile
and are accurately recorded
in the financial statements;
• increase our sample size of
staff costs by testing at
enhanced risk; and
• consider using an internal
Forvis Mazars IT
expert/specialist to assist with
our work.
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Significant risks and other key judgement areas (continued)
31
Other considerations
In consideration of ISA (UK) 260 Communication with Those Charged with Governance, we would like to seek the Audit and Scrutiny Committee‘s views/ knowledge of the following
matters:
• Did you identify any other risks (business, laws & regulation, fraud, going concern etc.) that may result in material misstatements?
• Are you aware of any significant communications between the Council and regulators?
• Are there any matters that you consider warrant particular attention during the course of our audit, and any areas where you would like additional procedures to be undertaken?
Significant difficulties encountered during the course of audit
In accordance with ISA (UK) 260 Communication with Those Charged with Governance, we are required to communicate certain matters to you which include, but are not limited to,
significant difficulties, if any, that are encountered during our audit. Such difficulties may include matters such as:
• Significant delays in management providing information that we require to perform our audit.
• An unnecessarily brief time within which to complete our audit.
• Extensive and unexpected effort to obtain sufficient appropriate audit evidence.
• Unavailability of expected information.
• Restrictions imposed on us by management.
• Unwillingness by management to make or extend their assessment of an entity’s ability to continue as a going concern when requested.
We will highlight to you on a timely basis should we encounter any such difficulties (if our audit process is unduly impeded, this could require us to issue a modified auditor’s report).
Internal audit function
Based on our assessment of the extent to which the internal audit function’s organisational status and relevant policies and procedures support the objectivity of the internal auditors, the
level of competence of the internal audit function, and whether the internal audit function applies a systematic and disciplined approach, including quality control, we do not expect to use
the work of the internal audit function for the purpose of our audit.
Nonetheless, we will obtain a copy of the reports issued by internal audit relating to the financial period under audit to determine whether any findings will have an impact on our risk
assessment and planned audit procedures.
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06Wider scope and Best Value
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Wider scope and Best Value
33
The framework for wider scope work
The Code of Audit Practice sets out the four areas that frame the wider scope of public sector audit. We are required to form a view on the adequacy of the Council’s arrangements in four
areas:
1. Financial management
2. Financial sustainability
3. Vision, leadership, and governance
4. Use of resources to improve outcomes
Financial
management
Financial management means having sound budgetary
processes. Audited bodies require the ability to understand the
financial environment and whether internal controls are
operating effectively.
Auditors consider whether the body has effective arrangements
to secure sound financial management.
Vision,
leadership and
governance
Audited bodies must have a clear vision and strategy and set
priorities for improvement within this vision and strategy. They
work together with partners and communities to improve
outcomes and foster a culture of innovation.
Auditors consider the clarity of plans to implement the vision,
strategy and priorities adopted by the leaders of the audited
body. They also consider the effectiveness of governance
arrangements for delivery.
Financial
sustainability
Financial sustainability means being able to meet the needs of
the present without compromising the ability of future
generations to meet their own needs.
Auditors consider the extent to which audited bodies have
shown regard to financial sustainability. They look ahead to the
medium term (two to five years) and longer term (over five years)
to consider whether the body is planning effectively so that it can
continue to deliver services.
Use of
resources to
improve
outcomes
Audited bodies need to make best use of their resources to meet
stated outcomes and improvement objectives, through effective
planning and working with strategic partners and communities.
Auditors consider the clarity of the arrangements in place to
ensure that resources are deployed to improve strategic
outcomes, meet the needs of service users taking account of
equalities, and deliver continuous improvements in priority
services.
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Wider scope and Best Value (continued)
34
Our approach
Our planned audit work against the four wider scope areas is risk based and proportionate. We need to gather sufficient evidence to support our commentary on the Council’s
arrangements and to identify and report on any significant weaknesses. We will carry out more detailed work where we identify significant risks. Where significant weaknesses are
identified we will report these to the Council and make recommendations for improvement. In addition to local risks, we consider challenges that are affecting the public sector generally.
Best Value
Under the Code of Audit Practice, the audit of Best Value in councils is fully integrated within our annual audit work. We are required to consider the seven Best Value themes which are:
1. Vision and leadership
2. Governance and accountability
3. Effective use of resources
4. Partnerships and collaborative working
5. Working with communities
6. Sustainability
7. Fairness and equality
We are required to consider the Council’s arrangements in respect of the seven Best Value themes, to identify any significant risks. Best Value at the Council will be assessed over the
period of the audit appointment. Where we identify risks or improvement areas we will plan appropriate coverage over the period of the audit appointment on a risk basis.
We will also follow up previously reported Best Value findings to assess the pace and depth of improvement. This work will be integrated into our audit approach, including our work on the
wider scope areas.
We will also conduct thematic reviews as directed by the Accounts Commission. In 2024/25 this will be on transformation. We will prepare a separate management report to document the
findings of this work.
At least once every five years, the Controller of Audit will report to the Accounts Commission on the Council’s performance in meeting its Best Value duties. The Council was included in
the second year of the programme in 2023/24.
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35
Wider scope and Best Value (continued)
Wider scope risks
The Code of Audit Practice requires us to consider the significant audit risks in areas defined in the Code as the wider scope audit.
Although we have not fully completed our planning and risk assessment work, the table below outlines the wider scope audit risks that we have identified to date. We will report any
further identified risks to the Audit and Scrutiny Committee on completion of our planning and risk identification work.
Blank
Risk Description Financial
management
Financial
sustainability
Vision,
leadership
and
governance
Use of
resources to
improve
outcomes
Planned procedures
1 Financial Sustainability
Before implementing measures to balance the
budget, the 2025/26 budget gap stood at £10.938
million. The budget also highlights a gap of
£9.528m in 2026/27 rising to a cumulative budget
gap of £29.537m by the end of 2029/30 based
upon a ‘mid-range’ scenario. The Council’s ‘worst
case’ scenario highlights a potential £55.999m
cumulative budget gap by the end of 2029/30.
This represents a risk in relation to financial
sustainability, impacting on the future provision
of services in the Council’s area.
No Yes No No
As part of our audit, we will review:
• the Council’s medium to long term financial
strategy;
• financial position and track record in delivering
planned recurrent and non-recurrent savings in
2024/25;
• financial performance in 2025/26 and updates to
its financial planning during the year, including
the implications for general reserves balances;
• regular reporting to Members on financial
performance, savings plans and financial risks;
and
• progress in developing plans to address future
years budget gaps.
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36
Wider scope and Best Value (continued)
Wider scope risks (continued)
Blank
Risk Description Financial
management
Financial
sustainability
Vision,
leadership
and
governance
Use of
resources to
improve
outcomes
Planned procedures
2 Corporate Plan
The Council's Strategic Plan 2023/2027, also
known as the Corporate Plan, outlines the vision
and key commitments for the Council. During the
previous year's audit, we noted that the Strategic
Plan and other key policy documents were being
revised due to a change in administration, with an
updated Strategy and other key policy documents
scheduled for publication in March 2025.
We therefore consider there to be a risk that these
strategic documents may be inconsistent with
other related policy documents, potentially
impacting the clarity of the Council's vision and
implementation of the administration’s policies.
No No Yes No
As part of our audit, we will consider:
• the Council's progress in implementing its
revised Corporate Plan and other key policy
documents;
• consider how the revised Corporate Plan
maintains clarity of vision, and how changes are
communicated to ensure effective
implementation; and
• how the Council ensures alignment between the
Corporate Plan, other key policy documents,
and key Council strategies (e.g., medium-term
financial plan and corporate savings plan).
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37
Wider scope and Best Value (continued)
Best Value risks
The Code of Audit Practice requires us to consider the significant audit risks in areas defined in the Code as the Best Value audit.
Although we have not fully completed our planning and risk assessment work, the table below outlines the best value audit risks that we have identified to date. We will report any further
identified risks to the Audit and Scrutiny Committee on completion of our planning and risk identification work.
Blank
Risk Description Reporting Criteria Planned procedures
1 Performance management
In connection with the risk identified on page 36 of
this report, we recommend that the Council ensure
the revised Corporate Plan includes Key
Performance Indicators (KPIs). These KPIs will help
assess Council performance, addressing the risk
that performance may not be effectively monitored.
Effectiveness of
performance reporting
We plan to:
• Understand how KPIs and performance metrics align with the Corporate Plan.
• Review and assess the appropriateness of KPIs and other performance
metrics.
• Understand the Council’s performance monitoring arrangements and how
KPIs are utilised to improve performance and deliver the Corporate Plan.
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38
Wider scope and Best Value (continued)
Best Value risks
.
Blank
Risk Description Reporting Criteria Planned procedures
2 Corporate Improvement Plans
In 2023/24, we reported that the Council's Corporate
Improvement Plan (CIP) concluded in 2022, and the
Council intended to publish an updated CIP in
2024/25.
Consequently, we identified a risk that the Council
might not track progress in achieving its Connect for
Success objectives.
We therefore recommended that the Council
updated its CIP to ensure alignment with other key
strategies and plans, including its workforce plan.
Effectiveness of
performance reporting
We plan to:
• Review the updated Corporate Improvement Plan (CIP) and understand how 
it aligns with other key strategic issues/plans.
• Understand the Council’s arrangements to monitor and deliver the CIP.
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39
Wider scope and Best Value (continued)
Best Value risks
Blank
Risk Description Reporting Criteria Planned procedures
3 Workforce Strategy
In 2023/24, we reported that the Council had
implemented a new people strategy and strategic
workforce plan, extending to 2028.
In connection with the Wider Scope risk highlighted
on page 36 of this report, we identified a risk that the
Council's strategic workforce plans may not be
aligned with the updated Corporate Plan and other
key strategies, including the MTFP. 
There is a risk that workforce planning does not
align with other strategic plans, including the MTFP. 
Thematic Review
We plan to:
• Review the Council’s strategic workforce plan to understand its alignment with
other strategic documents (e.g., MTFP, Corporate Plan, etc.).
• Consider the key assumptions used in developing the workforce plan and
evaluate the Council’s arrangements for monitoring and updating the plan to
ensure it remains current.
• Update our understanding of how updates to the workforce strategy inform
budget reporting and the MTFP. 
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40
Wider scope and Best Value (continued)
Best Value risks
Blank
Risk Description Reporting Criteria Planned procedures
4 Agency staff costs
In 2023/24, we reported that workforce trends
outlined in the Strategic Workforce Planning
Priorities indicated that temporary and casual staff
increased to approximately 16% of the workforce.
We therefore highlighted a risk that high turnover of
staff and reliance on agency recruitment may result
in increased costs and diminished service quality.
Thematic Review
We plan to:
• Update our understanding of the Council’s arrangements for monitoring and
reporting the impact of high turnover and the use of agency staff on both
financial and non-financial performance.
• Update our understanding of the strategies and plans the Council has
implemented to mitigate the risks associated with current turnover levels and
the use of agency staff for critical services.
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07Audit fees and other services
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Audit fees and other services
42
Our fees for the audit of the Council’s financial statements for the year ended 31 March 2025
are outlined below.
At this stage of the audit, we are not planning any divergence from the expected fees set by
Audit Scotland, which is available on the Audit Scotland website:
Audit Scotland expected fees for 2024/25 audits.
Area of work 2024-25 Proposed Fee 2023-24 Actual Fee
Auditor remuneration £262,260 £251,690
Pooled costs £6,590 £9,170
Contribution to PABV costs £60,940 £63,850
Sectoral cap adjustment £1,010 -£110
Total fees £330,800 £324,600
Fees for work as the Charitable Trust’s appointed auditor
We propose setting a fee for the audit of the Charitable Trusts of £9,750 (2023/24
fee was £9,000).  We have not provided any non-audit services to the Charitable
Trusts in 2024/25.
Services provided to other entities within the Council's group
In addition to auditing the Council’s Charitable Trusts, we are providing audit
services to the following entities in the Council’s group:
• Argyll and Bute Integration Joint Board (total fee of £34,000)
• Dunbartonshire and Argyll & Bute Valuation Joint Board (total fee of £9,500)
• Live Argyll (fee TBC for 2024/25)
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08Confirmation of our independence
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Confirmation of our independence
44
Requirements
We comply with the International Code of Ethics for
Professional Accountants, including International
Independence Standards issued by the International
Ethics Standards Board for Accountants together with
the ethical requirements that are relevant to our audit
of the financial statements in the UK reflected in the
ICAEW Code of Ethics and the FRC Revised Ethical
Standard.
Compliance
We are not aware of any relationship between Forvis
Mazars and Argyll and Bute Council that, in our
professional judgement, may reasonably be thought to
impair our independence.
We are independent of Argyll and Bute Council and have
fulfilled our independence and ethical responsibilities in
accordance with the requirements applicable to our audit.
Non-audit and Audit fees
We have set out a summary of the non-audit
services provided by Forvis Mazars (with related
fees) to Argyll and Bute Council in section 7,
together with our audit fees and independence
assessment.
We are committed to independence and confirm that we comply with the FRC’s Revised Ethical Standard. In addition, we have set out in this section any matters or relationships we believe
may have a bearing on our independence or the objectivity of our audit team.
Based on the information provided by you and our own internal procedures to safeguard our independence as auditors, we confirm that in our professional judgement there are no
relationships between us and any of our related or subsidiary entities, and you and your related entities, that create any unacceptable threats to our independence within the regulatory or
professional requirements governing us as your auditors.
We have policies and procedures in place that are designed to ensure that we carry out our work with integrity, objectivity, and independence. These policies include:
• All partners and staff are required to complete an annual independence declaration.
• All new partners and staff are required to complete an independence confirmation and complete annual ethical training.
• Rotation policies covering audit engagement partners and other key members of the audit team.
• Use by managers and partners of our client and engagement acceptance system, which requires all non-audit services to be approved in advance by the audit engagement partner.
We confirm, as at the date of this report, that the engagement team and others in the firm as appropriate, Forvis Mazars LLP are independent and comply with relevant ethical requirements.
However, if at any time you have concerns or questions about our integrity, objectivity or independence, please discuss these with me in the first instance.
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Confirmation of our independence
Prior to the provision of any non-audit services, Mark Outterside will undertake appropriate procedures to consider and fully assess the impact that providing the service may have on our
independence as auditor.
Principal threats to our independence and the associated safeguards we have identified and/ or put in place are set out in Framework Agreement issued by Audit Scotland available from
the Audit Scotland website: Audit Scotland Framework Agreement (audit-scotland.gov.uk). Any emerging independence threats and associated identified safeguards will be
communicated in our Annual Audit Report.
Any emerging independence threats and associated safeguards we identify or put in place will be communicated to you in our Annual Audit Report.
45
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Appendices
A: Key communication points
B: Current year updates, forthcoming accounting and other issues
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Appendix A: Key communication points
We value communication with you, as a two-way feedback process is at the heart of our
client service commitment. ISA (UK) 260 Communication with Those Charged with
Governance and ISA (UK) 265 Communicating Deficiencies In Internal Control To Those
Charged With Governance And Management specifically require us to communicate a
number of points with you.
Relevant points that need to be communicated with you at each stage of the audit are
outlined below.
Form, timing and content of our communications
We will present the following reports:
▪ Our Annual Audit Plan;
▪ Our Annual Audit Report;
▪ Our independent auditor’s report; and
▪ Our thematic report.
These documents will be discussed with management prior to being presented to
yourselves and their comments will be incorporated as appropriate.
Key communication points at the planning stage as included in this Annual
Audit Plan
Our responsibilities in relation to the audit of the financial statements;
• The planned scope and timing of the audit;
• Significant audit risks and areas of management judgement;
• Our commitment to independence;
• Responsibilities for preventing and detecting errors;
• Materiality and misstatements; and
• Fees for audit and other services.
Key communication points at the completion stage to be included in our
Annual Audit Report
▪ Significant deficiencies in internal control;
▪ Significant findings from the audit;
▪ Significant matters discussed with management;
▪ Significant difficulties, if any, encountered during the audit;
▪ Qualitative aspects of the entity’s accounting practices, including accounting policies,
accounting estimates and financial statement disclosures;
▪ Our conclusions on the significant audit risks and areas of management judgement;
▪ Summary of misstatements;
▪ Management representation letter;
▪ Our proposed draft audit report; and
▪ Independence.
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Appendix A: Key communication points
ISA (UK) 260 Communication with Those Charged with Governance, ISA (UK) 265 Communicating Deficiencies In Internal Control To Those Charged With Governance And Management
and other ISAs (UK) specifically require us to communicate the following:
Required communication Where addressed
Our responsibilities in relation to the financial statement audit and those of management and Those Charged with
Governance.
Annual Audit Plan
The planned scope and timing of the audit including any limitations, specifically including with respect to significant
risks.
Annual Audit Plan
With respect to misstatements:
• Uncorrected misstatements and their effect on our audit opinion;
• The effect of uncorrected misstatements related to prior periods;
• A request that any uncorrected misstatement is corrected; and
• In writing, corrected misstatements that are significant.
Annual Audit Report
With respect to fraud communications:
• Inquiries of the Audit and Scrutiny Committee to determine whether you have knowledge of any actual,
suspected, or alleged fraud affecting the entity;
• Any fraud that we have identified or information we have obtained that indicates that fraud may exist; and
• A discussion of any other matters related to fraud.
Annual Audit Report and discussion at the Audit and Scrutiny
Committee
Audit planning and clearance meetings
Where relevant, any issues identified with respect to authority to obtain external confirmations or inability to obtain
relevant and reliable audit evidence from other procedures.
Annual Audit Report
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Appendix A: Key communication points (continued)
Required communication Where addressed
Significant matters arising during the audit in connection with the entity’s related parties including, when applicable:
• Non-disclosure by management;
• Inappropriate authorisation and approval of transactions;
• Disagreement over disclosures;
• Non-compliance with laws and regulations; and
• Difficulty in identifying the party that ultimately controls the entity.
Annual Audit Report
Significant findings from the audit including:
• Our view about the significant qualitative aspects of accounting practices including accounting policies,
accounting estimates and financial statement disclosures;
• Significant difficulties, if any, encountered during the audit;
• Significant matters, if any, arising from the audit that were discussed with management or were the subject of
correspondence with management;
• Written representations that we are seeking;
• Expected modifications to the audit report; and
• Other matters, if any, significant to the oversight of the financial reporting process or otherwise identified in
the course of the audit that we believe will be relevant to the Council or the Audit and Scrutiny Committee in
the context of fulfilling their responsibilities.
Annual Audit Report
Significant deficiencies in internal controls identified during the audit. Annual Audit Report
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Appendix A: Key communication points (continued)
here
Required communication Where addressed
Audit findings regarding non-compliance with laws and regulations where the non-compliance is material and believed to be intentional (subject
to compliance with legislation on tipping off)} and inquiry of the Audit and Scrutiny Committee into possible instances of non-compliance with
laws and regulations that may have a material effect on the financial statements that the Audit and Scrutiny Committee may be aware of.
Annual Audit Report and the Audit and
Scrutiny Committee meetings
With respect to going concern, events or conditions identified that may cast significant doubt on the entity’s ability to continue as a going
concern, including:
• Whether the events or conditions constitute a material uncertainty;
• Whether the use of the going concern assumption is appropriate in the preparation and presentation of the financial statements; and
• The adequacy of related disclosures in the financial statements.
Annual Audit Report
Communication regarding our system of quality management, compliant with ISQM (UK) 1, developed to support the consistent performance
of quality audit engagements. To address the requirements of ISQM (UK) 1, our firm’s System of Quality Management team completes, as
part of an ongoing and iterative process, a number of key steps to assess and conclude on our firm’s System of Quality Management:
• Ensure there is an appropriate assignment of responsibilities under ISQM (UK) 1 and across Leadership
• Establish and review quality objectives each year, ensuring ISQM (UK) 1 objectives align with the firm's strategies and priorities
• Identify, review, and update quality risks each quarter, taking into consideration the number of input sources (such as FRC / ICAEW review
findings, internal monitoring findings, findings from our firm’s root cause analysis and remediation functions, etc.)
• Identify, design, and implement responses as part of the process to strengthen our firm's internal control environment and overall quality
• Evaluate responses and remediate control gaps or deficiencies
We perform an evaluation of our system of quality management on an annual basis. Our first evaluation was performed as of 31 August 2023.
Details of that assessment and our conclusion are set out in our 2022/2023 Transparency Report, which is available on our website here.
The details of our evaluation of our system of quality management as of 31 August 2024, and our conclusion, will be available in our 2023/24
Transparency Report, which will be available on our website by 31 December 2024.
Annual Audit Plan
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Appendix A: Key communication points (continued)
Required communication Where addressed
An overview of the work to be performed at the components of the group and the nature of our involvement in the
work to be performed by component auditors.
Annual Audit Plan and Annual Audit Report
Instances where our review of the work of the component auditor gave rise to a concern about the quality of the
component auditor’s work, and how we addressed that concern.
Annual Audit Report
Any limitations on the scope of the group audit, for example, significant matters related to restrictions on access to
people or information.
Annual Audit Plan and Annual Audit Report, as necessary
Fraud or suspected fraud involving group management, component management, employees who have significant
roles in the group’s system of internal control or others when the fraud resulted in a material misstatement of the
group financial statements.
Annual Audit Report and discussion at the Audit and Scrutiny
Committee meetings, audit planning meetings, and audit
clearance meetings
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52
Appendix B: Current year updates, forthcoming accounting & other issues Applicable for IFRS Reporters
Current and forthcoming accounting issues
New standards and amendments
Effective for accounting periods beginning on or after 1 January 2023
IFRS 17 Insurance Contracts (issued May 2017) and Amendments to IFRS 17
Insurance Contracts (Issued June 2020)
• IFRS 17 Insurance Contracts (IFRS 17) is a new standard that will replace IFRS 4
Insurance Contracts (IFRS 4). The standard sets out the principles for the recognition,
measurement, presentation and disclosure about  insurance contracts issued, and
reinsurance contracts held, by entities. The amendments, issued subsequently in June
2020, do not change the fundamental principles of IFRS 17 and are aimed at helping
companies implement the standard and make it easier for them to explain their financial
performance. The EU has endorsed the adoption of IFRS 17, although with some
changes to the version issued by the IASB. In May 2022, the UK Endorsement Board
(UKEB) adopted the standard and the associated amendments.
Amendments to IFRS 17 Insurance Contracts: Initial Application of IFRS 17 and IFRS
9 (Issued December 2021)
• The amendments address potential mismatches between the measurement of financial
assets and insurance liabilities in the comparative period because of different
transitional requirements in IFRS 9 Financial Instruments (IFRS 9) and IFRS 17. The
amendments introduce a classification overlay under which a financial asset is permitted
to be presented in the comparative period as if the classification and measurement
requirements of IFRS 9 had been applied to that financial asset in the comparative
period. The classification overlay can be applied on an instrument-by-instrument basis.
The amendments have been UK-adopted and endorsed by the EU.
Amendments to IAS 1 Presentation of Financial Statements and IFRS Practice
Statement 2 Making Materiality Judgements: Disclosure of Accounting Policies
(Issued February 2021)
• The amendments set out notable new requirements for accounting policy disclosures
that change the requirements for entities to disclose material accounting policy
information, rather than significant accounting policies, and not to disclose immaterial
accounting policy information, explaining that accounting policy information taken in
isolation is unlikely to be material, but it is when the information is considered together
with other information in the financial statements that may make it material. Earlier
application is permitted. The amendments have been UK-adopted and endorsed by the
EU.
Amendments to IAS 8 Accounting Policies, Changes in Accounting Estimates and
Errors: Definition of Accounting Estimates (Issued February 2021)
• The amendment introduces a new definition for accounting estimates and clarifies how
entities should distinguish changes in accounting policies from changes in accounting
estimates. The distinction is important because changes in accounting estimates are
applied prospectively only to future transactions and other future events, but changes in
accounting policies are generally applied retrospectively to past transactions and other
past events. Earlier application is permitted. The amendments have been UK-adopted
and endorsed by the EU.
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53
Appendix B: Current year updates, forthcoming accounting & other issues (continued)
Applicable for IFRS Reporters
Current and forthcoming accounting issues (continued)
New standards and amendments (continued)
Effective for accounting periods beginning on or after 1 January 2023
IFRS 18 Presentation and Disclosure in Financial Statements (Issued April 2024)
• IFRS 18 Presentation and Disclosure in Financial Statements (IFRS 18) is a new
standard that replaces IAS 1 Presentation of Financial Statements. The new standard
aims to increase the comparability, transparency and usefulness of information about
companies’ financial performance. It introduces three key new requirements focusing on
the presentation of information in the statement of profit or loss and enhancing certain
guidance on disclosures within the financial statements. Page 61

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54
Appendix B: Current year updates, forthcoming accounting & other issues (continued)
International Auditing Standard UK 600 Revised - Special considerations - Audits of group financial statements (Including the work of component auditors)
ISA UK 600 deals with the special considerations that apply to audits of group financial statements, including those circumstances when component auditors are involved. The auditing
standard has been revised. The revised standard is effective for audits of group financial statements for periods beginning on or after 15 December 2023. The revisions made to ISA (UK)
600 impact how we perform audits of group financial statements, and how we communicate our audit strategy and audit findings arising from audits of group financial statements, going
forward. This page sets out the key changes made to ISA (UK) 600 and how Forvis Mazars will apply the requirements of the revised standard in practice.
Key changes
The previous ISA (UK) 600 included prescriptive requirements in respect of the audit procedures required over ‘significant components’ of a group, i.e., a ‘full scope’ audit of a significant
component’s financial information relevant to the group financial statements was required. Forvis Mazars defined a ‘significant component’ as one that contributed to the group financial
statements more than 15% of the materiality benchmark selected to determine group materiality, e.g., if we had determined materiality using a profit before tax benchmark, any
component that contributed more than 15% of the group’s reported profit before tax would be classified as a significant component and a ‘full scope’ audit would be performed over that
component’s financial information.
ISA (UK) 600 Revised eliminates the 'significant component' concept, opting instead for consideration of risks of material misstatement at the assertion level of the group financial
statements that are associated with components. This results in a group audit that is better focused on the risks of material misstatement of the group financial statements and affords
greater flexibility in how we classify components and how we may design the nature and extent of audit procedures to be performed over a component’s financial information, i.e., we can
determine the nature and extent of the audit procedures to be performed over a component’s financial information based on the specific risks relevant to the group financial statements.
ISA (UK) 600 also, however, removed the option to limit the procedures performed over a ‘non-significant’ component’s financial information to desktop analytical procedures. We are
now required to perform substantive audit procedures (or a combination of substantive audit procedures and tests of controls) over the group financial statements, including the financial
information relating to components in the group, until the residual, untested balances, classes of transaction and disclosures in the group financial statements are below our group
materiality. This is to ensure that aggregation risk (the probability that the aggregate of uncorrected and undetected misstatements exceeds materiality for the financial statements as a
whole) is addressed appropriately.
In combination, these changes may result in a change to the nature and extent of the audit procedures we perform over the financial information of components on a group audit
compared to previous years and may result in components that were not previously in scope of our group audit being brought into scope going forward to ensure that we address
aggregation risk appropriately.
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55
Appendix B: Current year updates, forthcoming accounting & other issues (continued)
International Auditing Standard UK 600 Revised - Special considerations - Audits of group financial statements (including the work of component auditors)
Key changes (continued)
To ensure consistency of approach, Forvis Mazars will apply the definitions set out below when performing audits of group financial statements going forward:
Key component Material component Non-material component
Any component:
i.Which is greater or equal to 15% of
the benchmark chosen for calculating
group materiality (key by size); or
ii.Where the specific nature or
circumstance of its financial
information make it likely to include
significant risks of misstatement of the
group financial statements (key by
risk).
Any component, other than a key
component, that contributes to one or
more group financial statement areas
an amount that is above group financial
statement materiality.
A component, that is not a key
component or a material component,
that is scoped into a group audit to
reduce the risk of material misstatement
of the group financial statements to an
acceptably low level (based on size or
risk) in situations when, after assessing
which components are key components
and material components, the
aggregate amount of a financial
statement area related to un-scoped
components is still above group
financial statement materiality.
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56
Appendix B: Current year updates, forthcoming accounting & other issues (continued)
International Auditing Standard UK 600 Revised - Special considerations - Audits of group financial statements (including the work of component auditors)
Key changes (continued)
Definition of ‘component’ - The definition of ‘component’ has been revised to “an entity,
business unit, function or business activity, or some combination thereof, determined by the
group auditor for the purposes of planning and performing audit procedures in a group
audit”.
This provides clarity on how components may be identified in a group audit and may result
in a change to how we identify components on a group audit compared to previous years.
For example, we may group separate legal entities (e.g., subsidiaries) in a group based on
common characteristics (such as common management, common information systems, and
common geographical locations) and treat those components as a single component, when
appropriate to do so.
Common controls - The definition of ‘group-wide’ controls has been removed and we are
instead required to consider ‘common controls’, being controls that operate in a common
manner for multiple entities or business units.
This may assist us in grouping separate legal entities, business units, functions, or business
activities in a group into a single component for the purposes of a group audit; or it may
result in us grouping specific account balances or classes of transaction recorded by
individual legal entities, business units, functions, or business activities into a single
population for the purposes of our audit procedures.
For audits where we are adopting a controls-based audit strategy, this may result in
efficiencies, as we can rely on a single control for the purposes of the audits of more than
one component where that control is common to those components.
Definition of ‘engagement team’ - The definition of ‘engagement team’ has been revised
to include component auditors. While this change may seem inconsequential, it forms part
of the overall changes intended by ISA (UK) 600 Revised to enhance two-way
communication between the group auditor and component auditors during a group audit.
This will result in enhanced direction and supervision of component auditors by the group
auditor during a group audit.
Calculation of component materiality - The requirement to set overall materiality for a
component has been removed. We are now only required to determine component
performance materiality.
Other changes - ISA (UK) 600 Revised includes new and revised requirements and
application material that better aligns the standard with recently revised standards such
as ISQM (UK) 1, ISA (UK) 220, and ISA (UK) 315. The new and revised requirements
also strengthen our responsibilities related to professional scepticism, planning and
performing a group audit, two-way communications between the group auditor and
component auditors, and audit documentation. These changes are to encourage
proactive management of quality at the group engagement level and the component
level; reinforce the need for robust communication and interactions during a group audit;
and foster an appropriately independent and challenging sceptical mindset.
Scope of audit work to be performed over a component’s financial information -
Forvis Mazars will, going forward, determine the scope of work to be performed over a
component’s financial information on a group audit using the definitions set out below:
Full scope Specific scope
Group Engagement
Team Instructed
Procedures
Designing and performing
audit procedures on the
entire financial information
of a component.
Designing and performing
audit procedures on one
or more specified account
balances, classes of
transaction, and/ or
disclosures of a
component.
Performing specified audit 
procedures, as designed
and instructed by the
group engagement team.
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Contact
Forvis Mazars
www.auditregister.org.uk
Forvis Mazars LLP is the UK firm of Forvis Mazars Global, a leading global professional services network. Forvis Mazars LLP is
a limited liability partnership registered in England and Wales with registered number OC308299 and with its registered office at
30 Old Bailey, London, EC4M 7AU. Registered to carry on audit work in the UK by the Institute of Chartered Accountants in
England and Wales. Details about our audit registration can be viewed at www.auditregister.org.uk under reference number
C001139861. VAT number: GB 839 8356 73
© Forvis Mazars 2024. All rights reserved.
Contact information
Mark Outterside
Director – Public Sector Audit
Tel: 07824 086 593
mark.outterside@mazars.co.uk
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ARGYLL AND BUTE COUNCIL  AUDIT & SCRUTINY COMMITTEE   
FINANCIAL SERVICES  12 JUNE 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
one of 2025/26.  
1.2 Core activities together with a progress update statement are shown below: 
• 2024/25 Audit Plan progress: The plan is complete and all items reported to
the Committee. 
• 2024/25 Individual Audits undertaken: Seven audits have been completed
during the period, one has been assessed as providing high assurance, three
substantial assurance and three reasonable assurance. There is one report
concerning LiveArgyll issued since the last Committee. (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 later
in the calendar year. 
• 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. The established CFT
team member is on secondment to Housing for career and personal
development for a two year period.  The CFT have obtained a member of
staff, again on secondment for the same time period who has recently
completed the CIPFA Fraud Specialist Course. The team lead is currently
progressing through year 3 of a Master in Accountancy course.   
• Continuous Monitoring Programme Testing: A number of auditable units
are subject to continuous testing. There have been no new issues which we
have identified this quarter. 
• Performance indicators: Current status is green / on track.   
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2. RECOMMENDATIONS  
2.1 To review and endorse the Summary of Activities report.   
3. DETAIL  
3.1 Seven audits have been completed since the previous Committee in March 
2025. In addition, visits were undertaken to Coulcil depots in Lochgilphead,
Helensburgh, Dunoon and Rothesay which are detailed in section 5 of the
report, together with our work undertaken for the HSCP. 
Audits Completed 
• Short Term Lets
• Bridges Asset Management Plan 
• Asbestos Management 
• External Placements 
• Trading Standards 
• Leasing  - IFRS16
• Disclosure Checks - Protecting Vulnerable Groups (PVG) 
Audits in Planning / in Progress
reported to a future meeting of the Committee. 
• LGBF
• SPT Annual Claim
• Education Maintenance Allowance
• Payroll – iTrent 
3.2 In addition to those already in progress, indicative audits planned for Q2 2025/26
are: 
• School Residential Trips
• Music Service
• Reporting Concerns at Work – Whistleblowing Policy
• HSCP - Audits 
2025/26 Audit Plan  
3.3 Work is ongoing and is currently on track at this point in time. 
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Scrutiny  
3.4 It was agreed by the Committee that the chosen subject area for the 2024/25
scrutiny review would be on the Council’s complaints process.  This review has
now concluded and is reported as a separate agenda item at this committee. 
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
Waste (BMW) Landfill Ban.  A report is submitted to this Committee outlining the
suggested approach and appointment of the Panel to undertake this work.  A
background and scoping document will be prepared and issued to the Panel
members for agreement in due course.     
Counter Fraud  
3.5 The CFT is progressing well with both team members fully CIPFA accredited fraud
investigators. The current investigator has taken on a 2 year secondment to empty
homes for further skills development.  The investigator post was filled again on a
secondment basis.  The new member of staff has completed and passed the
CIPFA Fraud Specialist course. 
Both team members will revert to substantive post circa September 2025. 
Continued routine work is still progressing to track the full income recovered from
the team’s work, however, based on the amount of additional billing, even
accounting for a degree of non-recovery, the indications are that the team are still
exceeding their 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. 
Visits continue to play a vital role in the CFTs proactive and reactive work.  Recent
visits have taken place in Islay, Rothesay, Helensburgh, and Luss, the review for
Oban has been completed with both non-domestic rates and Council tax being
reviewed and rebilled.   
Both officers continue to be proactive and make visits when information is recieved
via the online portal and outher islands will soon be visited. 
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. 
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. 
The CFT now have an established referral system in place from council tax teams
and have already liaised with this team going forward into 2025 for the review of
the second and holiday home tax changes.  The aim is to assist with the single
person discount review within 2025. 
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
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identifying and finding appropriate solutions to enable empty homes to return to
residency or open market. 
The NFI exercise continues to be a routine work area for the CFT.  The 2024/2025
exercise has commenced with matches already being progressed, with additional
matches having recently been released.  Review and matches are completed
periodically. 
Since the inception of the CFT a total of £1,411,068 has been rebilled and
£924,810 has been recovered. A recovery percentage of 65% has been achieved
at the last review of the figures. Due to other commitments the rebilling has yet to
be checked and updated. 
Additional Updates from Quarter Four  
3.6 A series of visits to Council depots and HSCP Integrated Equipment Stores was
undertaken to verify quantities and values of stock items submitted for year-end
accounting purposes.  Stock items were found to be stored safely and securely
with robust systems an processes in place to provide accurate counts and
reasonable measurements, and whilst small differences were identified, the overall
value was found to be immaterial.    
3.7 We have been working closely with the Council’s HR and Payroll Teams to obtain
a suite of reports from the new system to inform our Continuous Monitoring
Programme.  These reports had not been provided since this system was
implemented in August 2024 due to development issues, however, a significant
amount of work has taken place by the development team and reports have now
been delivered.  Work has commenced to progress testing with the information
provided for the period August 2024 – March 2025, thereafter regular monthly and
quarterly reporting in addition to self-service functionality has been arranged for
future testing requirements.   
3.8 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
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.  
3.9 Our work as the contracted Internal Auditors for the HSCP has been progressing
well and priority has been given in this area due to the availability of staff, work has
completed for 2024/25 and commenced 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. 
3.10 Internal Audit staff continue to increase their skills and ultimately aim to complete
appropriate professional qualifications at the end of their training programmes.
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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  
3.11 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 have been no new findings within the quarter that
require to be reported. 
Table 2: Continuous Monitoring Findings 
Auditable
Area
Areas Tested Issues Identified Management comment /
action  
No issues identified. 
3.12 A follow up process is in place whereby management are advised of continuous
monitoring findings and, where appropriate, requested to take remedial action. 
There are currently no outstanding follow-up points arising from previous testing. 
Due to the volume of continuous monitoring tests carried out the decision was
made to report by exception only.      
National Reports  
3.13 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 four of 2024/25 due to be reported in quarter one of 2025/26.   
Table 3: National Reports 
National Report Issued To Detail Management response/
Action taken
Local
government in
Scotland:
Financial
Bulletin 2023/24
Executive
Director Kirsty
Flanagan
Scotland’s councils
continue to face
severe financial
pressures.  The
need to consult
with communities,
clearly
communicate the
impact on local
services, whilst
working together to
shape and deliver
The Interim Head of Financial
Services presented a report to
the Executive Leadership Team
on 11 March and is included as
a separate agenda item at this
committee.
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urgently needed
transformation , is
more important
than ever.
A review of
Housing Benefit
overpayments
2018/19 to
2021/22
Executive
Director Kirsty
Flanagan
Audit Scotland’s
Housing Benefit
overpayment
study.
The Council’s performance in
Housing Benefit overpayment
recovery is very strong,
consistently exceeding the
national average. The only
action required is to review and
update the existing
management checking protocol.
This will ensure it remains fit for
purpose, aligns with the
responsibilities of the newly
formed Revenues and Benefits
Business Support Team, and
that all management checks are
up-to-date, targeted, and
proportionate to the current
caseload and operational
challenges.
Additional
Support for
Learning
Executive
Director
Douglas
Hendry
The Scottish
Government and
Councils must
fundamentally
rethink how they
plan, fund and staff
additional support
for learning as part
of core school
education in
Scotland.
Following consideration of the
report and in terms of the
recommendations, if the
Scottish Government
determines these are being
taken forward, they will take the
lead on these matters at a
national level and we will
engage with them as
appropriate. 
Integration Joint
Boards Finance
bulletin 2023/24
Chief Officer
HSCP
Community health
and social care
finances are
increasingly
precarious. 
Integration Joint
Boards must
urgently work with
their partners in the
NHS and Councils
to reform how they
deliver services to
achieve financial
sustainability.
A summary of this report was
included in the HSCP Finance &
Policy Committee agenda on 19
May and will be considered at
the Audit and Risk Committee
on June 20.
The HSCP is in the process of
seeking approval for its financial
recovery plan and is developing
savings proposals to address
the issues raised by Audit
Scotland in respect of financial
sustainability in the Health and
Social Care Sector. 
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National Fraud Initiative (NFI)  
3.14 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.  
3.15 The previous NFI exercise has been completed and results are being compiled by
Audit Scotland.  Any follow up matches will be addressed if necessary.
This exercise was conducted throughout the year by officers and matches checked
and closed accordingly.  NFI provided additional data releases over the course of
the exercise and matches are addressed when these become available.   
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 and progress will be monitored monthly by the Counter Fraud team and
reported quarterly to the Audit and Scrutiny Committee.
New HMRC data has been uploaded and released back to us, and teams have
been contacted to start matching this data.    
3.16 The new 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. 
Table 4: National Fraud Initiative Progress at 18/05/2025
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 0 0
CT to HMRC
Household
Composition
1106 0 0 0
Housing
Benefits
13 9 9 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 10 3 Payroll records to other
datasets including other
payrolls and pensions to
ensure employee is not
receiving additional
income.
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Blue Badges 200 200 149 0 Blue badge records to
DWP data to identify
deceased claimant with
valid badge.
Housing
Waiting list
262 262 159 2 Housing waiting list
records to other
organisations HBCTR and
tenant data to identify
undisclosed changes in
circs or false info.
Council Tax
Reduction
245 174  46 1 CTR records with records
in other authorities / other
datasets including; student
loans, payroll and pensions
to identify undeclared
income and capital
Creditors 2340 0 573  1 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 0 0 Business rates records
within and between
authorities to identify
those fraudulently claiming
small business bonus
scheme and grants 
* Work in Progress
Overall Summary of Matches 
Matches
Complete
Work In
Progress
Cleared Frauds Errors Total
Value 
£
Recovering Recovering
Value 
£ 
3382  7 3312 0 70 54,786  0 
Internal Audit Development  
3.17 The table below details progress against the action points in our Internal Audit
development plan.   
Table 5: Internal Audit Development Key Actions: updated 31/3/25. 
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 September
2025 
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3.18 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 2024– 25 – FQ4 24/25 (as at March  2025)
BO115 We Are Efficient and Cost Effective    
Internal Audit Level of Satisfaction
Actual  97% 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% 
4 CONCLUSION  
4.1 The 2024/25 plan is complete and 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: 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
12 June 2025
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Page 77

ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE                                                            
FINANCIAL SERVICES  12 June 2025 
INTERNAL AND EXTERNAL AUDIT REPORT FOLLOW UP 2024-25 
1.0 INTRODUCTION 
1.1 Internal and external audit reports include an action plan with a
management response establishing the agreed action, timescale and
responsible officer. Internal Audit record these in a database and, on a
monthly basis, follow them up to ensure they are being progressed. 
1.2 This report updates the committee on all open actions as at 31 March
2025 including information on actions where the agreed implementation
date has been rescheduled.   
2.0 RECOMMENDATIONS 
2.1 To endorse the contents of the report. 
3.0 DETAIL 
3.1 The two tables below provide a numerical summary of open audit actions
with a split between actions due by and due after 31 March 2025. 
3.2 Appendix 1 provides further detail on actions that have been delayed and
rescheduled. 
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Table 1 - Actions Due by 31 March 2025 
SMT/Service
Complete
Delayed/
Rescheduled
Total
Internal Audit
DH – Education Performance & Improvement 0 1 1
DH – Legal & Regulatory Support 1 1 2
KF – Customer Support Services 1 0 1
KF – Development & Economic Growth 0 1 1
KF – Roads & Infrastructure Services 5 4 9
KF – Financial Services 7 1 8
H&SCP (IJB) – Strategic Planning & Performance 0 6 6
H&SCP (IJB) – Adult Services (Older Adults & Community Hospitals 1 1 2
H&SCP (SW) – Adult Services (Mental Health Learning Disability,
Addictions & Lifelong Conditions)
0 5 5
LiveArgyll 1 0 1
External Audit
Nil   
TOTAL 16 20 36 
Table 2 - Actions due after 31 March 2025 
SMT/Service
Complete
On Course
Total
Internal Audit
DH – Commercial Services 0 1 1
DH – Education Performance & Improvement 0 3 3
KF – Customer Support Services 1 0 1
KF – Development & Economic Growth 0 3 3
KF – Roads & Infrastructure Services 0 10 10
KF – Financial Services 0 7 7
H&SCP (IJB) – Adult Services (Older Adults & Community Hospitals 0 1 1
H&SCP (IJB) – Strategic Planning & Performance 0 2 2
H&SCP (SW) – Adult Services (Older Adults & Community Hospitals) 0 1 1
H&SCP (SW) – Children and Families and Criminal Justice 0 2 2
H&SCP (SW) – Finance/Transformation 0 2 2
H&SCP (SW) – Strategic Planning & Performance 0 2 2
External Audit
Nil   
TOTAL 1 34 35 
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4.0 CONCLUSION 
4.1 Satisfactory progress continues to be made implementing audit actions. 
5.0 IMPLICATIONS 
5.1 Policy: none
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: none
5.10 Consumer Duty: none
5.11 Island Communities: none
5.12 Children’s Rights and Wellbeing: none 
Paul MacAskill
Chief Internal Auditor
12 June 2025                                                  
For further information contact: Paul MacAskill, 01546 604108
Paul.macaskill@argyll-bute.gov.uk 
APPENDICES
Appendix 1 – Action Plan Points Delayed and Rescheduled.
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Appendix 1 - Action Plan Points Delayed & Rescheduled 
Actions Plan Points due by 31st March 2025 
Service, Report, Plan no. & Finding Agreed Action Dates Management Comment Responsible Officer
Medium
COMMERCIAL SERVICES 
EDUCATION PERFORMANCE & IMPROVEMENT
SCHOOL FUNDS & MANAGEMENT OF FUNDS 
2. Communicating amendments and updates  
Feedback from schools found that some clerical
staff and some committee members are
unaware of EMC 1.10 and therefore are
unaware of the standard processes and
templates.  Future updates and amendments to
EMC 1.10 should be communicated to all staff in
schools. 
Following update of Management
Circular information will be
cascaded to HTs and clericals. Will
be put on HT agenda for
discussion. 
31/03/2025
30 Apr 2025 
Delayed due to work priorities
and school holidays. 
Delayed and Rescheduled 
School Services Support
Manager 
Low
LEGAL & REGULATORY SERVICES 
Freedom of Information 
3. Publication Scheme  
The Council’s Publication scheme not updated
since May 2021, and the Council’s website was
updated in 2023.  A review of the Council’s
Publication scheme should be undertaken,
including checking that any links to information
are still working. 
Review and Update Publication
Scheme, publish on Website and
provide link to Audit. 
31/03/2025
30 Jun 2025 
Report still to be considered by
DMT & ELT. Subject to approval,
report will be published by end
of April. 
Delayed and Rescheduled 
Compliance &
Regulatory Officer 
Medium
DEVELOPMENT & ECONOMIC GROWTH 
PLANNING 
1. Staff Training Planning do not currently have
in place a training schedule for 2023/24 for
planning officers. 
Once the incorporation of the IDOX
project is completed a training
schedule will be introduced
covering both the new system and
other relevant areas such as the
National planning for framework 4. 
31/03/2024
31/12/2024
31/03/2025
30 Jun 2025 
Work has progressed on
delivery of urgent training, most
recently with delivery of
training on Ancient Woodlands
in February 2025 however a
longer term plan which
identifies resources and a
programme for delivery is still
Process and
Productivity
Improvement Officer 
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Service, Report, Plan no. & Finding Agreed Action Dates Management Comment Responsible Officer
being worked upon. 
Delayed and Rescheduled 
Medium
FINANCIAL SERVICES 
Non Domestic Rates (NDR) 
1. Entitlement to SBBS Relief  
During the testing process of records it was
found that there was very little in the way of
supporting documentation to substantiate
claims for reliefs, in particular for SBBS relief. 
There are no further checks undertaken to
ensure that where relief is applied that the
business is still trading and entitled to this relief. 
SBBS is reviewed a minimum of
every two years by the NDR team. 
Over and above that review the
team will produce an annual
schedule to check and verify that
the properties in receipt of SBBS
are still in active use. Some of this
review will be desk based however
a list of higher risk properties will
be split by area and issued to
Council Officers operating in that
area for inspection and manual
verification.  Any other reliefs that
are deemed higher risk can be
added to the
inspection/verification list. The first
schedule will be drafted by 31
March 2025 for the 2025/2026
year. 
31/03/2025
30 Jun 2025 
List provided to potentially
complete this action are
problem cases that have been
identified and not whether
properties are in use. 
Delay due to breakdown in
communication with NDR team. 
Delayed and Rescheduled 
Revenues and Benefits
Manager 
Low
ROADS & INFRASTRUCTURE SERVICES 
BRIDGE ASSET MANAGEMENT PLAN 
4. Audit Trail re Late Inspections  
The audit found that there is currently no audit
trail within the WebSMS sysytem (WDM) to
document late inspections, including reasons for
delay, actions taken and stakeholder
communication. 
Late Inspections are currently
being recorded manually via a
report infrastructure.  Design can
export on WDM as to which
reasons are added by the
Infrastructure Design team. An
automatic report is currently being
built within WDM that will send a
late inspections report.  Late
inspections and actions needed to
ensure they are undertaken will
form part of the quarterly
reporting to RIS senior
31/03/2025
30 Jun 2025 
Initial implementation of this is
in place. Monthly email being
automatically sent to
Infrastructure Design from
WDM with log of Late
Inspections. Work required to
rectify a number of errors
generated. Expected to be
developed to suitable stages by
30/06/2025. 
Delayed and Rescheduled 
Infrastructure Design
Manager 
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Service, Report, Plan no. & Finding Agreed Action Dates Management Comment Responsible Officer
management team. This will enable
the Infrastructure Design Team to
highlight risks, articulate
mitigations and to seek support
where required to implement
these. 
VFM
ROADS & INFRASTRUCTURE SERVICES 
External Hire 
4. Evaluating whether long term hires should be
leased or purchased outright There is currently
no mechanism that triggers an exercise where
“finance” considers whether cheaper long term
finance options are available such as an
operating lease or for the Council  to purchase
an item outright 
Roads and infrastructure services
are currently under a review of all
services and the recommendation
will be assessed as part of the
review. 
31/03/2024
31/12/2024
31/03/2025 
31 Dec 2025 
This work will be part of a wider
review in terms of a Fleet
Strategy and will be completed
by the end of the calendar year. 
Delayed and Rescheduled 
Principal Accountant,
Roads and
Infrastructure Services 
Low
ROADS & INFRASTRUCTURE SERVICES 
PIERS & HARBOURS 
7. Income Gaps  
We reviewed the fees and charges agreed by
the Council and compared these to fees and
charges applied in other piers and harbour
throughout Scotland, including Clydeport. It was
found that there were potential gaps. 
Complete a review of potential
new charges for Harbour Board
approval in Fees and charges
report. 
30/11/2024
28/02/2025
31/12/2025 
This will be considered as part
of the budget process for 2026. 
Delayed and Rescheduled 
Marine Operations
Manager 
VFM
ROADS & INFRASTRUCTURE SERVICES 
Pupil & Public Transport 
5. Cost and demand pressure Requests for
home to school transport for ASN placements
are a  direct driver for costs within School
Cost pressures relating to the
provision of ASN pupil transport
will be discussed during budget
holder engagement meetings and
handled in accordance with
corporate budget processes. 
31/03/2025
30 Sep 2025 
This action remains open until
Executive Directors agree the
outcome of funds. 
Delayed and Rescheduled 
Fleet, Waste and
Transport Manager 
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Service, Report, Plan no. & Finding Agreed Action Dates Management Comment Responsible Officer
Transport team, however these budgets sit
within different Services, namely Education and
Roads and Infrastructure, so have different
reporting structures. Any additional cost
pressures, relating to the provision of ASN pupil
transport, due to increased demand should be
escalated in accordance with corporate
budgeting processes, by the budget holder. 
Medium
STRATEGIC PLANNING AND PERFORMANCE 
H&SCP - Joint Strategic Planning 
1. Alignment of JSP to Workforce Plan  
In order to support the delivery of the JSP it is
important that a corresponding workforce plan
is in place that is aligned with priorities and
objectives of the JSP and that it supports the
attraction, recruitment, development and
retention of the workforce required to deliver
the JSP. A review of the workforce plan noted
that there was no evidence of a direct
alignment between the current workforce
planning document and the priorities and
objectives set forth in the Joint Strategic Plan. 
HSCP will look to develop the next
workforce plan to ensure direct
alignment with the priorities and
objectives outlined in the Joint
Strategic Plan (JSP) for 2022-2025. 
31/03/2025
31 Dec 2025 
Council workforce plan is due in
May, NHS workforce plan is due
in July. The Joint Strategic Plan
will be presented in draft to the
IJB in September 2025 then
shared for consultation with
communities. The Strategic
workforce oversight group is
developing an annual work-plan
with partner reps to ensure that
all aspects of workforce
planning are looked at
collectively for action and
monitored.  Workforce is a
strategic risk and this is
reflected in draft priorities (as
yet to go through the
governance). 
Delayed and Rescheduled 
Head of Strategic
Planning, Performance
and Technology 
Medium
STRATEGIC PLANNING AND PERFORMANCE 
HSCP CULTURE 
1. Surveys 
Recent surveys undertaken by each organisation
do not focus specifically on the HSCP in terms of
HR leads within ABC and NHSH to
review survey landscape and
explore joint survey option over
and above existing employer only
surveys.  To report to SLT and JPF. 
31/03/2025
30 Sep 2025 
The ‘imatter’ survey will run
mid-May for all HSCP staff and
we will await the outcomes of
this survey and then determine
what areas need to be
considered therefore no
additional survey will be
Depute Director of
People, NHS Highland 
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Service, Report, Plan no. & Finding Agreed Action Dates Management Comment Responsible Officer
culture (how are the services working together,
communicating with each other, sharing
information), instead focusing on staff
experiences in each organisation. 
undertaken. 
Delayed and Rescheduled 
Medium
STRATEGIC PLANNING AND PERFORMANCE 
HSCP CULTURE 
2. Work Plan 
The work plan outlines priorities, outcomes,
responsible person and timeframes. However,
these are not specific, targeted or in some
instances easily measurable with target dates
for completion marked as ‘ongoing’. 
Refresh and review of the remit
and purpose of the Culture Group. 
The work plan will be included as
part of the review to focus on
meaningful action and timescales. 
31/03/2025
30 Sep 2025 
The decision has been made to
cease the Culture Group and to
incorporate into the Joint
Partnership Forum but not in a
same way as it was before. The
agreed action doesn’t change
and supporting documentation
will be required to complete
this action. The Culture Group
will require to be embedded
into the new group. 
Delayed and Rescheduled 
Depute Director of
People, NHS Highland 
Medium
STRATEGIC PLANNING AND PERFORMANCE 
HSCP CULTURE 
3. Monitoring Progress 
There does not seem to be progress notes
assigned to the work plan therefore difficult to
assess, without reading every meeting note
what progress has made. In addition as noted
above a number of targets dates are simply
noted as ‘ongoing’. 
Refresh and review of the remit
and purpose of the Culture Group
to include timescales and progress
reporting as appropriate. 
31/03/2025
30 Sep 2025 
The decision has been made to
cease the Culture Group and to
incorporate into the Joint
Partnership Forum but not in a
same way as it was before. The
agreed action doesn’t change
and supporting documentation
will be required to complete
this action. The Culture Group
will require to be embedded
into the new group. 
Delayed and Rescheduled 
Depute Director of
People, NHS Highland 
Medium
STRATEGIC PLANNING AND PERFORMANCE 
HSCP CULTURE 
Chief Officer to communicate
commencement of surveys to all
staff via CO comms. 
31/03/2025
30 Sep 2025 
The ‘imatter’ survey will run
mid- May for all HSCP staff and
we will await the outcomes of
this survey and then determine
Chief Officer 
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Service, Report, Plan no. & Finding Agreed Action Dates Management Comment Responsible Officer 
4. Survey Participation 
The results of surveys have demonstrated
engagement and participation by HSCP staff
could be improved. 
what areas need to be
considered therefore no
additional survey will be
undertaken. 
Delayed and Rescheduled 
Medium
STRATEGIC PLANNING AND PERFORMANCE 
HSCP CULTURE 
5. Culture and Wellbeing Group 
Whilst the Culture Group is open to all staff
across the HSCP, there is a greater proportion of
representation of NHS staff. 
As per refresh and review of
Culture Group, review membership
as a result of revised remit and
purpose. 
31/03/2025
30 Sep 2025 
The decision has been made to
cease the Culture Group and to
incorporate into the Joint
Partnership Forum but not in a
same way as it was before. The
agreed action doesn’t change
and supporting documentation
will be required to complete
this action. The Culture Group
will require to be embedded
into the new group. 
Delayed and Rescheduled 
Depute Director of
People,  NHS Highland 
High
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO) 
CLIENT FUNDS 
6. Unaccounted Funds 
Detail Restricted 
Detail Restricted  30/06/2023
31/08/2023
31/12/2023
31/03/2024
30/09/2024
31/03/2025
30 Jun 2025 
Detail Restricted 
Delayed and Rescheduled 
SW Admin Manager 
Medium
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO) 
CLIENT FUNDS PROGRESS REVIEW
Detail Restricted  30/09/2024
31/03/2025
30 Jun 2025 
Detail Restricted 
Delayed and Rescheduled 
SW Admin Manager 
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Service, Report, Plan no. & Finding Agreed Action Dates Management Comment Responsible Officer 
1. Procedures   
Detail Restricted 
Medium
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO) 
CLIENT FUNDS PROGRESS REVIEW 
2. Meeting service users financial needs 
Detail Restricted 
Detail Restricted  30/12/2024
31/03/2025
30 Jun 2025 
Detail Restricted 
Delayed and Rescheduled 
SW Admin Manager
Medium
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO) 
CLIENT FUNDS PROGRESS REVIEW 
3. Implementation of new working practices 
Detail Restricted 
Detail Restricted  31/08/2024
31/12/2024
31/03/2025
30 Jun 2025 
Detail Restricted 
Delayed and Rescheduled 
SW Admin Manager 
Medium
ADULT SERVICES (MENTAL HEALTH LEARNING
DISABILITY, ADDICTIONS & LIFELONG
CONDITIONS/CSWO) 
Learning & Physical Disability Care Packages 
3. Case Notes   
Case notes are maintained on Eclipse, the
replacement client database for Carefirst. It was
noted that case notes were not always
maintained and up to date. 
· Record keeping session(s) to be
delivered by professional lead   
· Senior Managers to implement
case note audit within their 
respective services – this should be
linked to individual practitioner 
supervision 
30/06/2024
31/12/2024
31/03/2025
30 Sep 2025 
Examples will be provided
throughout the next few
months. 
Delayed and Rescheduled 
Senior Managers (Adult
Services) 
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Service, Report, Plan no. & Finding Agreed Action Dates Management Comment Responsible Officer
Low
ADULT SERVICES (OLDER ADULTS &
COMMUNITY HOSPITALS) 
Scottish Social Services Council (SSSC) 
Registration
3. Service-user information  Finding;  Service-
users and their family, friends and non-Council
carers are advised that violence, threats or
abuse towards them from Council employees
will not be tolerated, however, only one
handbook provided advised visitors on expected
conduct regarding violence, threats or abuse
towards employees. There was no
documentation containing information
regarding conduct of service users towards
employees.  Recommendation; Service-user
documentation should be revised to advise that
instanced of violence, threats or abuse directed
towards employees is not acceptable. 
Review all social work and social
care service user documentation in
adult services. 
31/08/2024
31/12/2024
28/02/2025
30 Sep 2025 
All the managers have ensured
this information is displayed
and available within the care
home information/introduction
paperwork. The whole
documentation review is more
complex and still a work in
progress. 
Delayed and Rescheduled 
Senior Manager -
Resources/Professional
Lead - Social Work 
Action Plan Points due after 31st March 2025 
Nil 
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Page 89

ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE 
FINANCIAL SERVICES  12 JUNE 2025 
INTERNAL AUDIT REPORTS TO AUDIT AND SCRUTINY COMMITTEE 2025/2026 
1. EXECUTIVE SUMMARY 
1.1 There are seven audits being reported to the Audit and Scrutiny Committee.     
1.2 The table below provides a summary of the conclusions for the audits performed.
The full reports are included as appendices to this report. 
Audit Name Level of
Assurance
High
Actions
Medium
Actions
Low
Actions
VFM
Actions
Short-Term Lets Substantial 1 1 0 0
Asbestos Management Reasonable 0 5 4 0
Bridges Asset Management Reasonable 1 1 2 0
Trading Standards High 0 0 0 0
External Placements  Reasonable 0 7 0 0
IFRS 16 - Leasing Substantial 0 0 1 0
Disclosure Checks – PVG – LiveArgyll Substantial 0 1 1 0 
1.3 Internal Audit provides a level of assurance upon completion of audit work. A
definition for each assurance level is documented in each audit report. 
2. RECOMMENDATIONS 
2.1 Audit and Scrutiny Committee to review and endorse this summary report and
the detail within each individual report. 
3.  DETAIL 
3.1 A high level summary of each completed audit report is noted below: 
Short Term Lets: this audit provided a substantial level of assurance.  This
means that internal control, governance and the management of risk is sound.
However, there are minor areas of weakness which put some system
objectives at risk and specific elements of residual risk that are slightly above
an acceptable level and need to be addressed within a reasonable timescale.
Policies and procedures have been put in place in respect of the Short Term
Lets scheme, a total of 9 policies were made available for review. Whilst the
policies and procedures in place are comprehensive, there are some elements
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of the policies that require to be completed in parts. Other developments,
including within the Oracle system have still to be progressed.  Processes and
controls in place are robust and ensure that applications are processed in
accordance with procedures.  Applications are processed through an online
‘bespoke’ oracle based database system (developed by Argyll & Bute Council
IT service), completed by the applicant.  Notes for Licencing Assistants are in
place which provide guidance on what to look for when carrying out first
checks in order to validate an application.  Licences are not issued until all
relevant supporting evidence has been submitted, any objections to the
applications (if applicable) have been considered, relevant consultations have
been undertaken and payment of licence fee has been received. Applications
can take some time to process, however, this is not due to inefficiencies in
processing, rather due to the applicant not providing all the information or
supporting evidence at that time of the application. Oracle could be updated to
include compulsory fields to ensure that applications cannot be submitted until
all relevant supporting documentation has been attached resulting in
efficiencies in processing applications. Fees and charges have been agreed
and set by the Council prior to the commencement of the Short Term Lets,
these charges will apply for the initial three year phase of the licence. 
Comprehensive details of the charges applied for Short Term Lets are
available on the Council website. 
Asbestos Management: this audit provided a reasonable level of assurance. 
This means that internal control, governance and the management of risk are
broadly reliable. However, whilst not displaying a general trend, there are areas
of concern which have been identified where elements of residual risk or
weakness may put some of the system objectives at risk. The Council has the
Asbestos Management Plan (the 2013 Plan) in place to manage its duty relating
to the risks associated with asbestos-containing materials (ACMs) across
Council establishments.  This should be updated to ensure it reflects the current
Council structure and revised working practices. HSE guidance requires that
individual buildings plans should be monitored and reviewed every 12 months
or sooner if necessary. Of the 188 required premises, 186 have had a re-
inspection within the last 12 months. The Council has procedures and guidance
in place to follow if ACMs are disturbed, these are detailed in the plan and
published in the Facility Responsible Person section on the Hub. The Health
and Safety Team and Property Services identified gaps in awareness amongst
staff and potential to consolidate the information available. A pilot scheme
providing training to site responsible persons, within Education Services, has
been developed and carried out by Health and Safety staff. This has proven
successful and is planned to be rolled out across all Council Services. There is
no clear mention of the retention period for the various documents relating to
the management of asbestos.  A review of the processes and training materials
associated with the management of asbestos, is currently underway, once
completed the 2013 Plan will be updated. 
Bridges Asset Management: this audit provided a reasonable level of
assurance.  This means that internal control, governance and the management
of risk are broadly reliable. However, whilst not displaying a general trend, there
are areas of concern which have been identified where elements of residual risk
or weakness may put some of the system objectives at risk. The Infrastructure
Design team lacks a documented procedure to ensure compliance with the
relevant national Codes of Practice relying instead on national Codes of
Practice and Standards and the WebSMS system. The infrastructure team
should develop its own documented procedure for bridge inspections to ensure
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and document the process for compliance with the Well-managed Highway
Infrastructure Code of Practice and DMRB CS 450. A review of inspection
reports from the WebSMS system confirmed that inspections are
comprehensive and adhere to the 'Well-managed Highway Infrastructure' Code
of Practice and DMRB CS 450 standards. A structured performance reporting
framework should be established to distribute reports to key stakeholders, and
include performance updates to Departmental Management Team (DMT)
meetings. Formal records should be maintained for all training completed by
Bridge Inspectors, including certification courses and in-house training on the
WebSMS asset management system, to enhance accountability and ensure
compliance with training requirements. The infrastructure team should establish
an audit trail within the WebSMS system to document late inspections, including
reasons for delays, actions taken, and stakeholder communication, to enhance
transparency and accountability. 
Trading Standards: this audit provided a high level of assurance. This means
that internal control, governance and the management of risk are at a high
standard. Only marginal elements of residual risk have been identified with
these either being accepted or dealt with. A sound system of control designed
to achieve the system objectives is in place and being applied consistently. The
Council’s Constitution, Scheme of Authorisations and Delegations allows for the
nomination and authorisation of officers to carry out the duties pertaining to the
enforcement of the various public protection legislation, which includes
consumer protection, fair trading and trading standards. Staff are issued with
warrant cards to act in accordance with, and to enforce, certain legislation based
on the professional qualifications they hold. The Trading Standards team follow
guidance and protocols relating to testing and enforcement of age restrictions
on tobacco and vapes (NVP), issued by the Scottish Government and the
Society of Chief Officers of Trading Standards in Scotland (SCOTSS). The
Council has a duty to prepare and carry out an annual programme of
enforcement. The annual Trading Standards Service Plan details the tasks and
actions team will take to meet the required standards and priorities for that year.
Observation of Test Purchase visits confirm that staff follow the guidance issued
by the Scottish Government and SCOTSS. Performance is reported internally
to Legal and Regulatory Support - Governance, Risk and Safety Managers
meeting, Department Team Meetings (DMT) and Senior Management Team
(SMT) meetings and externally to SCOTSS. The Trading Standards team
exceeded the statutory performance for advice visits and test purchase visits in
the financial year 2024/25. Two breaches were identified in relation to the sale
of tobacco products to someone under the age of 18. Fixed Penalty notices
were issued and promptly paid. 
External Placements: this audit provided a reasonable level of assurance. This
means that internal control, governance and the management of risk are broadly
reliable. However, whilst not displaying a general trend, there are areas of
concern which have been identified where elements of residual risk or
weakness may put some of the system objectives at risk.  An Option Appraisal
Meeting Practice Guidance Document (the Document) dated 2021, is in place
which outlines the agreed approach between Argyll and Bute Education
services and HSCP children’s services when considering possible care options
for any Looked after and accommodated young person.  The option appraisal
process clearly seeks to consider all options open to meet the needs of the
young person and where a child requires care, and where there are no kinship
options, the options appraisal process aims to match the child to the most
appropriate available care option. Roles and responsibilities are detailed in the
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document, however, it has not been updated to reflect the role of the Care
Assessment Reviewing Officers (CARO) in the process.  The processes for
consideration being given to an external placement are robust with a Multi-
agency Options Appraisal Panel being convened.  In addition, significant
scrutiny and oversight is also given to external placements.  Care plans are kept
up to date and amended following any interventions or reviews.  Care providers
do not routinely provide regular updates to Social Work or Education on
progress being made or whether outcomes are being achieved. The lack of
regular updates makes it challenging to monitor and adapt care plans where
goals and interventions are not meeting the needs of the young person.  It was
unclear whether there were robust procedures and monitoring in place for young
people leaving care with many returning to their previous locations.  Like other
authorities, the Council has very little control over the cost of external
placements, with providers setting the cost against a background of competing
demands from authorities throughout Scotland. The cost of individual care
packages is significant and can cost up to £10k per week, the demand is
projected to rise in line with the profile of the last few years. In many cases there
are no internal resources available to meet the needs of the young person,
leaving the only option open to the Authority to place externally.  It is difficult to
assess whether the Council is receiving value for money for each individual
placement, particularly if outcomes are not achieved or the placement does not
result in a positive destination, however, it is recognised that against this
backdrop, young people are provided with a safe environment. The increasing
demands within the Council is resulting in significant budget overspends. 
IFRS 16 - Leasing: this audit provided a substantial level of assurance.  This
means that internal control, governance and the management of risk is sound.
However, there are minor areas of weakness which put some system objectives
at risk and specific elements of residual risk that are slightly above an
acceptable level and need to be addressed within a reasonable timescale.
Procedures and systems have been put in place to ensure compliance with
IFRS 16. Initial work began in 2020 to start the process of collating information
of leases within the Council.  In June 2023 the Council’s consultant agency
commenced preparation of a Decisions and Policies draft paper and also an
Action List to assist with meeting our obligations under IFRS 16. In February
2024 a new Accounting Policies document was finalised, this, applying to lease
arrangements where Argyll and Bute Council is the lessee. In addition, in April
2024, the Finance Manager prepared an ‘Implementation of IFRS 16
Accounting for Leases’ document, clearly outlining the requirements of IFRS 16
and what should be included. A significant amount of work has been undertaken
from the end of 2024, accelerating at the beginning of 2025 to ensure that the
Council has captured all lease agreements which fall within the scope of IFRS
16 and the Code to provide assurance that everything is accounted for in the
Council’s Financial Statements for the year end March 2025. Communication
processes were put in place, commencing in 2020 and continuing throughout
the period to 2025 to ensure all lease information was gathered from
Departments, and all third-tier managers contacted in February 2025.  In
addition, meetings were held throughout 2025 with key officers, contacts and in
particular procurement and estates. Training commenced in 2020 with several
sessions being delivered by external providers and attended by, predominantly,
the Senior Business Support Officer. These early training events focussing
mainly on introducing and understanding IFRS 16.  In 2021 an IFRS 16 Forum
Webinar was attended with further training and workshops delivered in 2023
and attended by delegates for various services within the Council.  Further
training was provided throughout 2024 and 2025.
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Disclosure Checks - LiveArgyll: this audit provided a substantial level of
assurance.  This means that internal control, governance and the management
of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly
above an acceptable level and need to be addressed within a reasonable
timescale.  LiveArgyll operates using the Council’s overarching policies,
processes and guidance in respect of recruitment and PVG requirements with
some additional information to facilitate local application.  These documents are
available to all relevant employees, however, one document contained minor
historic errors and another lacked version control.  Regulated roles requiring
PVG membership are clearly communicated at recruitment and adequate
information and guidance is provided to applicants via the “MyJobScotland”
portal.  Management are also advised of the requirement to obtain specific forms
of identification from applicants to enable the PVG membership application to
proceed, however, we were unable to fully verify supporting documentation for
two employees.  As a result of updated legislation, membership is now required
for additional roles and an exercise is in progress and on track to meet
compliance, additionally, from April 2026, membership will be limited to 5 years
and renewal required to continue in the specific roles.  PVG membership of
employees and volunteers is recorded using robust systems and contains
adequate information to identify those approaching expiry and initiate a renewal
process where required.  Safeguarding training has been provided and
appropriate officers have been designated with responsibility to progress any
matters arising via the Council’s formal disciplinary process.  Independent
organisations using LiveArgyll facilities are responsible for managing their own
PVG requirements, however, those indicating failure to comply will be refused
use of the facility. 
4. CONCLUSION 
4.1 Management has accepted each of the reports submitted and have agreed
responses and timescales in the respective action plans. 
5. IMPLICATIONS 
5.1 Policy: none
5.2 Financial: none
5.3  Legal: none
5.4  HR: none
5.5 Customer Service:  none 
5.6 Risk – The implementation of recommendations contained in audit reports
may help mitigate the risk to the Council. 
5.7 Climate Change: none
5.8  Fairer Scotland Duty: none
5.9 Equalities: none
5.10 Consumer Duty: none
5.11 Island Communities: none
5.12 Children’s Rights and Wellbeing: none 
Paul Macaskill
Chief Internal Auditor
12 June 2025
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For further information contact: 
Paul Macaskill, Chief Internal Auditor
Tel:  01546 604108
Email: paul.macaskill@argyll-bute.gov.uk 
APPENDICES 
1. Short-term Lets
2. Asbestos Management
3. Bridges Asset Management
4. Trading Standards
5. External Placements 
6. IFRS 16 – Leasing
7. Disclosure Checks – PVG – LiveArgyll 
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Argyll and Bute Council
Internal Audit Report
MARCH 2025
FINAL
High Medium Low VFM
Number of
Findings
1 1 0 0
Short Term Lets
Audit Opinion: Substantial
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2
Argyll and Bute Council – Internal Audit Report – Short Term Lets, March 2025 
Contents
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 5
Audit Opinion ......................................................................................................................................... 5
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 13
Contact Details
Internal Auditor: Moira Weatherstone 
Telephone: 01546 604146 
e-mail: moira.weatherstone@argyll-bute.gov.uk
www.argyll-bute.gov.uk
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Argyll and Bute Council – Internal Audit Report – Short Term Lets, March 2025
1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to Short Term Lets.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with council officers and the information available at
the time the fieldwork was performed. The findings outlined in this report are only those which
have come to our attention during the course of our normal audit work and are not necessarily
all the issues which may exist. Appendix 1 to this report includes agreed actions to strengthen
internal control however it is the responsibility of management to determine the extent of the
internal control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. The Scottish Government introduced legislation which required local authorities to establish a
licensing scheme for short-term lets by 1 October 2022. The Civic Government (Scotland) Act
1982 (Licensing of Short-term Lets) Order 2022,  was brought in to ensure short term lets are
safe, to address issues faced by neighbours, and to help local authorities understand what is
happening in their area.  The legislation aims to balance economic and tourism benefits with the
needs and concerns of local communities.
5. The short-term licensing scheme covers a wide variety of residential and commercial
accommodation in Scotland and includes:
 B&B and guest houses;
 Cabins;
 Chalets;
 Lighthouses;
 Lodges and castles
6. A short-term letting licence is a mandatory licence for short-term lets across Scotland.  All short-
term let accommodation in Scotland requires a licence (unless it falls under of the excluded
types of accommodation). From the 1st of October 2023 you must have a licence before you
offer short-term lets, this includes the requirement to have a licence prior to taking bookings.
Existing hosts (operating before 1 October 2022) can continue operating until their application is
determined, however new hosts require to be licenced before they can commence letting.
7. The Council have received a significant number of short-term let applications and this is posing
significant challenges in assessing and determining them.  As of December 2024, the total
number of short-term letting application received by the Council was 3377.
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Argyll and Bute Council – Internal Audit Report – Short Term Lets, March 2025
8. Councils have up to 12 months to process applications from existing hosts if applied for before 1
October 2023 and for new hosts have up to 9 months to process the application.
9. Operating without a short-term licence is a criminal offence attracting a penalty fine of £2,500.
On conviction, Courts can impose a ban from applying for a licence for a year.  Resulting in hosts
being unable to continue to offer lets during this period.
10. In order to ensure the safety of the accommodation short-term let accommodation must meet
certain conditions to get a licence. This includes the following examples: Energy Performance
Certificate, fire safely, gas supply electrical installation condition report, portable appliance
testing report, building and public liability insurance.  The Scottish Government have set
mandatory conditions which must be attached to all licences and Local Councils have the ability
to apply additional conditions. These must be specified within the Councils Short-term Let Policy
and be listed on their website.
11. There is an application fee covering the cost of the Council’s administration of the scheme.
Councils were required to develop their own licensing schemes, having regard to legislation and
Scottish Government guidance to local authorities. The scheme required Councils to develop
digital and on-line systems to receive applications and set their own schedule of fees and
charges to cover the costs of delivering the licensing scheme on a self-financing basis. The
licence lasts for up to three years and it was determined if the Council generated a surplus
during the first period then the fee would be reduced next time and if the Council had under
estimated the fee it would be increased.
Scope
12. The scope of the audit was to review and assess the processes and controls in place for short
term lets and determine whether these support the efficiency and effectiveness of the service as
outlined in the Terms of Reference agreed with the Head of Development & Economic Growth
on 18 December 2024.
Key Dates
13. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below.
Exhibit 1 – Key Dates
Stage Actual
Date
Terms of Reference agreed 18/12/2024
Fieldwork Commencement 19/12/2024
Draft Report issued 24/02/2025
Management Comments received 11/03/2025
Final Report issued 14/03/2025
Audit and Scrutiny Committee 12/06/2025
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Argyll and Bute Council – Internal Audit Report – Short Term Lets, March 2025
Risks
14. The risks considered throughout the audit were:
 SRR01: Population, External Infrastructure and Economic Decline
 Audit Risk 1: Failure to have policies and procedures in place for the management of
short term lets
 Audit Risk 2: failure to process short term let application in a timely manner
 Audit Risk 3: failure to collect income from short term lets in a timely manner
Audit Opinion
15. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report.
16. Our overall audit opinion for this audit is that we can take a substantial level of assurance.  This
means that internal control, governance and the management of risk is sound. However, there
are minor areas of weakness which put some system objectives at risk and specific elements of
residual risk that are slightly above an acceptable level and need to be addressed within a
reasonable timescale.
Recommendations
17. We have highlighted one high priority recommendation and one medium priority
recommendation where we believe there is scope to strengthen the control and governance
environment.  These are summarised below:
 Remaining policies and procedures should be completed and circulated to staff and any
remaining identified actions regarding developments within the Oracle system
concluded as a priority;
 Oracle should be updated to include compulsory fields to ensure that applications
cannot be submitted until all relevant supporting documentation has been attached by
the applicant
18. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
19. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.
Exhibit 1 – Summary Assessment of Control Objectives
Control Objective Link to Risk Assessment Summary Conclusion
1 Policies which meet
the legislative
requirements have
been put in place
Audit Risk 1 Substantial Policies and procedures have been put
in place in respect of the Short Term
Lets scheme.  A total of 9 policies were
made available for review. Whilst the
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Argyll and Bute Council – Internal Audit Report – Short Term Lets, March 2025
and communicated
to all relevant
parties
policies and procedures in place are
comprehensive, there are some
elements of the policies that require to
be completed in parts. This includes
policies and procedures in respect of
Enforcement and Renewals which still
require to be brought together and
circulated to staff.  Other
developments, including within the
Oracle system have still to be
progressed.  At present this is not
affecting the efficiencies of progressing
applications.  All procedures, standard
templates, policy documents and
legislation are stored within a shared
drive which all staff team members
have access to. In addition, there is an
induction process in place for Licensing
Assistants, which is covered within the
first week or two of commencing their
job roles. 
2 Processes and
controls have been
put in place for
assessing  and
registering short
term lets, including
review processes
Audit Risk 1
Audit Risk 2
Substantial Processes have been put in place for
registering short term lets. Processes
and controls in place are robust and
ensure that applications are processed
in accordance with procedures. 
Applications are processed through an
online ‘bespoke’ oracle based database
system (developed by Argyll & Bute
Council IT service), completed by the
applicant.  Applications for Short Term
Lets are generally submitted online via
the Council website page or
alternatively a paper application can be
submitted.  Applications are allocated
to a Licencing Assistant who retains
responsibility for the processing of that
individual application.  Notes provide
guidance on what to look for when
carrying out first checks in order that
the Licencing Assistant can validate an
application.  Licences are not issued
until all relevant supporting evidence
has been submitted, any objections to
the applications (if applicable) have
been considered, relevant
consultations have been undertaken
and payment of licence fee has been
received.  Prior to issuing a licence a
further check of the application is
made by the Licencing Team Leader.
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Argyll and Bute Council – Internal Audit Report – Short Term Lets, March 2025
3 Applications for
short term lets are
processed in a
timely manner and
within legislative
requirements
SRR01 Substantial Applications can take some time to
process, however, this is not due to
inefficiencies in processing, rather due
to the applicant not providing all the
information or supporting evidence at
that time of the application.
4 Controls have been
put in place for the
collection of fees
and charges
Audit Risk 3 High Fees and charges have been agreed
and set by the Council prior to the
commencement of the Short Term
Lets, these charges will apply for the
initial three year phase of the licence. 
Comprehensive details of the charges
applied for Short Term Lets are
available on the Council website. Fees
and charges were set in accordance
with legislative requirements to cover
the expenses incurred in administering
the scheme. A comprehensive review
is currently underway with the support
of Financial Services to assess whether
the current fees and charges have
been sufficient to cover the expenses
for processing and issuing Short Term
Let licences.  
20. Further details of our conclusions against each control objective can be found in Section 3 of this
report.
3. Detailed Findings
Policies which meet the legislative requirements have been put in place and communicated to all
relevant parties
21. The Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022 introduces
a licensing regime for the short-term let of residential accommodation. This provides a definition
of short-term let and short-term let licence. In addition it also outlines the mandatory licence
conditions, which includes details of certificates to be supplied to the authority during the
application process. We were provided with copies of the relevant legislation.
22. Policies and procedures have been put in place in respect of short term lets.  A total of 9 policies
were made available for review. including:
 Validating Applications (Annex A – Validation Checklist and Annex B – Validation Notes)
 Consultees
 Objections / Hearings
 Issuing a Licence
 Notification of Changes & Alterations & Variation Requests
 Temporary Licences
 Provisional Licences (New Builds)
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Argyll and Bute Council – Internal Audit Report – Short Term Lets, March 2025
 Transfer of Licence
 Enquiries & Complaints
 Enforcement
 Renewals
23. Whilst policies and procedures in place are comprehensive, there are some elements of the
policies that require to be completed in parts. This includes policies and procedures in respect of
Enforcement and Renewals which still require to be brought together and circulated to staff.
Other developments, including within the Oracle system have still to be progressed.  These have
been identified and are noted for progression, including:
 develop a template licence revocation letter, with this status being added to oracle and
develop a way of tracking these;
 develop a template for provisional licence, including cover letter;
 include a new Licence type -  “Transfer Licence” and new application status  entitled
“transferred”.
Action Plan 1
24. All procedures, standard templates, policy documents and legislation are stored within a shared
drive which all staff team members have access to. In addition, there is an induction process in
place for Licensing Assistants, which is covered within the first week or two of commencing their
job roles.  New team members are initially allocated a ‘buddy/mentor’ for training purposes.
25. The general public have been made aware of the introduction of the Short Term Let legislation
with details of the Short Term Lets legislation available on the Council’s website. The website
also provides links to obtain further information about the legislation and read the Scottish
Government guidance for hosts and operators.  It also provides a link to Visit Scotland where
further information can be found. It is also noted that the Council have proactively engaged with
the Association of Scottish Self Caterers (ASSC) to discuss the scheme and receive feedback from
the sector. Were appropriate, this has led to changes in the Councils Policy or representations
to the Scottish Government
26. Applications for a Short Term Let are generally submitted online via the Council website page
Short term lets licence (argyll-bute.gov.uk) or alternatively a paper application can be submitted.
The website provides information on how to apply for a licence and details of the various pieces
of evidence that must be submitted with the licence application. Applicants are strongly advised
that before beginning the application process they refer to the pre-application checklist or the
Scottish Government's checklist to ensure you have gathered the appropriate information,
ensuring the application can be processed in a timely manner. Supporting evidence can be
uploaded as part of the online application process or emailed separately.
27. The Council website also provides a public register of short term lets available within Argyll &
Bute Council area.
Processes and controls have been put in place for assessing and registering short term lets,
including review processes
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28. Processes have been put in place for registering short term lets. Applications are processed
through an online ‘bespoke’ oracle based database system (developed by Argyll & Bute Council
IT service) which is completed by the applicant.  Applications for a Short Term Let are generally
submitted online via the Council website page or alternatively a paper application can be
submitted.  Applications submitted online receive an automatic response from the system to
acknowledge receipt of their application, this also includes their unique reference number.
29. Applications are allocated to a Licencing Assistant who retains responsibility for the processing
of that individual application.  Notes provide guidance on what to look for when carrying out
first checks in order that the Licencing Assistant can validate an application.  Licences are not
issues until all relevant supporting evidence has been submitted, any objections to the
applications (if applicable) have been considered, relevant consultations have been undertaken
and payment of licence fee has been received.  Prior to issuing a licence a further check of the
application is made by the Licencing Team Leader.
30. The Civic Government (Scotland) Act 1982, Schedule 1 as modified by The Civic Government
(Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022 specifies Chief Constable and
Scottish Fire and Rescue Service as mandatory consultees. In addition the following are
consulted:
 Argyll & Bute Council Planning Department
 Argyll & Bute Council Building Standards Service
 Argyll & Bute Council Environmental Health Service
 Loch Lomond & the Trossachs Parks Authority (where the property is within the National
Park)
Additional consultation may take place with the Private Water Supply Team and the Health and
Safety Lead Officer, Environmental Health.
31. Processes and controls in place are robust and ensure that applications are processed in
accordance with procedures.  We selected a random sample of processed applications for
testing and with one application reviewed every stage of the application process, including
reviewing all the supporting evidence and consultations. We found the applications to be
complete with all documentation to support the application attached.
Applications for short term lets are processed in a timely manner and within legislative
requirements
32. Applications can take some time to process, however, this is not due to inefficiencies in
processing, rather due to the applicant not providing all the information or supporting evidence
at that time of the application.
33. A number of documents of supporting evidence must be submitted with the licence application
prior to issuing of the licence.  Oracle currently has a number of compulsory fields which require
to be completed, this does not include the uploading of evidence.  Applications can be submitted
without all the supporting evidence attached resulting in time consuming delays contacting the
applicants.   There can be, at times, a lot of communication and emails back and forward to the
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applicant requesting information and documentation to support their application.  This can be
very time consuming for staff, in addition to the need to keep track of follow-up. 
Action Plan 2
34. Applications received in paper form, require a Licencing Assistant to manual processes the
application through the Oracle based online system for the applicant.  This ensures that all
applications, received in the various formats are all recorded on Oracle. Applications received by
post will take longer to process.
35. Councils have up to 12 months to process applications from existing hosts if applied for before 1
October 2023 and for new hosts have up to 9 months to process the application. In addition,
existing hosts can continue to take bookings and offer lets, whilst new hosts cannot take
bookings or receive guests until you have obtained a licence.  As a result of this, in order to
support new hosts, these applications have been prioritised for processing.
Controls have been put in place for the collection of fees and charges
36. The legislation allows for licencing fees to be charged: “licensing authority may, subject to sub-
paragraphs (2) and (3), charge such reasonable fees as they may determine in respect of—“
However, in doing so the legislations states: “In determining the amount of the different fees
under sub-paragraph (1), the licensing authority— must seek to ensure that the total amount of
fees receivable by the authority is sufficient to meet the expenses of the authority in exercising
their functions under Parts I and II of this Act and this schedule, they also may determine
different fees for different purposes”.  Therefore fees are set to offset the expenses incurred by
the authority.
37. Fees and charges have been agreed and set by the Council prior to the commencement of the
Short Term Lets, these charges will apply for the initial three year phase of the licence.
Comprehensive details of the charges applied for Short Term Lets are available on the Council
website.
38. A comprehensive review is currently underway with the support of Financial Services to assess
whether the current fees and charges have been sufficient to cover the expenses for processing
and issuing Short Term Let licences.  This will assist to inform the Council on whether the fees
and charges, when reviewed in 2026 should be reduced or increased when the renewal process
begins.
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Appendix 1 – Action Plan
No Finding Risk Agreed Action Responsibility / Due Date
High 1
Procedures
Whilst policies and procedures that are in place are
comprehensive, there are some elements of the policies
which require to be completed in parts. This includes
policies/procedures around Enforcement and Renewals
that still require to be brought together and circulated. 
Other developments are noted for progression on Oracle.
Inconsistencies in practice and
inefficiencies in processing 
1. Develop a Short-term Let
Enforcement policy
2. Develop procedures for the
renewal of Short-term let
Licences
3. Secure changes to the Oracle
STL system, including a
searchable public register, a
template licence revocation
letter, with this status being
added to oracle and tracking
these
4. Develop a template for
provisional licence, including
cover letter
5. Include a new Licence type -
“Transfer Licence” and new
application status entitled
“transferred”.
Officer title : Building
Standards Manager
Date: 30 September 2025
Medium
2
Oracle – Compulsory Fields
A number of documents of supporting evidence must be
submitted with the licence application prior to issuing of
the licence.  Oracle currently has a number of compulsory
fields which require to be completed, this does not include
the uploading of evidence.  Applications can be submitted
without all the supporting evidence attached resulting in
time consuming delays contacting the applicants.   
Inefficiencies in processing
leading to delays in issuing
licences
1. Upgrade to be applied to
Oracle system to ensure that
applications made without all
the necessary certification
and documentation, cannot
be submitted through the on-
line system.
2. A similar approach will be
applied to paper-based
applications
Officer title:  Building
Standards Manager
Date: 1 May 2025
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In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained.  The definitions
of each classification are as follows:
Grading Definition
High A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error.
Medium
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.
Low Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives.
VFM An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM).
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Appendix 2 – Audit Opinion
Level of Assurance Definition
High
Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently.
Substantial
Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale.
Reasonable
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk.
Limited
Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised.
No Assurance
Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues.
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Argyll and Bute Council
Internal Audit Report
April 2025
Final
High Medium Low VFM
Number of
Findings
0 5 4 0
Asbestos Management
Audit Opinion: Reasonable
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Contents
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 12
Appendix 2 – Audit Opinion ................................................................................................................. 17
Contact Details
Internal Auditor: Annemarie McLean 
Telephone: 01700 501354 
e-mail: annemarie.mclean@argyll-bute.gov.uk
www.argyll-bute.gov.uk
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1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to Asbestos Management.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with council officers and the information available at
the time the fieldwork was performed. The findings outlined in this report are only those which
have come to our attention during the course of our normal audit work and are not necessarily
all the issues which may exist. Appendix 1 to this report includes agreed actions to strengthen
internal control however it is the responsibility of management to determine the extent of the
internal control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. Although asbestos is a hazardous material, it can only pose a risk to health if the asbestos fibres
become airborne and then inhaled. Asbestos Containing Materials (ACMs) only release fibres
into the air when they are disturbed. If ACMs are not disturbed airborne fibres will not be
released and therefore, they will not pose a risk to health.
5. The Control of Asbestos Regulations (CAR) 2012 requires employers to prevent the exposure of
their employees to asbestos, or where this is not practicable, to reduce the exposure to the
lowest possible level. Specifically, the broad legal duties are to:
• take reasonable steps to find materials likely to contain asbestos;
• presume materials contain asbestos, unless there is strong evidence to determine they
do not;
• assess the risk of the likelihood of anyone being exposed to asbestos from these
materials;
• make a written record of the location and the condition of the ACMs and presumed
ACMs and keep it up to date;
• repair or remove any material that contains or is presumed to contain asbestos, if
necessary, because of the likelihood of disturbance, and its location or condition;
• prepare a plan to manage that risk and put it into effect to ensure that:
o information on the location and condition of ACMs is given to people who may
disturb them during work activities;
o any material known or presumed to contain asbestos is kept in a good state of
repair;
• monitor the condition of ACMs and presumed ACMs; and
• review and monitor the action plan and the arrangements made to put it in place.
6. The management of asbestos in premises is also covered under Health and Safety legislation,
including:
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• The Management of Health and Safety at Work Regulations 1999, which requires an
assessment of the risks to employees and users of premises be undertaken and
appropriate arrangements made for protecting those people’s health and safety; and
• The Workplace (Health, Safety and Welfare) Regulations 1992 which includes duties to
maintain workplace buildings/premises to protect occupants and workers.
Scope
7. The scope of the audit was to review and assess the arrangements for the management of
asbestos across Council establishments, as outlined in the Terms of Reference agreed with the
Head of Commercial Services on 23 October 2024.
Key Dates
8. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below.
Exhibit 1 – Key Dates
Stage Actual Date
Terms of Reference agreed 23 October 2024
Fieldwork Commencement 23 October 2024
Draft Report issued 04 February 2025
Management Comments received 01 April 2025
Final Report issued 02 April 2025
Audit and Scrutiny Committee 12 June 2025
Risks
9. The risks considered throughout the audit were:
• Audit Risk 1: Failure to comply with the Control of Asbestos and Health and Safety at
Work, Regulations.
Audit Opinion
10. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report.
11. Our overall audit opinion for this audit is that we can take a reasonable level of assurance.
This means that internal control, governance and the management of risk are broadly reliable.
However, whilst not displaying a general trend, there are areas of concern which have been
identified where elements of residual risk or weakness may put some of the system objectives
at risk.
Recommendations
12. We have highlighted five medium priority recommendations and four low priority
recommendations where we believe there is scope to strengthen the control and governance
environment.  These are summarised below:
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• The Council’s Asbestos Management Plan (the 2013 Plan) should be updated to ensure it
reflects the current Council structure and revised working practices.
• HSE guidance requires that individual buildings plans should be monitored and reviewed
every 12 months or sooner if necessary. The 2013 Plan and all associated documents
and checklists should be reviewed to ensure they reflect this requirement.
• Gaps in staff training and awareness were identified.  A pilot scheme providing training
to staff in Education Dept, proved successful. This should be rolled out to all Council
Services.
• When reviewing and updating the 2013 Plan and associated documents/ checklists, the
storage and retention period of the document should be clearly stated.
• The 2013 Plan and associated procedures, materials and information, should be updated
to clarify the role and responsibilities at individual site/premises level and should include
the requirement for a Deputy to be appointed to ensure cover for absence.
• Property Services must be advised of any changes to staff, nominated by Heads of
Services, to be the Site Premises Manager/ Site Responsible Persons for each site/
establishment.
• Mandatory LEON training for Facility Responsible Persons should be extended to include
the Site Premises Manager/ Site Responsible Persons and their nominated Deputies. This
should be completed annually.
• The Duties of the Facilities Responsible Person document should be updated to include
their responsibilities in relation to the management of asbestos. There may be benefit to
producing a checklist of facility related checks for sites/premises to collate these in one
place.
13. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
14. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.
Exhibit 1 – Summary Assessment of Control Objectives
Control Objective Link to Risk Assessment Summary Conclusion
1 The Council has a
plan/policy in
place to manage
its duty relating to
the risks
associated with
asbestos-
containing
materials (ACMs)
across Council
establishments. 
Audit risk 1 Reasonable • The Council has the Asbestos
Management Plan (the 2013 Plan) in place
to manage its duty relating to the risks
associated with asbestos-containing
materials (ACMs) across Council
establishments.  This should be updated
to ensure it reflects the current Council
structure and revised working practices.
• HSE guidance requires that individual
buildings plans should be monitored and
reviewed every 12 months or sooner if
necessary.
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• 186 of the 188 premises required, have
had a re-inspection within the last 12
months.
• The Council has procedures and guidance
in place to follow if ACMs are disturbed,
these are detailed in the plan and
published in the Facility Responsible
Person section on the Hub.
• The Health and Safety Team and Property
Services identified gaps in awareness
amongst staff and potential to consolidate
the information available. Testing
confirmed this.
• A pilot scheme providing training to site
responsible persons, within Education
Services, has been developed and carried
out by Health and Safety staff. This has
proven successful and is planned to will
be rolled out across all Council Services.
• There is no clear mention of the retention
period for the various documents relating
to the management of asbestos.
• A review of the processes and training
materials associated with the
management of asbestos, is currently
underway, once completed the 2013 Plan
will be updated.
2 Council staff are
aware of their
responsibilities in
relation to
monitoring
buildings and
reporting issues
that may relate to
asbestos-
containing
materials (ACMs).
Audit risk 1 Reasonable • The Facility Responsible Person (FRP)
takes responsibility for overseeing facility
safety and facility related activities.
• The Site Responsible Person (SRP) co-
ordinates arrangements between
Property Services and other Services
occupying the premises. The SRP role and
its responsibilities should be detailed in
the 2013 Plan and referred to in the wider
information and materials.
• Key contact details for staff nominated by
Services as SRP are not up to date.
• Mandatory LEON training for Facility
Responsible Persons, does not reference
the SRP role nor their deputies and there
is currently no mandatory training for
these staff.
• The Duties of the Facilities Responsible
Person document should be updated to
include their responsibilities in relation to
management of asbestos. There may be
benefit to producing a checklist of facility
related checks for sites/premises to
collate these in one place.
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15. Further details of our conclusions against each control objective can be found in Section 3 of this
report.
3. Detailed Findings
The Council has a plan/policy in place to manage its duty relating to the risks associated with
asbestos-containing materials (ACMs) across Council establishments.
16. The Council has the Asbestos Management Plan (the 2013 Plan) in place to manage its duty
relating to the risks associated with asbestos-containing materials (ACMs) across Council
establishments. It applies to all parts of the Council’s estate constructed prior to 2000, when the
use of asbestos in construction was considered to be officially banned.
17. The 2013 Plan, and the management system it contains, is designed to provide the basis for
implementing the key legislative elements, some examples include:
• to provide and maintain an Asbestos Register for each site where asbestos may be
present and an Onsite Control of Asbestos Logbook;
• to develop, implement and review an effective management strategy so that
appropriate measures, such as sealing, labelling, inspection or removal of ACMs are
undertaken to prevent exposure to the hazards associated with asbestos;
• to promote awareness of the Asbestos Management Plan and the hazards of asbestos,
through training and induction of staff and those working on behalf of the Council.
18. Property Services is responsible for maintenance of the building fabric and building services. In
relation to the management of asbestos within Council premises, Property Services arrange for
the compilation, consultation, implementation and monitoring of specific management
arrangements for Asbestos Containing Materials (ACMs) or suspected ACMs.
19. The Health and Safety Team offer advice and support on all matters relating to health, safety
and welfare. The relevant asbestos policies and procedures are contained within the Health and
Safety Team site on the Council’s Intranet, the Hub.
20. The 2013 Plan is the over-arching guide for all Council staff and while it is comprehensive and
takes cognisance of the legislation it has not been updated since its approval in May 2013 as
there has, we are advised, been no significant changes in legislation or working practices.
21. A review of the processes, procedures and training relating to managing asbestos is currently
being undertaken by staff from Property Services and the Health and Safety Team, once
complete the 2013 Plan will be updated to reflect the revised working practices.
22. In line with statutory requirements, the Council has defined the organisational structure and
management responsibilities for the Control of Asbestos. The 2013 Plan contains a flow chart
depicting the organisation structure and the roles/ titles of those persons appointed to key roles
of Dutyholder, Responsible Person, and Competent Persons. Alongside this structure the Health
and Safety Team are involved in providing advice, specifically in terms of the legal requirements,
at all stages of the management process.
23. The Dutyholder has overall responsibility for ensuring that the Control of Asbestos is adequately
managed to mitigate the risks identified, they can delegate tasks to the Deputy Dutyholder and
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can nominate others to do tasks. The Responsible Person, nominated by individual Services,
implements the Control of Asbestos Management Plan with assistance from the designated
Competent Persons. Competent Persons, ensure local control of the Risk Assessment Process at
a site or multi-site level. Site Responsible Persons are the employees appointed by Services to be
the person responsible for individual Council establishments. 
24. Appendix One – Register of Role holders details the Organisational Structure Key Personnel. This
includes the names and contact details of individuals and deputies that have been appointed to
the main roles, Dutyholder, Deputies, Responsible Persons and Competent Person, and while
some of the names remain the same, this list has does not reflect the current Council structure.
Action Plan 1
25. The management of asbestos in non-domestic premises requires the Council, as Dutyholder, to
have as a minimum a Management Survey to have been undertaken for its premises. The
purpose of the survey is to gather the base information required for an asbestos register and
plan to be prepared, a suitable risk assessment to be carried out and a written plan to manage
the risks is required to be produced.
26. The Management Surveys for each premises will identify whether the establishment is affected
by the Control of Asbestos Regulations by:
• Checking for, identifying and assessing the condition of Asbestos Containing Materials;
• Assessing the risk;
• Providing a Control of Asbestos Risk Assessment indicating the relevant information and
recommendations necessary to manage the risk and to minimise the risk of ACMs being
disturbed.
27. Property Services maintain the Asbestos Site History spreadsheet which is a central register of
establishments/premises where the initial Management Survey has identified as containing or
suspected to have Asbestos Containing Materials (ACMs). The register includes details of:
• the site name:
• management survey date;
• re-inspection by a competent person date;
• date next re-inspection due; and
• whether the sites have an asbestos register and asbestos location plan.
28. Property Services issue the Onsite Control of Asbestos Logbook folder to each of the
establishments, this is onsite information specific to that facility. It includes the most up to date
asbestos management survey, a location plan showing where ACMs are present, a register of
where there is ACM present and re-inspection register.  For completeness, if applicable, copies
of any Refurbishment/Demolition surveys that have been undertaken in the facility.  There is a
visitor’s sign in sheet for most facilities and a contractors sign in/register for all sites. If
something changes in the building, the Property Asbestos Officer will arrange for the register to
be updated to reflect this.
29. The review of the 2013 Plan includes the re-alignment of scheduled re-inspections by Property
Services to match the geographic areas covered by staff and the review of the Health and Safety
risk assessments for each site. Given the size and geography of the Council area this is a resource
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intensive exercise, in terms of both staff time and travel related costs. Where possible staff plan
the site visits to coincide with other inspections. 
30. The HSE duty to manage asbestos in buildings guidance states that, as part of the Control of
Asbestos Regulations, buildings plans should be monitored and reviewed every 12 months or
sooner if necessary. There is limited mention of this requirement within the 2013 Plan and the
associated documents. These should be reviewed to ensure that they refer to this requirement
and that they specify staff roles and responsibility for completion of reviews, monitoring of the
ACMs and where applicable carrying out risk assessments.
Action Plan 2
31. A review of the Asbestos Site History spreadsheet confirms that of the 188 Council premises that
have been identified as containing, or are suspected to have ACMs, 186 have been re-inspected
within the past 12 months.
32. The Council has procedures and guidance in place to follow if ACMs are disturbed. The 2013 Plan
provides details of the internal requirements for each of the duties within the roles and
responsibilities section. It also sets out Emergency Procedures which are predominately targeted
where works are being carried, so aimed at external contractors. The information is published in
the Facility Responsible Persons section of the Health and Safety site on the Hub.
33. The Health and Safety Team and Property Services identified that there were gaps in awareness
amongst staff and potential to consolidate the information available. They decided to update the
Onsite Control of Asbestos logbook by collating the relevant information and guidance into one
place rather than have it spread between the 2013 Plan, the site plans/logbooks and the Hub.
34. The Health and Safety Team have produced a Site Asbestos Management Plan (Site AMP), based
on the Council’s overarching 2013 Plan and developed new awareness training materials for Site
Responsible Person (SRP). This includes showing how to complete the Site AMP and highlights
what their responsibilities are. This has been piloted within Education services with awareness
training sessions delivered to Head Teachers, as the SRP.
35. Testing, as noted in paragraph 45 below confirms the awareness and training gap and highlights
the success of the pilot scheme. Following completion of the pilot, staff within Health and Safety
and Property Services are reviewing and updating the documentation, processes and
procedures, to ensure that they reflect the revised working practices. The awareness training is
planned to will be rolled out by the Health and Safety Team to other Services after the review.
Records of this training should be maintained.
Action Plan 3
36. There is no clear mention of the retention period for the various documents relating to the
management of asbestos.  When reviewing and updating the 2013 Plan and associated
documents/ checklists and training materials, the storage and retention of the document should
be clearly stated.
Action Plan 4
37. As noted in paragraph 21 above, the 2013 Plan will be updated once the working practices and
training is fully revised. For completeness, any linked documents referred to or based upon the
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2013 Plan, including the Education Management Circular 1.31, should be listed to ensure that
they are updated/ reviewed any time the Plan is revised and vice versa. 
Council staff are aware of their responsibilities in relation to monitoring buildings and reporting
issues that may relate to asbestos-containing materials (ACMs).
38. The Facility Responsible Person (FRP) is the Head of Service, they have responsibility for
overseeing facility safety and facility related activities (other than maintaining building fabric and
building services which remain the responsibility of Property Services). Heads of Service
nominate a member of staff as the Site/Premises Manager for each establishment and notify
Property Services who record the appointment on the Council’s Property Management System,
Concerto, which contains the central register.
39. The SRP co-ordinates arrangements between Property Services and other Services occupying the
premises and performs specific facility related tasks, including monitoring buildings and
reporting issues that may relate to disturbances of areas identified as having asbestos containing
materials (ACMs). Some documents in the Health and Safety Intranet site refer to Site Premises
Manager. To avoid confusion there should be consistent use of one title.
40. The 2013 Plan currently refers to Site Manager or Head Teacher rather than the current title of
Site Responsible Person.  While there is no requirement for the 2013 Plan to include titles of the
individual SRP, this is an important role. The 2013 Plan and associated procedures, materials and
information and the Education Management Circular 1.31, should be updated to clarify the role
and responsibilities of the SRP and include the requirement for a Deputy to be appointed to
ensure cover for any absences.
Action Plan 5 and 6
41. Services should advise Property Services of any changes of staff nominated as SRP but in practice
this does not happen consistently meaning that these records are not up to date. Property
Services have in the past issued emails to Heads of Services asking for staffing updates, but due
to a lack of response this practice was stopped. Consideration should be given to whether this
could be reinstated and where there is no response if this should be escalated to DMT/SMT.
Action Plan 7
42. Mandatory training for staff nominated by Services as FRP, is available on the LEON system,
which also records and monitors completion. This does not reference the SRP role and there is
currently no mandatory training for staff appointed to this role.  Mandatory training should be
extended to include SRPs and their nominated Deputies to ensure that there is cover for
absence.
Action Plan 8
43. To establish the extent to which Council staff are aware of their responsibilities in relation to
monitoring buildings and reporting issues that may relate to ACMs, a survey was issued to 34
sites/ establishments. These were selected on a risk basis so included schools, Homes For the
Elderly, Customer Service Points, Social Work premises and Roads Depots. In total, we received
26 completed surveys, the results are set out in the table below.
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Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025
Survey Questions and Results y n % Yes
Q1 Is there an asbestos management plan the building? 20 6 77%
Q2 If yes, is it prominently displayed 19 7 73%
Q3
Have you received training in relation to your duties?  
specifically, your duties relating the monitoring and reporting of Asbestos
Containing Materials (ACM)
12 14 46%
Q4 Have you completed the Facility Responsible Person LEON training? 12 14 46%
Q5
Do you carry out undertake regular inspections of the establishment/
building, (this includes checking the whether the location of ACM has
been disturbed)? 
13 13 50%
Q6
Do you know where to find information and who to contact if you have
queries relating to: 
• Management of Asbestos
19 7 73%
Q6a • Health and Safety of users of that Council establishment 21 5 81%
Q6b • the location of ACMs 18 7 69%
Q6c • where to find information and who to contact if you have queries 17 9 65%
Q6d • what to do/how to report if the ACMs may be disturbed? 18 8 69%
Q7 Have you ever reported a potential disturbance to the area containing
the ACMs? 0 26 0%
44. The responses from schools were positive with all 12 confirming they have received training and
only one school unaware that Property Services have to be notified of potential asbestos related
issues, in addition to contacting Health and Safety Team. This highlights the success and impact
of the recent pilot scheme. As noted in paragraph 33 above, the awareness training is planned to
be rolled out to other Services, after the plan and linked materials have been updated.
45. The survey responses highlight the gap in awareness of staff responsibilities and training already
identified by Property Services and Health and Safety Teams as 46% of staff have not received
training - neither awareness training nor the LEON module. In particular five of the six Council
Depots contacted have not received training and were unaware of the asbestos management
plan for the site, staff highlighted a lack of handover in relation to SRP duties, when changes of
staff occurred.
46. Currently the Duties of the FRP document makes no mention of their responsibilities relating to
the management of asbestos. This should be updated to include the need to appoint an SRP and
Deputy for each site/premises and where appropriate, a visual check for disturbances to
locations identified as containing or suspected to contain ACMs.
47. Half of the staff surveyed carry out regular inspections. In addition to clarifying the role and
responsibilities of the SRP, there would be benefit to producing a checklist of facility related
checks for sites/premises to collate these in one place e.g. fire alarm testing, legionella testing,
visual check of ACMs, including the frequency that these are required.
Action Plan 9
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Appendix 1 – Action Plan
No Finding Risk Agreed Action Responsibility /
Due Date
Medium
1
Asbestos Management Plan (the 2013 Plan)
The 2013 Plan, states that it will be reviewed annually, but it has
not been updated since approval in May 2013.
Appendix 1, includes the Register of Role holders which details
the Organisation Structure Key Personnel, however, this does
not reflect the current Council Structure. 
At the time of the audit, the 2013 Plan was under review. This
should be updated to ensure it reflects the current Council
structure and revised working practices. Consideration should be
given as to what is an appropriate period of review for this
document. 
Failure to comply with
the Control of Asbestos at
Work, and, Health and
Safety at Work,
Regulations.
Property Services and Health and Safety
Team are reviewing the 2013 Plan.  It
will be renamed as the Management
Standard for the Control of Asbestos
and will be updated to refer to the job
titles of key personnel. 
Heads of Service will need to make
necessary commitment to any changes.
Property Services will monitor this every
12 months. 
Property
Maintenance
Manager
Governance, Risk
and Safety
Manager 
1st April 2026
Medium
2
Managing Asbestos in Buildings
The HSE duty to manage asbestos in buildings guidance states
that buildings plans should be monitored and reviewed every 12
months or sooner if necessary.
The 2013 Plan, Onsite Control of Asbestos Logbooks and
Individual Site AMPs, and all associated documents and
checklists should be reviewed to ensure that they refer to the
above requirement and specify staff roles and responsibility for
completion of reviews and monitoring of the ACMs, including
risk assessments.
Failure to comply with
the Control of Asbestos at
Work, and, Health and
Safety at Work,
Regulations.
Property Services and Health and Safety
Team will include this requirement and
make any necessary amendments, while
they are reviewing the 2013 Plan, the
individual Site Asbestos Management
Plans and associated/ linked
documents. 
The updated documents will be
provided to audit to evidence
completion
Property
Maintenance
Manager
Governance, Risk
and Safety
Manager 
1st April 2026
Low 3
Training and awareness raising 
Gaps in asbestos awareness amongst staff were identified.
Testing confirmed this. A pilot scheme providing training to Site
Responsible Persons, within Education Services, has been
developed and carried out by Health and Safety staff. This has
proven successful and is planned to be rolled out across all
Council Services. Records of this training should be maintained. 
Failure to comply with
the Control of Asbestos at
Work, and, Health and
Safety at Work,
Regulations.
The Pilot with Education dept is now
complete. Health and Safety Link
Officers will liaise with other Services to
develop the asbestos system across
council for monitoring buildings and
reporting issues.
Governance, Risk
and Safety
Manager 
1st April 2026
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No Finding Risk Agreed Action Responsibility /
Due Date
Medium
4
Document Retention
There is no clear mention of the retention period for the various
documents relating to the management of asbestos.  
When reviewing and updating the 2013 Plan and associated
documents/ checklists etc., the storage and retention period
should be clearly stated. 
For completeness, any linked documents referred to, based
upon the revised 2013 plan, should be listed to ensure that they
are updated/ reviewed any time the plan is revised and vice
versa.
Failure to comply with
the Control of Asbestos at
Work, and, Health and
Safety at Work,
Regulations.
Property Services and Health and Safety
Team when reviewing the 2013 Plan
(and updating to the Management
Standard for the Control of Asbestos)
and associated documents, will develop
a list of linked documents and specify a
storage & the retention period for
these. 
Property
Maintenance
Manager
Governance, Risk
and Safety
Manager 
1st April 2026
Medium
5
Roles and Responsibilities
There is inconsistent use of the title, role and responsibilities
when referring to the member of staff, nominated as the
individual Site Responsible Person.  Different titles include Site
Manager, Head Teacher, Site Premises Manager or Site
Responsible Person (SRP).  To avoid confusion there should be
consistent use of one title.
The 2013 plan and associated procedures, materials and
information, should be updated to clarify the role and
responsibilities of the SRP and include the requirement for a
Deputy to be appointed to ensure cover for absence. 
Council staff may be
unaware of their
responsibilities in relation
to monitoring buildings
and reporting issues that
may relate to asbestos
containing materials
(ACMs).
Property Services and Health and Safety
Team are reviewing the Plan (and
updating to the Management Standard
for the Control of Asbestos) currently to
update and include a consistency in role
titles across the various documents.
Property
Maintenance
Manager
Governance, Risk
and Safety
Manager 
1st April 2026
Medium
6
Education Management Circular 1.31
This document will need reviewed to ensure it reflects:
The HSE guidance that buildings plans should be monitored and
reviewed every 12 months or sooner if necessary.
Any revision to titles, roles and responsibilities of the member of
staff, nominated as the individual Site Responsible Person
Retention period for the various documents relating to the
management of asbestos. 
Council staff may be
unaware of their
responsibilities in relation
to monitoring buildings
and reporting issues that
may relate to asbestos-
containing materials
(ACMs).
School Services Support Manager will
update the EMC 1.31 and will liaise with
Property Services and Health and Safety
Team, who are reviewing the Plan (and
updating to the Management Standard
for the Control of Asbestos) currently to
update and include a consistency in role
titles across the various documents.
School Services
Support Manager
Governance, Risk
and Safety
Manager 
1st April 2026
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Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025
No Finding Risk Agreed Action Responsibility /
Due Date
Low 7
Site Responsible Person Records
Services should advise Property Services of any changes of staff
nominated as SRP but in practice this does not happen
consistently meaning that these records are not up to date. 
Property Services have in the past issued emails to Heads of
Services asking for staffing updates, but due to a lack of
response this practice was stopped. Consideration should be
given to whether this could be reinstated and where there is no
response if this should be escalated to DMT/SMT. 
Council staff may be
unaware of their
responsibilities in relation
to monitoring buildings
and reporting issues that
may relate to asbestos-
containing materials
(ACMs).
Property Services will issue emails to
Heads of Services asking for staffing
updates then enter details into
Concerto 
Commercial
Services Admin
Officer
30th September 25
Low 8
Mandatory Training
Mandatory training for Facility Responsible Persons (HoS), is
available on the LEON system, which also records and monitors
completion. This does not reference the Site and Premises
Manager/ Site Responsible Person role and there is currently no
mandatory training for staff appointed to this role.  Mandatory
training should also extend to these roles and their nominated
Deputies to ensure that there is cover for absence. 
Consideration should be given to this being an annual
requirement.
Council staff may be
unaware of their
responsibilities in relation
to monitoring buildings
and reporting issues that
may relate to asbestos-
containing materials
(ACMs).
Mandatory Training will be developed
and available on LEON for all
appropriate personnel. Deputies will be
included
Governance, Risk
and Safety
Manager 
30th September 25
Low 9
Duties of the Facility Responsible Person 
Currently the Duties of the FRP document makes no mention of
their responsibilities relating to the management of asbestos. 
This should be updated to include, the need to appoint an SRP
and Deputy for each site/premises and where appropriate, a
visual check for disturbances to locations identified as containing
or suspected to contain ACMs. 
There may be benefit to producing a checklist of facility related
checks for sites/premises to collate these in one place e.g. fire
alarm testing, legionella testing, visual check of ACMs, including
the frequency that these are required.  
Council staff may be
unaware of their
responsibilities in relation
to monitoring buildings
and reporting issues that
may relate to asbestos-
containing materials
(ACMs).
Property Services and Health and Safety
Team are currently reviewing the Plan
(and updating to the Management
Standard for the Control of Asbestos) to
update and include roles and
responsibilities for key personnel.
Health and Safety Link Officers will liaise
with other Services to develop the
asbestos system across council for
monitoring buildings and reporting
issues.
Property
Maintenance
Manager
Governance, Risk
and Safety
Manager 
1st April 2026
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No Finding Risk Agreed Action Responsibility /
Due Date
There are various site checklists on the
hub, these will be reviewed to include
Asbestos.
In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained.  The definitions
of each classification are as follows:
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Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025
Grading Definition
High A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error.
Medium
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.
Low Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives.
VFM An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM).
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Argyll and Bute Council – Internal Audit Report – Asbestos Management, April 2025
Appendix 2 – Audit Opinion
Level of Assurance Definition
High Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently. 
Substantial Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale. 
Reasonable
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk.
Limited Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised. 
No Assurance Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues. 
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Argyll and Bute Council
Internal Audit Report
March 2025
Final
High Medium Low VFM
Number of
Findings
1 1 2 0
Bridge Asset Management
Plan 
Audit Opinion: Reasonable
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Argyll and Bute Council – Internal Audit Report – Bridge Asset Management, March 2025
Contents
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 15
Contact Details
Internal Auditor: David Sullivan 
Telephone: 01546 604125 
e-mail: david.sullivan@argyll-bute.gov.uk
www.argyll-bute.gov.uk
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Argyll and Bute Council – Internal Audit Report – Bridge Asset Management, March 2025
1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of Argyll and Bute Council’s (the Council / ABC)
system of internal control and governance in relation to Bridge Asset Management Plan.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with council officers and the information available at
the time the fieldwork was performed. The findings outlined in this report are only those which
have come to our attention during the course of our normal audit work and are not necessarily
all the issues which may exist. Appendix 1 to this report includes agreed actions to strengthen
internal control however it is the responsibility of management to determine the extent of the
internal control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. The Infrastructure Design team is responsible for the oversight of 903 bridges within Argyll and
Bute Council. The Infrastructure Design team’s approach is to follow the 'Well-managed Highway
Infrastructure' Code of Practice and the Standards for Highways/Design Manual for Roads and
Bridges (DMRB) CS 450 - Inspection of Highway Structures.
5. These national Codes of Practice and Standards categorise bridge inspections into three types:
General Inspections, Principal Inspections, and Special Inspections and set out the frequency of
inspections that should be undertaken. General Inspections should be conducted every 24
months, encompassing visual assessments from ground level without additional access
equipment. Principal Inspections are more comprehensive, requiring close examinations within
touching distance of all accessible parts of a structure, and are recommended every 72 months.
Special Inspections are performed as needed to address specific concerns raised by various
stakeholders.
6. The Infrastructure Design team recently transitioned the structures' asset management system
to the cloud-based WebSMS platform by WDM, replacing the previous server-based version of
the WDM system maintained by Argyll and Bute Council. This system migration aimed to
enhance the accessibility of bridge inventory data. Inventory validation is being integrated into
WebSMS through tablet input by Bridge Inspectors or manually via desktop entries. Additionally,
ad-hoc validation is performed by Bridge Inspectors and Engineers as required.
7. This audit will aim to provide an analysis of the data integrity within the WebSMS system and
evaluate the effectiveness and compliance of the cyclic bridge inspection process with the
national Code of Practice and Standards.
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Argyll and Bute Council – Internal Audit Report – Bridge Asset Management, March 2025
Scope
8. The scope of the audit was to review the data held in the bridges asset management system
together with a review of the cyclic bridge inspection process as outlined in the Terms of
Reference agreed with the Head of Roads and Infrastructure Services on July 24th 2024.
Key Dates
9. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below.
Exhibit 1 – Key Dates
Stage Actual
Date
Terms of Reference agreed 24th July 2024
Fieldwork Commencement 24th July 2024
Draft Report issued (Information
required for the review was
delayed)
25th November
2024
Management Comments received 17th March
2025
Final Report issued 19th March
2025
Audit and Scrutiny Committee 12th June 2025
Risks
10. The risks considered throughout the audit were:
 SRR02:  Infrastructure and Asset Base does not meet future requirements
 Audit Risk 1: There are no procedures in place for Bridge inspections
 Audit Risk 2: Information within the Bridge Asset Management system is not complete
and accurate
 Audit Risk 3: Bridge Inspections are carried out as per agreed policies
 Audit Risk 4: Reputational damage to the Council
 Audit Risk 5: There are no procedures in place for mitigating the risk of late inspections
 Audit Risk 6: Monitoring and reporting of inspections is not in place
Audit Opinion
11. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report.
12. Our overall audit opinion for this audit is that we can take a Reasonable level of assurance.  This
means that Internal control, governance and the management of risk are broadly reliable.
However, whilst not displaying a general trend, there are areas of concern which have been
identified where elements of residual risk or weakness may put some of the system objectives at
risk.
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Argyll and Bute Council – Internal Audit Report – Bridge Asset Management, March 2025
Recommendations
13. We have highlighted one high priority recommendation, one medium priority recommendation
and two low priority recommendations where we believe there is scope to strengthen the
control and governance environment. These are summarised below:
 The Council should ensure a structured performance reporting framework is established
to distribute reports to key stakeholders, include performance updates to Departmental
Management Team (DMT) meetings,
 The Council should develop its own documented procedure for bridge inspections to
ensure and document the process for compliance with the Well-managed Highway
Infrastructure Code of Practice and DMRB CS 450, to enhance clarity, accountability, and
adaptability while aligning inspection activities with external standards and the Council’s
specific operational requirements.
 The Council should ensure formal records are maintained for all training completed by
Bridge Inspectors, including certification courses and in-house training on the WebSMS
asset management system, to enhance accountability and ensure compliance with
training requirements.
 The Council should establish an audit trail within the WebSMS system to document late
inspections, including reasons for delays, actions taken, and stakeholder communication,
to enhance transparency and accountability.
14. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
15. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.
Exhibit 1 – Summary Assessment of Control Objectives
Control Objective Link to Risk Assessment Summary Conclusion
CO1 There are
Procedures in place
for Managing Bridge
Inventory Data
which are
Documented and
communicated to
appropriate
personnel
Audit Risk 1 Reasonable The Infrastructure Design team
oversees 903 bridges, operating
within a legislative and procedural
framework that includes the Roads
(Scotland) Act 1984 and the DMRB
standards.
The Infrastructure Design team lacks
a documented procedure to ensure
compliance with the relevant national
Codes of Practice relying instead on
national Codes of Practice and
Standards categorise and the
WebSMS system. This reliance could
result in reduced adaptability to local
conditions, potential accountability
gaps, and inconsistent processes.
Additionally, while inspectors are
trained, there is no formal record to
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Argyll and Bute Council – Internal Audit Report – Bridge Asset Management, March 2025
verify this, highlighting the need for
documented procedures and training
records to enhance accountability
and transparency.
CO2 All bridge inspection
are carried out in
accordance with
General, Principal,
and Special
Inspections per the
recommended
frequencies and
standards as
outlined in the
'Well-managed
Highway
Infrastructure' Code
of Practice and the
DMRB CS 450.
Audit Risk 2
Audit Risk 3
Audit Risk 4
Substantial A review of inspection reports from
the WebSMS system confirmed that
inspections are comprehensive and
adhere to the 'Well-managed
Highway Infrastructure' Code of
Practice and DMRB CS 450 standards.
The reports include calculated
Condition Indicators & Scores,
inspection of each bridge element,
estimated costs of repairs and
summary of work required.
CO3 There are
procedures in place
for identifying and
mitigating risks
associated with late
inspections,
particularly for high-
priority structures.
Audit Risk 5 Reasonable The audit found gaps in WebSMS for
managing late bridge inspections, as
the system lacks a formal reporting
mechanism to document delays,
actions taken, and risk mitigation.
Currently, inspectors manage this
manually, though plans for an
automated email report are
underway. While risks for high-
priority structure delays are
addressed as needed, no formal
procedures or records exist within
WebSMS for these mitigation
strategies or resource reallocation.
CO4 There are regular
performance
reports generated
and reviewed by
relevant
stakeholders and
reports include key
performance
indicators in
relation to
inspection
schedules and late
inspections
Audit Risk 6 Limited The audit identified gaps in
performance reporting, including the
absence of a structured framework to
distribute reports to key stakeholders
on a regular basis. Additionally,
performance reports are not
routinely included in Departmental
Management Team (DMT) meetings
or other forums, limiting
opportunities for enhanced
monitoring, accountability, and
informed decision-making.
Furthermore, there are no specific
regular reports addressing late bridge
inspections, nor are there formal
action plans or follow-up measures to
ensure compliance with inspection
schedules.
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16. Further details of our conclusions against each control objective can be found in Section 3 of this
report.
3. Detailed Findings
There are Procedures in place for Managing Bridge Inventory Data which are Documented and
communicated to appropriate personnel.
17. The cyclic bridge inspection process, recorded within WebSMS, follows established standards
including the 'Well-managed Highway Infrastructure' Code of Practice and the Standards for
Highways/Design Manual for Roads and Bridges (DMRB) CS 450 - Inspection of Highway
Structures. The Infrastructure Design team is responsible for the oversight of 903 bridges within
Argyll and Bute Council. Management within Infrastructure Design follow a framework of
legislative, procedural, and operational documents to ensure effective and compliant
management of highway structures. This includes the Roads (Scotland) Act 1984, adherence to
the Code of Practice: Well-Managed Highway Infrastructure, and implementation of design
standards as outlined in the DMRB - Highway Structures and Bridges Series. Furthermore, the
team operates in alignment with the Council's strategic objectives as detailed in the Roads Asset
Management Plan (RAMP) - June 2017, providing a structured approach to maintaining and
managing bridge infrastructure.
18. The audit found that the Council does not have its own documented service procedure for
ensuring that bridge inspections are conducted in line with the national codes of practice.
Instead, the Management complies with 'Well-managed Highway Infrastructure' Code of
Practice and the Standards for Highways/Design Manual for Roads and Bridges (DMRB) CS 450 -
Inspection of Highway Structures and records asset management information within WDM
WebSMS. The sole reliance on national Codes of Practice and Standards and the WebSMS
(WDM) system without agreed internal procedures tailored to the Councils operational
requirements may result in
 Reduced adaptability to address specific local requirements or unique structural
conditions
 Potential gaps in accountability and clarity for staff responsible for inspections
 Inconsistent application of inspection processes, especially when relying solely on
system outputs
 Vulnerability to interruption in service of the WebSMS (WDM) system including: failures
by the provider, cyber-attack or other long duration ICT outage requiring reversion to
“manual / paper based” approaches to bridge inspection and associated data collection.
The Council should consider developing its own documented service procedure for bridge
inspections setting out how compliance with the national codes of practice will be achieved in
the context of Argyll and Bute Council. This would enhance clarity, accountability, and
adaptability, ensuring that all inspection activities align with both external standards and the
Council’s specific operational requirements.  
Action Plan 2
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19. Council officers advised that Bridge Inspectors have completed comprehensive training under
the Bridge Inspector Certification Scheme, ensuring they are qualified to conduct inspections in
line with established standards. Inspectors follow the Inspection Manual for Highway Structures,
Volumes 1 and 2, which guides inspection procedures. Additionally, training on the WDM
WebSMS asset management system is provided internally by the Infrastructure Design team, as
the system was developed specifically to meet the team's unique operational needs. This in-
house, tailored training equips inspectors with the necessary skills to effectively manage bridge
inventory data in the WebSMS system. While the client has indicated that Bridge Inspectors have
completed relevant certification courses and received in-house training on using the WebSMS
asset management system, there is no formal record of training maintained on file.
Action Plan 3
20. Special Inspections are recorded within the WebSMS system, the current limitation is the
inability to export these reports. The client was already aware of this issue and had instructed
WDM to enhance the system's functionality to allow for exporting Special Inspection data in
future for full Inspection History reports. This enhancement will facilitate more efficient audits
and improve accessibility to inspection data.
All bridge inspection are carried out in accordance with General, Principal, and Special
Inspections per the recommended frequencies and standards as outlined in the 'Well-managed
Highway Infrastructure' Code of Practice and the DMRB CS 450.
21. A sample of inspection reports from the WebSMS system were viewed via a desktop exercise.
The review found inspections were comprehensive and aligned with 'Well-managed Highway
Infrastructure' Code of Practice and the DMRB CS 450 standards. Checked carried out detailed
within Inspections reports include:
 Calculated Structural Condition Indicators and Condition indicator scores indicating the
average and critical condition of each bridge,
 Inspection of each bridge element including deck, sub structure, safety elements, and all
other structural elements of each bridge,
 Estimated costs of repairs for each inspected bridge element which requires work,
 Work required section indicating where structures require works, including immediate
attention (High Priority) where applicable.
22. The audit found that 38 bridges have inspections late by 26 months or more. While the report
provided details on the late status, it did not specify the risk category of these bridges. This lack
of information limits the Council’s ability to prioritise and address inspections based on the
potential risk level associated with each structure.
23. The audit found that inspection resources for bridge inspections, particularly for high-priority or
urgent matters, are allocated on an ad hoc basis, according to immediate needs. Consideration
should be given to establishing a more structured approach for allocating inspection resources,
particularly for high-priority or urgent inspections, to ensure that critical inspections are
consistently prioritised and adequately resourced.
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24. Concerns raised by the public are addressed through the same process as those initiated by
Inspectors' recommendations following General Inspections. While Special Inspections are
primarily triggered by Inspectors' observations, any inspections prompted by public concerns are
handled consistently within the established inspection framework.
There are procedures in place for identifying and mitigating risks associated with late
inspections, particularly for high-priority structures.
25. The Code of Practice states that there should be a formal and traceable documentation process
in place to manage and report on late inspections. This ensures accountability and continuous
monitoring of inspection schedules and compliance with the 'Well-managed Highway
Infrastructure' Code of Practice and the DMRB CS 450 standards.
26. The audit found that there is currently no audit trail within the WebSMS system (WDM) to
document late inspections, including reasons for delays, actions taken, and stakeholder
communication. Instead, this process is managed manually by inspectors outside of the system.
Council officers noted that steps are underway to develop an automated report from WDM to
capture and record this information formally via email. Establishing an integrated, automated
audit trail within WebSMS would enhance transparency, accountability, and ease of access to
records related to late inspections, providing a more robust system for tracking and managing
inspection compliance.
Action plan 4
27. The audit found that while council officers confirmed that risks associated with late inspections
of high-priority structures are addressed as they arise, there is no formalised documentation of
specific risk mitigation plans within the WebSMS system. To strengthen oversight, it is
recommended that a formal process for documenting these risk mitigation strategies within the
WebSMS system be implemented, ensuring consistent and transparent management of
inspection delays.
28. The audit found that resources are reallocated as needed in response to inspection delays,
including prioritisation for high-priority structures. This flexible approach helps to mitigate risks
associated with inspection delays and ensures that high-priority structures receive attention
promptly. However, formalising this process with documented procedures could enhance
consistency and transparency in resource reallocation, providing clearer guidance for staff and
further supporting effective risk management.
There are regular performance reports generated and reviewed by relevant stakeholders and
reports include key performance indicators in relation to inspection schedules and late
inspections. 
29. The Council's Annual Report highlights key data on the condition of bridge stock and associated
challenges. The Bridge Stock Condition is now evaluated using a weighted average per span, with
recent cyclic assessments showing a decline in condition over time. In the most recent cycle
(2022-24), the Average Bridge Stock Condition was reported as 87.86 (out of 100), and the
Critical Element Stock Condition as 79.08 (out of 100), both showing a significant drop compared
to earlier cycles, such as 2016-18 when these figures were 89.46 and 82.40, respectively. A
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backlog of maintenance works currently amounts to £32.4 million, exacerbating the declining
condition trend. Additionally, the report identifies specific weak bridges within the Council's
network, which are subject to weight restrictions ranging from 3 tonnes to 18 tonnes. Examples
include Laggan Old Bridge (10T, Islay), Glendaruel Bridge (3T, Cowal), and Kilbride Bridge (10T,
Cowal). In the near term it is unlikely that significant increases in capital budget allocation will
enable a meaningful programme of works to address this backlog maintenance liability. These
findings underscore the need for prioritised maintenance to address the growing infrastructure
deficit and ensure public safety and functionality while recognising that difficult decision may be
required that prioritizes the limited available resources to maximise the preservation of
transport network functionality on the more highly used / critical road routes.
30. The audit found that no key performance indicators (KPIs) are currently established for the
bridge inspection process, resulting in an absence of KPI-based performance reporting.
Introducing relevant KPIs and incorporating them into regular performance reporting would
enhance transparency, facilitate better decision-making, and support the timely identification
and resolution of potential issues in bridge inspections.
Action plan 1
31. The audit found that no performance reports are currently generated within the WebSMS
system for distribution to relevant stakeholders. Without a structured reporting process, key
stakeholders lack critical information needed to monitor inspection performance and allocate
resources effectively. It is recommended that the Council establish a clear reporting framework
to ensure that key stakeholders receive regular performance updates, enhancing oversight and
accountability in bridge management.
Action Plan 1
32. The audit determined that performance reports are not forwarded to Departmental
Management Team (DMT) meetings or other relevant forums. Establishing regular performance
reporting and including these in DMT meetings would strengthen monitoring practices, foster
accountability, and enable timely decision-making regarding the bridge inspection management.
Action plan 1
33. The audit revealed that no regular performance reports generated specifically for late bridge
inspections, and consequently, no formal action plans or follow-up measures are developed to
address these delays. Implementing a structured reporting process focused on late inspections,
along with associated action plans to resolve identified issues, would improve oversight and help
ensure that inspection schedules are adhered to, thereby enhancing the safety and reliability of
the bridge infrastructure.
Action Plan 1
34. Regular team meetings are held to discuss bridge inspection matters, ensuring ongoing oversight
and coordination. A review of the meeting minutes confirmed that these discussions address key
issues related to inspection schedules, prioritisation of high-risk structures, and any arising
concerns regarding bridge maintenance and safety.
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Appendix 1 – Action Plan
No Finding Risk Agreed Action Responsibility / Due Date
High 1
Performance Reporting
There are no regular performance reporting on the
following:
 Structured reporting framework to distribute
performance reports to key stakeholders on a
regular basis.
 Performance reporting into Departmental
Management Team (DMT) meetings and other
relevant forums to improve monitoring,
accountability, and decision-making.
 Specific regular performance reports for late
bridge inspections, accompanied by formal action
plans and follow-up measures to address delays
and ensure compliance with inspection schedules.
The absence of regular
performance reporting also
restricts visibility for relevant
stakeholders, which may lead
to delays in addressing late
inspections and hinder
proactive maintenance
planning.
A report setting out key
performance information in
relation to the annual programme
of bridge inspections will be
produced for review by the RIS
senior management team on a
quarterly basis. The report will be
received by the RIS senior
management team by the end of
the month following quarter end
at the latest. The first of these
reports will be produced for
review during the month of April
2025 for Q4 of 2024.
A Quarterly Report on appropriate
KPIs will be generated by WDM
and can be aligned around ABC
Reporting timescales.  Currently a
QR is being implemented to
report on every bridge’s most
recent inspection.  The Quarterly
Report will be accompanied by
the most recent Late Inspections
report.
The overall suite of performance
measures used by RIS is currently
under review. Until such time as
this review work is completed and
a refreshed approach to service
performance reporting is
implemented the HoS will provide
a by exception report to the
Infrastructure Design
Manager 
30th June 2025
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No Finding Risk Agreed Action Responsibility / Due Date
Departmental Management Team
on a quarterly basis setting out
key metrics and risks associated
with the annual bridge inspection
programme. This reporting will
commence for the Q4 period of
2024 and will follow reporting into
the RIS senior management team
and will therefore take place as
early as possible in the month 2
months after quarter end i.e.
commencing in June 2025.
Medium
2
Procedures
The Council should consider developing its own
documented procedure for bridge inspections which sets
out how the Council will achieve and ensure compliance
with Well-managed Highway Infrastructure Code of
Practice and DMRB CS 450. This would enhance clarity,
accountability, and adaptability, ensuring that all
inspection activities align with both external standards and
the Council’s specific operational requirements.
Reliance on national Codes of
Practice and Standards
without internalised
procedures may reduce
adaptability to local
requirements, create gaps in
accountability, and result in
inconsistent application of
inspection processes.
A service manual will be
developed setting out how the
Council implements and assures
compliance with Well-managed
Highway Infrastructure Code of
Practice and DMRB CS 450. This
will not seek to replace the
national Code of Practice but
rather to articulate how the
Council ensures compliance with
it.
Infrastructure Design
Manager
30th September 2025
Low 3
Training
While the client has indicated that Bridge Inspectors have
completed relevant certification courses and received in-
house training on using the WebSMS asset management
system, there is no formal record of training maintained
on file.
The absence of documented
training records creates a gap
in verifying staff competency,
which could lead to potential
compliance issues and hinder
accountability.
Records shall be stored on
Infrastructure Design network
drive until instructed otherwise.
Infrastructure Design
Manager 
31st March 2025
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No Finding Risk Agreed Action Responsibility / Due Date
Low 4
Audit Trail Re late Inspections
The audit found that there is currently no audit trail within
the WebSMS system (WDM) to document late inspections,
including reasons for delays, actions taken, and
stakeholder communication.
Without an integrated,
automated audit trail, there is
limited transparency and
accountability in tracking late
inspections.
Late Inspections are currently
being recorded manually via a
report Infrastructure.
Design can export on WDM as to
which reasons are added by the
Infrastructure Design team.
An automatic report is currently
being built within WDM that will
send a late inspections report. 
Late inspections and actions
needed to ensure they are
undertaken will form part of the
quarterly reporting to RIS senior
management team. This will
enable the Infrastructure Design
Team to highlight risks, articulate
mitigations and to seek support
where required to implement
these.
Infrastructure Design
Manager
31st March 2025
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In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained.  The definitions
of each classification are as follows:
Grading Definition
High A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error.
Medium
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.
Low Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives.
VFM An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM).
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Appendix 2 – Audit Opinion
Level of Assurance Definition
High
Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently.
Substantial
Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale.
Reasonable
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk.
Limited
Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised.
No Assurance
Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues.
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Argyll and Bute Council
Internal Audit Report
May 2025
FINAL
High Medium Low VFM
Number of
Findings
0 0 0 0
Trading Standards
Audit Opinion: High
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Contents
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 6
Appendix 2 – Audit Opinion ................................................................................................................. 11
Contact Details
Internal Auditor: Annemarie McLean 
Telephone: 01700 501354 
e-mail: Annemarie.mclean@argyll-bute.gov.co.uk
www.argyll-bute.gov.uk
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1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to Trading Standards.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with council officers and the information available at
the time the fieldwork was performed. The findings outlined in this report are only those which
have come to our attention during the course of our normal audit work and are not necessarily
all the issues which may exist. Appendix 1 to this report includes agreed actions to strengthen
internal control however it is the responsibility of management to determine the extent of the
internal control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. The Tobacco and Primary Medical Services (Scotland) Act 2010 contains measures aimed
specifically at reducing the attractiveness and availability of tobacco to persons under 18.
The Act:
• bans the sale of tobacco from vending machines;
• introduces a tobacco sales registration scheme, which will be free for retailers to join;
• makes it an offence for under 18s to attempt to purchase tobacco;
• makes it an offence for adults to buy tobacco on behalf of under 18s (known as proxy
purchase);
• gives trading standards officers powers to issue fixed penalty notices, and ;
• gives courts the power to ban retailers from selling tobacco where they have repeatedly
broken the law.
5. Since the 1 April 2011, local authorities have had a statutory duty to enforce the tobacco-related
provisions of the 2010 Act and related regulations. They have also had a statutory duty to carry
out an annual programme of enforcement in their area.
6. From the 1 April 2017, The Health (Tobacco, Nicotine etc and Care) (Scotland) Act 2016
amended the 2010 Act, requiring that tobacco products be extended to include NVPs, commonly
known as ‘vapes’. This includes:
• making it an offence to sell NVPs to under 18s,
• making it an offence to buy for under 18s (‘proxy purchase’),
• creating a national register of NVP retailers,
• introducing banning orders for NVP retailers who flout the law, and
• creating a fixed penalty enforcement regime for offences.
7. At the same time, additional requirements were brought in for both tobacco and NVPs, namely:
• a requirement to have an ‘age verification policy’ (AVP), and
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• a requirement for under 18s to have authorisation from a responsible person to sell
these products.
8. Trading Standards Officers work in partnership with the Scottish Government to monitor and
support sellers, who need to comply with regulations associated with the retail sale of both
tobacco and vaping products. Officers work with young (under-18) people locally and in tightly
controlled test purchase situations to check that sellers are abiding by the law by asking for
proof of age where appropriate and refusing to sell to children. Those found to be selling to
under-18s can be issued with fixed penalty notices or even be banned from selling these
products.
9. Enforcement is critical to ensuring that tobacco and vaping products are sold legally. All retailers
have a responsibility to ensure that they are complying with the law.
Scope
10. The scope of the audit was to review and assess the duties relating to age restrictions on
tobacco and vapes (NVP), together with how such restrictions are monitored and enforced by
the Council as outlined in the Terms of Reference agreed with the Head of Legal and Regulatory
Services.
Key Dates
11. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below.
Exhibit 1 – Key Dates
Stage Actual Date
Terms of Reference agreed 20 March 2025
Fieldwork Commencement 20 March 2025
Draft Report issued 14 April 2025
Management Comments received 17 April 2025
Final Report issued 02 May 2025
Audit and Scrutiny Committee 12 June 2025
Risks
12. The risks considered throughout the audit were:
• Audit Risk 1 - Failure to comply with tobacco related Legislation
Audit Opinion
13. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report.
14. Our overall audit opinion for this audit is that we can take a high level of assurance.  This means
that internal control, governance and the management of risk are at a high standard. Only
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marginal elements of residual risk have been identified with these either being accepted or dealt
with. A sound system of control designed to achieve the system objectives is in place and being
applied consistently.
2. Objectives and Summary Assessment
15. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.
Exhibit 1 – Summary Assessment of Control Objectives
Control Objective Link to Risk Assessment Summary Conclusion
1 The Council has
processes and
procedures in place
to ensure
compliance with its
duties relating to
age restrictions on
tobacco and vapes
(NVP)
Audit Risk 1 High • The Council’s Constitution, Scheme
of Authorisations and Delegations
allows for the nomination and
authorisation of officers to carry
put the duties pertaining to the
enforcement of the various public
protection legislation, which
includes consumer protection, fair
trading and trading standards.
• Staff are issued with warrant cards
to act in accordance with, and to
enforce, certain legislation based
on the professional qualifications
they hold.
• The Trading Standards team follow
guidance and protocols relating to
testing and enforcement of age
restrictions on tobacco and vapes
(NVP), issued by the Scottish
Government and the Society of
Chief Officers of Trading Standards
in Scotland (SCOTSS).
2 The Councils
monitors adherence
to age related
restrictions on
tobacco and vapes
(NVP) and enforces
compliance when
breaches are
identified.
Audit Risk 1 High • The Council has a duty to prepare
and carry out an annual
programme of enforcement.
• The annual Trading Standards
Service Plan details the tasks and
actions team will take to meet the
required standards and priorities
for that year.
• Observation of Test Purchase visits
confirm that staff follow the
guidance issued by the Scottish
Government and SCOTSS.
• Performance is reported internally
to Legal and Regulatory Support -
Governance, Risk and Safety
Managers meeting, Department
Team Meetings (DMT) and Senior
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Management Team (SMT)
meetings and externally to SCOTSS.
• The Trading Standards team
exceeded the statutory
performance for advice visits and
test purchase visits in the financial
year 2024/25.
• Two breaches were identified in
relation to the sale of tobacco
products to someone under the
age of 18. Fixed Penalty notices
were issued and promptly paid.
16. Further details of our conclusions against each control objective can be found in Section 3 of this
report.
3. Detailed Findings
The Council has processes and procedures in place to ensure compliance with its duties relating
to age restrictions on tobacco and vapes (NVP)
17. The Council’s Constitution Part C- Scheme of Authorisation and Delegations allows for the
nomination/authorisation of officers to carry out the duties pertaining to the enforcement of the
various public protection legislation, which includes consumer protection, fair trading and
trading standards.
18. Staff within the Trading Standards are authorised to act in accordance with, and to enforce, over
200 pieces of current legislation on behalf of Argyll and Bute Council.  Authorisation for warrant
cards to enforce certain elements of legislation, e.g. Weights and Measures, Animal Health and
Welfare, and Under Age sales (UAS), is dependent upon the professional qualifications held by
staff.
19. Professional training teaches staff to interpret legislation and this judgement/professional
knowledge is what is used by staff when carrying out their role. Individual officers maintain
records of their own Continuing Professional Development (CPD), this is used by Chartered
Trading Standards Professionals to maintain their chartered status and ensures they enhance
the knowledge, skills, and competencies for their roles throughout their careers.
20. The Council’s Trading Standards team follow guidance and protocols relating to testing and
enforcement of age restrictions on tobacco and vapes (NVP), issued by the Scottish Government
and the Society of Chief Officers of Trading Standards in Scotland (SCOTSS). Given the volume
and breadth of legislation covered by the Trading Standards and Money Advice team, we are
advised that it is not practicable to develop separate Council procedure notes for each of these
pieces of legislation.
21. The key documents are:
• The Scottish Governments’: Tobacco and Nicotine Vapour Product Sales  Guidance for
Local Authorities – Enforcement Guidance & Protocols document (the Enforcement
Guidance);
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• SCOTTS: Guidance for Local authorities on Test Purchasing Age Restricted Products
(Testing Guidance);
22. SCOTSS works with a wide range of government, regulatory, consumer, business, and third
sector organisations, mixing operational and technical expertise with policy work, in order to
ensure the effectiveness of consumer protection services in Scotland and provide a source of
knowledge and support for trading standards staff.
23. SCOTSS also maintains the Approved Trader database which is an online portal to all of
Scotland's trading standards functions who run assured trader schemes.
24. The Enforcement Guidance document was developed by the Scottish Government in
consultation with key stakeholders, including SCOTSS, to help local authorities and individual
officers carry out enforcement of the Tobacco and NVP related provisions of the 2010 Act
including the changes brought in by the 2016 Act, and ensure the legislation is implemented
effectively, fairly and consistently across Scotland.
25. Information relating to age restrictions on tobacco and vapes (NVP) is published on the Trading
Standards Sale of age restricted goods, of the Council’s website, it is up to date and easily
available to the public.
26. The web page provides information and links to quick guides for business, regarding the sale,
supply or offer to supply, tobacco products and nicotine vapour products, (NPV’s). It clearly
states the age restrictions applicable (minimum age of 18) and that traders should always ask
young people to produce proof of their age prior to selling, as “Challenge 25” is a legal
requirement in Scotland.
27. Within the scope of this review, the key tasks relate to the provision of advice, responding to
complaints, test purchase (TP) visits and enforcing compliance with relevant legislation. There
are currently two staff who can be the Lead Officer when carrying out the test purchases. Staff
within the wider team have been involved in test purchases and are aware of the roles and
requirements of each staff member involved, but are currently not authorised to be the Lead
Officer.
28. Discussions with the Trading Standards & Advice Services Manager confirm that within the
confines of the resources available, there is an ongoing plan, utilising ‘grow our own’ where skills
and training are developed for current staff in order to try and support business continuity in the
future. There are currently two Trading Standards Officers, one Regulatory Servicers Officer, a
Trainee Trading Standards Officer, and the Enforcement Officer post is in the process of being
filled. Both the Trainee Trading Standards Officer and the Enforcement Officer are/will be
undertaking professional training at differing levels.
29. Currently there is not an excessive over reliance on one member of staff, however, operations
and business continuity, would be restricted due to authorisation levels linked to professional
qualifications held by staff.
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The Councils monitors adherence to age related restrictions on tobacco and vapes (NVP) and
enforces compliance when breaches are identified.
30. Local Authorities have a statutory duty to enforce the provisions within the 2010 Act and related
regulations and are required to prepare and carry out an annual programme of enforcement in
their area, as part of the Enhanced Tobacco Sales Enforcement Programme (ETSEP) and the
Enhanced Nicotine Vapour Product Sales enforcement programme (ENSEP). To enable this
programme, the Scottish Government provide funding which is embedded within the Local
Authorities annual budget allocation.
31. The Trading Standards team have arrangements in place to monitor adherence to age related
restrictions on tobacco and vapes (NVP), including how to enforce breaches.
32. The annual Trading Standards Service Plan, is based on the resources available and details the
tasks and actions team will take to meet the required standards and priorities for that year.
Performance is recorded and monitored using a spreadsheet which has a breakdown of the
actions of required to complete each task.
33. There are 2 specific tasks for the annual enforcement plan for age related restrictions on
tobacco and vapes (NVP) and enforcement of breaches.
• TP 5 – Tobacco and Related Products (TARP) Programme of test purchased and advice
visits.
• TP 19 - Consider Civil Enterprise Act Action (Fair Trading) or Tobacco Banning Orders
(TARP).
34. The statutory targets are percentages so vary from year and are based upon the number of
registered retailers/supplier within the Council area, as detailed in the Scottish Tobacco Retailers
Register.
35. The Enforcement Guidance states that all test purchasing operations:
• should be carried out in accordance with the SCOTSS document ‘Guidance for Local
authorities on Test Purchasing Age Restricted Products’ ; and
• may lead to formal action being taken against the staff member and the owner of the
business, for non-compliance with the Age Verification/Challenge 25 Guidance.
36. Observations of the Testing of premises by the Auditor, confirm that:
• Staff follow the guidelines/best practice issued by the Scottish Government and SCOTTS;
• There are pre Test Purchase risk assessments and discussions;
• Staff involved in the operation were all aware of and familiar with the requirements of
the legislation and guidance.
• There are established processes for the collection and storage of documentation,
information and evidence relating to age restrictions on tobacco and vapes (NVP) and
Under Age Sales (UAS).
• No breaches were identified during any of the observed visits.
37. When breaches occur Fixed Penalty Notices (FPN) must be issued to the person committing the
offence within 7 days. Details on how to pay these are provided on the back of the notice. When
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a FPN is issued, Trading Standards staff notify the cash receipting team who monitor the income
and advise when payment is received.
38. During Test Purchase visits, not attended by internal audit, two breaches were identified in
relation to the sale of tobacco products to someone under the age of 18. Fixed Penalty notices
were issued and promptly paid.
39. Performance towards meeting the statutory targets is reported:
• Internally – monthly and quarterly, at the Legal and Regulatory Support - Governance, Risk
and Safety Managers meeting and to Departmental Management Team;
• Internally quarterly to Senior Management Team (SMT);
• Externally, quarterly returns to SCOTSS who record performance for the Scottish
Government.
40. Single Use Vapes (SUV) are due to be banned in 2025/26. In preparation for this, to support and
educate retailers and suppliers, the decision was taken to focus resources towards this,
increasing the number of both advice visits and vapes (NVP) Test Purchases.
41. This has been a success and in the financial year 2024/25 the Trading Standards team exceeded
the statutory performance for advice visits and test purchase visits and achieved the undernoted
results:
Vape (NVP) Tobacco
Retailers given advice 236% 108%
Retailers test purchase visits 110% 114%
Under Age Sales (UAS) breaches 0 2
Fixed Penalty Notices Issued 0 2
Fixed Penalty Notices Paid 0 2
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In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained.  The definitions
of each classification are as follows:
Grading Definition
High A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error.
Medium
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.
Low Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives.
VFM An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM).
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Appendix 2 – Audit Opinion
Level of Assurance Definition
High Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently. 
Substantial Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale. 
Reasonable
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk.
Limited Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised. 
No Assurance Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues. 
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Argyll and Bute Council
Internal Audit Report
May 2025
FINAL 
High Medium Low VFM
Number of
Findings
0 7 0 0 
External Placements
Audit Opinion: Reasonable 
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Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 15 
Contact Details 
Internal Auditor: Moira Weatherstone 
Telephone:  01546 604146 
e-mail:   moira.weatherstone@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to External Placements.
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with council officers and the information available at
the time the fieldwork was performed. The findings outlined in this report are only those which
have come to our attention during the course of our normal audit work and are not necessarily
all the issues which may exist. Appendix 1 to this report includes agreed actions to strengthen
internal control however it is the responsibility of management to determine the extent of the
internal control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. The Children (Scotland) Act 1995 is centred on the needs of children and their families and
defines both parental responsibilities and rights in relation to children.  Councils have a duty to
provide social care for those who need it, whether they provide these services themselves,
contract with the voluntary or private sector to provide them or give clients a budget to arrange
their own care.  This includes placements which are out with the authority area. 
5. Argyll & Bute Council (the Council) Children & Families provide a range of services to protect and
support vulnerable children to enable them to continue to live safely in their own communities
and to meet the Council’s statutory responsibilities. The Council also provides, where
appropriate, to meet the needs of the young person, out of authority placements in Scotland.
Out of authority placements require effective planning, engagement, and information sharing
with the services likely to be responsible for meeting the needs of children.   
6. In 2023/24 the annual budget for external placement services was £2.961m, with Social Work
providing £1,697m of this and Education providing £1.264m.  The actual spend in 2023/24
amounted to £3.411m (Social Work £1.744m and Education £1.667m). The number of young
people requiring an external placement has been increasing in recent years, the current number
of external placements is 16.  The increase in the number of placements and the increase in
rates imposed by external providers (one provider increased rates by 19%) has resulted in
budget overspends on an annual basis. 
7. In addition, with demand for external placements increasing and a large number of authorities
throughout the UK requiring placements, the availability to meet those demands is becoming
challenging.   
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Scope 
8. The scope of the audit was to determine if clear measures and goals of external placements,
including the actual interventions offered meets the expected long term outcomes and
represents Best Value as outlined in the Terms of Reference agreed with the Head of Children &
Families & Criminal Justice, in addition to Head of Education-Wellbeing, Inclusion and
Achievement on the 10 February 2025.
Key Dates
9. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below. 
Exhibit 1 – Key Dates
Stage Actual
Date
Terms of Reference agreed 10/02/2025
Fieldwork Commencement 24/02/2025
Draft Report issued 19/05/2025
Management Comments received 23/05/2025
Final Report issued 23/05/2025
Audit and Scrutiny Committee 12/06/2025 
Risks
10.  The risks considered throughout the audit were:
• SRR07:  Health and Social Care Partnership: Failure of the HSCP to deliver on its Strategic
Priorities results in deteriorating health and wellbeing outcomes for the population and /or
reduced access to appropriate health and social care services. This could also result in
financial and reputational risk to the Council
• Audit Risk 1: failure to have policies and procedures in place for external placements
• Audit Risk 2: failure to have robust care plans with detailed outcomes in place for external
placements
• Audit Risk 3: Failure to review and monitor young people’s progress in external placements
in terms of agreed outcomes 
• Audit Risk 4: Failure to set and monitor budgets to ensure value for money
Audit Opinion
11. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report. 
12. Our overall audit opinion for this audit is that we can take a reasonable level of assurance.  This
means that internal control, governance and the management of risk are broadly reliable.
However, whilst not displaying a general trend, there are areas of concern which have been
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identified where elements of residual risk or weakness may put some of the system objectives at
risk. 
Recommendations
13. We have highlighted 7 medium priority recommendations where we believe there is scope to
strengthen the control and governance environment. These are summarised below:
• Procedures should be put in place that outline the various steps to be taken when
placing young people in external placements, this should include details of the review
processes
• Consideration should be given to inviting education to participate in the weekly resource
panel meetings and/or minutes shared
• Consideration should be given to requesting regular reports from providers detailing
achievements and progress towards outcomes
• Visits to providers should resume 
• Procedures should be put in place for young people leaving care to ensure that they
have a clear pathway towards a positive destination and destinations are being recorded
• There is increased risks associated with the current model of care and increased demand
on Social Work and Education budgets resulting in significant overspends. Budgets could
be reviewed in conjunction to considering alternate models of care which could be
delivered internally, where that is deemed appropriate
• the costs of care and education must be fully transparent and broken down into each
element with reports provided to both services for each individual package
14. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
15. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.  
Exhibit 1 – Summary Assessment of Control Objectives 
Control Objective Link to Risk Assessment Summary Conclusion
1 Policies and
procedures are in
place for the
assessment and care
planning  of young
people
SRR07
Audit Risk 1
Audit Risk 2
Reasonable An Option Appraisal Meeting Practice
Guidance Document (the Document)
dated 2021, was made available for
review.  This document outlines the
agreed approach between Argyll and
Bute Education services and HSCP
children’s services when considering
possible care options for any looked
after and accommodated young
person. Roles and responsibilities are
detailed in the document, however this
has not been updated to reflect the
role of the Care Assessment Reviewing
Officers (CARO) in the process.  The
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document outlines who is authorised
to approve admissions to care,
including if this is an emergency
placement.  There was no process
document which outlined, for
practitioners, the various stages of the
process from referral (or emergency
placement) stage to the actual
placement of the young person. 
Procedures are understood by those
undertaking the tasks.
2 All young people in
external placements
have care plans in
place with clear
goals and
intervention which
meet the needs of
the young person
Audit Risk 2 Reasonable Care plans are kept up to date and
amended following any interventions
or reviews.  In addition, as detailed
above weekly internal reviews are
undertaken looking at each placement. 
However, it is noted that Care Plans
and case notes were not always
updated timeously on Eclipse.  Care
providers do not routinely provide
regular updates to Social Work or
Education on progress being made or
whether outcomes are being achieved.  
3 Reviews are
undertaken with
progress to
achieving goals
discussed
Audit Risk 3 Reasonable Formal case reviews are held within 72
hours of placement, 6 weeks and then
3 months.  Visits to the providers were
undertaken by the Virtual Head
Teacher and the Residential and
Aftercare Manager, this allowed more
informal discussions to take place
around whether outcomes were being
achieved and discuss any amendments
to the care plan in place.  Due to staff
changes these have not been taking
place.  
4 Long term outcomes
are assessed and
destinations
recorded at the end
of the external
placement
Audit Risk 3 Reasonable It was unclear whether there were
robust procedures and monitoring in
place for young people leaving care
with many returning to their previous
locations.  This became more
challenging when the young person left
education, although it was noted that
the Virtual Head Teacher ensured that
all efforts were made to secure a
positive destination for that young
person.
5 Budgets are aligned
to ensure costs
reflect the cost of
care and education
elements of the
Audit Risk 4 Reasonable Like other authorities, the Council has
very little control over the cost of
external placements, with providers
setting the cost against a background
of competing demands from
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placement, with
value for money
being monitored
authorities throughout Scotland.  In
addition, the need for external
placements is increasing each year.  In
many cases there are no internal
resources available to meet the needs
of the young person.  Clear costings are
given from the providers, they are
available to see in advance of
contacting them to discuss any
prospective placement, and these are
available through the Scotland Excel
procurement service website. The
breakdown of all cost of care and
education placements is 38%
education and 62% care with the
placements agreed jointly by Heads of
Service for both care and education. 
16. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
Policies and procedures are in place for the assessment and care planning of young people 
17. An Option Appraisal Meeting Practice Guidance Document (the Document) dated 2021, was
made available for review.  This document outlines the agreed approach between Argyll and
Bute Education services and HSCP children’s services when considering possible care options for
any Looked after and accommodated young person.   
18. Roles and responsibilities are detailed in the document, however, it has not been updated to
reflect the role of the Care Assessment Reviewing Officers (CARO) in the process.  The document
outlines who is authorised to approve admissions to care, including if this is an emergency
placement, however, it does not outline the complete process or responsibilities in terms of
identifying placement information, contracting, sharing information with providers and the
review follow up processes.                                                                                                                                                               
Action Plan 1
19. The option appraisal process clearly seeks to consider all options open to meet the needs of the
young person and where a child requires care, and where there are no kinship options, the
options appraisal process aims to match the child to the most appropriate available care option.
It is stated that consideration should only be given to an external care option where other
options have been exhausted.  At this point, the Senior Manger Children’s Resources may
request an external care screening panel and authorise initial approaches to potential providers
where urgent. 
20. The processes for consideration being given to an external placement are robust with a Multi-
agency Options Appraisal Panel being convened. The options appraisal meeting will consider all
provider’s proposals to meet the child’s needs, along with; cost, previous experience of the
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provider and any registration or inspection issues, to identify a recommended preferred option.
The panel has 2 purposes: 
• To consider whether an options appraisal of external care providers should be
undertaken 
• To approve a preferred external option – where required 
21. Significant scrutiny and oversight is also given to external placements. A Joint Resource Group
(JRG) Terms of Reference was provided. The JRG is the interagency management group with
operational responsibility for promoting and overseeing effective joint working between
Education, Health and Social Work, and for ensuring the effective prioritisation and deployment
of interagency resources in respect of individual children, in line with the principles and values of
GIRFEC (Getting it Right for Every Child) and best value. The remit of the JRG group includes: 
• Consideration of requests for funding of complex interagency packages of support,
including Social Work packages over £30,000
• Consideration of requests for external placements including residential school and day
education placements and CAMHS tier 4 commissioned services 
• Monitor the progress of care planning for high profile cases including children at risk,
secure placements and children in the community 
• Consider any issues of concern around meeting the needs of looked after and
accommodated children as identified by the CAROs
• Monitor receptions into care, transfers and discharges
• Consider variations in contracts in respect of children in external placements 
22. Weekly Children’s Resource Panel meetings are chaired by the Senior Manager for Resources
and are attended by the Senior Managers for Resources and Justice and the two operational
Service Managers.  This is an internal meeting where each external placement is reviewed, in
addition to discussion on any potential placements coming forward.  Minutes of this meeting are
recorded, however are not shared with education.  The details of individual children’s plans are
shared with education at review meetings, however, we understand that such meetings may not
always be taking place within expected timescales or are being postponed.            
Action Plan 2
All young people in external placements have care plans in place with clear goals and
intervention which meet the needs of the young person 
23. Care plans are kept up to date and amended following any interventions or reviews.  In addition,
as detailed above, weekly internal reviews are undertaken looking at each placement.  It is noted
that Care Plans and case notes were not always updated timeously on Eclipse, however, regular
supervision by the Line Manager ensured that case records were discussed and where necessary
highlighted if care plans are not updated. 
24. Care providers do not routinely provide regular updates to Social Work or Education on progress
being made or whether outcomes are being achieved.  The lack of regular updates makes it
challenging to monitor and adapt care plans where goals and interventions are not meeting the
needs of the young person.                                                                                                                                              
Action Plan 3
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Reviews are undertaken with progress to achieving goals discussed 
25. Formal case reviews should be held within 72 hours of placement, after 6 weeks and also after 3
months.  Visits to the providers were previously undertaken by the Virtual Head Teacher and the
Residential and Aftercare Manager, this allowed more informal discussions to take place around
whether outcomes were being achieved and discuss any amendments to the care plan in place. 
Due to staff changes these have not been taking place.                                                                                                                                                               
Action Plan 4
Long term outcomes are assessed and destinations recorded at the end of the external
placement 
26. It was unclear whether there were robust procedures and monitoring in place for young people
leaving care with many returning to their previous locations.  This became more challenging
when the young person left education, although it was noted that the Virtual Head Teacher
ensured that all efforts were made to secure a positive destination for that young person. 
Action Point 5                                                                                                                                              
Budgets are aligned to ensure costs reflect the cost of care and education elements of the
placement, with value for money being monitored 
27. Like other authorities, the Council has very little control over the cost of external placements,
with providers setting the cost against a background of competing demands from authorities
throughout Scotland.  In addition, the need for external placements is increasing each year.  In
many cases there are no internal resources available to meet the needs of the young person,
leaving the only option open to the Authority to place externally.  The increasing demands
within the Council is resulting in significant budget overspends, the demand for such services are
projected to increase in the coming years. 
Action Point 6             
28. Clear costings are given from the providers, they are available to see in advance of making
contact to discuss any prospective placement, and these are available through the Scotland Excel
procurement service website. The breakdown of all care and education placements is 38%
education and 62% care with the placements agreed jointly by Heads of Service for both Care
and Education. In addition to the breakdown of Care and Education, providers detail their
costing for any specialist resources that may be necessary to meet the individual needs of the
young person.  It is unclear whether education are provided with a copy of the costs of the
provision of the education in order that they can review best value for the service provided. 
Action Point 7 
29. The costings for the placements are reviewed in line with the Individual Placement Agreement
(IPA) contracts that are generated through Scotland Excel, contained within these contracts are
the parameters of any increments planned for coming years. Working alongside Financial
Services, Social Work are alert to any deviation from agreed costs signed for with IPA and no
additional funds will ever be released unless an updated and jointly signed IPA is in place. Both
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Care and Education Financial Services work jointly to ensure that invoices are accurate and
reflect only what has been confirmed within the IPA. 
30. The cost of individual care packages is significant and can cost up to £10k per week, the demand
is projected to rise in line with the profile of the last few years.  It is difficult to assess whether
the Council is receiving value for money for each individual placement, particularly if outcomes
are not achieved or the placement does not result in a positive destination, however, it is
recognised that against this backdrop, young people are provided with a safe environment. 
Without alternate internal solutions regarding the mode of care, the Council will require to
continue placing young people externally.  Greater monitoring of outcomes, achievements and
destinations, including regular reporting on progress from providers will ensure that value for
money in each placement is achieved. 
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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
1
Options Appraisal Meeting Practice Guidance
The Options Appraisal Meeting Practice Guidance
document does not outline the complete process or
responsibilities in terms of identifying placement
information, contracting, sharing information with
providers and the review follow up processes.
Inconsistencies in practice and
a lack of shared understanding
of processes
A simplified pathway schematic
will be drawn.
Head of Children Families
and Justice 
31 March 2026
Medium
2
Sharing of Information
Children’s Resource Panel meetings take place weekly. 
This is an internal meeting where each external placement
is reviewed, in addition to discussing any potential
placements coming forward.  Minutes of this meeting are
recorded, however, are not shared with Education.
Important updates regarding
education may not be shared
A member of the senior education
team will attend the weekly
meeting, where possible. 
Minutes of meetings will be
shared with Education Service-
directly to Principal Educational
Psychologist, Ed Mgr Inclusion and
ASN and Virtual Headteacher. 
Head of Children Families
and Justice/Head of
Education-Wellbeing,
Inclusion and
Achievement 
31 March 2026
Medium
3
Reports from providers
The lack of regular updates from providers makes it
challenging to monitor and adapt care plans where goals
and interventions are not meeting the needs of the young
person.
Failure to achieve early
interventions and adapt Care
Plans to meet the changing
needs of young people
Termly updates from providers
will be requested and shared with
Social Work and Education staff as
appropriate, and discussed at
relevant multi-agency review
meetings.
Head of Children Families
and Justice/Head of
Education-Wellbeing,
Inclusion and
Achievement 
31 March 2026
Medium
4
Provider Monitoring Visits 
Visits to the providers were previously undertaken by the
Virtual Head Teacher and the Residential and Aftercare
Manager, this allowed more informal discussions to take
place around whether outcomes were being achieved and
discuss any amendments to the care plan in place.  Due to
staff changes these have not been taking place.  
Lack of monitoring of care
providers 
Virtual Headteacher will work
with relevant staff in SW C&F
team to undertake a programme
of visits to all care settings over
the course of a rolling 12 month
period. 
These will be of a commissioning
nature rather than care planning
and feedback shared via the
placement review process.
Head of Education-
Wellbeing, Inclusion and
Achievement/Head of
Children Families and
Justice 
31 March 2026 
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No Finding Risk Agreed Action Responsibility / Due Date
Medium
5
Destinations
It was unclear whether there were robust procedures and
monitoring in place for young people leaving care with
many returning to their previous locations and no clear
pathway for the future.  
No positive destination for
young person leaving care
There requires to be a
fundamental review of the models
of care within A&B encompassing
the use of external placements. 
The child’s journey within
placement and discharge planning
requires as much focus as
admission. 
Head of Children Families
and Justice 
31 March 2026
Medium
6
Model of Care and Costs
The increasing demands within the Council is resulting in
significant budget overspends and the demand for services
is projected to increase in the coming years. In many cases
there are no internal resources available to meet the
needs of the young person, resulting in the only option
being looking for external placements.
Budgets not aligned to
demand increasing risks of
budget overspends
Continue to explore options to
develop internal resources for the
education and care of Argyll and
Bute’s children within its existing
asset base- specifically in line with
Education’s work on the
development of Secondary
Wellbeing Hubs and the
development of the work of
Children’s Houses. 
As in finding 5 there is a need for
a fundamental review of the
models of care. 
Head of Children Families
and Justice/Head of
Education-Wellbeing,
Inclusion and
Achievement 
31 March 2026
Medium
7
Sharing of Costs 
It is clear that need is currently outstripping the budget
available to accommodate this cohort of children. The
breakdown of all care and education placements is 38%
education and 62% care with the placements agreed
jointly by Heads of Service for both care and education. It
is unclear if a detailed breakdown of cost in regards the
care and education service of each placement is provided.
The value of what is provided
by external placements is not
clear. This is particularly the
case where costs move
beyond the baseline and extra
is provided. 
If the current numbers of
young people in external
Providers are expected to provide
a more detailed breakdown of
costs, particularly extra costs to
inform consideration and decision
making at service level. 
There will need to be a focus on
data trends.
Head of Children Families
and Justice/Head of
Education-Wellbeing,
Inclusion and
Achievement 
31 March 2026
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No Finding Risk Agreed Action Responsibility / Due Date
placements is in fact a longer
term trend the current budget
will result in an inherent
deficit 
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In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained.  The definitions
of each classification are as follows: 
Grading    Definition
High  A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error. 
Medium 
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.  
Low  Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives. 
VFM  An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM). 
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Appendix 2 – Audit Opinion 
Level of Assurance  Definition 
High  Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently. 
Substantial  Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale. 
Reasonable 
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk. 
Limited  Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised. 
No Assurance  Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues. 
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Argyll and Bute Council
Internal Audit Report
May 2025
FINAL
High Medium Low VFM
Number of
Findings
0 0 1 0
Preparedness for IFRS16
Audit Opinion: Substantial
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Contents
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 4
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 7
Appendix 1 – Action Plan ..................................................................................................................... 10
Appendix 2 – Audit Opinion ................................................................................................................. 12
Contact Details
Internal Auditor: Moira Weatherstone 
Telephone: 01546 604146 
e-mail: moira.weatherstone@argyll-bute.gov.uk
www.argyll-bute.gov.uk
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1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of Argyll and Bute Council’s (the Council) system of
internal control and governance in relation to Preparedness for IFRS16.
2. The audit was conducted in accordance with the Global Internal Audit Standards (GIAS) with our
conclusions based on discussions with council officers and the information available at the time
the fieldwork was performed. The findings outlined in this report are only those which have
come to our attention during the course of our normal audit work and are not necessarily all the
issues which may exist. Appendix 1 to this report includes agreed actions to strengthen internal
control however it is the responsibility of management to determine the extent of the internal
control system appropriate to the Council.
3. The contents of this report have been agreed with the appropriate council officers to confirm
factual accuracy and appreciation is due for the cooperation and assistance received from all
officers over the course of the audit.
Background
4. Leasing is an important method of financing the acquisition of assets for many organisations, this
can include assets as diverse as buildings, vehicles, machinery, and computers. In a lease the
lessor owns the asset and leases it to the user, the lessee.  This is an agreement which is legally
binding and generally non-cancellable without early termination penalties.
5. Leases can be classified into finance leases and operating leases. A finance lease usually involves
repayment to the lessor by a lessee of the full cost of the asset together with a return on the
finance provided by the lessor. The lessee enjoys substantially all the risks and rewards of
ownership of an asset.  An operating lease is an agreement whereby the lessor retains the risks
and rewards of ownership and normally assumes responsibility for repairs, maintenance and
insurance.  The lessee pays a rental for the hire of an asset for a period of time which is normally
substantially less than its useful economic life.
6. Under IFRS 16 (International Financial Reporting Standard) a lease is defined as a ‘contract, or
part of a contract, that conveys the right to use an asset for a period of time in exchange for
consideration’.  IFRS 16 defines a lease term as the non-cancellable period for which the lessee
has the right to use an underlying asset, meeting the definition of capital expenditure.
7. The introduction of IFRS 16 requires all leases or lease type arrangements, including ‘embedded
leases’ to be recognised on the balance sheet through a ‘right to use’ asset, meeting the
requirements of capital expenditure and together with the associated lease liability and impacts
to income and expenditure. Local Authorities are required to implement IFRS 16 from 1st April
2024, first reporting in the financial accounts for the year ended March 2025.
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Scope
8. The scope of the audit was to review and assess the arrangements for the compliance with
IFRS16 as outlined in the Terms of Reference agreed with the Interim Head of Financial Services
on 13 March 2025.
Key Dates
9. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below.
Exhibit 1 – Key Dates
Stage Actual
Date
Terms of Reference agreed 13 March 2025
Fieldwork Commencement 14 March 2025
Draft Report issued 8 May 2025
Management Comments received 8 May 2025
Final Report issued 14 May 2025
Audit and Scrutiny Committee 12 June 2025
Risks
10. The risks considered throughout the audit were:
 Audit Risk 1 - failure to have procedures in place to ensure compliance with IFRS 16
 Audit risk 2 - Failure to account for all leases to be included within the scope of IFRS 16
 Audit Risk 3 - failure to implement the requirements of IFRS 16
Audit Opinion
11. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion is provided in Appendix 2 to this report.
12. Our overall audit opinion for this audit is that we can take a substantial level of assurance.  This
means that internal control, governance and the management of risk is sound. However, there
are minor areas of weakness which put some system objectives at risk and specific elements of
residual risk that are slightly above an acceptable level and need to be addressed within a
reasonable timescale.
Recommendations
13. We have highlighted one low priority recommendations where we believe there is scope to
strengthen the control and governance environment.  These are summarised below:
 Robust procedures should be established and circulated to departments to ensure the
lease database is maintained and kept up to date
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14. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
15. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.
Exhibit 1 – Summary Assessment of Control Objectives
Control Objective Link to Risk Assessment Summary Conclusion
1 Procedures and
systems have been
put in place to
ensure compliance
with IFRS 16
Audit Risk 1 Substantial Procedures and systems have been put
in place to ensure compliance with
IFRS 16. Initial work began in 2020 to
start the process of collating
information of leases within the
Council.  In June 2023 the Council’s
consultant agency commenced
preparation of a Decisions and Policies
draft paper and also an Action List to
assist with meeting our obligations
under IFRS 16. In February 2024 a new
Accounting Policies document was
finalised, this, applying to lease
arrangements where Argyll and Bute
Council is the lessee. In addition, in
April 2024, the Finance Manager
prepared an ‘Implementation of IFRS
16 Accounting for Leases’ document,
clearly outlining the requirements of
IFRS 16 are and what should be
included.  It also outlined what needs
to be done to meet our obligations
under IFRS 16. Although it was not
clear whether the ‘Implementation of
IFRS 16 Accounting for Leases’
document had been widely circulated
it formed part of the preparation for
the relevant Finance team. A
significant amount of work has been
undertaken from the end of 2024,
accelerating at the beginning of 2025
to ensure that we the Council has
captured all lease agreements which
fall within the scope of IFRS 16 and the
Code to provide assurance that
everything is accounted for in the
Councils Financial Statements or the
year end March 2025.
2 Communication
processes have been
put in place
Audit Risk 2 Substantial Systems and processes within the
Council over the years have resulted in
leases being arranged by departments,
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between the
services and
Financial Services to
ensure all leases
within the scope of
IFRS 16 have been
accounted for
historical leases renewed and/or
carried forward, this has led to there
being no single complete register for
leases throughout the Council.  This
has resulted in the requirement to
gather and collate a significant amount
of information, setting up processes to
record the information gathered and
the necessity to analyse information
gathered to assess whether leases fall
within the scope of IFRS 16.  Extensive
communication and engagement with
Financial Service and the Departments
has been ongoing, with meetings
undertaken.  Communication process
were put in place, commencing in 2020
and continuing throughout the period
to 2025 in order to ensure all lease
information was gathered from
Departments, all third tier managers
being contacted in February 2025.  In
addition meetings were held
throughout 2025 with key officers,
contacts and in particular procurement
and estates.
3 Training has been
provided to relevant
staff members or
specialist services
procured in order to
ensure compliance
with  IFRS 16, with 
systems and
processes updated
accordingly
Audit Risk 3 Substantial Training has been provided to relevant
staff members to ensure there is a
clear understanding of IFS 16 and our
obligations on how to account for
lease agreements. Training has been
delivered by external providers and
has been provided internally to key
staff. Training commenced in 2020
with several sessions being delivered
by external providers and attended by,
predominantly, the Senior Business
Support Officer. These early training
events focussing mainly on introducing
and understanding IFRS 16.  In 2021 an
IFRS 16 Forum Webinar was attended
with further training and workshops
being delivered in 2023 and attended
by delegates for various department
within the Council.  Further training
was provided throughout 2024 and
2025.
16. Further details of our conclusions against each control objective can be found in Section 3 of this
report.
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3. Detailed Findings
Procedures and systems have been put in place to ensure compliance with IFRS 16
17. All local authorities require to account for leases in accordance with IFRS 16 Leases rom 1 April
2024, first reporting in the financial statements for the year ended 31 March 2025. This, with the
exception where adaptations to fit the public sector have been made in the Code of Practice on
Local Authority Accounting in the United Kingdom (the “Code”).
18. Systems and processes within the Council over the years have allowed lease agreements to be
arranged by departments, historical leases renewed and/or carried forward. This has resulted in
there being no single complete register or central overview of leases held throughout the
Council.  In order to comply with IFRS 16 Finance Staff have undertaken a significant amount of
work gathering and setting up a processes to record lease information, in addition to analysing
information gathered to assess whether leases fall within the scope of IFRS 16.
19. Policies, processes and systems have been implemented and the Council is on track to fulfil their
obligations to comply with IFRS 16 for the financial year end 2025, with extensive work being
undertaken to gather, collate, analyse and record lease information.
20. Work on the implementation of IFRS 16 began in 2020, with an initial email being sent from the
Senior Business Support Officer, to key staff, requesting the identification of all items currently
rented or leased by the Council.  An attached spreadsheet, based on a spreadsheet provided by
the Council’s leasing advisors, showed the information required to be kept for each item rented
or leased by the Council. Following the initial email being circulated in 2020, a lease template
was sent out at every subsequent year end.
21. June 2023 the Council’s consultant agency commenced preparation of a Decisions and Policies
draft paper and also an Action List to assist with meeting our obligations under IFRS 16.
22. In November 2023, an email was sent to all Finance contacts, Principal Accountants,
administration Finance contacts (schools AFAs), finance departmental contacts and
procurement, highlighting that the deadline was fast approaching to have a new database up
and running to comply with IFRS 16. It outlined that the Senior Accounting assistant had been
tasked with gathering as much information and copies of all hired, rental and leased agreements
for the whole of the Council whether these agreements were under or over 12 months, that this
information was required to enable finance to start populating the new database which was to
come in to effect from 1 April 2024. It also highlighted that it was extremely important to have
accurate and up to date information and the importance of finance being kept informed going
forward of any changes to leases, hires, and contracts. A lease template was attached for
completion.
23. In February 2024 a new Accounting Policies document was finalised, this, applying to lease
arrangements where Argyll and Bute Council is the lessee. In addition, in April 2024, the Finance
Manager prepared an ‘Implementation of IFRS 16 Accounting for Leases’ document, clearly
outlining the requirements of IFRS 16 are and what should be included.  It also outlined what
needed to be done to meet our obligations under IFRS 16. Although it was not clear whether the
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‘Implementation of IFRS 16 Accounting for Leases’ document had been widely circulated it
formed part of the preparation for the relevant Finance team. 
24. Due to a combination of circumstances and staff changes little progress was made during 2024
until mid-February 2025 when the Executive Director and Section 95 Officer circulated an email
to all third tier managers and above explaining IFRS 16, how it affects the services, what’s
changing, describing what a lease is, outlining who will decide whether arrangements contain a
lease, key dates and what is being asked of the services.  The email also stressed that the
requirement to notify financial services of any future lease agreements, any changes to existing
lease arrangements was ongoing and provided a link to a corporate email address set up for the
specific purpose.  Importantly a deadline of 25 February 2025 was set for the gathering of
information.
25. The Council has entered into a contract to use cloud software, LS2, as its lease register. The LS2
database will store all information required to meet the accounting and disclosure requirements
of IFRS 16 on an ongoing basis.  The LS2 database was recommended as a solution for the
management of leases. By the end of the financial year the Council had obtained, from
departments, an extensive list of contract arrangements that may indicate a lease for a Right of
Use an asset as defined by IFRS 16 and adapted by the Code. As information was received,
Financial Services assessed the information and applied the requirements of the Code to
determine if the arrangement was within the scope of IFRS 16 and, if so, whether any
exemptions or practical expedients could be applied. In addition, by the end of the financial year
2024-2025, Financial Services had substantially completed the list ready for forwarding to the
lease register provider, the initial upload of data being carried out by the provider.  The provider
has confirmed they are operating on around 2-week turnaround which the Council deems to be
satisfactory in terms of not hindering the production of the annual financial statements.
26. Continuing to meet the requirements of IFRS 16 will rely on good communication with
departments and a clear understanding of the processes involved for updating Financial Services
with new lease arrangements or changes to existing lease arrangements.  In addition, a large
part of the future recording and maintenance of the data base will be important to ensure
continued compliance with IFRS 16.  The Council’s Financial Services department will operate the
database post-transition/implementation phase, adding and amending lease data. In addition to
lease information that is provided to the team as new leases are entered into or contract
variations occur, information will be sought from other Council departments to confirm that no
changes have occurred other than those notified to Financial Services.
Action Plan 1
Communication processes have been put in place between the services and Financial Services to
ensure all leases within the scope of IFRS 16 have been accounted for
27. The success of gathering information relied on robust communication across the Council in
particular with finance staff, procurement staff, budget holders, the HSCP, LiveArgyll and
departments.  Regular communication and support has been provided by our Treasury advisors.
28. Communication process were put in place, commencing in 2020 and continuing throughout the
period to 2025 in order to ensure all lease information was gathered from Departments, all third
tier managers being contacted in February 2025.  In addition meetings were held throughout
2025 with key officers, contacts and in particular procurement and estates.
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29. Budget holders were contacted and provided with guidance on IFRS 16 in relation to leases and
the importance of providing information to Financial Services. In addition, DMT’s (Department
Management Teams) were presented with information on what is required in terms of IFRS.
Training has been provided to relevant staff members or specialist services procured in order to
ensure compliance with IFRS 16, with systems and processes updated accordingly
30. Training has been provided to relevant staff members to ensure there is a clear understanding of
IFS 16 and our obligations on how to account for lease agreements. Training has been delivered
by external providers and has been provided internally to key staff.
31. Training commenced in 2020 with several sessions being delivered by external providers and
attended by, predominantly, the Senior Business Support Officer. These early training events
focussing mainly on introducing and understanding IFRS 16.  In 2021 an IFRS 16 Forum Webinar
was attended with further training and workshops being delivered in 2023 and attended by
delegates for various department within the Council.
32. During 2024 and 2025 a number of training courses were delivered by our leasing advisors,
attended by a number of finance staff.  A further technical workshop was delivered by CIPFA in
2025 which was attended by the Finance Manager.
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Appendix 1 – Action Plan
No Finding Risk Agreed Action Responsibility / Due Date
Low 4
Database Maintenance
Continuing to meet the requirements of IFRS 16 will rely
on good communication with departments and a clear
understanding of the processes involved for updating
Financial Services with new lease arrangements or changes
to existing lease arrangements.  
Failure to maintain robust
lease arrangement records
Policy document and training will
be developed to provide a
framework for ongoing
compliance with IFRS 16 Leases,
and will be reviewed and updated
as appropriate. 
Year-end processes will be
developed to provide additional
checks and Heads of Service will
be provided with a current list of
leases for their sign off.
Finance Manager
31 December 2025
31 May 2026
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In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained.  The definitions
of each classification are as follows:
Grading Definition
High A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error.
Medium
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.
Low Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives.
VFM An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM).
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Appendix 2 – Audit Opinion
Level of Assurance Definition
High
Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently.
Substantial
Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale.
Reasonable
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk.
Limited
Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised.
No Assurance
Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues.
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LiveArgyll
Internal Audit Report
May 2025
FINAL 
High Medium Low VFM
Number of
Findings
0 1 1 0 
Disclosure Checks –
Protecting Vulnerable Groups
Audit Opinion: Substantial 
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Contents 
1. Executive Summary ........................................................................................................................ 3
Introduction ............................................................................................................................................ 3
Background ............................................................................................................................................. 3
Scope ....................................................................................................................................................... 4
Key Dates ................................................................................................................................................ 4
Risks ........................................................................................................................................................ 4
Audit Opinion ......................................................................................................................................... 4
Recommendations ................................................................................................................................. 5
2. Objectives and Summary Assessment ........................................................................................... 5
3. Detailed Findings ............................................................................................................................ 6
Appendix 1 – Action Plan ..................................................................................................................... 11
Appendix 2 – Audit Opinion ................................................................................................................. 13 
Contact Details 
Internal Auditor: Mhairi Weldon 
Telephone:  01546 604294 
e-mail:   Mhairi.weldon@argyll-bute.gov.uk 
www.argyll-bute.gov.uk
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1. Executive Summary
Introduction
1. As part of the 2024/25 internal audit plan, approved by the Audit & Scrutiny Committee in
March 2024, we have undertaken an audit of LiveArgyll’s system of internal control and
governance in relation to Disclosure Checks – Protecting Vulnerable Groups (PVG).
2. The audit was conducted in accordance with the Public Sector Internal Audit Standards (PSIAS)
with our conclusions based on discussions with LiveArgyll officers and the information available
at the time the fieldwork was performed. The findings outlined in this report are only those
which have come to our attention during the course of our normal audit work and are not
necessarily all the issues which may exist. Appendix 1 to this report includes agreed actions to
strengthen internal control however it is the responsibility of management to determine the
extent of the internal control system appropriate to LiveArgyll.
3. The contents of this report have been agreed with the appropriate LiveArgyll and Argyll and Bute
Council (The Council) officers to confirm factual accuracy and appreciation is due for the
cooperation and assistance received from all officers over the course of the audit.
Background
4. The PVG scheme is managed by Disclosure Scotland.  It helps ensure people who are unsuitable
to work with children and protected adults cannot undertake regulated roles with these
vulnerable groups.
5. From 1 April 2025, it is a legal requirement for individuals to be a member of the PVG scheme
when carrying out a regulated role with children, protected adults, or both.  Organisations must
ensure that individuals who are to carry out a regulated role (paid or voluntary) have PVG
scheme membership from 1 April 2025 onwards.  Failure to do so will be considered an offence.
6. It is also an offence for individuals to seek, agree to do or carry out a regulated role if they are
barred from doing so or for organisations to offer a regulated role to someone who is barred
from that specific type of regulated role.  Penalties for these offences are up to five years
imprisonment and/or a fine up to the statutory maximum.
7. Schedules 2 and 3 of the PVG Act 2007 provides listings of regulated roles in working with
children and protected adults.  The listings are comprehensive and roles that are relevant to
services provided by LiveArgyll include:
• Education and training – Teaching, instructing or delivering training 
• Leisure activities – Providing cultural, leisure, social or recreational activities 
• Sports activities – Coaching in relation to sports or physical activity
8. Any posts that fall within the scope of the PVG scheme requires the successful candidate to
obtain membership of the scheme prior to any unconditional offer of appointment being made,
additionally, any current employee changing to a regulated role must have the necessary
membership in place.
9. The disclosure process includes a requirement for applicants to share a copy of their disclosure
with the accredited body that countersigned the application from 1 April 2025, or to notify
Disclosure Scotland that they will seek a review of the content of their disclosure result.
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10. Organisations should notify Disclosure Scotland when a PVG scheme member stops doing
regulated work with them to ensure compliance with data protection legislation.
11. The Council operates as the lead signatory on the overarching account with Disclosure Scotland,
including PVG requirements for LiveArgyll employees and volunteers.  All correspondence on
behalf of LiveArgyll, therefore, takes place through the Council’s Human Resources (HR) and
Education services.  
Scope 
12. The scope of the audit was to assess the systems in place for the processing of staff and
volunteer Disclosure Checks for those working and volunteering with vulnerable individuals. 
This review covered staff employed and volunteers engaged by LiveArgyll in such roles as
outlined in the Terms of Reference agreed with the Chief Officer on 01 May 2025. 
Key Dates
13. The Terms of Reference provided provisional timescales for the review to take place, the actual
dates are noted below. 
Exhibit 1 – Key Dates
Stage Actual
Date
Terms of Reference agreed 01 May 2025
Fieldwork Commencement 18 March 2025
Draft Report issued 16 May 2025
Management Comments received 29 May 2025
Final Report issued 29 May 2025
Audit and Scrutiny Committee 12 June 2025 
Risks
14.  The risks considered throughout the audit were:
• LA RR People 3:  Failure to ensure young people and vulnerable adults are safeguarded
when engaging with LiveArgyll
• Audit Risk 1:  Failure to comply with requirements of the Protection of Vulnerable
Groups (Scotland) Act 2007 
Audit Opinion
15. We provide an overall audit opinion for all the audits we conduct. This is based on our
judgement on the level of assurance which we can take over the established internal controls,
governance and management of risk as evidenced by our audit work.  Full details of the five
possible categories of audit opinion are provided in Appendix 2 to this report.
16. Our overall audit opinion for this audit is that we can take a substantial level of assurance.  This
means that Internal control, governance and the management of risk is sound. However, there
are minor areas of weakness which put some system objectives at risk and specific elements of
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residual risk that are slightly above an acceptable level and need to be addressed within a
reasonable timescale.
Recommendations
17. We have highlighted one medium priority recommendations and one low priority
recommendations where we believe there is scope to strengthen the control and governance
environment. These are summarised below:
• Management should be reminded of the importance of ensuring that all documentation
in support of employee PVG applications is checked and passed to the Council’s HR team
in its entirety for retention purpose.
• Version control should be added to the managers guide to recruitment and the
Safeguarding policy should have existing errors corrected during review to update for
new PVG legislation requirements.
18. Full details of the audit findings, recommendations and management responses can be found in
Section 3 of this report and in the action plan at Appendix 1.
2. Objectives and Summary Assessment
19. Exhibit 1 sets out the control objectives identified during the planning phase of the audit and our
assessment against each objective.  
Exhibit 2 – Summary Assessment of Control Objectives 
Control Objective Link to Risk Assessment Summary Conclusion
1 Policies, procedures
and processes are in
place to manage
PVG requirements,
are regularly
reviewed and clearly
guide management
to identify regulated
roles requiring PVG
scheme
membership
All Risks Substantial LiveArgyll operates using the Council’s
policies, processes and guidance in
respect of recruitment and PVG
requirements. These documents are
available to all employees and are due
to be updated to incorporate new
legislation, however there is no version
control on one document and some
historic errors have not been corrected
on another.  Guidance is available and
followed to identify roles requiring PVG
membership and comprehensive
information is provided to applicants
during advertising and recruitment.
2 Job descriptions and
volunteer roles
clearly identify
where PVG
membership is
required and
mechanisms are in
place to ensure
membership is in
place prior to
All Risks Substantial Records of employee and volunteer
applications and status are maintained.
Regulated roles requiring PVG
membership are clearly communicated
at recruitment, and management are
advised of relevant documentation
required to support applications. PVG
membership had been confirmed for
all relevant employees and volunteers
within the samples selected, however,
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Control Objective Link to Risk Assessment Summary Conclusion
commencing these
roles
all supporting documentation could
not be located for 2 employees.
3 Arrangements are in
place to follow-up
on allegations made,
updates provided by
Disclosure Scotland
and to renew
membership after 5
years
All Risks Substantial Safeguarding training is provided at
induction and periodically thereafter
with records maintained at each
LiveArgyll facility.  A Safeguarding Lead
and Officers have been appointed and
are appropriately positioned within
LiveArgyll to progress any reported
matters regarding safeguarding.  A
robust disciplinary process is in place to
progress any safeguarding concerns
arising.  Plans for routine renewal of
PVG membership will be considered
once the current exercise to process
new PVGs as a result of changed
legislation is complete.
4 Arrangements are in
place to confirm
that partner
organisations have
valid PVG
membership and
training in place
All Risks Substantial Independent organisations are
responsible for ensuring their own
compliance with PVG legislation.  To
use LiveArgyll facilities, these
organisations are required to indicate
compliance on their registration and
booking information and are subject to
periodic sample checking for ongoing
compliance.  Any organisation
indicating non-compliance will be
refused use of the facility. 
20. Further details of our conclusions against each control objective can be found in Section 3 of this
report.  
3. Detailed Findings
Policies, procedures and processes are in place to manage PVG requirements, are regularly
reviewed and clearly guide management to identify regulated roles requiring PVG scheme
membership
21. LiveArgyll has adopted the Council’s policies and processes in respect of recruitment and
safeguarding with some adjustments made to accommodate local requirements.  The Council’s
suite of documentation is available via the HUB intranet site and MyCouncilWorks resource
website and are accessible to management and employees with corporate email accounts.  The
LiveArgyll specific versions are available to relevant employees on a shared drive within the
corporate server area.
22. Both the LiveArgyll specific Manager’s Guide to Recruitment and Safeguarding Policy are
planned to be updated to incorporate new legislation.  The Managers Guide is comprehensive,
providing clear guidance on PVG requirements when recruiting, however, it has no version
control applied to help ensure the most up-to-date guidance is being used.  The Safeguarding
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Policy, is also comprehensive, however, it contains historic errors regarding page numbering and
an incorrect reference to a PVG policy.  The errors had previously been identified by the Senior
Business Support Officer and amendments requested but these have not yet been completed
and made available to the relevant employees.
Action Plan 2
23. The need for PVG membership is most commonly identified during recruitment or transfer to
regulated roles.  The overarching recruitment process adopted by the Council and LiveArgyll is
embedded within the MyJobScotland recruitment portal used by local authorities and other
public sector bodies in Scotland.  Within this portal, the need for PVG membership is
communicated to all applicants alongside the specific role requirements to help guide the
applicant through the recruitment process and provide the relevant supporting documentation.
Where PVG membership is a requirement of a specific role, all applicants are advised at
interview stage that no formal offer of employment is made pending PVG clearance.
24. Roles requiring PVG membership are identified by management in consideration of duties to be
performed and who the employee is likely to interact with, additionally, guidance provided
within the Disclosure Scotland website and details stated within the Protection of Vulnerable
Groups (Scotland) Act 2007 and Disclosure (Scotland) Act 2020 are referred to.  All job
descriptions are currently under review to ensure compliance with updated legislative
requirements which extends the necessity for PVG membership to roles where it may not have
previously been required, this includes both frontline employees and their respective managers
throughout the LiveArgyll hierarchy.  
25. The Council is the “umbrella” organisation for progressing PVG scheme memberships on behalf
of LiveArgyll, and as such, it submits all applications to Disclosure Scotland via an online portal
and receives outcomes that are passed onto LiveArgyll via confirmation email. 
26. The Council’s new HR system contains a user defined field to identify whether a post requires
the holder to be a member of the PVG scheme and the supporting documentation is retained on
the associated document management system.  
27. Volunteer information is not retained on the HR system, instead, a database is maintained by
the Council’s Education team to monitor PVG status.  Documentation required in support of PVG
applications for volunteers is not retained once confirmation of membership is received so as to
comply with data protection requirements.   
Job descriptions and volunteer roles clearly identify where PVG membership is required and
mechanisms are in place to ensure membership is in place prior to commencing these roles
28. LiveArgyll maintain a register of PVG applications sent to the Council for processing dating from
January 2023.  A full list of current post holders requiring membership of the PVG scheme was
requested from the Council’s HR team and this was used to select a sample for review to assess
if PVGs were in place and that the application process was followed correctly.  
29. Job adverts are not retained in the individual’s HR file, these are posted on the MyJobScotland
recruitment portal and can be viewed while active and for a period when recruitment has
completed.  Adverts state that applicants should note that the post requires PVG membership in
relation to the specific protected groups for which the role covers i.e. children or vulnerable
adults.  
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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
30. Job descriptions do not routinely include details of whether the post is considered to be a
regulated role or whether PVG membership is required, however, where the post does entail a
regulated role, a separate information document is included within the portal advising this is the
case and the additional information required to be provided to support the application process.
31. An additional pack of documents is provided to the recruiting manager to ensure all information
required in support of a PVG application is gathered, verified and passed to their relevant
colleagues for processing.
32. A sample of 15 LiveArgyll employees requiring PVG membership was selected for review to
confirm that the appropriate supporting documentation had been provided to management for
passing to HR to progress a PVG application.  The appropriate documentation was located for all
but 2 employees, one of whom was transferred from Education and one whose recruitment pre-
dates information held on “Cryoserver” (email archive) for retrieval.  We are advised that the
appropriate documentation must have been provided to enable the application to progress,
however, this could not be located at the time of the audit.
Action Plan 1
33. Evidence of PVG membership was located for 13 of the 15 employees reviewed, one did not
require a PVG and one was in progress due to updated legislation.  
34. The same sample was reviewed to assess if the appointment commenced prior to confirmation
of PVG membership and this was found to be satisfactory taking into account a brief supervised
induction period, changes to roles and new legislation requirements.  
35. A full list of current volunteers requiring membership of the PVG scheme was requested from
the Council’s Education team and this was used to select a sample of 15 for review to assess if
PVG memberships were in place and that the application process was followed correctly.
36. The LiveArgyll website provides a dedicated area for volunteering allowing interested parties to
obtain information and apply for roles they are interested in, specific roles are not advertised as
vacancies for filling. 
37. A suite of documents was made available for review including a volunteer policy, agreement and
forms for completion and were found to be comprehensive in providing the volunteer and
management with relevant and useful information regarding PVG membership requirements.
38. As with employees, volunteers are required to provide 3 forms of ID to enable their PVG
application to be processed.  These documents along with the application form are passed to the
Council’s Education team and deleted by both parties upon receipt of confirmation of PVG
scheme membership so as to comply with data protection requirements.  
39. Confirmation of PVG membership was provided for all 15 volunteers within the sample selected
and whilst there is no evidence of volunteer start date, we are advised that roles do not
commence prior to receipt of PVG confirmation in compliance with the Safeguarding Operating
procedure. 
40. The Council’s HR team routinely advise Disclosure Scotland when employees undertaking
regulated roles leave the Council/LiveArgyll to remove the noted interest in the individual.  The
Council’s Education team also indicate that Disclosure Scotland are informed of leavers upon
completion of their annual review of volunteers.
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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
Arrangements are in place to follow-up on allegations made, updates provided by Disclosure
Scotland and to renew membership after 5 years
41. The Safeguarding Policy states that induction and ongoing training is provided to employees,
safeguarding training is also included within employee conversations and refresher training
provided every 3 years.  Each LiveArgyll facility retains its own training records and these were
reviewed for 2 facilities where safeguarding training was evidenced as having been completed
between January 2024 and March 2025.  
42.  The Safeguarding Policy is available within the staff rooms of each facility and includes the
named Designated Safeguarding Lead (DSL) and Officers (DSO) who are appropriately positioned
within the organisation to take action regarding any reported matters. 
43. LiveArgyll follows the Council’s disciplinary process, this is a robust process guided by the
Council’s HR team and Disclosure Scotland would be notified if there were any reportable
findings.  Similarly, should the Council/LiveArgyll be notified of any concerns directly from
Disclosure Scotland, an investigation would take place in accordance with the Disciplinary
process.  Results of any investigation would be assessed on an individual basis to arrive at a
decision with the employee/volunteer placed on suspension in the intervening period.  To date,
there has been no requirement to follow this process for either employees or volunteers.
44. From 1 April 2026, lifetime membership of the PVG scheme will end and be replaced by a time-
limited membership requiring to be renewed every 5 years.   The Council’s HR system is under
development to generate alerts when PVG renewals are due and will liaise with LiveArgyll in
respect of their employees.  In addition to this planned functionality of the HR system, LiveArgyll
currently maintains a spreadsheet containing date fields that will enable identification of
employees who are due for PVG renewal.   LiveArgyll has commenced an exercise to identify
employees whose PVG membership requires to be renewed in advance of the 1 April 2026
implementation date and will be progressed upon completion of the current exercise to arrange
PVG membership for employees whose roles newly require PVG membership as a result of the
recent legislative changes.
45. Initial discussions have taken place within the Education team regarding renewal requirements
of PVG membership for volunteers.  The PVG records maintained within the database contain
the relevant date fields required to identify volunteers approaching their renewal dates and
management will be informed using the same communication links as the annual review of
volunteers.
Arrangements are in place to confirm that partner organisations have valid PVG membership
and training in place 
46. Independent organisations using LiveArgyll facilities may opt for accreditation to demonstrate
their commitment to being safe, well organised, inclusive and making a difference to their local
community.  Accreditation must be renewed annually and is encouraged, it also provides the
additional benefits of discounts, recognition and support from LiveArgyll.   As part of the
accreditation requirement, organisations must have PVG processes and safeguarding policies in
place unless they provide assurance that no under 18s or vulnerable adults participate.
47. The facility booking form includes a section advising that it is the responsibility of the
independent organisation to ensure compliance with the PVG Act where relevant and a link to
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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
the national guidance is provided for further information.  Any organisation indicating non-
compliance will be refused use of the facility.  
48. Independent organisations using LiveArgyll facilities are subject to a periodic sample check to
ensure ongoing compliance with PVG requirements and other specific criteria. 
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Appendix 1 – Action Plan 
No Finding Risk Agreed Action Responsibility / Due Date
Medium
1 PVG application Supporting ID documentation 
Finding:  The appropriate supporting documentation to
progress a PVG application was located for all but 2
employees, one of whom was transferred from a long-
term role in Education and one whose recruitment pre-
dates information held on “Cryoserver” for retrieval. 
Recommendation:  Whilst these are exceptional and
historical issues, it would be prudent to remind 
management of the importance of ensuring that all
supporting documentation is checked and provided to HR
for retention in support of employee’s PVG applications.
PVG may be processed
based on provision of
insufficient/incorrect
documentation 
Communication to all
managers reminding
them of the importance
of ensuring that all
supporting
documentation is sent
to LiveArgyll HR to be
checked and
documented.
Services and Support
Manager 
02 June 2025 
Low
2 Policies, Procedures & Guidance 
Finding:  The Manager’s Guide to Recruitment lacks
version control to help users ensure they are using the
most current and up-to-date version and the Safeguarding
Policy requires amendment to correct/remove errors. 
Recommendation:  When updating documentation to
incorporate new legislation, Management should ensure
that version control is applied and all errors
corrected/removed.
Managers and
employees may refer to
and follow expired or
erroneous guidance
Document control
protocols in relation to
legislative updates will
be reviewed and the
process updated where
needed.
Services and Support
Manager 
31 July 2025 
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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
In order to assist management in using our reports a system of grading audit findings has been adopted to allow the significance of findings to be ascertained. 
The definitions of each classification are as follows: 
Grading    Definition
High  A major observation on high level controls and other important internal controls or a significant matter relating to the critical success of the
objectives of the system.  The weakness may therefore give rise to loss or error. 
Medium 
Observations on less significant internal controls and/or improvements to the efficiency and effectiveness of controls which will assist in meeting
the objectives of the system.  The weakness is not necessarily substantial however the risk of error would be significantly reduced if corrective
action was taken.  
Low  Minor recommendations to improve the efficiency and effectiveness of controls or an isolated issue subsequently corrected.  The weakness does
not appear to significantly affect the ability of the system to meet its objectives. 
VFM  An observation which does not highlight an issue relating to internal controls but represents a possible opportunity for the council to achieve
better value for money (VFM). 
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LiveArgyll – Internal Audit Report – Disclosure Checks - PVG, May 2025 
Appendix 2 – Audit Opinion 
Level of Assurance  Definition 
High  Internal control, governance and the management of risk are at a high standard. Only marginal elements of residual risk have
been identified with these either being accepted or dealt with. A sound system of control designed to achieve the system
objectives is in place and being applied consistently. 
Substantial  Internal control, governance and the management of risk is sound. However, there are minor areas of weakness which put some
system objectives at risk and specific elements of residual risk that are slightly above an acceptable level and need to be
addressed within a reasonable timescale. 
Reasonable 
Internal control, governance and the management of risk are broadly reliable. However, whilst not displaying a general trend,
there are areas of concern which have been identified where elements of residual risk or weakness may put some of the system
objectives at risk. 
Limited  Internal control, governance and the management of risk are displaying a general trend of unacceptable residual risk above an
acceptable level and placing system objectives are at risk. Weakness must be addressed with a reasonable timescale with
management allocating appropriate resources to the issues raised. 
No Assurance  Internal control, governance and the management of risk is poor. Significant residual risk and/or significant non-compliance with
basic controls exists leaving the system open to error, loss or abuse. Residual risk must be addressed immediately with
management allocating appropriate resources to the issues. 
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ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE
FINANCIAL SERVICES 12 JUNE 2025 
INTERNAL AUDIT – ANNUAL REPORT  2024/25 
1.0 INTRODUCTION 
1.1 The purpose of this report is to advise the Audit and Scrutiny Committee
(the Committee) of the work undertaken by Internal Audit in respect of the
Annual Audit Plan 2024/25 and advise the Committee of the contents of
the Chief Internal Auditor’s (CIA) independent annual opinion on the
effectiveness of the Council’s risk management, internal control and
governance processes. 
1.2 The Public Sector Internal Audit Standards (PSIAS) became effective on 1st
April 2013 and remained valid until 31 March 2025, required that: 
“The chief audit executive [ABC: Chief Internal Auditor] must deliver
an annual internal audit opinion and report that can be used by the
organisation to inform its governance statement. 
The annual internal audit opinion must conclude on the overall
adequacy and effectiveness of the organisation’s framework of
governance, risk management and control. 
The annual report must also include a statement on conformance
with the Public Sector Internal Audit Standards and the results of the
quality assurance and improvement programme.” 
1.3 Attached as appendices to this report are: 
• Appendix 1 – Internal Audit Annual Report and Summary of the audits
completed in 2024/25
• Appendix 2 – Internal Audit Opinion for 2024/25 
2.0 RECOMMENDATIONS 
2.1 The Audit and Scrutiny Committee endorses the content of this report 
and the associated annual opinion of the CIA. 
3.0 DETAIL 
3.1 Internal Audit is an independent and objective assurance function
designed to add value and improve the Council's operations. It helps the
Council accomplish its objectives by bringing a systematic, disciplined
approach to evaluate and improve the effectiveness of the Council's risk
management, internal control and governance processes.
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3.2 Internal Audit's purpose, authority and responsibilities are set out in
detail in the Internal Audit Charter, which was most recently approved by
the Committee in March 2025. Internal Audit reports its outputs regularly
throughout the year to the Committee. The Committee also approves
Internal Audit’s annual plan and monitors the performance of the
function. 
3.3 The risk based audits contained within the 2024/25 Internal Audit Annual
Plan are shown in the table included at Appendix 1 page 12.  This
shows the overall audit opinion for each audit and the number and
significance of agreed actions. 
3.4 Internal audit activity is planned to enable an independent annual
opinion to be given by the CIA on the adequacy and effectiveness of
internal controls within the authority, including the systems that achieve
the corporate objectives of the Council and those that manage the
material risks faced by the authority. It should be noted, however, that
the presence of an effective internal audit function contributes toward,
but is not a substitute for, effective control and it is primarily the
responsibility of line management to establish internal controls so that
the Council's activities are conducted in an efficient manner, to ensure
that management policies and directives are adhered to and that assets
and records are safeguarded. 
3.5 Internal Audit operated during financial year 2024/25 and reported
directly to Kirsty Flanagan as Section 95 Officer.  I also have
unrestricted access to those charged with governance, specifically:
Elected Members; the Chief Executive; Executive Directors including the
Executive Director who is the Council’s Monitoring Officer. In addition,
Internal Audit staff have unrestricted access to all documents, systems
and information necessary to reach an opinion or view on any matter
under consideration.   
3.6 Internal Audit activity during the year was undertaken in accordance with
the revised Internal Audit Annual Plan. 
3.7 There were no substantial changes made to the 2024/25 audit plan.
Three reviews relating to ‘New Roads and Street Works Coordination’
‘Eclipse post implementation’ and ‘Roads and Flood Prevention’ were
cancelled due to a variety of reasons, respectively ranging from recent
work having been undertaken internally, postponement to another
financial year and a national review to be undertaken in the specific
area. 
3.8 I am pleased to report that, successful attempts have been made to
address the vast majority of outstanding historical recommendations with
close ongoing monitoring by Internal Audit and SMT.  Council officers have
continued to make progress in terms of implementing agreed audit
recommendations, despite challenging and competing demands and finite
resources.  Furthermore, there are robust follow up procedures in place
with reports taken to the SMT on a quarterly basis and reported as a
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standing item on the Committee’s agenda. 
3.9 There is a formal requirement for me to prepare an annual opinion on
the Council’s internal control system. The opinion is presented to
members of the Committee and is intended to provide independent and
objective assurance as to the adequacy and effectiveness of internal
controls within the Council. 
3.10  In addition to the work carried out by internal audit, my opinion is also
informed by: 
• the work of External Audit
• the work of other external inspection agencies who report on the
Council’s work 
• statements of assurances provided by the Chief Executive, Executive
Directors and Heads of Service providing their opinion on the
effectiveness of control, governance and risk management within their
areas of responsibility. 
3.11 My evaluation of the control environment is informed by these sources
and in bringing these together, consideration has been given to whether
there is evidence that any key controls are absent, inadequate or
ineffective and whether the existence of any weaknesses identified,
taken independently or with other findings, significantly impairs the
Council's overall systems of internal control. Wider issues relating to the
Council's corporate governance and risk management arrangements
have also been considered. 
3.12 The nature of individual audit assignments is such that most Internal
Audit reports identify some weaknesses or areas where scope for
improvement exists. However, I am pleased to report that, generally
across the Council, there continues to be a strong recognition amongst
management of the importance of proportionate but effective internal
controls. Senior management has also established an operating culture
where good standards of governance are seen as a key requirement in
the way in which the Council conducts its activities. 
3.13 During work undertaken in 2024/25 there have been instances where
the control environment was not strong enough or complied with
sufficiently to prevent risks to the organisation. In these cases, Internal
Audit has made recommendations to further improve the systems of
control and compliance. Although sometimes significant to the control
environment in place for the individual system or areas that have been
audited, I do not consider these weaknesses material enough to have a
significant impact on the overall opinion on the adequacy of the
Council's control environment at the year end. 
3.14 My formal annual Internal Audit opinion on the soundness of the
Council's internal control systems is presented in my Internal Audit
Annual Report in particular at Appendix 2. Overall, the results of the
work of Internal Audit in 2024/25 taken with other information available
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to me did not lead me to conclude that the Council's overall systems of
internal control were significantly or materially impaired. 
3.15 It has been a particularly busy year for the internal audit team as they have
supported the Chief Internal Auditor in the further development of our work
practices including working closely with the counter fraud team, together
with the preparation for the implementation of the new Global Internal audit
Standards (GIAS).  The team have worked hard to deliver the internal
audit plan, I am pleased to report that one of our trainees has completed
the Chartered Institute of Internal Audit qualification and has been placed
into the vacant auditor post. Interim arrangements will continue until other
staff members have qualified and training plans are sufficiently
progressed, this will support staff in developing experience along with
underpinning professional qualifications in order to improve resilience. It is
my opinion that the profile of Internal Audit continues to improve within the
Council as does the quality of the work it delivers and is evident in the
feedback received from post-audit surveys indicating a satisfaction rate of
97%. 
3.16 As required by the PSIAS a five-yearly external assessment took place in
2022-23 and the service was found to be fully compliant in all 14 areas of
review. Two minor housekeeping issues were identified and these have
now been fully implemented. All identified actions for improvement have
been tracked through our quality assurance and improvement programme
with updates reported to Committee as part of a standard agenda item.
The next scheduled external independent assessment is in 2027. 
3.17 On behalf of my team I would like to thank all Council staff who have
assisted Internal Audit during the course of our work throughout 2024/25
and to thank senior management and elected Members for the
consideration and due regard given to our work. It is important that good
relationships exist in order to promote and improve controls within the
Council and it is clear that such relationships are in place. 
4.0 CONCLUSION 
4.1 Subject to the matters listed in the Annual Governance Statement
reasonable/satisfactory assurance can be taken that the systems of
governance and internal control are operating effectively. Internal Audit
continues to develop and improve as a service. Our Internal Audit Annual
Report 2024/25 on page 10 provides a dashboard of our opinion in each
area of Governance, Risk Management and Internal Control. 
5.0 IMPLICATIONS  
5.1 Policy: none
5.2 Financial: none
5.3  Legal: none
5.4  HR: none
5.5 Customer Service:  none 
5.6 Risk – The implementation of recommendations contained in audit reports may
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help mitigate the risk to the Council. 
5.7 Climate Change: none
5.8  Fairer Scotland Duty: none
5.9 Equalities: none
5.10 Consumer Duty: none
5.11 Island Communities: none
5.12 Children’s Rights and Wellbeing: none 
Paul Macaskill
Chief Internal Auditor
12 June 2025 
For further information contact: 
Paul Macaskill, Chief Internal Auditor 
Tel: 01436 604108
Email:  paul.macaskill@argyll-bute.gov.uk 
APPENDICES
1. Internal Audit Annual Report 2024/25, Counter Fraud update and summary of
planned work in 2024/25
2. The Certificate of internal Audit Opinion 2024/25 
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ARGYLL AND BUTE COUNCIL
COMHAIRLE EARRA-GHÀIDHEAL AGUS BHÒID 
INTERNAL AUDIT ANNUAL REPORT 2024-25
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2 
Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Contents 
Introduction ..................................................................................................................................................................................................................................... 1
Basis of opinion ............................................................................................................................................................................................................................... 2
Analysis of the Internal Audit Coverage and Performance ........................................................................................................................................................... 4
Quality Assurance and Improvement Programme ........................................................................................................................................................................ 5
Confirmation of Independence ....................................................................................................................................................................................................... 8
Counter Fraud Services ................................................................................................................................................................................................................... 8
Opinion, Conclusions and Observations ....................................................................................................................................................................................... 10
Appendix 1 – Summary of Internal Audit Plan 2024/25 .............................................................................................................................................................. 13
Appendix 2 – Certificate of Internal Audit Opinion 2024/25 ....................................................................................................................................................... 14 
Contact Details 
Chief Internal Auditor: Paul Macaskill
Telephone: 01546 604108
e-mail: paul.macaskill@argyll-bute.co.uk
www.argyll-bute.gov.uk
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Introduction 
1. This report aims to provide the Audit & Scrutiny Committee with an evaluation of elements of Argyll and Bute Council’s internal control, risk
management and corporate governance systems based on our work during 2024/25 and to summarise the Internal Audit coverage in the year.
2. Corporate governance is the system by which local authorities direct and control their functions and relate to their communities. The three
fundamental principles of corporate governance are openness, integrity and accountability. A sound system of internal control must be
maintained to support Councils in operating effective corporate governance arrangements.
3. Good governance practice and internal control suggests that:-
• Council Members should set appropriate policies on internal control and seek regular assurance that the system of internal control is functioning
effectively;
• management should implement the Council’s policies on internal control and design, implement and monitor suitable systems; 
• a well-established and effective Audit and Scrutiny function should be in place within the Council;
• a local Code of Corporate Governance exists and is reviewed annually; and
• Internal Audit should provide an independent assessment of the adequacy of the system of internal control.
4. In Argyll and Bute Council a system of good governance is in existence and this is supported by a variety of policies, codes and guidance to promote
expected conduct of its business on a day to day basis. The national framework ‘Delivering Good Governance in Local government’ which was published
by the Chartered Institute of Public Finance and Accountancy (CIPFA) and the Society of Local Authority Chief Executives (SOLACE) in April 2016 aims to
assist authorities in reviewing and assessing their own governance arrangements. The Council has a ‘Local Code of Corporate Governance’ in place and
these arrangements are reviewed periodically and improvements required will be implemented, where necessary.
5. To support the governance statement the Council will need to carry out a review of the effectiveness of internal control, deriving evidence from a
variety of sources including Internal Audit, senior managers within the authority with responsibility for developing and maintaining internal control and
cognisance of external/internal audit recommendations along with recommendations of other regulatory bodies.
6. This report provides internal audit information in support of the assurance statements and covers the period from 1 April 2024 to 31 March 2025. The
attached Appendix reports the Internal Audit activity against the operational audit plan
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Basis of opinion 
7. We are able to provide assurance on the adequacy of internal controls and governance arrangements within the Council arising only from the results of
Internal Audit reviews we have completed during the period in accordance with the programme of Internal Audit work approved by the Audit and
Scrutiny Committee.  In this context, it is important to note that:
(a) it is Management’s responsibility to maintain internal control and good governance arrangements on an ongoing basis;
(b) the Internal Audit function forms part of the overall internal control and governance structure of the organisation;
(c) while we have planned our work so that we have a reasonable expectation of detecting significant control and governance weakness, internal
audit procedures alone do not prevent the possibility of poor judgement in decision making, human error, control processes being deliberately
circumvented by employees and others, management overriding controls and the occurrence of unforeseeable circumstances;
(d) a sound system of corporate governance and internal control provides reasonable but not absolute assurance that the Council will not be hindered
in achieving its objectives or in the orderly and legitimate conduct of its business by circumstances which may reasonably be foreseen. However,
a system of corporate governance and internal control cannot provide protection with certainty against any organisation failing to meet its
objectives or all material errors, losses, fraud or breaches of laws or regulations;
(e) it is the responsibility of Internal Audit to assess the adequacy of the internal control and governance processes as far as it is reasonably possible
by reviewing arrangements put in place by management and to perform testing to confirm whether those controls were operating for the period
under review; and
(f) reasonable expectations of senior management, the Audit and Scrutiny Committee and other stakeholders have been taken into account in terms
of our duty to report all matters which come to our attention for the period under review.
8. In our reports issued to date we have made recommendations, where appropriate, to improve internal controls and promote good governance. On the
basis of our sample testing of key controls, we concluded that these controls were generally operating as expected during the period under review, with
some exceptions that have been reported to management. Appropriate responses to the recommendations made in our reports have been obtained and,
if actioned, should provide management with additional comfort that the system of control operates as intended.
9. Summaries of the issues arising in relation to each system or activity covered by the internal audit work in 2024/25 have been reported to management
and the Audit and Scrutiny Committee throughout the year. We do not, therefore, propose to repeat the matters in this report. There have been no
significant issues which have come to our attention that have not been reported to management.
10. The services provided to the Council in 2024/25 by Internal Audit and Counter Fraud Services are summarised below:- 
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
INTERNAL AUDIT AND COUNTER FRAUD SERVICES 
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Analysis of the Internal Audit Coverage and Performance
11. In respect of 2024/25 the Internal Audit days planned and delivered can be summarised as follows: 
12. We have been able to achieve 100% of the agreed 2024/25 audit plan. In addition to the Council’s audit plan we have completed the agreed work for
the Health and Social Care Partnership (HSCP) contract and also that for LiveArgyll. The work demands on the service continue to be high and this is
expected to continue, therefore, our focus will remain on our high risk work and core continuous monitoring of our key financial systems.
Notwithstanding, the service remains focused on providing a high quality service and output supporting the Council to achieve its desired goals and
outcomes for the communities we serve. We have had sufficient resources provided to us in 2024/25 to fulfil the approved internal audit plan and our
other commitments with the HSCP, LiveArgyll and agreed Scrutiny work.
13. We have worked with Council services and our appointed External Auditors, Forvis Mazars, to focus our work on those areas of the highest business risk
to the Council and those on which External Audit may wish to place reliance.
14. At Appendix 1, we provide details of the internal audit work undertaken in 2024/25.
0
20
40
60
80
100
2022/23 2023/24 2024/25
Percentage of Internal Audit Plan
Completed
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
15. In 2024/25, we issued 15 reports, which contained a variety of recommendations to improve the system of control, along with verification work in a
further 3 areas. Follow up internal audit work has been and will continue to be undertaken to establish if the more significant recommendations made
in those reports have been implemented as agreed. Three planned reviews were cancelled due a variety of reasons from recent work having been done
internally, postponement to another financial year and a national review to be undertaken in the specific area, respectively, these areas will be
considered as part of future risk assessed internal audit planning processes, these were noted as amendments to the audit plan. During the year we
undertook quarterly ‘follow up’ arrangements to report progress made by management in relation to previously agreed recommendations. In addition,
regular reporting of outstanding recommendations are considered by the Council’s Strategic Management Team (SMT) on a regular basis to monitor
progress and where appropriate seek that managers resolve any outstanding matters where these have gone beyond agreed implementation dates;
SMT are supportive in our work and this is helpful in our continued monitoring and progress assessments until such time as our recommendations are
fully implemented.
16. We also submitted formal progress reports to the Audit & Scrutiny Committee throughout the course of the year.
Quality Assurance and Improvement Programme
17. Internal Audit monitors its performance in a number of ways.  This allows us the opportunity to gauge the effectiveness of our service and may inform
future improvements. Principally, we monitor performance by the use of client questionnaires which are issued after each piece of work and allow
client departments to feedback contributions we have made to improve control, address any areas of value for money and raise any concerns. We are
pleased to report, from the questionnaires returned, that clients are generally very satisfied with our service. In addition, Internal Audit produce
quarterly and annual reports to the Audit and Scrutiny Committee allowing our progress to be monitored. 
18. CIPFA has issued a statement that sets out the role of the Head of Internal Audit in Local Government in 2019. The purpose of this statement is to
outline the core activities and behaviours that belong to the role of Head of Internal Audit and how these should influence and champion good
governance, risk management and internal control. The Council’s Internal Audit section conforms to the Statement.
19.  CIPFA and the Chartered Institute of Internal Auditors (CIIA) have reviewed the guidance and made amendments in order to have a common set of
standards across the whole public sector. These changes are primarily based on the International Professional Practices Framework (IPPF). The
standards termed Public Sector Internal Audit Standards (PSIAS) became effective in April 2013 and amended in 2017. It should, however, be noted that
a comprehensive review of the IPPF has been completed and a new set of standards called the ‘Global Internal Audit Standards’ (GIAS) have been
implemented in April 2025 for local government. New and updated Standards reflecting these changes have been issued to public bodies and a gap
analysis has been undertaken to identify changes that Internal Audit and the Committee may need to make to our documentation and processes in
order to achieve full compliance.
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
20. A key requirement of the PSIAS is that Internal Audit sections are required to state whether or not they conform to these standards as part of their
annual reporting. In addition, they should outline the results of the quality assurance and improvement programme together with progress against any
improvements identified during this assessment.
21. In 2022/23 financial year, Internal Audit were subject to an external evaluation against the PSIAS, Local Government Application note and Quality
Assurance Improvement Programme. It is a requirement of the new standards that all public sector Internal Audit sections will require to be
independently assessed against these standards during a five year rolling period. The assessment found that in all 14 categories the Council’s Internal
Audit section were fully compliant. This is the highest level of standard attainable in the assessment and a report outlining the findings was presented
to the Council’s Audit and Scrutiny Committee in March 2023. Arrangements for the next review will be scheduled in for January 2028. The table below
outlines each of the 14 categories of assessment and the level of compliance/conformance achieved. 
Assessment Area Level of Conformance
External Independent EQA 2023
Level of Conformance Internal
Self-Assessment 2025
Mission of Internal Audit and Core Principles Fully Conforms Fully Conforms
Definition of Internal Auditing Fully Conforms Fully Conforms
Code of Ethics Fully Conforms Fully Conforms
Purpose, Authority and Responsibility Fully Conforms Fully Conforms
Independence and Objectivity Fully Conforms Fully Conforms
Proficiency and Due Professional Care Fully Conforms Fully Conforms
Quality Assurance and Improvement Programme Fully Conforms Fully Conforms
Managing the Internal Audit Activity Fully Conforms Fully Conforms
Nature of Work Fully Conforms Fully Conforms
Engagement Planning Fully Conforms Fully Conforms
Performing the Engagement Fully Conforms Fully Conforms
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Assessment Area Level of Conformance
External Independent EQA 2023
Level of Conformance Internal
Self-Assessment 2025
Communicating Results Fully Conforms Fully Conforms
Monitoring Progress Fully Conforms Fully Conforms
Communicating the Acceptance of Risks Fully Conforms Fully Conforms
Assessment Gradings: Fully
Conforms
Generally
Conforms
Partially
Conforms
Does Not
Conform
22. In terms of the findings of the EQA a number of areas of good practice were identified:
• Full compliance with the PSIAS;
• Qualified Internal Auditors with extensive local authority experience;
• Internal Audit staff who are enthusiastic, experienced and focused on providing a good and professional service;
• Well defined procedures which ensures that the service provided is robust, reliable and efficient in carrying out audit activity; and
• The ability of External Audit to place reliance on the work of Internal Audit. 
The overall conclusion was that the Internal Audit Service Fully Conforms to the PSIAS. 
It was, however, noted that the two areas for improvement highlighted in the report are as follows:
• The need to undertake an annual review of the declarations of interest – this has now been implemented.
• Clearer referencing in the internal audit annual report to matters referenced in the Annual Governance Statement – this has now been
implemented.
As part of the annual process the Internal audit service undertakes a self-assessment against the PSIAS and this has concurred with the independent
assessment which was reported to the Council’s Audit and Scrutiny Committee in March 2023. A full copy of the EQA report can be accessed using the link
provided.
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Confirmation of Independence 
23. Internal audit activity is planned to enable an independent annual opinion to be given by the CIA on the adequacy and effectiveness of internal controls
within the authority, including the systems that achieve the corporate objectives of the Council and those that manage the material risks faced by the
authority. It should be noted, however, that the presence of an effective internal audit function contributes toward, but is not a substitute for, effective
control and it is primarily the responsibility of line management to establish internal controls so that the Council's activities are conducted in an efficient
manner, to ensure that management policies and directives are adhered to and that assets and records are safeguarded.
24. Internal Audit operates as part of the Directorate of Kirsty Flanagan and reports directly to the Council’s Section 95 Officer and the Head of Financial
Services on an administrative basis only, however, has unrestricted access to those charged with governance, specifically: Elected Members; the Chief
Executive; Executive Directors including the Executive Director who is also the Council’s Monitoring Officer.
25. Internal Audit operated without any restriction and had unfettered access to all staff and documents both electronic and paper to allow full and effective
assessment of the work during 2024-25. We are therefore pleased to note that there are no matters which require to be drawn to the Audit and Scrutiny
Committee’s attention or wider senior management contained within this report regarding the independence of the Internal Audit service during 2024-
25.
Counter Fraud Services
26. The Counter Fraud Team (CFT) was established in September 2020 on a two year trial basis, during this period significant successes have been made in
identifying monies due to the Council and issuing bills for the rightful charges. In September 2022, on conclusion of the trial period and having
demonstrated a need for the service and its continued success, these arrangements were made permanent. The work of the CFT is wide in nature,
covering complaints of theft, fraud, dishonesty and irregularity to reviewing and proactively working to maximising the Council’s revenue streams by
reducing the amount of benefit fraud, not to mention educating and training staff on such issues. The Council also participates in the National Fraud
Initiative (NFI) which uses data analysis and matching to highlight potential irregularities that are reported back to each participating authority to
investigate.
27. The CFT consists of two full time staff who have formal qualifications in CIPFA Accredited Fraud investigators course. Indeed, both members of staff
have significant public sector experience in dealing with such matters and this has contributed to a successful approach.
28. The table below summaries the total income recovered by the team to date. This has been broken down into reactive work through referrals, which can
also be quantified in terms of numbers, and proactive work such as large scale council tax reviews. The total funds recovered by the Fraud Team are: 
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Reactive Work Total Rebilled Value
Employee 2 0
Council Tax 33 74,090
Blue Badge 2 0
DWP 3 0
Grants 0 0
Other 7 0
Welfare Fund 0 0
Total 47 74,090
Proactive Work
Total combined work rebilled 1,411,068
Total combined work recovery 924,810 
29. These figures represent the rolling total since the inception of the team to date and so far 65.5% of the income due that has been rebilled has been paid
to the Council. The rebilled accounts are routinely monitored and recovery is updated regularly.  The recovery figure is still ongoing as large re-billings
were made in 2024 and the beginning of 2025.  These values take time to recover and are underway via debt recovery, payment plans and recovery
agents. It is not within the CFT’s remit to pursue rebilling as that rests with the Debt Recovery teams.  The CFT will liaise with Debt Recovery for long
term debts, and work closely together to maximise the income for the Council. The CFT monitor recovery for its own records.  The unquantifiable work
carried out by the CFT also raises awareness of the potential for suspicious activity toward the Council and information is passed nationally to other
local authorities and Police Scotland.
30. Local visits throughout Argyll and Bute were undertaken in the year and this will form part of a rolling programme of visits going forward, focusing on
maximising the income due to the Council. In addition, the CFT 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.
31. In addition to the above role the CFT undertake investigative work on complaints received regarding allegations against staff and where these require
to be looked at in terms of fraud, theft or other irregularity then a full examination of the facts will follow and be reported. This work can be and often
is time consuming and is fitted into the overall demands of the role. The nature of this work is sensitive and confidential and reporting is therefore
restricted in terms of data protection and associated rights.
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Opinion, Conclusions and Observations
32. We agreed a rolling programme of Internal Audit coverage based on an assessment of risk factors with Management and the Audit and Scrutiny
Committee. This programme related to the level of available resources, focusing on higher risks and areas identified by management as requiring audit
review within the Council. On the basis of the internal audit systems and work completed in respect of this year, we consider that the assessment of key
systems are as noted below. A certificate of opinion is noted within Appendix 2 of this document reflecting our opinion. 
Governance     Risk Management      Internal Control               
Classification and Assessment 
Poor and Requiring Improvement – Does not meet any key areas of good practice or partially or fails to meet most key areas of good practice. 
Adequate and/or Improving - Attempting to meet or meets most key areas of good practice/ with effort being made to improve further. 
Reasonable/Satisfactory - Substantially meets all key areas of good practice.
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
33. We would, however, point out the following exceptions and/or observations:
• Across Scotland’s public sector significant pressures continue as a result of financial settlements and this has been particularly compounded due
to the impact of inflationary pressures and rising costs of fuel, gas and electricity, together with the risk of unfunded or partly funded pay
settlements. These pressures are likely to remain going into 2025/26 financial year and will continue to add an element of uncertainty in
relation to the overall financial picture affecting the Council. The Council continues to undertake appropriate medium to long term financial
planning using a scenario modelling approach which helps to provide Members with a thorough overview of the implications of funding and
cost pressures.
• The Health and Social Care sector across Scotland is in a difficult position at present due to the financial challenges they are facing. Most HSCPs
have significant forecast deficits and depleted reserves. Audit Scotland have repeatedly reported that the sector is not operating on a financially
sustainable basis. The Integrated Joint Board approved the HSCP budget for 2025/26 at their meeting on 26 March 2025. Social Work had a
balance of £0.500m of savings still to be identified and Health had a gap of £4.2m as the HSCP were not able to identify the required 3% in NHS
savings. This is a notable risk for the HSCP, as this is likely to impact and require the use of non-recurring funding and general reserves to
balance this overspend. The use of reserves to address this and future overspends increases the risk of exhausting the reserves and this may
further create an ongoing risk to the HSCP in being able to mitigate any unplanned significant issues arising in the future.  Furthermore, the
need to implement, risk assess and monitor the financial savings recovery plan to address the gap requires to be a primary priority as this may
increase the risk to parent bodies in terms of financial support being required in the event that such gaps remain and reserves are not sufficient
to set a balanced budget and/or to sustain ongoing services. The Accounts Commission published a report in March 2025 concerning
Integration Joint Board finances across Scotland called ‘Integration Joint Board finances continue to be precarious’. Whilst there are local
challenges within Argyll and Bute area, these are consistent with the Scottish wide picture.   
• The Council introduced a new HR/Payroll System called i-Trent in September 2024, we understand that there have been a number of post
implementation issues resulting in operational aspects of functionality requiring ‘work arounds’ having to be implemented pending remedial
and permanent solutions. Additional resources have been made available in order to address these problems identified post implementation
and where possible, deliver permanent solutions. As a result, there was a delay in the planned work relating to continuous monitoring of this
system in 2024/25, we have recently been provided with a suite of reports covering this period and have commenced work in this area.  
However, arrangements for system access and reporting tools to access data have been provided to Internal Audit from April 2025 onwards.
Whilst we have not undertaken formal work in this area in 2024/25, we will be undertaking a comprehensive audit of the new system as part of
the 2025/26 audit plan.
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
• Due to a significant weather event, specifically, Storm Eowyn in January 2025, extensive damage was reported to have occurred at the
Helensburgh Leisure Centre, which at present remains closed. The closure of this facility could have financial implications for LiveArgyll as the
operators who, whilst a separate legal entity, have a direct link with the Council and this may increase the risk of the need of financial
assistance in the short term until the facility is reinstated and operational. At this stage whilst notable, we do not anticipate this as a material
risk to the Council. 
• During our planned work for 2024/25, we found no significant reporting issues that have not already been drawn to the Audit and Scrutiny
Committee’s attention.
• The Work of our CFT continues to be supportive and preventative in approach and where there is evidence of error, fraud or complaint which
has a financial impact on the Council, every attempt will be made to actively recover monies due in order to maximise income and serve as a
deterrent.
• Our findings contained within this report should be considered in the preparation and reporting of the Council’s Annual Governance Statement
which can be found on the Council’s web page. 
34. Finally, we would also like to highlight our appreciation to the Council’s Audit & Scrutiny Committee for their strong support, together with the full co-
operation of the Council’s Management Team and ongoing good working relationship with the appointed External Auditors, Forvis Mazars. 
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13 
Argyll and Bute Council – Internal Audit 2024/25 Annual Audit Plan 
Appendix 1 – Summary of Internal Audit Plan 2024/25 
Appendix 1 - Summary of 2024/25 Internal Audit Plan 
No. of Recommendations
Report Title
Overall
Opinion High Medium Low VFM
Community Education High 0 0 1 0
School Funds and Management of
Funds
Reasonable 2 5 0 0
Trading Standards High 0 0 0 0
Leasing – Estates (IFRS 16) Substantial 0 0 1 0
Asbestos Management Reasonable 0 5 4 0
External Placements Reasonable 0 7 0 0
Bridges Asset Management Plan
and Inspection Regime
Reasonable 1 1 2 0
Oban Airport High 0 0 0 0
Short-Term Lets Substantial 1 1 0 0
Data Security & Information
Security
Substantial 0 1 0 0
IT Risk Register and Mitigation
Processes
High 0 0 2 0
NDR – Including Reliefs and
Appeals
Substantial 0 3 0 0
IR35 Off-Payroll Working and
Compliance
Limited 2 2 0 0
Disclosure Checks – Protecting
Vulnerable Groups (PVG)
Substantial 0 1 1 0
LGBF n/a 0 0 0 0
Stores & Stock Control n/a 0 0 0 0
EMA High 0 0 0 0
SPT Concessionary Fares n/a 0 0 0 0  
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
Appendix 2 – Certificate of Internal Audit Opinion 2024/25
To the Members of Argyll and Bute Council, the Chief Executive, other members of the Council’s
Senior Management Team including the Section 95 Officer 
As the Chief Internal Auditor of Argyll and Bute Council (the Council), I am pleased to present my
annual statement on the adequacy and effectiveness of the internal financial control system of the
Group Accounts prepared by the Council for the year ended 31 March 2025.
Respective responsibilities of management and internal auditors in relation to internal control
It is the responsibility of the Council’s senior management to establish an appropriate and sound
system of internal financial control and to monitor the continuing effectiveness of that system. It is
the responsibility of the Chief Internal Auditor to provide an annual overall assessment of the
robustness of the internal financial control system.
The Council’s framework of governance, risk management and internal control
The Council has a responsibility to ensure that its business is conducted in accordance with
legislation and proper standards. The governance framework comprises the systems and processes,
culture and values by which the Council is directed and controlled and how it accounts to
communities. It enables the Council to monitor the achievement of its strategic priorities and to
consider whether those objectives have led to the delivery of appropriate services and value for
money.
The main objectives of the Council’s internal control systems are to ensure: 
• adherence to management policies and directives in order to achieve the organisation’s
objectives 
• economic, efficient, effective and safe use of resources and assets 
• the relevance, reliability and integrity of information, so ensuring as far as possible the
completeness and accuracy of records 
• compliance with statutory requirements.
The system of internal control is a significant element of the governance framework. Any system of
control can only ever provide reasonable and not absolute assurance that control weaknesses or
irregularities do not exist or that there is no risk of material errors, losses, fraud, or breaches of laws
or regulations. Accordingly, the Council is continually seeking to improve the effectiveness of its
systems of internal control in order to identify and prioritise the risks that would prevent the
achievement of the Council’s strategic objectives.
The work of internal audit
Internal auditing is an independent, objective assurance and consulting activity designed to add
value and improve an organisation’s operations. It helps an organisation accomplish its objectives by
bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk
management, control and governance processes.
The Council’s Internal Audit Section operates in accordance with the Public Sector Internal Audit
Standards (PSIAS) which have been agreed to be adopted from 1 April 2013 by the relevant public
sector Internal Audit Standard setters. PSIAS applies the Institute of Internal Auditors International
Standards to the UK Public Sector. 
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
PSIAS requires that a Quality Assurance and Improvement Programme (QAIP) is developed in order
to provide assurance that internal audit activity: 
• is conducted in accordance with an Internal Audit Charter 
• operates in an efficient and effective manner 
• is perceived to be adding value and improving operations.
PSIAS also requires, as outlined in Standard 1300 “QAIP”, that: 
“External assessments must be conducted at least once every five years by a qualified, independent
assessor or assessment team from outside the organisation. External assessments can be in the form
of a full external assessment or a self-assessment with independent external validation”.
To meet this requirement, a reciprocal arrangement to complete a programme of inspections has
been developed by the Scottish Local Authorities Chief Internal Auditors Group (SLACIAG). This
process identified East Dunbartonshire Council as the body to undertake the independent review of
the Council’s Internal Audit function’s level of compliance with PSIAS. This output of this review was
presented to the Audit and Scrutiny Committee in March 2023. It concluded that the internal audit
service demonstrates full compliance/conformance with PSIAS and identified many areas of strong
practice including the internal audit team is highly qualified, delivers a high quality service, good
engagement and clear reporting lines and clear evidence of supervision and audit follow up.
Internal Audit undertakes an annual programme of work based on a risk assessment process which is
revised on an ongoing basis to reflect evolving risks and changes within the Council.
All Internal Audit reports identifying system weaknesses and / or non-compliance with expected
controls are brought to the attention of management and the Audit and Scrutiny Committee
together with appropriate recommendations and agreed action plans. It is management’s
responsibility to ensure that proper consideration is given to Internal Audit reports and that
appropriate action is taken on audit recommendations.
The internal auditor is required to ensure that appropriate arrangements are made to determine
whether action has been taken on internal audit recommendations or that management has
understood and assumed the risk of not taking action. A programme of follow-up on assignment
findings and recommendations provides assurance on the complete and timeous implementation of
internal audit recommendations.
Internal Audit staff regularly attended the following external user group meetings: 
• SLACIAG, the purpose of which is to develop and improve the practice of internal audit
activity with Scottish local authorities. It achieves this by meeting to discuss issues of
common concern, commissioning work to develop ideas, sharing good practice, working in
partnership with other professional / governing bodies and promoting SLACIAG as the
representative body for internal audit in local authorities. We have attended meetings of
SLACIAG during 2024/25. 
• SLACIAG Computer Audit sub group: a member of the audit team attends this forum and
contributes to outputs and communications that are regularly exchanged with the aim of
ensuring that audit teams are better equipped to perform technical information systems
audits.
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Argyll and Bute Council – Internal Audit Annual Audit Report 2024/25 
• The CIA also meets the Chief Internal Auditors of West Dunbartonshire Council, East
Dunbartonshire Council, West Lothian Council, Falkirk Council and Inverclyde Council on a
quarterly basis to discuss developments and share knowledge. In-between these meetings
we are in regular contact to share information which helps deliver audit plans more
efficiently including consistent use of benchmarking indicators.
• Chartered Institute of Internal Auditors Data Analytics, Local Authority and Heads of Internal
Audit Virtual Forums: a member of the audit team attends forums on an ad-hoc basis where
subject matter is deemed to be useful, e.g. continuous monitoring and cyber security
Basis of Opinion
My evaluation of the control environment is informed by a number of sources: 
• the audit work undertaken by Internal Audit during the year to 31 March 2025, including risk
based audits, continuous monitoring and follow-up activity. 
• the assurance statements signed by the executive directors and heads of service on the
operation of the internal financial controls for the services for which they were responsible
during the year to 31 March 2025. 
• the assurance statement signed by the Chief Executive for the overall Council for the year
ended 31 March 2025. 
• reports issued by the Council’s external auditors, Forvis Mazars, and other external review
agencies.
• my knowledge of the Council’s governance, risk management and performance monitoring
arrangements.
Limitation to Resources or Scope of Internal Audit Work
I can report that Internal Audit operated throughout 2024/25 with no impairments or restrictions in
scope or independence.
There were sufficient resources available to deliver the amended programme of audit assignments
contained within the 2024/25 Internal Audit Plan and no significant threats emerged to the
independence of the internal audit activity such as inappropriate scope or resource limitations.
Opinion
It is my opinion, based on the above, that reasonable assurance can be placed upon the adequacy
and effectiveness of the Council’s systems of governance, risk management and internal control in
the year to 31 March 2025.
Signature: 
Paul Macaskill FCPFA CMIIA
Title: Chief Internal Auditor 
Date: 12 June 2025
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ARGYLL AND BUTE COUNCIL  AUDIT AND SCRUTINY COMMITTEE
FINANCIAL SERVICES  12 JUNE 2025 
COMPLAINTS SCRUTINY REVIEW 
1. SUMMARY
1.1  The complaints scrutiny review was carried out as per the 2024/25 scrutiny
plan agreed by the Audit and Scrutiny Committee at their 14 March 2024
committee meeting.   
1.2 The Consultations scrutiny panel comprised of Mr Martin Caldwell (Panel
Chair), Mrs Janice Wasson-Hall (Chair) Councillor Mulvaney, Councillor
Vennard and Councillor Howard with support provided by internal audit
officers. 
1.3 The complaints process was chosen for inclusion in our scrutiny priorities for
2024/25 due to the importance of having a complaints process which meets
expected best practice and adopting identified improvement actions across
the Council where applicable.   
2. RECOMMENDATIONS 
2.1 Committee to agree the Draft Complaints Scrutiny Report. 
2.2 Committee to agree the most appropriate committee or other Council group for
the Complaints Scrutiny Report to be presented to for consideration. 
3.  DETAIL 
3.1 The agreed objectives of the scrutiny review were to:
• Ensure the Complaints Handling Procedure contains clear guidance
defining what can and cannot be considered as a complaint, it is well
communicated and referenced within key council documentation:
o In constitution, governance statement and Council policies
o In guidance to Members, line managers and officers
• Ensure the Council’s procedure is aligned with national guidance and best
practice:
o Scottish Public Services Ombudsman
o Identified best practice within public service
o Robust sources of evidence are used in arriving at complaints
resolutions
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• Ensure performance data is captured, reported and used to inform senior
management of areas for improvement and share good practice
o Surveys to gather information
o Reports to senior management and committees
o Submissions to appropriate partner organisation for monitoring and
benchmarking
o Information published on Council website
• Assess methods of identifying and sharing improvement actions
o Improving complaints handling process
o Informing service performance improvements
o Information sharing across Council Services
• Development and final agreement of improvement actions 
3.2 Throughout this review two panel meetings were held to gather evidence.
• Panel one – Head of Legal and Regulatory Support, Governance, Risk
and Safety Manager and  Compliance and Regulatory Officer 
• Panel two – those attending panel one. 
3.3 We would like to extend our appreciation for the cooperation and assistance
received from all witnesses invited to provide evidence over the course of the
review. 
3.4 Based on the information obtained over the course of the review the panel has
identified two findings specific to this review. These are detailed in the report
attached as appendix 1. 
3.5 The report has been discussed with the officers and panel members involved in
the review to confirm accuracy and it is now for the Committee to decide
whether to approve the report and, if so, to agree the most appropriate
committee or other Council group for the Complaints Scrutiny Report to be
presented to for consideration. 
4.  CONCLUSION 
4.1 Committee is requested to agree the attached report and agree the most
appropriate Committee or other Council group for the report to be presented to
for consideration. 
5. 
5.1
5.2
5.3
5.4
5.5
5.6
5.7
IMPLICATIONS 
Policy: none
Financial: none
Legal: none
HR: none
Customer Service:  none 
Risk: none
Climate Change: none
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5.8
5.9
5.10
5.11
5.12 
Fairer Scotland Duty: none
Equalities: none
Consumer Duty: none
Island Communities: none
Children’s Rights and Wellbeing: none 
Martin Caldwell
Chair of the Complaints Scrutiny Panel
12 June 2025  
For further information please contact: 
Paul Macaskill, Chief Internal Auditor
Tel: 01546 604108
Email: paul.macaskill@argyll-bute.gov.uk 
Appendices:
Appendix 1 – Draft Complaints Scrutiny Report
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Argyll and Bute Council
Scrutiny Report
March 2025
FINAL 
Complaints Process
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2 
Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
Contents 
1. Executive Summary ........................................................................................................................ 3
2. Detail ............................................................................................................................................... 4
Introduction ............................................................................................................................................ 4
Objectives ............................................................................................................................................... 4
Background ............................................................................................................................................. 5
Scrutiny Initiation Briefings – 30 November 2022 ................................................................................ 7
Exhibit 1 – Scrutiny Meetings Attendees and Key Areas for Discussion ............................................. 8
3. Scrutiny Meetings ........................................................................................................................... 8
Scrutiny Panel Meeting – Council Officers – 02 & 24 February 2023 ................................................... 8
Exhibit 2 – Scrutiny Meetings – Council Officers - Key Messages ....................................................... 9
4. Overall Conclusion and Findings .................................................................................................. 12
Exhibit 3 – Findings ........................................................................................................................... 12
APPENDIX 1........................................................................................................................................... 14 
Contact Details 
Chair: Martin Caldwell (Independent Chair of Audit and Scrutiny Committee)
Chief Internal Auditor: Paul Macaskill (paul.macaskill@argyll-bute.gov.uk)
www.argyll-bute.gov.uk
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3 
Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
1. Executive Summary
1. In January 2024, Elected Members requested that a scrutiny review of the Council’s Complaints
Process take place as part of Argyll and Bute Council’s (the Council) 2024/25 scrutiny plan.  The
Audit and Scrutiny Committee (the Committee) agreed to progress with this review and work
should commence to define the scope of the work to be carried out.
2. A briefing paper was prepared by the scrutiny officer and passed to the panel to provide
background information.  Discussion took place to establish the scope of the review which
resulted in the following themes of enquiry:
• The Council’s complaints process is aligned to the national guidance provided by the
Scottish Public Services Ombudsman (SPSO).
• Sufficient comprehensive guidance has been prepared and made available to assist
officers conduct complaints investigations and provide adequate responses to the
complainant within the stipulated timelines.  
• Suitable oversight is in place to ensure the complaints process is operating as intended.
• Sufficient measures are in place to assess satisfaction with the complaints process
separately from dissatisfaction with specific outcomes relating to the subject matter of
the complaint to exclude undue/subjective negativity.
• Improvements identified as a result of learning from complaints are shared equitably
throughout the Council to avoid recurrence in other service areas.
• Sufficient, comprehensive training and guidance is in place to assist Members and
Officers decide when to progress communications as complaints, expressions of
dissatisfaction or an enquiry. 
3. Research took place to establish legislative requirements and examples of good practice to form
a basis for assessing the Council’s complaints handling process.  An extensive examination
followed to measure compliance with the established assessment basis and identify any areas
for improvement.  The findings of this review formed the basis of discussions held with key
officers involved, the full details of which are included in Exhibit 2.  
4. The panel reviewed and discussed a large suite of documents obtained over the course of the
review to reach its conclusions, these can be summarised as follows:
• The Council’s Complaints Handling Procedure is based on the SPSO’s Model Complaints
Handling Procedure.
• The Complaints Handling Procedure is comprehensive and readily available to all Council
employees, supplementary information and templates provide additional support.
• Monthly, quarterly and annual reporting provides senior management with oversight of
the complaints handling process.  This information is made available to DMTs and
separately to Heads of Service and service single points of contact for complaints, 
however, there is no evidence of this information being cascaded to operational levels
to share learning and improvement actions. 
• Customer satisfaction is subjective and difficult to assess, satisfaction surveys may be
biased and return rate is low. 
• Training and guidance materials help Members and officers understand what is and is
not a complaint.  
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4 
Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
The full conclusions reached are included in paragraph 33 with findings and recommendations
outlined in exhibit 3.
2. Detail
Introduction
5. As part of the Council’s 2024/25 scrutiny plan, approved by the Committee in March 2024, we
have undertaken a scrutiny review of the Council’s complaints process. 
6. Throughout this report references to ‘the panel’ refers to the former independent Chair of the
Committee (to provide guidance to new panel members), the new independent Chair and three
Committee Elected Members who conducted this review. They were:
• Martin Caldwell (panel chair)
• Janice Wasson-Hall (Chair)
• Councillor Mulvaney
• Councillor Vennard 
• Councillor Howard
7. The panel was supported by council officers who gave willingly of their time to help deliver the
review.  We would like to extend our appreciation for the co-operation and assistance received
from all attendees invited to provide evidence over the course of the review.
Scope
8. Consider whether the Complaints Handling Procedure provides sufficient clarity over service
expectations, what does and does not constitute a complaint and whether services are learning
lessons from complaints feedback to inform continuous improvement.  As social Work Servies
are the responsibility of the HSCP, the Panel should exclude this service area from
considerations.
Objectives
9. The agreed objectives of the scrutiny review were to:
• Ensure the Complaints Handling Procedure contains clear guidance defining what can
and cannot be considered as a complaint, it is well communicated and referenced within
key council documentation:
o In constitution, governance statement and Council policies
o In guidance to Members, line managers and officers
• Ensure the Council’s procedure is aligned with national guidance and best practice:
o Scottish Public Services Ombudsman
o Identified best practice within public service
o Robust sources of evidence are used in arriving at complaints resolutions
• Ensure performance data is captured, reported and used to inform senior management
of areas for improvement and share good practice
o Surveys to gather information
o Reports to senior management and committees
o Submissions to appropriate partner organisation for monitoring and
benchmarking
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Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
o Information published on Council website
• Assess methods of identifying and sharing improvement actions
o Improving complaints handling process
o Informing service performance improvements
o Information sharing across Council Services
• Development and final agreement of improvement actions
Background
10. Within the Council’s website and Complaints Handling Procedure, a complaint is defined as “the
expression of dissatisfaction with an organisation’s procedures, charges, employees, agents or
quality of service”, and “an expression of dissatisfaction about the Council’s action or lack of
action, or about the standard of service provided by or on behalf of the Council”.  
11. Complaints may relate to the following examples:
• failure or refusal to provide a service 
• inadequate quality or standard of service, or an unreasonable delay in providing a
service 
• dissatisfaction with one of our policies or its impact on the individual 
• failure to properly apply law, procedure or guidance when delivering services 
• failure to follow the appropriate administrative process 
• conduct, treatment by or attitude of a member of staff or contractor (except where
there are arrangements in place for the contractor to handle the complaint themselves:
see Complaints about contracted services); or 
• disagreement with a decision, (except where there is a statutory procedure for
challenging that decision, or an established appeals process followed throughout the
sector).
12. The above complaint definition is broad, but not every concern raised with the Council is a
complaint. For example, a complaint is not: 
• a request for information or an explanation of policy or practice 
• a request under the Freedom of Information Act or Data Protection legislation.    
13. There are also some matters we can’t deal with under the Complaints Procedure. These include: 
• A first time request for a service e.g. a request for a street-lighting repair 
• A request for compensation only 
• Where there is a statutory or other formal right of appeal e.g. decision on housing or
council tax benefit or in regard to formal enforcement action 
• Insurance claims or potential claims concerning injury to people or damage to property,
however if they are also complaining about the cause of the injury/damage this part
should be dealt with as a complaint
• Matters which are currently subject to court proceedings or have already been heard in
court or at a tribunal 
• Complaints regarding the conduct of a Councillor 
• Disagreement with decisions or conditions that are based upon social work
recommendations, but determined by a court or other statutory body, for example
decisions made by a children's panel, parole board or mental health tribunal 
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Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
• A concern about a child or an adult’s safety 
• A complaint which has already been investigated and a final decision given.
14. The Council Constitution states that “Citizens have the right to complain to the Council under its
complaints procedure about any service failure”.  The Council is committed to providing high
quality services for the people in Argyll and Bute, however, sometimes services may fail to fully
meet their objectives, and when this happens, the Council needs to know so that weaknesses
can be addressed and lessons are learned from the actions taken. 
15. The Council has developed a formal complaints procedure to help those wishing to raise a
complaint to do so either in person at any of the Council’s customer service points, or by
telephone, in writing, by email or via the Council’s or Health and Social Care Partnership’s
(HSCP) websites.
16. The Council has a dedicated area on its website providing information about complaints.  This
includes an explanation of what a complaint is, the Council’s aims and commitments regarding
the complaints procedure, how to raise a complaint, what can and cannot be complained about,
who can complain, how long a customer has to make a complaint, a link to what happens when
complaints have been submitted and performance information.  
17. The Complaints Handling Procedure operated by the Council and the HSCP is comprehensive
and was developed by local government complaints handling experts working closely with the
SPSO.  The Model Complaints Handling Procedure (MCHP) was revised in 2019, combining both
local authority and social work procedures into one containing core text applicable to all public
services in Scotland with some additional text specific to local authorities and HSCPs handling
social work complaints.    
18. The procedure sets out what constitutes a complaint, the complaints handling process and what
is expected from employees during the complaints process, it also provides some examples and
guidance with regard to issues raised.  
19. The Complaints procedure consists of two stages:
• Stage one: Frontline Response
• Stage two: Investigation
20. Complaints will be resolved wherever possible and this may happen at any point within the
process.  Action taken, if any, to resolve the complaint will be agreed between the complainant
and the Council/HSCP.  Where a complaint is resolved, it is not usually necessary to continue
investigating, although it may be useful to do so e.g. to identify learning opportunities to
prevent recurring complaints.  All investigations will be undertaken by a senior officer
independent of the service area under review and a clear record of how the complaint was
resolved will be maintained, noting what action was agreed and the customer’s agreement to
the final outcome.
21. The Council welcomes and indeed values complaints as the feedback received can be used to
inform service improvements and ensure that customers are treated fairly.  Where appropriate,
action will be taken to improve services on the basis of complaints findings.  The outcomes and
actions taken are recorded for all complaints and this data is used to analyse trends and
themes.  Complaints data is used to analyse and improve services and learning is shared
throughout the Council/HSCP as relevant.
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Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
Scrutiny Preparatory Meeting – 02 October 2024 
22. In October 2024 the Panel Chair and scrutiny officers met with key service officers to gather
information and discuss possible focus areas for the review.   
23. The attendees recognised the nature of this briefing and discussion noted the following :
• The definition of a complaint is provided by the SPSO, however there may be benefit in
further explaining “expectations”
• We follow the SPSO Model Complaints Handling Process to progress complaints, it is not
useful to step outside of this guidance
• Complaints should focus on service provision and not overarching policy
• The Member’s Portal is not a conduit for submitting a complaint, anything that looks like
a complaint should be passed to relevant officers to progress through the appropriate
channels if deemed appropriate
• Members have been provided with induction training
• It is important to understand the difference between a complaint and a disagreement 
• The complaints procedure includes issue of a survey upon completion
• Survey return rate is low and more commonly returned by those who are unhappy with
the outcome rather than the complaint process, this has an impact on the annual
complaints report
• Services use feedback inconsistently for learning and benchmarking purposes, there is
no mechanism across the Council to share improvement actions e.g. to provide more
timeous responses to complaints
• Heads of Service are provided with monthly complaints reports and SMT quarterly,
however, there is no evidence of this being cascaded to operational management to
highlight need for improvement
24. The scrutiny officer thereafter prepared and circulated a “Background and Scoping Document”
to the Panel which contained a great deal of information to help inform the review.  As well as
providing the scope (para 8), Objectives (para 9) and background information (paras 10-21
above) the document also contained a briefing paper providing a summary of the contents of
the Council’s Complaints Handling Procedure and performance reporting mechanisms.
25. Attendees agreed that a panel meeting be held to consider the following:
• SPSO Model Complaints Handling Guidance is communicated within Council guidance
and training provided to Members and officers and helps provide a clear understanding
of what can and cannot be considered a complaint
• performance data is captured and shared with management to inform improvement
actions and where relevant share information across the Council
• benchmarking arrangements are in place to learn from other Councils
26. The panel agreed that they should meet with appropriate representatives of the groups set out
in Exhibit 1.   
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Exhibit 1 – Scrutiny Meetings Attendees and Key Areas for Discussion
Group Key Areas for Discussion
Council
Officer(s)
SPSO guidance is communicated within Council procedures and training to
provide clear understanding of what is and what is not a complaint 
• In Complaints Handling Procedure
• In Council website
• In service information 
Performance data is captured, reported and shared sufficiently to inform
improvement actions
• Survey feedback
• KPI reporting
• Information sharing across services 
Benchmarking Arrangements
• Local Authorities Complaints Handlers Network (LACHN)
• How improvements are shared within other Councils
• How improvements are shared between Councils 
3. Scrutiny Meetings 
Scrutiny Panel Meeting – Council Officers – 29 November 2024
27. The Panel meeting consisted of Panel Chair, Chair of the Audit and Scrutiny Committee,
Councillor Vennard, Councillor Howard, Head of Legal and Regulatory Support and the
Compliance and Regulatory Officer.    
28. The scrutiny officer undertook a review of the Council’s procedure document on complaints
handling against the SPSO Model Complaints Handling Procedure to assess their alignment. 
This revealed that the Council’s guide is clearly based on this document with additional details
advising of how the procedure should be applied locally within services.  This is a lengthy
document and a summary was provided for the convenience of the Panel.   
29. Against this finding and building on the overall purpose of the review that had been agreed
within the Background and Scoping document following the first meeting, the six themes
identified in paragraph 2 were agreed by the panel as the final scope of the review.
30. Scrutiny officers thereafter reviewed the Council’s procedure against these themes and
considered improvements. (See conclusions at Paragraph 33) 
31. The panel focussed on how satisfaction with the complaints process is assessed, learning from
complaints and what is and is not considered to be a complaint.  
32. The panel met with Council Officers at a single panel meeting. The Exhibit 2 lists the themes in
order and the key messages emerging from each theme representing the respective views of
the panel and the Officers.  
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Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
Exhibit 2 – Scrutiny Meetings – Council Officers - Key Messages 
Theme  Detail 
The Council’s complaints
process is aligned to the
national guidance provided by
the Scottish Public Services
Ombudsman (SPSO). 
The SPSO Model Complaints Handling Procedures has been
adopted by the Council with some additional detail around
how to apply the requirements at a local level. 
When we consider aspects of the complaints process, we
will not be able to deviate away from what the SPSO
expects of a local authority. 
The Complaints Handling Procedure is considered to be
comprehensive and useful. 
The definition of a complaint used by the Council is derived
from the SPSO.   
Sufficient comprehensive
guidance has been prepared
and made available to assist
officers conduct complaints
investigations and provide
adequate responses to the
complainant within the
stipulated timelines.   
The Complaints Handling Procedure is available to all
members of staff with a Council email address on the HUB
intranet resource website. 
The complaints process is underpinned by best practice. 
The Council uses a suite of templates provided by the
Compliance and Regulatory Team, including examples of
what is and is not a complaint.   
Suitable oversight is in place to
ensure the complaints process
is operating as intended. 
Annual report is published and passed to the Audit and
Scrutiny Committee. 
Heads of Service are passed monthly reports detailing how
many complaints were received in the period, how many
were dealt with within the required timeframe, how many
were late, number of issues arising and any lessons learned. 
Each Service has a Complaints Representative (Rep) who
coordinates the response to complaints within that Service. 
The Rep liaises with the Compliance and Regulatory Team
for advice and assistance and attends regular meetings held
by the team for all Reps to discuss matters related to
performance, current issues and advice related to that.   
Strategic Leadership Team (SLT) are passed quarterly
summaries of the above.  The format of this report is
undergoing development to provide an easier to
understand graphic summary.  The SPSO will be interested
to see this development. 
There is no evidence of information being cascaded to
operational management to implement improvements at
front-line service delivery. 
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No complaints were required to be investigated by the SPSO
in 2023/24, our performance is considered to be very good. 
Most teams/services have a single point of contact for
complaints and regular discussions take place, especially
where issues arise. 
We do not publish the content of individual complaints but
we do publish  a high level overview of the number of
complaints and our complaints performance. 
Stage two complaints are investigated by someone
completely independent to the situation and is usually a
Head of Service.  The investigating officer cannot have had
any involvement in the specific situation that the complaint
relates to. 
Sufficient measures are in
place to assess satisfaction
with the complaints process
separately from dissatisfaction
with specific outcomes relating
to the subject matter of the
complaint to exclude
undue/subjective negativity. 
The Panel may wish to consider how we assess satisfaction
with the complaints process.  This can often be difficult as
there is a distinct difference between someone being happy
with the process but not necessarily happy with the
outcome.  One option would be to benchmark what other
Council’s do and see if there are any learning points to
consider in terms of improving. 
Customer satisfaction is difficult to gauge, it is subjective,
often closely linked to whether the complainant agrees or
disagrees with the outcome. 
Customer satisfaction survey response rate is low and this is
comparable with other Councils across the Local Authorities
Complaints Handlers Network (LACHN). 
Improvements identified as a
result of learning from
complaints are shared
equitably throughout the
Council to avoid recurrence in
other service areas. 
The Panel may wish to consider how the Council learns from
complaints.  The most important element to emerge from a
complaint is learning and using that information to inform
improvements.  Identified improvements may be relevant in 
more than one area of the Council, therefore the Panel may
wish to consider how this learning is cascaded equitably
throughout the Council and if there are any ways that this
can be improved.   
It is not a quantitative assessment but a quality assessment
on how we are improving and what we can do to continue. 
We publish an Annual Report on complaints which includes
some examples of lessons learned and improvements made
as a result, “You said and We did”.  It was suggested that it
might be useful to draw this out further e.g. to the website. 
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Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
It is important to admit that we make mistakes.  The Council
is on a journey for continuous improvement along with the
members of the public. 
This information is made available to DMTs and separately
to Heads of Service and Service single points of contact for
Complaints.  It is important that services share successful
improvements to managing complaints.  It would be useful
and of value if the Panel were able to suggest areas for
improvement to help cascade information across the
Council.  It may be beneficial to undertake a benchmarking
exercise to establish what measures are taken within other
Councils.  (This exercise was undertaken but received only 4
responses that were of very limited use, these can be
viewed within Appendix 1.) 
How do we translate what we say in terms of good
governance and meeting the needs of the SPSO into
relaying that to our community so they have an
understanding on how we use complaints to improve. 
Making changes as a result of complaints shows that we are
listening and taking notice, two examples were provided
regarding email system failure and use of acronyms within
Council reports.   
Stage 1 complaints can be resolved relatively informally and
as a result the outcome might not necessarily require to be
recorded. 
Sufficient, comprehensive
training and guidance is in
place to assist Members and
Officers decide when to
progress communications as
complaints, expressions of
dissatisfaction or an enquiry. 
The Panel may wish to consider whether there is clear
distinction and understanding regarding what is and is not a
complaint.  There may, at times, be confusion when a
communication is received, as to whether it should be
treated as a formal complaint or is an expression of
dissatisfaction.  Would further guidance, training and
support help develop a more consistent approach. 
People may disagree with the Council on a number of areas
but the mere fact there is a disagreement is not the basis
for a complaint.  The manner of how a disagreement may
have arisen may be the basis of a complaint.   
Members induction slides contain useful information with a
lot of focus on how we use the complaints data for
improvements and other aspects on governance that may
arise. 
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4. Overall Conclusion and Findings 
33. Based on the information obtained over the course of the review the panel has concluded that:
• The Council’s Complaints Handling Procedure is a useful, comprehensive document that
is based on the Scottish Public Sector Ombudsman’s (SPSO) Model Complaints Handling
Procedure with additional guidance on local application.
• Sufficient comprehensive guidance is available to all Council employees via the Council’s
intranet resource, the “HUB”.  This guidance is supported by a suite of templates
provided by the Compliance and Regulatory Team, including some useful examples.  
• The most important element to emerge from a complaint is learning and using that
information to inform improvements.  Suitable oversight is in place via monthly,
quarterly and annual reporting mechanisms.  This information is made available to DMTs
and separately to Heads of Service and Service single points of contact for Complaints,
however, there is no evidence of information being cascaded to operational
management from senior management.
• Customer satisfaction is subjective and difficult to assess, the return rate for surveys is
low and those that are returned are often biased by those who are unhappy with the
outcome as opposed to the complaints process.
• New elected Members are provided with induction training promptly after elections
take place as well as regular development sessions to explain what is and is not
considered to be a complaint and how these matters should be addressed.
34. The review has identified 2 findings which have been discussed with management. These, and
the management responses, are detailed in Exhibit 3.
Exhibit 3 – Findings
No. Recommendations Management Response
1 Satisfaction with the complaints process 
It is difficult to gauge satisfaction due to
the poor return rate of surveys issued
upon completion.   
The complaints system administrator may
wish to consider whether there would be
any benefit in having a further stage in the
reminder process, given the current level
of engagement from complainers.   
Noted 
This can be investigated, however, this
may be additional work for no guaranteed
benefit.  Most people respond, based on
the outcome of their complaint, not
necessarily in terms of the spirit of the
survey, i.e. on the process.  This is
reflected in the limited benchmarking. 
2 Learning from Complaints 
There is insufficient evidence of lessons
learned identified being implemented as a
result of the complaints process despite
having been cascaded within and across
the Council’s Service areas. 
Noted 
Improvement actions are identified and
shared with Heads of Service and Service
Reps.  There is a current requirement for
Heads of Service to ensure that
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Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
No. Recommendations Management Response
Whilst lessons learned are discussed at
senior management level and details
cascaded to ensure that improvements
should be identified and can be used to
inform improvements across all Council
service areas, this is not always evident in
terms of process within individual service
areas/teams. 
As part of the cascade arrangements,
Heads of Service should confirm to Legal
and Regulatory Services how identified
improvement actions which have been
shared with them and with their Service
Representatives have been or will be
implemented in practice for inclusion in
the annual report. 
Management should consider cascading
learning to all Council employees via
periodic bulletins where it is deemed that
there is sufficient benefit for wider
circulation (linked to monthly/ quarterly
reporting) to share insights with all
involved in service delivery. 
improvement actions have been
completed, and this is confirmed to L&RS
by the Service Rep updating the Oracle
case form – this is simply not always done. 
Most improvement actions relate to the
individual complaint and actions taken to
reduce the likelihood that a similar issue
will arise again for that individual, where it
is something that affects other areas of
the Service, then they should be discussed
at DMT and cascaded as appropriate. 
Services already have “Service Reps” and
they fill that champion role – but issues
with getting confirmation that
improvement actions have been
completed and the case file updated
continue. 
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Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
APPENDIX 1
Review of Argyll and Bute Council’s Learning from Complaints compared to other Councils
The Scrutiny officer prepared four questions for submitting to other councils to assess if there are any lessons we
can learn to share improvement ideas across the Council.  The Compliance and Regulatory Officer issued these
questions to the Local Authority Complaints Handlers Network on behalf of the Panel with a view to reach across as
may local authorities as possible, unfortunately, only 4 responses were received despite an additional reminder
being sent.  The response from one Council indicated that they receive a good return rate in relation to feedback
surveys and were contacted to obtain further information, unfortunately they did not respond.  The limited
information received is detailed below:
Responses to questions submitted to other Councils
No. Question Responses
1 Surveys requesting feedback on
satisfaction with the complaints
handling process have a low
return rate, have you taken or are
you planning to take any
additional action to encourage a
greater responses rate?  
If so, what are those actions?
We stopped surveys a number of years ago as we had to do manually,
and response was little.  We are in the process of getting a new system
and hoping that it will be able to issue a survey once complaint is
complete. 
Ours are over 50% and we are happy with that. 
We ask customers to opt into our surveys.  If they do, they get one.  We
review the feedback and incorporate it into our annual report, but
beyond that we don’t do anything with it.  If we had time, we would do
more with it, but we just don’t have the resource. 
We have not taken any action to encourage a greater response rate. 
We are aware that the return rate is low and is skewed towards those
who are unhappy. 
2 Have you considered any
alternative means of gauging
satisfaction with the complaints
process within your Local
Authority?  
If so, what are these?
As an authority we are looking at customer satisfaction across services
and how best to capture. 
No 
No, we haven’t considered any alternative methods.  Again, this is a
resource issue. 
No, we haven’t but it is something that we should look at in the future. 
3 By addressing complaints
received, services are able to
identify improvements, can you
please advise if these
improvements are shared across
other service areas within your
Local Authority?
If so, how are these
improvements communicated
and is there any information
gathered to evidence successful
implementation?
Improvements are shared within Management Teams within Services
only unless they have implications for all Services. 
Only shared in our annual report, we include some “stories”. 
This is an area for improvement for us.  Sharing learning is not
happening in the way it should. 
We do not communicate this directly with Services, however, we do
share it with our Information Management Group and publish it in our
Quarterly and Annual Complaints Monitoring report.  We are currently
looking at developing a Power BI dashboard to make this more widely
accessible and introducing shared learning across Services at our
internal Complaint Handlers and Co-ordinators Network.
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Argyll and Bute Council – Scrutiny Report – Complaints Process 2024/25 
No. Question Responses
4 Is improvement information
currently shared across other
Local Authorities?
If so, how is this communicated?
No. 
No. 
Beyond looking at the benchmarking and considering anything that
comes up at LACHN meetings, we don’t share improvement
information. 
No 
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Page 241

ARGYLL AND BUTE COUNCIL            AUDIT AND SCRUTINY COMMITTEE                                                                         
FINANCIAL SERVICES                                               12 JUNE 2025 
LOCAL GOVERNMENT IN SCOTLAND – FINANCIAL BULLETIN 2023/24 
1.0 EXECUTIVE SUMMARY 
1.1 The ‘Local Government in Scotland – Financial Bulletin 2023/24’ forms part of
a series of overview reports, published by the Accounts Commission.  These
provide an independent overview of the financial and operational performance
of Scotland’s local government sector. 
1.2 The purpose of this report is to highlight the key messages and
recommendations contained within the Accounts Commission report. 
Information on Argyll and Bute Council’s position in respect of key facts and
analysis across Scotland, and an assessment of the authority’s current position
in respect of compliance with the report’s recommendations is also provided.
1.3 It is recognised that in the current financial and economic climate, the
management of budget pressures in respect of pay and other inflationary cost
increases, together with increasing demands for key services, will continue to
be challenging.  Opportunities for efficiency savings will require to be
maximised, whilst maintaining service improvements, through transformation.  
1.4 Argyll and Bute Council is well placed to respond to these challenges, in terms
of compliance with the Accounts Commission report recommendations.  Robust
financial planning will continue to support the financial sustainability of the
council. 
1.5 The Audit and Scrutiny Committee is requested to note the contents of the report. 
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ARGYLL AND BUTE COUNCIL            AUDIT AND SCRUTINY COMMITTEE                                                                         
FINANCIAL SERVICES                                               12 JUNE 2025 
LOCAL GOVERNMENT IN SCOTLAND – FINANCIAL BULLETIN 2023/24 
2.0 INTRODUCTION 
2.1 The Accounts Commission publish a series of overview reports, which provide
an independent overview of the financial and operational performance of
Scotland’s local government sector.  The ‘Local Government in Scotland –
Financial Bulletin 2023/24’ report examines councils’ financial performance
during 2023/24. This follows the unprecedented challenges of the Covid-19
pandemic and cost of living crisis and sits against a backdrop of the whole of
the Scottish public sector facing challenges to its financial sustainability. 
2.2 The report sets out: 
• Councils’ funding and budget-setting;
• Councils’ financial performance; and 
• Councils’ position at the end of 2023/24 and the financial outlook. 
A copy of the full report is given at Appendix 1 for information. 
3.0 RECOMMENDATIONS 
3.1 The Audit and Scrutiny Committee is requested to note the contents of the
report. 
4.0 KEY FACTS AND ANALYSIS 
4.1 A summary of key facts from across Scottish local authorities, covering Funding
and Budgets, Financial Performance, and Financial Position and Outlook is
provided at Page 3 of the Accounts Commission report.  The position of Argyll
and Bute Council, alongside Scottish local government in general, in respect of
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Financial Performance, and Financial Position and Outlook key facts, is given
within Appendix 2.
4.2 In addition, the report provides further analysis and displays some information
in graphical format, outlining the position of Argyll and Bute Council, alongside
other Scottish local authorities, where available.  Key points worth noting
include the following:
a) The total budget gap across Scottish councils (27 councils)
represented 4.8% of net cost of services.  Argyll and Bute ranked 14
(from 27 councils) in terms of highest 2023/24 budget gap, as a
percentage of net cost of service, at 4.4%.  This authority wholly met
the budget gap by increased council tax and savings, both recurring
and non-recurring, while councils across Scotland bridged over a
quarter of the total budget gap using reserves (18 councils).  Financial
flexibilities (10 councils) and other measures (11 councils) were also
used to meet the budget gaps across Scotland. 
b) The use of reserves and other non-recurring measures is
unsustainable unless they are used to support service transformation
and generate future savings.  Argyll and Bute ranked 4 (from 27
councils) in terms of the highest reliance on non-recurring savings as
% of overall savings target to meet the 2023/24 budget gap.  Non-
recurring savings accounted for 28% of Argyll and Bute Council’s
savings target, while the total across Scotland (27 councils) accounted
for 15%. 
c) Borrowing was used to finance 15% of total capital expenditure
incurred during 2023/24 within Argyll and Bute Council, while this
accounted for 49% of all capital funding across Scotland.   
d) Argyll and Bute Council currently has a 3 year capital plan, while most
councils reported having a 5-10 year capital plan in place.  
e) Few councils reported documenting information on committed reserves
in performance monitoring reports.  Argyll and Bute Council report on
reserves and balances on an ongoing basis throughout the year, as
part of the financial monitoring reporting pack to Policy and Resources
Committee. 
f) The report suggests that delivering transformation successfully
requires resources to be committed towards it.  Most councils (27 from
30 returning data) reported holding reserves earmarked for
transformation. Of the 26 providing information on the value held, a
total of £270 million was reported, about 13% of the committed General
Fund balance.  Most councils’ transformation reserves were equivalent
to no more than 2% of net cost of services but some earmarked a
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significantly higher proportion. Argyll and Bute earmarked £30m to
support transformation, the equivalent of 10% of net cost of services. 
This comprised major strategic change and transformation projects,
including £9m Learning Estate Investment, £7m Rothesay Pavilion and
£4m Biodegradable Municipal Waste (BMW) Ban. 
5.0 KEY MESSAGES 
5.1  In 2023/24, councils’ total revenue and income fell, including another real
terms decrease in revenue funding from the Scottish Government. Councils
are increasingly reliant on identifying savings, which becomes progressively
more difficult year-on-year, and again used reserves to remain within their
agreed budgets. 
5.2  In 2023/24, capital funding remained constrained, with councils borrowing
more and managing a range of complex funding models. Capital funding from
the Scottish Government reduced slightly in real terms, continuing a longer-
term trend. Capital expenditure was lower than planned. Councils continue to
borrow more to enable investment in their estates and council debt, and
annual interest costs, continue to increase.
5.3 In 2023/24, usable reserves, which are those that can be used to support
service delivery, reduced and most are already committed for specific
purposes. This presents an ongoing challenge for councils reliant on reserves
to balance their budgets, as well as to longer-term financial sustainability.
Using reserves to routinely balance budgets is not sustainable.
5.4 Councils need to intensify transformation activity, progressing at scale and
pace to ensure their financial sustainability. How councils plan to use their
reserves, make savings and transform their services needs to become more
transparent. The need to consult local communities and clearly communicate
the implications for local services of the budget decisions taken has never
been more important. 
6.0 ACCOUNTS COMMISSION REPORT RECOMMENDATIONS 
6.1 An assessment of Argyll and Bute Council’s current position in terms of
compliance with the Accounts Commission report recommendations, together
with potential future improvement actions, where relevant, are outlined within
Appendix 3.   
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7.0 CONCLUSION 
7.1 Argyll and Bute Council is well placed in terms of compliance with the Accounts
Commission report recommendations, with opportunities for further
improvement identified.  A review of capital is already planned for 2025/26 and
this will provide an opportunity for greater convergence between capital and
revenue financial planning. 
7.2 Against a backdrop of historic real terms standstill/reducing Local Government
Finance Settlements and the global economic climate, the management of
budget pressures in respect of pay and other inflationary cost increases,
together with increasing demands for key services, will continue to be
challenging.  Opportunities for efficiency savings will require to be maximised,
whilst maintaining service improvements, through transformation.  Robust
financial planning and modelling will continue to support financial
sustainability. Transformation should be a key focus of future service planning
and decision making, in order to safeguard the financial sustainability of the
council. 
8.0 IMPLICATIONS
8.1 Policy - None
8.2 Financial - Opportunities for enhancement of capital arrangements
8.3  Legal - None 
8.4  HR - None
8.5 Customer Service - None
8.6 Risk - Financial risk will continue to be monitored and reported
8.7 Climate Change - None
8.8  Fairer Scotland Duty - None
8.9 Equalities - protected characteristics - None
8.10 Consumer Duty - None
8.11 Island Communities - None
8.12 Children’s Rights and Wellbeing - None 
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Kirsty Flanagan
Executive Director with responsibility for Financial Services
Councillor Ross Moreland, Policy Lead for Finance and Commercial Services
11 March 2025                                                  
For further information contact: Carolyn Earl, Interim Head of Financial Services
carolyn.earl@argyll-bute.gov.uk 
APPENDICES
Appendix 1 – ‘Local Government in Scotland – Financial Bulletin 2023/24’, 
a report by the Accounts Commission 
Appendix 2 – Key Facts 
Appendix 3 – Compliance with Recommendations 
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Local government in Scotland
Financial bulletin
2023/24
Prepared by Audit Scotland
January 2025
APPENDIX 1
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2Financial bulletin 2023/24
Contents
Key facts 3
Key messages 4
Recommendations 6
Introduction 7
1. Council funding and budgets 9
2. Financial performance 15
3. Financial position and outlook 24
Appendix 1 34
Accessibility
You can find out more and read this report using assistive
technology on our website www.audit.scot/accessibility.
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3
Key facts
Some of these are based on a sample – see paragraph 4 for further information 
on our methodology
Funding and budgets
• 1.8 per cent: the real-terms reduction in revenue funding from the
Scottish Government in 2023/24 compared to 2022/23
• 21 per cent: the proportion of Scottish Government revenue funding
that was ring-fenced or directed towards national policy commitments in
2023/24
• £759 million: the budget gap identified by our sample of 29 councils at
the start of 2023/24. The 2024/25 budget gap identified by all 32 councils
was £585 million
• 1.2 per cent: the real-terms reduction in capital funding from the Scottish
Government in 2023/24 compared to 2022/23.
Financial performance
• 3.3 per cent: the real-terms reduction in councils’ total revenue funding
and income in 2023/24 compared to 2022/23
• 9 out of 29: the number of councils that reported overspends against
their agreed revenue budgets
• 11 out of 30: the number of councils that achieved all their planned
savings
• 25 out of 30: the number of councils that reported lower expenditure
than planned across their capital programmes in 2023/24
• £19.8 billion: councils’ net debt in 2023/24, a 15.8 per cent increase on
2022/23, as councils become more reliant on borrowing to finance their
capital programmes.
Financial position and outlook
• 5 per cent: the decrease in councils’ total usable reserves
• 84 per cent: the proportion of the General Fund that is committed
• 12 out of 29: the number of councils that made unplanned use of their
reserves in 2023/24 to manage budget pressures
• 15 out of 30: the number of councils that have long-term financial plans
in place, with councils reporting difficulty planning for the longer term due
to future uncertainty.
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4Key messages
Key messages
Key messages
Key messages
Despite an increase in overall revenue and capital funding
for councils in 2024/25, and the Scottish Government’s
budget proposals in December 2024 indicating a further real
terms uplift in funding for 2025/26, the financial outlook for
Scotland’s councils remains challenging.
1 In 2023/24, councils’ total revenue and income fell, including
another real terms decrease in revenue funding from the
Scottish Government. Councils are increasingly reliant on
identifying savings, which becomes progressively more difficult
year-on-year, and again used reserves to remain within their
agreed budgets.
2 In 2023/24, capital funding remained constrained, with councils
borrowing more and managing a range of complex funding
models. Capital funding from the Scottish Government reduced
slightly in real terms, continuing a longer-term trend. Capital
expenditure was lower than planned. Councils continue to
borrow more to enable investment in their estates and council
debt, and annual interest costs, continue to increase.
3 In 2023/24, usable reserves, which are those that can be 
used to support service delivery, reduced and most are already
committed for specific purposes. This presents an ongoing
challenge for councils reliant on reserves to balance their
budgets, as well as to longer-term financial sustainability. 
Using reserves to routinely balance budgets is not sustainable.
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Key messages 5
4 Councils need to intensify transformation activity, progressing
at scale and pace to ensure their financial sustainability. How
councils plan to use their reserves, make savings and transform
their services needs to become more transparent. The need
to consult local communities and clearly communicate the
implications for local services of the budget decisions taken 
has never been more important.
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6RecommendationsRecommendations
Recommendations
In 2025, councils should:
• Report on the savings made within their management commentaries more
comprehensively, including provision of comparisons to savings targets agreed
during budget-setting, and whether they were recurring or non-recurring
(paragraphs 29 - 30).
• Ensure that the impact of capital underspends, future borrowing projections and of
using financial flexibilities on their indebtedness are reported clearly alongside the
impact of these on future revenue budgets (paragraphs 34 - 41).
• Ensure reserves policies indicate explicitly and clearly the impact of financial
flexibilities on reserves held; the nature, level of and intended timing of the
deployment of committed usable reserves held; and the level of uncommitted and
contingency funding held within General Funds (paragraph 54 and Case study).
• Prioritise service transformation, considering the impact of current service delivery
models on longer-term financial sustainability, including the medium-term impact
on reserve levels (paragraphs 61 - 62).
• Ensure that financial sustainability becomes a central focus of financial monitoring
and reporting, making greater use of financial sustainability indicators within
reports to elected members and within their regular public reporting and financial
strategies and plans (paragraphs 63 - 67).
We note progress against the recommendations from our Financial bulletin 2022/23
in Appendix 1.
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Introduction
About this report
1. This report is part of a series of overview outputs produced by
the Accounts Commission which together provide an independent
overview of the financial and operational performance of Scotland’s local
government sector.
2. This report examines councils’ financial performance in 2023/24.
This follows the unprecedented challenges of the Covid-19 pandemic
and cost-of-living crisis and sits against a backdrop of the whole of the
Scottish public sector facing challenges to its financial sustainability. 
The bulletin sets out:
• councils’ funding and budget-setting
• councils’ financial performance
• councils’ position at the end of 2023/24 and the financial outlook.
3. In spring 2025, we will publish a budget briefing examining the 2025/26
budgets set by councils, including analysis of anticipated budget gaps and
the decisions made by councils when setting their budgets. This will be
followed by a report focused on service performance later in 2025.
Methodology
4. The primary sources of information for this report are councils’
2023/24 accounts and annual audit reports, a data request issued to
councils in October 2024 and Scottish Budget documents.
5. Our findings are based primarily on:
• The 2023/24 annual accounts for 29 councils (20 audited and
nine unaudited). At our 2 December 2024 deadline, accounts
were unavailable for Clackmannanshire, Eilean Siar and East
Dunbartonshire and these councils are not included in our 2023/24
analysis (or comparisons to previous years).
• Supplementary information from 30 councils collected via a data
return issued to council directors of finance and was also reviewed
by appointed auditors. At our 25 November 2024 deadline, data
returns were unavailable for Clackmannanshire and Eilean Siar and
these councils are not included in our analysis. We also utilised
7IntroductionPage 253

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Introduction 8
elements of data returns previously submitted to us in support of
our Financial bulletin 2022/23 report.
• Scottish Government Budget documents. Our analysis of Scottish
Government funding reports on the funding position for all 32 of
Scotland’s councils.
6. When looking at trends, we convert some figures to real terms. 
This adjusts financial information from past and future years to prices for
the year under review (ie, 2023/24). This is to take account of inflation
so that trend information is comparable. To adjust for inflation, we use
gross domestic product (GDP) deflators, which are published quarterly by
HM Treasury. GDP deflators are the standard approach adopted by both
the UK Government and Scottish Government when analysing public
expenditure.
7. Financial trend data (both capital and revenue) relating to funding,
income or expenditure will generally be shown in real terms. Financial
information from the councils’ accounts’ balance sheets remains
unadjusted. This includes trend analysis on reserves, sources of capital
finance, borrowing and debt. These are not adjusted to real terms as they
are already subject to revaluations within the councils’ accounts to reflect
current prices.
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1. Council funding 
and budgets
Both revenue and capital funding from the Scottish
Government to councils were reduced in real terms in
2023/24, with councils once again setting budgets that
required significant gaps to be addressed.
Councils are reliant on Scottish Government funding
which makes up over 60 per cent of income
8. As the largest source of funding or income for councils, at over 60 per
cent, Scottish Government funding shapes the fiscal environment that
councils operate in. Currently councils receive a single year settlement,
with a draft allocation published in the Scottish Budget in December. This
is revised throughout the year and in recent years a low initial settlement
has been followed by large additional transfers during the financial year.
9. In 2023/24, the Scottish Government allocated councils total revenue
and capital funding of £13.7 billion. This settlement was higher than
before the pandemic but in real terms funding was reduced year-on-year
since 2020/21. The 2024/25 settlement has reversed this trend and the
2025/26 draft settlement published in December 2024 indicates another
real-terms uplift in funding for councils (Exhibit 1, page 10).
10. This initial 2025/26 draft settlement allocates £15 billion of revenue
and capital funding to councils, a 5.8 per cent real terms increase on
the 2024/25 draft settlement. Increases to revenue funding include an
uplift to the general revenue grant, funding for pay awards and teachers’
pensions. Increases to capital include additional funds to support inter-
islands connectivity and climate change. There is still uncertainty as
to how increased employers’ National Insurance (NI) contributions,
announced by the UK Government, will be funded. The Convention of
Scottish Local Authorities (COSLA) estimates these will be an additional
£265 million cost pressure for councils in 2025/26.
11. The funding increase for councils recently announced as part of the
Scottish Government’s 2025/26 draft budget in December 2024 does
not change the fact that the financial outlook remains challenging 
(Part 3). We will examine the implications of the Scottish Budget for
councils’ own budget-setting in our next Local government in Scotland
publication, Local government budgets 2025/26.
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1. Council funding and budgets 10
Exhibit 1. 
Scottish Government revenue and capital funding to councils since 
2018/19 in real terms
Funding in 2023/24 was higher than before the pandemic but in real terms has reduced
year-on-year since 2020/21. This trend reversed in 2024/25 and 2025/26 sees a further
funding uplift.
2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2018/19
Outurn Autumn budget revision Draft budget
13
14.313.6 14.7 14.6 14.2 13.7 13.7
Funding was higher than before the
pandemic but in real terms has reduced
year-on-year since 2020/21
Funding increased in
2024/25 and 2025/26
sees another uplift
Draft Budget Allocation
Note: Draft budget allocations include transfers from other portfolios. 2020/21 and 2021/22 totals
include Covid-19 funding allocations. Barnett consequentials (and other funding) will be allocated to
2024/25 in the Spring Budget Revision. The draft 2025/26 settlement will be subject to additional
in-year allocations that are already included in earlier year totals.
Source: Scottish Government Budget documents
Revenue funding from the Scottish Government
fell by 1.8 per cent in real terms in 2023/24, despite
significant in-year allocations
12. In 2023/24, revenue funding from the Scottish Government (at the
spring revision) was £12.7 billion, a 4.2 per cent cash increase on the
previous year but 1.8 per cent lower in real terms. General revenue grant
funding and non-domestic rates combined decreased by 1.5 per cent.
Specific revenue grants saw no cash increase which meant a reduction
of 6.9 per cent in real terms.
£ billion
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1. Council funding and budgets 11
13. Some further Scottish Government funding received by councils,
although not formally ring-fenced, is provided with the expectation that
it is directed to specific purposes. This is announced and distributed to
councils in-year. In 2023/24, councils received an additional £1.6 billion
at the autumn revision including additional funding to support teachers’
salaries as well as the expected transfers from other portfolios including
health and education. A further £0.3 billion was transferred from other
portfolios at the spring revision.
14. In 2023/24, we calculated that ring-fenced and directed funding
amounted to almost £2.7 billion, which is 21 per cent of Scottish
Government revenue funding to councils. This is lower than in 2022/23.
In the 2024/25 Scottish Budget, following a commitment in the Verity
House Agreement to reduce the level of ring-fenced funding, a number
of ring-fenced or directed items were ‘baselined’ into the general revenue
grant. This includes all £522 million of the early learning and childcare
specific revenue grant and £429 million of in-year transfers including adult
social care Living Wage funding, Free Personal and Nursing Care and
Free School Meals Intervention. While no longer ring-fenced, spending
will still need to be directed towards these policies. In the 2025/26
Scottish Budget, initial indications do not show any significant alterations.
Councils identified £759 million of budget gaps at
the start of 2023/24, and planned to use savings and
reserves to address these
15. Councils set their own budgets in February and March for the
financial year ahead using the initial allocation from the Scottish
Government. At the time of setting their 2023/24 budgets, councils in our
sample of 29 identified a cumulative budget gap of at least £759 million
for the year. This represented a budget gap of 4.8 per cent of the total
net cost of services.
16. To close the budget gap and set a balanced budget, councils took a
range of actions. Over 90 per cent was covered by agreeing:
• to make £260 million of recurring savings (34 per cent of the total
share)
• to make a further £30 million of non-recurring, one-off savings 
(four per cent)
• to use £202 million of reserves (26 per cent)
• to raise £144 million through increases to council tax (19 per cent)
• to use £73 million of funding released via application of financial
flexibilities (nine per cent)1 (Exhibit 2, page 13).
1 The budget gap and values that make up the bridging actions vary from those published in last
year’s Financial bulletin as the sample is different and additional data returns were received post
publication that are now included.
During the budget-
setting process,
councils may
identify a budget
gap, which is the
difference between
their anticipated
expenditure for the
year and the funding
and income they
expect to receive.
Councils will identify
and agree bridging
actions to allow them
to set a balanced
budget. This may
include an agreement
on savings to be made
during the year.
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1. Council funding and budgets 12
17. The use of reserves and other non-recurring measures is
unsustainable and is only a temporary plug for a budget gap in that one
year. The gap will remain in future years until recurring measures such
as recurring savings or increases to income are found or the service cost
base is reduced.
18. The setting of council tax levels is an important mechanism available
to councils in delivering a balanced budget. In 2023/24, councils
increased their tax by an average of 5.4 per cent. This was used to
bridge 19 per cent of the overall budget gap. The Scottish Government
imposed a council tax freeze for 2024/25, instead providing £144 million
to ‘fully fund’ the freeze to the equivalent of a five per cent increase. The
Cabinet Secretary for Finance and Local Government confirmed during
her budget statement in December 2024 that there will be no council tax
freeze or cap for 2025/26.
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1. Council funding and budgets 13
Exhibit 2. 
The bridging actions councils identified within their 2023/24 budgets 
as a proportion of net cost of services
Recurring savings and using reserves made up the majority of how councils intended
to meet their identified budget gaps.
Fife
Glasgow
Dundee
East Ayrshire
Renfrewshire
North Lanarkshire
Dumfries and Galloway
Inverclyde
Midlothian
East Lothian
West Lothian
Aberdeenshire
City of Edinburgh
Argyll and Bute
Scottish Borders
South Ayrshire
North Ayrshire
Stirling
East Renfrewshire
Falkirk
Perth and Kinross
Aberdeen
Angus
Highland
West Dunbartonshire
South Lanarkshire
Moray
Scotland
0% 1% 2% 3% 4% 5% 6% 7% 8% 9%
Increase to council tax
Use of reserves Financial flexibilities Other
Agreed savings recurring Agreed savings non-recurring
Note: In addition to the three councils whose 2023/24 annual accounts were not available, Shetland
and Orkney are excluded from this chart as both are outliers due to their high use of reserves to set
their budget, reflecting the councils’ regular utilisation of the returns from significant investments and
harbour income. Shetland’s bridging actions made up 35 per cent of their net cost of services (over 80 per
cent of which related to reserves use). Orkney’s bridging actions made up 13 per cent of their net cost of
services (of which over 90 per cent was use of reserves).
Source: Council data returns (2023) and Councils’ annual accounts 2023/24 (audited and unaudited)
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1. Council funding and budgets 14
With Scottish Government capital funding remaining
constrained, councils are increasingly reliant upon
borrowing to fund planned investment decisions
19. Capital funding from the Scottish Government (at the spring revision)
fell by 1.2 per cent in real terms between 2022/23 and 2023/24 and
was 21 per cent lower than 2018/19. Both the general capital grant and
specific capital grant have decreased in real terms. The specific capital
grant, the proportion of funding that is ring-fenced for specific uses, 
was much lower than five years ago and has been relatively static for
the past three years. This is due to the completion of the capital element
of the Early Learning and Childcare Expansion Programme. Councils
received £70 million of capital funding for use in 2023/24, by allowing 
an equivalent amount of revenue reserves to be released, and a further 
£22 million of funding to support the cost of local government pay
awards (for example by allowing councils to use this instead of planned
transfers from revenue budgets).
20. Capital funding was reduced further in 2024/25. The initial draft
allocation for 2025/26 saw an increase compared to 2024/25 but capital
funding remains lower than 2023/24 and earlier years. The longer-term
reduction in capital grants means councils are having to finance their
chosen investment in new facilities by other means. Councils are now
more reliant on other sources of finance, such as borrowing, transfers
from their revenue budgets and making use of financial flexibilities, than
has previously been the case (paragraphs 33 - 41).
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15
2. Financial performance
Councils increasingly relied on savings and reserves to
ensure they remained within agreed revenue budgets;
capital expenditure was lower than planned and borrowing
increased. Improvements in how councils report their
savings are still needed.
Councils’ total revenue funding and income fell by 3.3 per
cent in real terms in 2023/24, with income from service fees
still below pre-pandemic levels.
21. In addition to Scottish Government funding and council tax, councils receive
funding and income from several other sources, including fees and charges for
using services and council house rents (Exhibit 3).
22. In 2023/24, from our review of 29 councils’ annual accounts, councils received
£21.2 billion in revenue funding and income. This is £540 million more than 2022/23
but represents a real terms decrease of 3.3 per cent (£725 million) as increases in
income have not kept pace with inflation. In 2023/24, total funding and income fell
back to 2019/20 levels.
2. Financial performance
Exhibit 3. 
Sources of council funding and income in 2023/24
The proportion of funding from each source is similar to 2022/23.
GRG
NDR
Council Tax
Grants (including Scottish
Government & others)
Customer and
client receipts
HRA rents
Interest receivable
& similar charges 1% (£0.2 billion)
7% (£1.4 billion)
9% (£1.8 billion)
16% (£3.4 billion)
13% (£2.8 billion)
14% (£3 billion)
40%
(£8.5 billion)
Note: Interest receivable refers to the interest that has been earned by investments, loans, or income
to be received from overdue invoices.
Source: Councils’ annual accounts 2023/24 (audited and unaudited) (based on 29 annual accounts)
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2. Financial performance 16
23. Council tax is an important source of income for councils, providing
£2.8 billion in 2023/24. The proportion has remained static for the last
five years at around 13 per cent of total funding and income. In 2023/24,
councils received £11 million more income from council tax than in
2022/23, which is a 0.4 per cent real terms increase.
24. Income from customer and client receipts dropped significantly during
the pandemic and has not yet returned to previous levels. Customer and
client receipts are 12 per cent (£253 million) lower in real terms than in
2019/20. Councils reported receiving lower income than budgeted for
as a reason for service overspends in 2023/24 across a broad range
of services, with parking and waste the most common. However, the
picture is mixed and for some councils and service areas increased
income offset expenditure and led to services underspending against
their budgets. Income generation, and the limited capacity to increase
this, was cited by a number of councils as a risk to financial sustainability.
Overall, councils remained within their agreed
revenue budgets, but some services spent more 
than planned
25. In 2023/24, councils managed net budgets of around £15 billion,
compared to £13.4 billion in 2022/23. Overall, councils reported a
revenue budget underspend of £111 million or 0.7 per cent. This is around
half the variance seen in 2022/23. Since 2019/20 there has been a small
overall underspend each year and, except for 2020/21, this variance has
decreased year-on-year. Despite the overall underspend, nine reported
overspends against their agreed revenue budgets.
26. Councils reported both underspends and overspends at a service
level, with workforce issues and income a common theme for both
(Exhibit 4, page 17).
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2. Financial performance 17
Exhibit 4. 
Council overspends and underspends at a service level and reasons 
for them
Workforce issues and income generation are a common theme for both.
Service area Reasons for
Overspends
• Reported in a wide range of
service areas with culture and
leisure, children and families,
education and adult social care
being noted most often.
• Service area overspends were
mostly attributed to a lack of
funding, workforce pressures
and general cost increases.
• Underperformance of a range of
income streams also contributed
to overspends in some councils.
Underspends
• Education and early years were
referred to most often.
• Communities, culture and
leisure, and planning and
economic development were
also identified by some councils
as areas of underspend.
• Underspends in education and
early years were often attributed
to lower than anticipated
demand and unfilled staff
positions.
• Underspends were sometimes
attributed to more favourable
income position, such as
generating greater income than
budgeted for and receiving
additional VAT reimbursements.
• Workforce issues, such as
challenges with recruitment,
and high vacancy levels, were
also identified as a cause of
underspends.
Note: Culture and leisure services were reported in both but twice as often as an area of overspend
than an underspend.
Source: Council data returns
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2. Financial performance 18
Councils delivered significant savings, but some
remain reliant on one-off measures and reporting
against savings targets should be more transparent
27. From our sample of 30, 28 councils set a savings target in 2023/24,
totalling £362 million, with £332 million (92 per cent) being achieved.
This is significantly higher than the savings target reported by the same
councils last year (£214 million).
28. Of the 30 councils:
• eleven achieved their full savings target or more
• thirteen missed their target but achieved 80 per cent or more
• four achieved less than 80 per cent of their target
• two councils (Fife and Orkney) did not have savings targets 
in place.
29. Not all councils could split savings targets or achieved savings
information into recurring or non-recurring categories. Where we have a
breakdown of how savings were achieved (27), 85 per cent (£244 million)
were achieved on a recurring basis, compared to 82 per cent in 2022/23. 
Non-recurring savings accounted for 15 per cent of total savings
achieved, at £42 million (Exhibit 5, page 19).
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2. Financial performance 19
Exhibit 5. 
Proportion of savings targets achieved in 2023/24, split by recurring and
non-recurring savings (based on 27 councils that can split their savings in
this way)
Some councils continue to rely upon one-off measures to deliver in-year savings.
0 20 40 60 80 100 120
Shetland
East Dunbartonshire
Scottish Borders
Aberdeenshire
Highland
Falkirk
Argyll & Bute
South Ayrshire
Midlothian
East Lothian
Stirling
City of Edinburgh
Glasgow
Dumfries & Galloway
Perth & Kinross
North Ayrshire
Angus
East Renfrewshire
West Dunbartonshire
Renfrewshire
South Lanarkshire
East Ayrshire
North Lanarkshire
Inverclyde
West Lothian
Dundee City
Moray
Scotland
Percentage
% of total target  - recurring
% of total target  - non-recurring
Note: In addition to the two councils that did not submit a data return, a further three councils are
excluded from this exhibit. Aberdeen City sets a savings target to be achieved in the year but does
not differentiate between recurring and non-recurring savings for monitoring purposes. The savings
target was achieved for 2023/24. Fife and Orkney did not have a savings target in place in 2023/24.
Source: Council data returns
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2. Financial performance 20
30. In our Financial bulletin 2022/23 we recommended that councils
prioritise the achievement of recurring savings and avoid reliance
on non-recurring measures. The overall extent of progress against
our recommendation is difficult to assess due to a lack of detail and
transparency in reporting on savings performance. Non-recurring savings
are not always included in savings targets or performance information so
it remains difficult to assess the overall reliance on these or, indeed, the
overall savings achieved.
31. Additionally, a review of management commentaries within annual
accounts found that not all councils are reporting progress against
savings plans and, for the majority that are, these largely focus on their
previous or future plans. The majority lacked detail on areas such as
performance trends and, again, often did not report if savings were
recurring or non-recurring.
32. Councils have identified the need to generate future savings as
they undertake wider-scale transformation, redesign how services
are delivered and consider their future policies on fees and charges
for accessing services. This will need to be done in consultation with
their partners and citizens. Councils should report more transparently
the nature of their savings and how these could impact services on an
ongoing basis.
Capital expenditure was 20 per cent lower than
planned and funded by increased borrowing
33. The value of council estates, mainly council owned property
(including buildings and schools) and equipment, increased by £5 billion
in 2023/24 to £51 billion. This reflects continuing investment by councils
and, in 2023/24, capital expenditure was £3.5 billion. This is comparable
in cash terms to 2022/23. Borrowing increased again in 2023/24 to 
£1.7 billion, a significant increase of £406 million (31 per cent) since
2022/23, and up £1.2 billion (196 per cent) since 2018/19. Borrowing
was used to finance 49 per cent of total capital expenditure (Exhibit 6,
page 21).
34. From our sample of 30 councils providing information through the
data return, 25 reported a capital underspend in 2023/24 of £755 million.
This equates to 20 per cent of councils’ total capital budget. This is less
than the underspend of 24 per cent in 2022/23; however, it is still higher
than the 17 per cent reported in 2018/19. Significant underspends were
reported for both General Fund (23 per cent of budget) and HRA 
capital programmes (15 per cent of budget). Councils reported a range 
of project types and reasons for why capital underspends had occurred
(Exhibit 7, page 21).
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2. Financial performance 21
Exhibit 6. 
Capital expenditure split by sources of finance, in cash terms
Borrowing and government grants remain the most significant means of financing
capital investment.
2022/23 2023/24
-0.5 0 0.5 1 1.5 2
Other contributions and
Public Private Partnership (PPP)
Internal loans fund
repayments available to reinvest
Government grants
Capital receipts
Capital Funded from
Current Revenue (CFCR)
An increase in borrowing
billion
Note: Internal loans fund repayments are an annual charge that recognise capital costs in the revenue
budget. Once repaid, they allow borrowed funds to be used elsewhere. Capital receipts are income
councils generate from selling existing assets. Revenue transfers is capital expenditure funded from
service revenue budgets.
Source: Councils’ annual accounts 2022/23 and 2023/24 (audited and unaudited)
Exhibit 7. 
Type and reasons for underspends on councils’ capital programmes
Project type Reasons for
Underspends
• School and early learning building
projects. 
• Housing projects.
• Large-scale infrastructure projects
(with a small number of councils
underspending in relation to
projects being delivered as part of
their City Deals).
• Project and programme slippage,
caused by a range of supply chain
and capacity issues.
• Project delays caused by cost,
contract and legal negotiations and
unexpected issues arising during
the course of works.
• Project deferment.
Source: Council data returns
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2. Financial performance 22
35. Managing their capital programmes is an important tool for councils
to control their annual expenditure. All but two councils reported having
a multi-year capital plan in place. These covered a range of periods from
five to 30 years, with most covering five to ten years. South Lanarkshire
and Stirling councils both reported only having an annual capital plan in
place. A multi-year plan allows councils to manage their capital spending
over this period.
36. However, consistently failing to invest in estates and infrastructure
increases the risk that asset failures may impact services, projects will
become more expensive to deliver, and that maintenance spending will
need to increase due to assets becoming older. It also impacts the ability
of councils to manage their overall estates, identify surplus assets and
consider the efficiency of partnership working, including co-location with
other services.
Borrowing means debt has again increased, 
and further borrowing will be needed to invest 
in new schools
37. Due to the increased reliance on borrowing to fund investment,
councils’ net debt has now risen to £19.8 billion. This is an increase of
15.8 per cent from 2022/23 and a 29.7 per cent increase since 2018/19.
All but one council increased their debt in 2023/24. The cost of servicing
debt has risen, with a 16 per cent rise in interest payable and similar
charges since 2022/23. Interest payable as a proportion of net cost of
services, was six per cent compared to five per cent in 2022/23.
38. Under LEIP, councils borrow to meet the cost of building new
schools, with the Scottish Government providing revenue grant funding
over a 25-year period linked to specific outcomes (maintenance, energy
efficiency, digital infrastructure and job creation) to meet maintenance
and life-cycle costs. Councils, however, need to fund the £1 billion cost
of building schools, including any interest on the money borrowed to
fund this. The programme has faced significant delays and cost increases
and, to complete the programme by the planned date of 2027, significant
further borrowing by councils will be needed.  
39. Alongside investing and maintaining their own estates, councils
have made use of a range of different Public Private Partnership (PPP)
contracts to invest in their estates. A number of earlier Private Finance
Initiative (PFI) contracts are now nearing the end of their terms. Councils
are having to prepare for, and manage, complex closing arrangements.
Councils have already entered into negotiations relating to contracts that
are ending, with 10 PFI contracts due to expire by the end of 2030.
In September
2019, the Scottish
Government
announced it would
support £1 billion of
capital investment
in the school estate
on a match-funding
basis. In consultation
with councils, this
created a joint £2
billion Learning
Estate Improvement
Programme (LEIP),
enabling additional
investment without
the use of private
finance contracts.
Councils provide
upfront capital
funding and Scottish
Government revenue
follows over 25 years
for achievement of
outcomes.
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2. Financial performance 23
40. By making use of financial flexibilities across 2022/23 and
2023/24, councils have been able to reprofile the debt associated
with PPP contracts. This has allowed councils to recognise significant
gains from annual contractual payments they have previously made,
recognising these within their usable reserves. Future capital expenditure
will be able to be offset against these, but they are not cash backed.
This means the need for councils to borrow to finance their future capital
investment has not changed, nor have their current external debts.
Alongside LEIP projects, councils have already committed to significant
future borrowing.
41. Councils set and agree their borrowing and treasury management
strategies individually, deciding on what is a prudent and affordable level
of debt under the Prudential Code. As part of this, a range of indicators
are considered, including the cost of servicing their debts, to show that
capital plans are affordable and sustainable. Increased borrowing means
increased costs that will need to be met annually from revenue budgets.
While auditors have not expressed specific concerns about the level of
borrowing (in the 15 annual audit reports that were available at the time
of our review), it is a factor in the assessment of financial sustainability
and auditors are expressing greater concerns about the overall financial
sustainability of councils (paragraph 58).
Between 2020 and
2024, the Scottish
Government
permitted councils
to make use of a
range of financial
flexibilities to
manage financial
pressures. One of
these related to
service concessions
(including PPP) and
allowed councils
to reprofile debt
repayments. This
offered an immediate
benefit of significant
one-off increases to
reserves but these
are not cash backed,
and debt payments
will need to be made
for longer, deferring
costs to later years
which has implications
for future revenue
budgets.
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24
3. Financial position 
and outlook
Using reserves to manage financial pressures and stay
within agreed budgets is not sustainable. Usable reserves
fell in 2023/24, and most are committed for specific
purposes. Progress on transformation and reform must 
be prioritised to ensure longer-term financial sustainability.
Councils’ usable reserves remain higher than before
the pandemic, mainly due to the use of financial
flexibilities, but decreased in 2023/24 
42. Holding and using reserves is a normal, and helpful, way of 
managing council finances but reserves are a one-off resource meaning
councils need to carefully plan and monitor how these are being used.
Using reserves to support services in the short term is not sustainable
unless they are used to support service transformation and generate
future savings.
43. In 2023/24, councils’ total usable reserves decreased by five per
cent to £4.1 billion which equates to around 25 per cent of net cost of
services. The overall decrease is attributed to a fall in capital reserves
along with a very modest increase in revenue reserves (Exhibit 8, 
page 25).
44. Usable reserves remain £1.66 billion higher than before the
pandemic. Revenue reserves were boosted in recent years by:
• Covid-19 funding, but these are largely exhausted with only around
£67 million remaining earmarked (2.8 per cent of the committed
General Fund balance)
• making use of financial flexibilities related to service concessions,
resulting in reprofiled debt and significant one-off increases to
reserves. Although an accounting adjustment, and not cash backed,
these can be used to support services.
3. Financial position and outlook
Usable reserves can
be used to support
service delivery,
and to meet in-year
expenditure (and are
sometimes referred
to as cash backed
reserves).
Unusable reserves
represent accounting
adjustments to reflect
things such as an
increase in the value
of council-owned
buildings. They
generally cannot be
routinely accessed
or used to support
services. 
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3. Financial position and outlook 25
Exhibit 8. 
Councils’ usable reserves, 2023/24 compared to 2022/23 and 2018/19
Revenue reserves are higher than pre-pandemic but have remained relatively static 
in the last year.
0
.5
1
1.5
2
2.5
3
3.5
4
£ billion
Revenue Capital
2018/19 2022/23 2023/24
Note: Total usable reserves were £4.1 billion in 2023/24. Between 2022/23 and 2023/24 revenue
reserves increased by 0.8 per cent, capital reserves fell by 33 per cent. Total usable reserves are 
68 per cent higher than in 2018/19, up from £2.4 billion (90 per cent increase in revenue reserves,
four per cent decrease in capital reserves)
Source: Councils’ annual accounts 2023/24 (audited and unaudited)
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3. Financial position and outlook 26
45. The overall decrease in usable reserves in 2023/24 is notable as they
have been increasing significantly in recent years. Two-thirds of councils
still increased their total usable reserves, but this is largely attributable
to councils making use of financial flexibilities (a number of councils
accounted for this in 2022/23, while others introduced it in 2023/24).
46. Around a third of councils saw their total usable reserve fall in
2023/24, including some large decreases related to the drawing down
of committed reserves. These reserves were used for Equal Pay
settlements, pay awards, budget support and the further deployment 
of Covid-19 reserves.
General Fund reserves increased slightly but over 
80 per cent are committed for specific purposes
47. General Fund reserves (excluding the HRA element which not
all councils have) continued the upward trend of the past five years,
increasing by three per cent in 2023/24 to £2.8 billion. This equates to 
17 per cent of net cost of services and is driven by growth in committed
reserves. Uncommitted reserves have remained constant at between
two and three per cent of net cost of services (Exhibit 9, page 27).
48. In 2023/24, over 80 per cent of the General Fund was committed.
This means that it has been allocated for specific purposes and is not
readily available for other uses.
The General Fund
is the principal usable
revenue reserve held
by councils. It can be
used for a wide range
of purposes, including
bridging budgets gaps
as it can be used to
finance spending on
services or some
elements of capital
spending.
The Housing Revenue
Account (HRA)
reserve can only be
used to fund spending
on council-owned
housing.
Committed reserves
have been allocated (or
earmarked) for specific
purposes and are not
readily available for
other uses.
Uncommitted
reserves can be
deployed more easily
and, because of the
nature and scale of
it, the uncommitted
element of the
General Fund can
be considered to
represent a degree of
contingency funding.
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3. Financial position and outlook 27
Exhibit 9. 
Councils’ General Fund balance between 2018/19 and 2023/24, 
split by committed and uncommitted
General Fund reserves are increasing but over 80 per cent is committed.
2019/20 2020/21 2021/22 2022/23 2023/24 2018/19
General Fund committed General Fund uncommitted
£730m
£360m
£848m
£467m
£0.9bn
£0.3bn
£0.9bn
£0.3bn
£1.9bn
£0.4bn £2.2bn
£0.4bn
£2.3bn
£0.4bn
£2.4bn
£0.5bn
Source: Councils’ annual accounts 2023/24 (audited and unaudited)
Some councils’ levels of uncommitted reserves are
low, but they have specific reserves earmarked for
contingency
49. Councils have reserve policies in place, which set out the rationale for
the minimum level of uncommitted reserves held by the council. Most
have an agreed minimum level, usually two per cent of their net budgeted
revenue expenditure, although four councils have set this higher.
50. In 2023/24, nine councils had an uncommitted reserves level of less
than two per cent of net budgeted revenue expenditure. However, a
review found that in many cases these low reserve levels were planned
decisions and the levels were deemed to be sufficient and/or supported
by additional committed funds for contingencies. Aberdeenshire, South
Ayrshire and West Dunbartonshire all had uncommitted reserves below
their minimum level and intend to review this during 2024/25.
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3. Financial position and outlook 28
51. While councils hold uncommitted reserves for contingencies,
around a third reported also earmarking some reserves specifically for
contingencies to either manage budget risks or specific risks, such as
adverse weather. The nine councils providing information on the value of
the reserves earmarked for contingencies reported a total of £50 million.
Councils continue to use their reserves to manage
budget pressures, but this is not sustainable
52. While overall usable reserves levels remain high, there is evidence
that councils are continuing to use reserves to support service spend and
this is not sustainable. In 2023/24:
• Councils bridged over a quarter of their budget gap using reserves
(£202 million).
• Twelve councils reported making unplanned use of reserves in
2023/24, to support in-year spending and to balance the outturn
position. This was most often to cover the cost of the 2023/24
pay award; to address specific service or project pressures, or to
provide financial support to IJBs.
53. Usable reserves held as a proportion of spending has reduced. 
In 2023/24, 15 councils held usable reserves that were over 20 per cent
of their net cost of services, which is less than 2022/23 (20 councils) but
still higher than before the pandemic (nine councils). This indicates that
reserves are increasing at a slower rate than expenditure, even with use
of financial flexibilities. One council had total usable reserves of less than
ten per cent of their net cost of services. 
Councils could improve how clearly they report on
how they intend to use their reserves
54. With the use of reserves to support services and the low level of
uncommitted reserves across the sector it is increasingly important that
councils report how and when the intend to make use of their reserves
(Case study 1, page 29).
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3. Financial position and outlook 29
Case study 1. 
Councils could be more transparent within their published plans about
how they intend to make use of reserves
A review of councils’ management commentaries found that all councils
clearly identify key areas of reserves and explain their purpose, with most
identifying their minimum reserve level.
All but two councils reported, through their data return, that they formally
document or publish at least some information about their committed
reserves. Committed reserves information is usually documented in
councils’ accounts or financial outturn reports, and sometimes in other
formats, such as reserves reports. Few councils reported documenting
information in performance monitoring reports.
Nearly all councils publish and document a full costed breakdown of
committed reserves categories and details of what has been drawn
down within the year. Although most formally document what is
committed for major initiatives, this information is not always published.
Only two thirds of councils document or publish information on planned
spend for future years.
Source: Council data returns and Council annual accounts 2023/24
(audited and unaudited)
Recent changes to pension contribution rates offer
councils a short-term window to reduce costs
55. The result of the 2023 triennial revaluation showed a significantly
improved funding position across Scotland’s 11 local government pension
funds. Councils are using this as an opportunity to lower their employer
contributions and reduce their costs in the short-term. The 12 councils
who are members of Strathclyde Pension Fund are reducing their
contribution rates from 19.3 per cent to 6.5 per cent for 2024/25 and
2025/26 (increasing to 17.5 per cent in 2026/27), significantly reducing
their annual contribution costs for two years. Other councils are making
more modest reductions to their contribution rates of between two and
three percentage points.
Ensuring medium- and long-term financial
sustainability is a significant challenge
56. The risks to financial sustainability are well known. These include
external factors such as increased demand, demographic changes and
the need to invest significantly to address certain policy areas such as
climate change and its impact. There are also specific pressures that
councils identified as presenting risks to achieving future financial balance/
sustainability including:
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3. Financial position and outlook 30
• Uncertainty about future funding: single-year settlements,
ring-fencing of funding and directed funding for specific Scottish
Government policies limiting local flexibility (for example, teacher
numbers, social care provision and IJB allocations).
• Council tax freezes: while there is no freeze in 2025/26, the
Scottish Government froze council tax between 2008/09 and
2016/17, and in 2021/22, and capped increases at three per cent in
2017/18 and 2018/19. The risk of future freezes is seen as a main
challenge to ensuring medium- to long-term financial sustainability.
Even when ‘fully funded’ a council tax freeze suppresses the
growth of the council tax base over that period and the income
generated when the freeze is lifted is lower than if councils were
able to make tax-raising decisions at a local level.
• Pay awards and employers’ NI costs: overspends have been
caused by pay awards, with some councils reporting that the
budgets provided are not enough to cover the costs or these costs
are unfunded. In 2023/24, three councils made unplanned use of
reserves to meet pay awards and there is ongoing uncertainty about
the scale of future annual offers. There is now also uncertainty over
how increased employers’ NI contributions will be funded.
• Inflationary pressures: general pressures and some specific
issues that impact the delivery of capital programmes (costs of
goods and services, service demand, public perception, borrowing,
funding, increasing standards and difficulty with asset sales).
• Savings: some councils cited the challenge of identifying and
achieving recurring savings.
57. Most councils reported that financial sustainability was a significant
challenge. Some specific challenges reported by councils include:
• Angus Council reported the need for change if they are to be
financially sustainable over the medium to long term. The scale of
reductions required could leave some services unable to function.
• East Lothian Council identified critical risks to its fiscal sustainability
and reported managing their financial environment as the highest
ever scoring risk on their Corporate Risk Register.
• Inverclyde Council reported that ongoing depopulation may mean
significant future funding reductions.
• Orkney Islands Council highlighted the growing contribution from
reserves to meet in-year service costs as being unsustainable.
• Shetland Islands Council reported they were financially
unsustainable on the basis of current plans.
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3. Financial position and outlook 31
58. Alongside councils’ own assessment of their financial sustainability,
many auditors highlighted in their 2023/24 annual audit reports (15
available for review) the challenges councils face in achieving financial
balance in future years and securing long-term financial sustainability. 
These centred on the scale of budget gaps; the need to keep on top of
savings plans; low levels of uncommitted reserves; unsustainable cost
bases and the difficult choices to be made.
Councils have medium-term financial plans in place
but must now make progress on transformation 
and reform
59. While several councils reported confidence that they had robust
processes and actions in place to ensure they were financially
sustainable, councils largely reported that it is difficult to plan into the
future without clarity on medium- or long-term government funding and
priorities, stating there is general economic uncertainty and volatility.
This difficulty, however, underlines the importance of councils ensuring
that they have a clear understanding of risks to their financial positions,
effective risk management processes to monitor these, and indicative
forecasts informed by scenario planning.
60. All councils that provided data returns to us reported having medium-
term financial plans in place, with most of these spanning 3-5 years 
(25 out of 30 councils). Most councils (25) reported that they reviewed
their financial plans in 2024. Half of councils (15 out of 30) have a long-
term financial plan in place and, for those that do, most cover a 10-year
period.
61. As we set out in our recent Transformation in councils report,
councils must prioritise and progress the delivery of their plans for
transformation. And a step change is needed in terms of scale and
pace. That could look like new innovative approaches to service delivery,
reconsidering which services could be more effectively delivered by other
partners, exploring opportunities for new income generation (including
those that are being legislated for) or identifying how economies of scale
could be achieved by sharing services.
62. Delivering transformation successfully requires resources to be
committed towards it and it is positive to see that most councils 
(27 from our data return sample of 30) reported holding reserves
earmarked for transformation. Glasgow, Orkney and Shetland did not. 
Of the 26 providing information on the value held, a total of £270 million
was reported which is about 13 per cent of committed General Fund
balance and equates to two per cent of the net cost of services. Most
councils’ transformation reserves were equivalent to two per cent or
lower of net cost of services, but some earmarked a significantly higher
proportion. Argyll and Bute earmarked the equivalent of ten per cent of
net cost of services, Scottish Borders six per cent, and Aberdeenshire,
East Lothian and Highland all earmarked five per cent.
Transformation is
our next Best Value
thematic focus and
we will be auditing
councils’ plans for
transformation as 
part of the 2024/25
annual audit.
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3. Financial position and outlook 32
Councils could make more use of financial
sustainability indicators, including to inform their
longer-term planning
63. Assessing and monitoring financial sustainability is essential. Councils
use a range of indicators to do so, but the type used, and extent of their
use, varies. The Local Government Benchmarking Framework includes
sustainability indicators, currently being reviewed by Directors of Finance,
to ensure that they remain appropriate, and CIPFA also recommends
indicators. Councils are not required to use specific indicators and have
discretion as to how they assess their own financial sustainability. 
64. We asked councils how they assess and monitor financial
sustainability, including how this is reported to elected members:
• Around three-quarters of councils use the Local Government
Benchmarking Framework Indicators and the CIPFA level of
reserves indicator. 
• Around a third of councils use the CIPFA change in reserves and
reserves sustainability measures.
• Some councils reported that they use their own equivalent
calculations or different indicators including outturn against
expenditure, ratio of council tax to overall funding, ratio of financing
costs to net revenue stream, external debt and borrowing levels,
and recurrent versus non-current budget mitigation.
65. Most councils reported that they assess and monitor financial
sustainability more generally, such as via the regular monitoring of
budgets, reserves and the capital financing requirement; and carrying out
periodic risk assessments. For example, East Ayrshire Council’s ‘East
Ayrshire Performs’ reports financial and service performance information
about the council publicly, including a suite of financial resilience
indicators, focusing on council reserves and liquidity but also capital
financing, investment and borrowing.
66. Most councils include and consider financial indicators within
their financial plans, with 17 councils including an analysis of financial
sustainability and/or resilience indicators within their medium-term
financial plans and nine within their longer-term plans.
67. All councils reported to us that elected members had been provided
with a summary of the council’s medium- to long-term financial
sustainability but more needs to be done to regularly and formally report
upon the consideration of financial sustainability. This should be reported
publicly, as a minimum, as part of annual budget-setting papers and
within annual refreshes of financial plans.
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3. Financial position and outlook 33
Financial outlook
68. Within this report we outline the financial challenges Scotland’s
councils are now facing. While indications are that the 2025/26 budget
will result in increased funding, and councils are now free to vary council
tax rates, it is unlikely that increased funding and income will be able
to keep pace with increasing costs. In recent years councils have been
able to increase the reserves they hold, but much of this has been due
to additional Covid-19 funding, use of financial flexibilities and other one-
off actions. The initial benefits of these measures, and the reserves
that councils were able to build, do not negate the need for significant
reform and transformation. 2023/24 saw a reduction in usable reserves
and while this represented only five per cent of these reserves, this was
equivalent to over eight per cent of the usable reserves held as recently
as 2019/20.
69. How councils plan to use their reserves, make savings and
transform their services needs to become more transparent as financial
sustainability issues are to be addressed. The need to consult local
communities and clearly communicate the implications of budget
decisions has never been more important.
70. Our next Local government in Scotland publication, Local
government budgets 2025/26, will examine the steps that Scotland’s
councils take as they set their budgets for 2025/26, setting out the
finalised funding settlement from the Scottish Government, decisions
taken in setting council tax and the steps they intend to take to fund and
transform services.
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Appendix 1
Progress against the recommendations in Local
Government in Scotland Financial Bulletin 2022/23
Councils should: Progress/ status
Prioritise the achievement of recurring
savings and avoid reliance on non-recurring
savings to enhance longer-term financial
sustainability
In progress/Limited progress
The overall extent of progress against this
recommendation is difficult to assess due to a
lack of detail and transparency in reporting on
recurring and non-recurring savings performance
(paragraph 30).
An updated recommendation on savings
performance and transparency is included in this
report.
Ensure that management commentaries are
open and transparent, include a clear link
between budget outturn and the financial
performance in the accounts and report on 
the achievement of planned savings targets
In progress
Our review of 2023/24 management
commentaries found that that most councils
reported outturn against budget with significant
variations explained. However not all councils
provided sufficient information on savings target
achievement.  
An updated recommendation on savings
performance and transparency is included in 
this report.
Provide clear statements about reserves
policy and explicitly set out the purpose
of committed reserves within their
annual accounts. This will enhance the
level of assurance that councils can
provide regarding their ongoing financial
sustainability
Complete / In progress
A review of available councils’ management
commentaries found that key areas of reserves
were clearly identified, with the purpose
explained and the majority identifying a
minimum reserve level. However publication 
of committed reserve information was less 
well evidenced (Case study 1).  
An updated recommendation on greater
transparency of reserves is included in this
report.
Cont.
34Appendix 1Page 280

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Appendix 1 35
Councils should: Progress/ status
Ensure effective and timely consultation
and engagement with communities on the
options that must be considered to achieve
a balanced budget
In progress
Less than half of councils stated, via our data
return, that public consultation was undertaken
when preparing budgets for 2023/24. In our
Local government budgets 2024/25 publication,
24 out of 32 councils stated they undertook
community engagement on financial pressures.
We will follow this up in our budget briefing in
Spring 2025 when we look at councils’ 2025/26
budget setting.
Strengthen their monitoring and reporting
of financial resilience including clearer and
more public-facing use of performance
against financial resilience indicators and
measures. Financial resilience indicators
should be a component of councils’ medium
and longer-term financial plans to provide
assurance that they are balancing short-term
pressures with robust planning for long-
term financial sustainability
In progress
Most councils reported that they assess and
monitor financial sustainability, with financial
indicators used in financial plans, with 17
explicitly using these within their medium- and
long-term financial plans (paragraphs 63 - 67).
An updated recommendation on the use of
financial indicators in monitoring and reporting is
included in this report.
Work with the Scottish Government to 
build momentum and accelerate progress 
in the development of a fiscal framework 
for local government to enhance the clarity
and certainty of budgets for councils in
future years
In progress
We understand that COSLA and the Scottish
Government have been progressing the
development of a fiscal framework
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Local government in Scotland
Financial bulletin
2023/24
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500 Email: info@audit.scot
www.audit.scot
ISBN 978 1 915839 60 2
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Appendix 2
Local Government in Scotland – Financial Bulletin 2023/24
Key Facts
Financial Performance
Local Government in Scotland Argyll and Bute Council
3.3%: the real-terms reduction in councils’
total revenue funding and income in 2023/24
compared to 2022/23
• Total revenue funding and income from government grants, fees and charges,
and Council Tax increased by £19.8m or 6.9% from £287.6m in 2022/23 to
£307.4m in 2023/24, representing a standstill in real terms (per the report,
standstill budget equivalent to 6.9% reduction in real terms)
9 out of 29: the number of councils that
reported overspends against their agreed
revenue budgets
• Net underspend of £4.9m reported (prior to £3.2m earmarkings), mainly in respect
of debt charges (£5.9m underspend), partially offset by overspends across and
RIS and unbudgeted severe weather costs not covered by the Bellwin Scheme
11 out of 30: the number of councils that
achieved all their planned savings
• 100% or £2.6m of non-recurring savings target achieved
• 97% or £6.6m of recurring savings target achieved
• 98% or £9.2m of £9.4m savings target achieved overall (92% of savings across
28 councils achieved)
25 out of 30: the number of councils that
reported lower expenditure than planned
across their capital programmes in 2023/24
• Slippage of £28.7m approved throughout 2023/24
• Overspend of £4.7m on revised budget of £33.2m for the year due to income
profiling, with no variance projected over the £219.8m programme
£19.8 billion: councils’ net debt in 2023/24, a
15.8% increase on 2022/23, as councils
become more reliant on borrowing to
finance their capital programmes
• Net debt (excluding PPP/Finance Leases) increased by £20m or 29% from £69m
as at 31 March 2023 to £89m as at 31 March 2024
• The Capital Financing Requirement increased by £7m or 4% from £180m as at 31
March 2023 to £187m as at 31 March 2024
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Appendix 2 Continued
Financial Position and Outlook
Local Government in Scotland Argyll and Bute Council
5%: the decrease in councils’ total usable
reserves 
• The balance of usable reserves has increased by £28m or 30% from £94m as at
31 March 2023 to £122m as at 31 March 2024, largely in respect of an increase of
£29.4m in the General Fund balance (£35.7m Service Concessions)
84%: the proportion of the General Fund
that is committed 
• As at 31 March 2024, the General Fund balance totalled £115.7m, of which
£107.4m or 93% was earmarked for specific purposes, £6m or 5% general
contingency (2% of net expenditure) and £2.3m or 2% unallocated
12 out of 29: the number of councils that
made unplanned use of their reserves in
2023/24 to manage budget pressures 
• It was not necessary to make an unplanned use of reserves during 2023/24
• Budget pressures were managed within overall available budget resources
15 out of 30: the number of councils that
have long-term financial plans in place,
with councils reporting difficulty planning
for the longer term due to future
uncertainty
• Medium term (3-5 years) Revenue Budget 5 year financial plan set out within
annual budget pack and updated on an ongoing basis throughout the year, as part
of the Budget Outlook report
• Medium term (3-5 years) 3 year Capital Plan set out within annual budget pack and
updated on an ongoing basis throughout the year, as part of the Capital Monitoring
report
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Appendix 3
Local Government in Scotland – Financial Bulletin 2023/24
Compliance with Recommendations
Recommendation Current Status
1. Report on the savings made within their
management commentaries more
comprehensively, including provision of
comparisons to savings targets agreed during
budget-setting, and whether they were recurring
or non-recurring.
Fully compliant with recommendation.
2. Ensure that the impact of capital
underspends, future borrowing projections and
of using financial flexibilities on their
indebtedness are reported clearly alongside the
impact of these on future revenue budgets.
Partially compliant with recommendation. 
• The capital plan is reflected within the borrowing requirements set out within
the approved Treasury Management Strategy, with the impact of slippage in
the capital programme reflected within updated borrowing projections,
reported as part of the regular monitoring of the capital programme and of
treasury management strategy and activity.
• Improvements can be made to deliver longer term capital planning and
greater convergence between capital and revenue budgets. It is anticipated
that this will be addressed as part of the review of capital arrangements to be
undertaken during 2025/26.
3. Ensure reserves policies indicate explicitly
and clearly the impact of financial flexibilities on
reserves held; the nature, level of and intended
timing of the deployment of committed usable
reserves held; and the level of uncommitted and
contingency funding held within General Funds.
Fully compliant with recommendation.
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Recommendation Current Status
4. Prioritise service
transformation,
considering the impact of
current service delivery
models on longer-term
financial sustainability,
including the medium-
term impact on reserve
levels.
Examples of good practice/compliance exist.
• Significant resources earmarked for investment in transformation to deliver service reform and
efficiencies, supporting future long term savings and financial sustainability.  Budget savings include
targets to be delivered from service reviews (Education and RIS), predicated on service efficiency
and redesign.
• Additional resources have also been made available to HSCP, specifically to support transformation
and longer term financial sustainability.
• This will continue to be a key focus in making the best use of our available resources, including the
transfer of budget underspends to reserves and earmarking of reserves for specific purposes.
5. Ensure that financial
sustainability becomes a
central focus of financial
monitoring and reporting,
making greater use of
financial sustainability
indicators within reports
to elected members and
within their regular public
reporting and financial
strategies and plans.
Largely compliant, with good evidence of compliance.  However, opportunities for further improvement
should be considered within future monitoring and reporting in respect of greater use of financial
sustainability indicators, where appropriate.  
• Policy and Resources Committee review and approve financial monitoring reports, as required, on
an ongoing basis throughout the year.  This includes reporting on the revenue and capital budget
monitoring, revenue budget outlook, reserves and balances, financial risks.
• Treasury management strategy and activity, including Prudential and Treasury Indicators, ensuring
that our capital plans are prudent, affordable and sustainable are scrutinised by committee and
referred to full Council for approval.
• Council considers the longer term revenue budget outlook, the reserves and balances position,
financial risk and the capital plan, as part of the annual budget setting process.
• Council requires to approve the audited annual accounts, including key financial indicators within the
management commentary; and also considers the annual audit report, covering financial
sustainability as a key theme.
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ARGYLL AND BUTE COUNCIL          AUDIT AND SCRUTINY COMMITTEE 
CUSTOMER SUPPORT SERVICES          12 JUNE 2025 
LOCAL GOVERNMENT BENCHMARKING FRAMEWORK (LGBF): 2023/24 
1.0 INTRODUCTION 
1.1 This report provides a high-level summary of Argyll and Bute’s performance as
reported in the Local Government Benchmarking Framework data. 
2.0 RECOMMENDATIONS 
It is recommended that the Audit and Scrutiny Committee: 
2.1 Considers the contents of this report and notes the trend of net improvement
across the council’s functions. 
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ARGYLL AND BUTE COUNCIL          AUDIT AND SCRUTINY COMMITTEE 
CUSTOMER SUPPORT SERVICES          12 JUNE 2025 
LOCAL GOVERNMENT BENCHMARKING FRAMEWORK (LGBF): 2023/24 
3.0 DETAIL 
3.1 All Scottish Councils engage with the Local Government Benchmarking
Framework (LGBF), which is managed by the Improvement Service. The
purpose of the LGBF is to enable local authorities to improve their performance
through benchmarking and the sharing of good practice. The Accounts
Commission noted in their recent Best Value report the council’s intention to use
LGBF indicators in our self-assessment activity. This is being picked up as part
of the ongoing Performance Excellence Project. In addition, the use of the LGBF
in the context of our newly agreed corporate plan was discussed at the Chief
Officer’s group on 29th April. Further sessions have been agreed with Heads of
Service to identify relevant Key Performance Indicators (including those relevant
indicators from the LGBF) that will support the Council to monitor progress
against the priorities set out in the Corporate Plan. 
3.2 In an effort to produce more timely data, the Improvement Service made
changes to its publication schedule last year. Six indicators are now being
updated monthly. However, for the purposes of this report, data for the most
recent full years for which data are available are used, with comparisons being
made with previous years. 
3.3 The number of indicators within the LGBF has grown over time from 55 in
2010/11 to the current 108 (see Appendix 1). The breadth of areas covered by
the indicators has also expanded over time and currently covers the following
service areas. 
• Corporate services
• Social Work services
• Culture and Leisure
• Environmental Services
• Housing Services (Argyll and Bute does not submit any data in this area)
• Corporate Assets / Property
• Economic Development
• Financial Sustainability
• Tackling Climate Change 
It is worth noting that these ‘service areas’ have been identified by the
Improvement Service and do not match directly to Services within the council’s
organisational structure.
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3.4 The geography and demography of our area impact on indicators in a variety of
ways. For some indicators, we recognise we cannot improve our performance
relative to other councils (for example the cost of providing pre-school, primary,
and secondary education per pupil, and indicators relating to roads conditions,
where we consistently perform toward the bottom of the fourth quartile) 
3.5 Despite the caveats around our population profile and geography, the proportion
of indicators in the bottom performance quartile has been decreasing over time. 
3.6 Figures 1 and 2 show an overall pattern of relative improvement in recent years. 
3.7 The data needs to be treated with a degree of caution as it does not show
continuous improvement by individual indicators. Performance of a single
indicator may fluctuate from year to year; also, the number of indicators reported
varies from year to year. Rather, the figures show the percentage of indicators
within each performance quartile to give a high-level overview of the council’s
performance relative to other local authorities. This profile of indicators has
shifted to suggest a pattern of relative improvement. Where performance falls
within the quartiles 1 and 2, performance is above the Scottish average. 
3.8 In the last year, 60% of indicators for Argyll and Bute were in quartiles 1 and 2
(25% in quartile one, and 35% in quartile two). 
Figure 1: Performance by quartile (2022/23 and 2023/24). 
Figure 2: Percentage of indicators in each LGBF performance quartile over recent
years.
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3.9 A comparison of the data for the years 2022/23 and 2023/24 shows that, for the
99 indicators for which comparison can be made: 
• 23 indicators moved to a higher quartile, suggesting improved relative
performance. (This compares to 34 moving to a higher quartile reported
last year)
• 65 indicators stayed within the same quartile (this compares to 34
reported last year)
• 11 indicators moved to a lower quartile, suggesting worsening relative
performance (this compares to 29 reported last year)
• 3 indicators moved out of quartile four, compared to 4 moving in. 16
indicators were in quartile four for both the latest and the previous year.
These include the previously mentioned indicators relating to cost of pre-
school, primary and secondary education per pupil and roads conditions 
3.10 For further information about how councils are collectively performing across
Scotland, and how challenges facing local authorities have impacted on
performance, see the National Benchmarking Overview Report 2023-24 
3.11 For further information about performance for individual indicators and
comparisons with our ‘family groups’ of councils, see the Improvement Service’s
Local Government Benchmarking Framework Dashboard. 
0
5
10
15
20
25
30
35
40
45
2016/17 2017/18 2018/19 2019/20 2020/21 2021/22 2022/23 2023/24
Percentage of indicators in each quartile
Year
Indicators in each LGBF performance quartile over time: Argyll
and Bute
Quartile 1 Quartile 2 Quartile 3 Quartile 4
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3.12 As part of the Performance Excellence Project, we are continuing to engage with
managers to understand how they currently use the LGBF and to encourage
more effective use in the future. 
4.0 CONCLUSION 
4.1 This report has outlined our performance position relative to other Scottish local
authorities as revealed by the Local Government Benchmarking Framework
data. Overall, the picture is a positive one, suggesting net overall improvements
in performance. 
4.2 Work to improve the effectiveness and efficiency of how we use the Local
Government Benchmarking Framework data as part of our wider benchmarking
activity will continue as part of the Performance Excellence Project. 
5.0 IMPLICATIONS 
5.1 Policy:   none arising directly from this report. 
5.2 Financial:   none arising directly from this report. 
5.3  Legal:   none arising directly from this report. 
5.4  HR:     none arising directly from this report. 
5.5 Customer Service:  none arising directly from this report. 
5.6 Risk:    none arising directly from this report. 
5.7 Climate Change:  none arising directly from this report. 
5.8  Fairer Scotland Duty:  none arising from this report. An IIA
is not required for performance
reporting. 
5.9 Equalities:   none arising from this report. An IIA
is not required for performance
reporting. 
5.10 Consumer Duty:  none arising from this report. An IIA
is not required for performance
reporting. 
5.11 Island Communities:  none arising from this report. An IIA
is not required for performance
reporting. 
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5.12 Children’s Rights and Wellbeing:  none arising from this report. An IIA
is not required for performance
reporting. 
Kirsty Flanagan
Executive Director with responsibility for Customer Support Services 
Policy Lead: Councillor Mark Irvine 
16 May 2025 
For further information contact: 
Jane Fowler, Head of Customer Support Services, jane.fowler@argyll-bute.gov.uk 
Chris Carr, OD Project Officer, chris.carr@argyll-bute.gov.uk 
APPENDICES 
Appendix 1: List of Local Government Benchmarking Framework indicators  
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Appendix 1: List of Local Government Benchmarking Framework indicators
Indicator
Code Indicator Title Service Area
C&L01 Cost per attendance at Sports facilities Culture & Leisure Services
C&L02 Cost per Library Visit Culture & Leisure Services
C&L03 Cost per Museum Visit Culture & Leisure Services
C&L04 Cost of Parks & Open Spaces per 1,000 Population Culture & Leisure Services
C&L05a Proportion of adults satisfied with libraries Culture & Leisure Services
C&L05b
Proportion of adults satisfied with parks and open
spaces Culture & Leisure Services
C&L05c
Proportion of adults satisfied with museums and
galleries Culture & Leisure Services
C&L05d Proportion of adults satisfied with leisure facilities Culture & Leisure Services
CHN01 Cost per Primary School Pupil Children's Services
CHN02 Cost per Secondary School Pupil Children's Services
CHN03 Cost per Pre-School Education place Children's Services
CHN04 % of Pupils Gaining 5+ Awards at Level 5 Children's Services
CHN05 % of Pupils Gaining 5+ Awards at Level 6 Children's Services
CHN06
% of Pupils from 20% most Deprived Areas Gaining 5+
Awards at Level 5 Children's Services
CHN07
% of Pupils from 20% most Deprived Areas Gaining 5+
Awards at Level 6 Children's Services
CHN08a
Gross Costs of 'Children Looked After' in residential-
based services per child per week Children's Services
CHN08b
Gross Cost of "Children Looked After" in a community
setting per child per Week Children's Services
CHN09
Proportion of children being looked after in the
community Children's Services
CHN10 Proportion of adults satisfied with local schools Children's Services
CHN11 Proportion of pupils entering positive destinations Children's Services
CHN12a Overall Average Total Tariff Children's Services
CHN12b Average Total Tariff SIMD Quintile 1 Children's Services
CHN12c Average Total Tariff SIMD Quintile 2 Children's Services
CHN12d Average Total Tariff SIMD Quintile 3 Children's Services
CHN12e Average Total Tariff SIMD Quintile 4 Children's Services
CHN12f Average Total Tariff SIMD Quintile 5 Children's Services
CHN13a
% of P1, P4 and P7 pupils achieving expected CFE
level in Literacy Children's Services
CHN13b
% of P1, P4 and P7 pupils achieving expected CFE
level in Numeracy Children's Services
CHN14a Literacy Attainment Gap (P1,4,7 Combined) Children's Services
CHN14b Numeracy Attainment Gap (P1,4,7 Combined) Children's Services
CHN17
Proportion of Children meeting developmental
milestones Children's Services
CHN18
Proportion of funded early years provision which is
graded good/better Children's Services
CHN19a School attendance rates (per 100 pupils) Children's Services
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Indicator
Code Indicator Title Service Area
CHN19b School attendance rates (per 100 'looked after pupils') Children's Services
CHN20a School exclusions rates (per 1,000 pupils) Children's Services
CHN20b
School exclusions rates (per 1,000 'looked after
pupils') Children's Services
CHN21 Participation rate for 16-19 year olds (%) Children's Services
CHN22
Proportion of Child Protection re-registrations within
18 months Children's Services
CHN23
Proportion of LAC with more than 1 placement in the
last year Children's Services
CHN24
Proportion of children living in poverty (after housing
costs) Children's Services
CLIM01 CO2 emissions area wide per capita Tackling Climate Change
CLIM02
CO2 emissions area wide: emissions within scope of
LA per capita Tackling Climate Change
CLIM03 CO2 emissions from Transport per 1000 population Tackling Climate Change
CLIM04 CO2 emissions from Electricity per 1000 population Tackling Climate Change
CLIM05 CO2 emissions from Natural Gas per 1000 population Tackling Climate Change
CORP01
Support services as a percentage of Total Gross
expenditure Corporate Services
CORP03b
Proportion of the highest paid 5% of employees who
are women Corporate Services
CORP03c Gender pay gap (%) Corporate Services
CORP04 Cost per dwelling of collecting Council Tax Corporate Services
CORP06a Sickness absence days per teacher Corporate Services
CORP06b Sickness absence days per employee (non-teacher) Corporate Services
CORP07
Percentage of income due from Council Tax received
by the end of the year Corporate Services
CORP08
Percentage of invoices sampled that were paid within
30 days Corporate Services
CORP09 Proportion of SWF Crisis Grant decisions within 1 day Corporate Services
CORP10
Proportion of SWF Community Care Grant decisions
within 15 days Corporate Services
CORP11 Proportion of SWF budget spent Corporate Services
CORP12 Proportion of DHP funding spent Corporate Services
CORP-
ASSET01
% of operational buildings that are suitable for their
current use Corporate Services
CORP-
ASSET02
% of internal floor area of operational buildings in
satisfactory condition Corporate Services
ECON01
Percentage of Unemployed People Assisted into work
from Council Programmes Economic Development
ECON02
Cost of Planning & Building Standards per planning
application Economic Development
ECON03
Average time per business and industry planning
application (weeks) Economic Development
ECON04 Proportion of procurement spent on local enterprises Economic Development
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Indicator
Code Indicator Title Service Area
ECON05
No of business gateway start-ups per 10,000
population Economic Development
ECON06
Investment in Economic Development & Tourism per
1,000 population Economic Development
ECON07 Proportion of people earning less than the living wage Economic Development
ECON08
Proportion of properties receiving Superfast
Broadband Economic Development
ECON09 Town Vacancy Rates Economic Development
ECON10
Immediate available employment land as a % of total
land allocated for employment purposes Economic Development
ECON11 Gross Value Added (GVA) per capita Economic Development
ECON12a Claimant Count as a % of Working Age Population Economic Development
ECON12b Claimant Count as % of 16-24 Population Economic Development
ENV01a Net cost per Waste collection per premises Environmental Services
ENV02a Net cost per Waste disposal per premises Environmental Services
ENV03a Net cost of street cleaning per 1,000 population Environmental Services
ENV03c Street Cleanliness Score Environmental Services
ENV04a Cost of roads per kilometre Environmental Services
ENV04b
Percentage of A class roads considered for
maintenance treatment Environmental Services
ENV04c
Percentage of B class roads considered for
maintenance treatment Environmental Services
ENV04d
Percentage of C class roads considered for
maintenance treatment Environmental Services
ENV04e
Percentage of unclassified roads considered for
maintenance treatment Environmental Services
ENV05
Cost of Trading Standards and environmental health
per 1,000 population Environmental Services
ENV05a
Cost of Trading Standards, Money Advice & Citizens
Advice per 1,000 population Environmental Services
ENV05b Cost of environmental health per 1,000 population Environmental Services
ENV06
Proportion of total household waste arising that is
recycled Environmental Services
ENV07a Proportion of adults satisfied with refuse collection Environmental Services
ENV07b Proportion of adults satisfied with street cleaning Environmental Services
FINSUS01
Total useable reserves as a % of council annual
budgeted revenue Financial Sustainability
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Indicator
Code Indicator Title Service Area
FINSUS02
Uncommitted General Fund Balance as a % of annual
budgeted net revenue Financial Sustainability
FINSUS03
Ratio of Financing Costs to Net Revenue Stream -
General Fund Financial Sustainability
FINSUS04
Ratio of Financing Costs to Net Revenue Stream -
Housing Revenue Account Financial Sustainability
FINSUS05
Actual outturn as a percentage of budgeted
expenditure Financial Sustainability
HSN01b
Gross rent arrears (all tenants) as a percentage of rent
due for the year Housing Services
HSN02
Proportion of rent due in the year that was lost due to
voids Housing Services
HSN03
Proportion of council dwellings meeting Scottish
Housing Quality Standards Housing Services
HSN04b
Average number of days taken to complete non-
emergency repairs Housing Services
HSN05a
Proportion of council dwellings that are energy
efficient Housing Services
SW01 Home care costs per hour for people aged 65 or over Adult Social Care Services
SW02
SDS (DP + MPB) spend on adults as a % of total adult
social work spend  Adult Social Care Services
SW03a
% of people 65+ with long-term care needs who are
receiving personal care at home Adult Social Care Services
SW04b
% of adults supported at home who agree that their
services and support had an impact in improving or
maintaining their quality of life Adult Social Care Services
SW04c
% of adults supported at home who agree that they are
supported to live as independently as possible Adult Social Care Services
SW04d
% of adults supported at home who agree that they
had a say in how their help, care or support was
provided Adult Social Care Services
SW04e
% of carers who feel supported to continue in their
caring role Adult Social Care Services
SW05
Residential costs per week per resident for people
aged 65 or over Adult Social Care Services
SW06
Rate of readmission to hospital within 28 days per
1,000 discharges Adult Social Care Services
SW07 Proportion of adult care services graded good or better Adult Social Care Services
SW08
Number of days people spend in hospital when they
are ready to be discharged, per 1,000 population (75+) Adult Social Care Services  
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ARGYLL & BUTE COUNCIL 
LEGAL AND REGULATORY
SUPPORT
FINANCIAL SERVICES 
AUDIT AND SCRUTINY COMMITTEE 
12 June 2025      
STATEMENT OF GOVERNANCE AND INTERNAL CONTROL    
1. INTRODUCTION  
1.1  This report advises that the statement of governance and internal
control for 2023/24 has been reviewed and updated which allows the
Council to include a statement of governance and internal control in the
Annual Accounts for 2024/25.
2. RECOMMENDATIONS  
2.1 
2.2 
2.3
The Committee note the updates in the Action Plan for 2024/25. 
The Committee consider and approve the content of the areas for
further development for 2025/26. 
The Committee consider and approve the draft statement of
governance and internal control for 2024/25.  
3. DETAIL  
3.1 CIPFA and SOLACE published a revised Framework for ‘Delivering
Good Governance in Local Government’ in 2016. The Framework was
defines seven core principles that should underpin the governance of
local authorities and provides a structure to assist authorities with
assessing their own approach to governance. 
3.2 
3.3
The Council is required to prepare a statement of governance and
internal control confirming the Council’s position in regard to the seven
core principles for 2024/25. The draft document which is attached at
Appendix 1 provides details of the position for 2024/25 and includes an
update on the ‘areas for further development’ identified in the 2025/26
document. It has been approved by ELT. 
Once approved the statement of governance and internal control is
included in the Council’s Annual Accounts for 2024/25 and identifies
areas within the Council where work to improve its governance
arrangements will be being undertaken in 2025/26.  
3.4 The seven principles contained in the local code are: 
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1. Behaving with integrity, demonstrating strong commitment to
ethical values, and respecting the rule of law. 
2. Ensuring openness and comprehensive stakeholder
engagement. 
3. Defining outcomes in terms of sustainable economic, social and
environmental benefits. 
4. Determining the interventions necessary to optimise the
achievement of the intended outcomes. 
5. Developing the entity’s capacity, including the capability of its
leadership and the individuals within it. 
6. Managing risks and performance through robust internal control
and strong public financial management 
7. Implementing good practices in transparency, reporting, and
audit to deliver effective accountability  
3.5 The review of the effectiveness of the system of governance and
internal control is informed by the: 
• work of council officers 
• work of External and Internal Audit
• Statements of Governance or Internal Control provided by
external bodies
• external review and inspection reports
• recommendations from the Audit and Scrutiny Committee  
4. CONCLUSION  
4.1 This review gives assurance about the robustness of the Council’s
governance arrangements.  
5. IMPLICATIONS  
5.1 Policy: none
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: none
5.10 Consumer Duty: none
5.11 Island Communities: none
5.12 Children’s Rights and Wellbeing: none
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Douglas Hendry
Executive Director with responsibility for Legal and Regulatory Support 
Kirsty Flanagan
Executive Director with responsibility for Internal Audit 
For further information please contact:
Iain Jackson, Governance, Risk and Safety Manager - 01546 604188
Paul MacAskill, Chief Internal Auditor - 01546 604108 
Appendices
Appendix 1 - Draft Statement of Governance and Internal Control 24/25   
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1. BACKGROUND AND SCOPE OF RESPONSIBILITY 
Argyll and Bute Council’s (the Council) governance framework includes the systems,
processes and culture by which the Council is controlled, engages with communities and
monitors the achievement of strategic objectives. The Council conducts its business in
accordance with the law and proper standards. The Council has a duty to make
arrangements to secure continuous improvement in the way in which its functions are
exercised, having regard to the economic, efficient and effective use of public money. 
The system of internal control is a key part of the framework and is designed to manage
risk to an acceptable level.   
In discharging these responsibilities, the Council has put in place proper arrangements
for the governance of its affairs and the stewardship of the resources at its disposal. The
Council has approved and adopted a Local Code of Corporate Governance (the Code)
which is consistent with the principles and requirements of the CIPFA/SOLACE revised
Framework for ‘Delivering Good Governance in Local Government. This Statement
explains how the Council has complied with the Code and meets the requirements of
current good practice. 
2. THE GOVERNANCE FRAMEWORK
The Code details how the Council will demonstrate compliance with the fundamental
principles of corporate governance for public sector bodies.  The seven key principles of
our governance arrangements in 2023/24 are described in the Code, along with our
supporting principles and key aspects of our arrangements to ensure compliance. 
1. Behaving with integrity, demonstrating strong commitment to ethical values,
and respecting the rule of law.
We have four values, which underpin all that we do and provide a sound basis to
achieve transformation to ensure we meet the challenges of the future and deliver
quality services. These values are that we have a workforce which is: 
Caring  Committed  Collaborative  Creative  
The Council has developed a change programme ‘Connect for Success’ with the seven
principles – One Council One Place Approach, Purpose and Mission Focus, Employee
Empowerment, Data and Evidence Driven Decision Making, Learning Council, Agile and
Maximise Opportunities that Technology Offers - Connect for Success 
We have developed and communicated an Ethical Framework within the Council's
Constitution, which defines standards of behaviour for Members and staff. Protocols for
Member/Officer relations are also detailed within the Constitution.   
The Councillors’ Code of Conduct is set out at a national level, applying to all members
in Scottish local authorities and is incorporated into the Council’s Constitution as part of
the ethical framework which also includes a protocol for the Monitoring Officer. Each
Members interests can be found in their respective profiles at Members Interests is
publically available for inspection. 
In addition, the Constitution has a section on conduct at meetings and meeting agendas
require declarations of interest to be made where appropriate. Standing orders for
meetings are included within the Council’s constitution and training and support is
provided to members on their role in Council committees. 
Anti-fraud and whistleblowing policies are in place and the Council has adopted the
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Scottish Public Services Ombudsman’s (SPSO’s) Model Complaints Handling
Procedure.
The Council complies with CIPFA’s Statement on the Role of the Chief Financial Officer
in Local Government. 
In addition, Professional advice on the discharge of statutory social work duties is
provided to the Council by the Chief Social Work (CSWO). 
A structure of governance and framework across our day to day activities and which
supports accountability, control, risk management and appropriate overview of the
Council are outlined in the diagram below: 
Constitution, Governance, Risk Management and Accountability
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2. Ensuring openness and comprehensive stakeholder engagement.
We have established clear channels of communication with the community and other
stakeholders through our Communication Strategy.  Key mechanisms include:
Consultation Diary 
The Council has developed a consultation section on its website which hosts all consultations
run by the Council and includes a section which publicises the results and/or outcome of the
Decision Making /
Procedural
Council and
Committee Structure
Council and
Committee Terms of
Reference
Council and
Committee Standing
Orders
Scheme of Delegated
Functions
Standing Orders
Relating to Contracts
Councillor's Code of
Conduct
Corporate Governance
Executive Leadership
Team and Senior
Management Team
Risk Management
Integrity
HR and Individual
Capability
Strategic Planning
Performance
Management
Framework
Community Planning
and Empowerment
Stakeholder
Engagement
Financial Governance
Internal Control
ALEO Governance
Scheme of Delegation
ALEO Governance
Framework
Risk and Governance
Reporting
Financial and
Operational
Performance
ALEO Risk Register
Asset Governance
Corporate Asset
Management Strategy
Corporate Asset
Managment Plan and
Capital Plan
Records Management
Information
Management and
Security
Local Development
Plan
ICT and Digital
Strategy
Major
Programmes/Projects
Capital Investment
Programme
Conservation Area
Regeneration Scheme
(CARS) Projects
Campbeltown,
Helensburgh, Oban,
Rothesay & Dunoon
(CHORD) Projects
Marine Asset
Management Plan
Rural Growth Deal
Annual Status and
Options Report
External and Internal Audit and other regulatory inspections
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consultation and the resultant decisions that have been taken, showing how they were
informed by the consultation process. This is part of our commitment to You Said, We Did
information sharing for the public. Consultations provide communities with an opportunity to
get involved with wide ranging aspects of the council’s work and life in Argyll and Bute. 
These include for example, play park funding, active travel routes, primary school
consultations, and the council’s customer service strategy. 
Keep in the Loop Service  
Over 14,000 customers currently subscribe to receive notifications across 22 different
subscription services. In 2024/25 386,303 email notifications, newsletters and alerts were
issued via the Keep in the Loop Service to its subscribers. 
'Myaccount' 
This is a secure sign-in service for accessing online public services in Scotland. It provides
the ability to set up an online account and use it to access a growing range of online public
services, Scotland-wide, including Argyll and Bute Council services. Currently 19,231
customers have linked their national Myaccount to the Argyll and Bute Council instance and
use it to access and personalise their interaction with the Council on a range of services e.g.
it gives authenticated access to our Council Tax and Benefits Portal.
Public Performance Reporting
The Council’s website makes all relevant performance information available to the public. This
includes information on performance scorecards, budgets and other service related
information. This promotes open accountability to the public for its performance against
agreed policies and standards. As part of phase two of the Performance Excellence Project
a review of the council's approach to public performance reporting is being undertaken. It also
includes all copies of the Council’s financial accounts and papers for all Council and
Committee Meetings, supplemented by webcasts of meetings.  
Accessibility
In 2024/5 77% of 528,606 customer interactions through the council’s Customer Engagement
Team were made using digital self-service. This very high proportion is because of the scope
and quality of the digital services provided. In order to ensure maximum accessibility for
everyone and meet our equalities responsibilities, the Council’s website is independently
assessed against the international WCAG2.2 standard and in April 2025 it scored 99% and
was the second highest ranked website in Scotland. The website had 4,501,450 page views
in 2,868,330 separate sessions in 2024/25, an increase of 5.4% on the previous year. A new
online service for all council employees called MyCouncilWorks was completed and it had
512,000 page views. In addition our 24/7 voice automated telephone service had 41,309 calls
and collected £2.2m in automated phone payments. The council also fully reviewed and
updated it Customer Service Strategy with a focus on inclusivity and accessibility.
Community Engagement   
To support strengthening communities, community empowerment and engagement, the
Council has in place: 
• An officer Community Engagement Strategy Group which has supported the
development and implementation of the Council’s Engagement Framework; advising
on best practice in engagement tools and techniques, and supporting skills
development and capacity within the Council to effectively engage with communities
which has included training for officers, elected members and communities. On this
group sit those officers with expertise in engagement from a range of services across
the Council, including those from Corporate Communications and the Communities &
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Partnership Team. The Council’s Communications Team has developed an
engagement app for services to use, and the Council’s Communities & Partnership
Team has resources and expertise to support hard-to-reach groups, community
organisations and remote communities, to have a voice in decision making. 
• A Community Development service, with a focus on improving active citizenship and
capacity building by delivering best practice in community development through a
responsive and effectively targeted programme of Community Development support,
internally to the Council and externally within communities across Argyll and Bute.  
• A range of training and resources to help build the knowledge, skills and confidence
of community organisations and development trusts, including publishing webinars
on key topics of relevance to community organisations.  
• Funding support to help empower community organisations to take forward priority
projects and activities in their area: Monthly funding alert | Argyll and Bute Council
(argyll-bute.gov.uk), hosting GrantNet for self-service funding searches, supporting
funding applications through the Community Funding Toolkit, and undertaking
tailored funding searches on request.  
• The annual delivery of a Supporting Communities Fund grant award scheme which
community groups can apply for (up to £1500 each), including offering advice and
support on applications and other funding routes. 
• Resourcing community council liaison activities, including training and support
activity, helping to build the capacity of community councils.  Delivering capacity
building to communities to increase the use of the Gaelic language and to make it
more accessible and visible.   
• Resourcing and supporting delivery of the statutory requirements under Part 3
(Participation requests) and Part 5 (Asset transfer requests) of the Community
Empowerment (Scotland) Act 2015. Council departments are also provided with
support in relation to Part 9 of the Act (Allotments). 
The Council also has a statutory lead role to ensure Community Learning and Development
provision in Argyll and Bute is set out in an Argyll and Bute Community Learning and
Development Strategic Plan, and this is delivered through collaboration with its Arms-length
External Organisation (ALEO) partner, Live Argyll, and the Argyll and Bute Third Sector
Interface (TSI). 
The Council continues to promote the Community-led action plan toolkit (developed in
partnership with Scottish Community Development Centre) to help support communities
interested in developing a local Community-led Action Plan. The Council also provides
support for communities interested in development a Place Plan: Local Place Plans | Argyll
and Bute Council (argyll-bute.gov.uk). 
The Council directly resources the management of the Community Planning Partnership
(CPP) to bring partners together, including the community, to deliver the statutory
requirements under Part 2 (Community Planning) of the Community Empowerment (Scotland)
Act 2015, including a Local Outcomes Improvement Plan.  Support is also provided to the four
Area Community Planning Groups   
The Community Planning Partnership seeks to ensure that young people are engaged in
community planning and has implemented the following: 
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• The 3 local Members of the Scottish Youth Parliament (MSYPs) are invited to
attend the Community Planning Partnership Management Committee meetings on
a rotational basis.   
• The Area Community Planning Groups (ACPGs) invite members of local youth
forums to attend meetings when they are held in their local areas, with information
passed on to young people by youth workers who are kept updated on any
developments.  
• The revised Scheme of Establishment for Community Councils outlines the
requirement to encourage young people to attend and participate in community
council meetings and the age to become a community councillor was lowered to
be 16, to encourage more young people to become involved. 
The Council also provides opportunities for community organisations to engage with
Community Planning and Community Development through the following resources:
Community Development Bulletin, Community Planning Bulletin, Gaelic Newsletter,
Community Planning Podcast. 
Council/Committee Meetings
Meetings are always held in public, unless one of the statutory exemptions in the Local
Government (Scotland) Act 1973, schedule 7A applies to the content of the report. Agendas
for and minutes of meetings are detailed on the Council’s website. When schedule 7A applies
papers are adjusted to ensure that the maximum amount of content is in the public domain.
The Council’s Constitution defines the roles and responsibilities of the administration,
committees, scrutiny and officer functions, with clear delegation arrangements and protocols
for effective communication. 
The Standards Commission Advice Note for Councillors on Distinguishing between their
Strategic Role and any Operational Work has previously been included in an Elected Member
Seminar and is hosted on the Members Resource page on the Hub for ease of reference.
3. Defining outcomes in terms of sustainable economic, social, and environmental
benefits.
Our Corporate plan sets out our, and our community planning partner’s, vision for Argyll and
Bute’s economic success to be built on a growing population. It also defines our mission “To
make Argyll and Bute a place people choose to live, learn, work and do business” and
establishes our outcomes, priorities and approach to delivering on our shared ambition with
our community partners.
We have a Performance Improvement Framework (PIF) that ensures performance is integral
to the work of the Council.  The PIF is focused not just on measuring what we do but on
measuring the difference we make in terms of our outcomes.   
Asset management planning and capital investment is structured to consider and balance the
combined economic, social and environmental impact of policies and plans when taking
decisions about service provision. The Council has put arrangements in place to comply with
key elements of the Community Empowerment Act.
In determining how services and other courses of action should be planned and delivered the
Council is increasingly engaging with internal and external stakeholders. Community benefit
is an important consideration in the procurement of goods and services.
The Council has acknowledged the effects of the ‘Cost of Living’ within Argyll and Bute and
during 2024/2025 client gain achieved by the Flexible food and Fuel fund project reached
£5.2 million. This project, supporting the most vulnerable low income households and those
using foodbanks in our area to access short-term grants to cover the cost of food and fuel in
the short term. In the longer term support through the provision benefit maximisation, money
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advice and energy advice services is provided by third sector partner agencies. 
In addition, this year the Council has issued 1,300 Scotland Loves Local Gift Cards to low
income households in the year ensuring the £110,000 loaded onto the gift cards is spent in
Island based local businesses in Argyll and Bute. The Council and the Third Sector Interface
is supporting the Poverty Alliance on a project entitled “Taking Action on Rural Poverty”
which is looking at new ways of addressing rural poverty in Argyll and Bute by reducing the
rural poverty premium.   
The Council has also provided a one-stop-shop webpage where individuals and families can
access energy advice, money advice and links to the services the Council provides in this
area and those provided by third sector partner organisations. 
Throughout 2024/25, Argyll & Bute Council actively drove forward its commitment to
reducing carbon emissions, guided by our Decarbonisation Plan. We continued to deliver a
range of projects aimed at lowering our environmental impact. This included tangible
progress in enhancing energy efficiency within our buildings, advancing renewable
technology installations such as the solar PV system at Cardross Primary School, and
progressing the transition towards a lower-emission fleet. Efforts to minimise waste sent to
landfill also remained a key operational focus. 
A significant development in 2024/25 was commencing the adoption of the Scottish
Government's ClimateOS platform. This strategic tool is set to enhance our climate action
planning capabilities, a positive step being embraced by local authorities across Scotland.
These dedicated actions and project deliveries during the year reinforce our steadfast
commitment to achieving Scotland's net zero targets and ensuring a greener Argyll & Bute. 
4. Determining the interventions necessary to optimise the achievement of the
intended outcomes.
Decision makers receive detailed information indicating how intended outcomes would be
achieved together with the implications associated with the proposals covering financial,
risks and mitigations, integrated impact assessment, acting sustainably, carbon
management, island proofing, and changes to schemes, by way of the compulsory sections
of the Committee report.
The Council’s Executive Leadership Team (ELT) meet regularly with the administration to
discuss their key priorities and requirements for decision making in addition there is regular
survey and feedback on their needs and a regular review of governance arrangements to
ensure that decision making is fully supported.
In determining how services and other courses of action should be planned and delivered
the Council is increasingly engaging with internal and external stakeholders. Community
benefit is an important consideration in the procurement of goods and services.
The Council fosters effective relationships, collaborative working and contractual
arrangements with other public, private, and voluntary organisations in delivering services
that meet the needs of the local community as stated in the Council’s Corporate Plan 
5. Developing the entity’s capacity, including the capability of its leadership and the
individuals within it.
Elected Member Development
The Council has signed up to the Improvement Service’s Continuing Professional
Development Framework for Elected Members. All Elected Members are provided with
opportunities to progress personal development plans so that individual training needs and
aspirations are identified and support provided as appropriate. This is complemented by a
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comprehensive seminar and workshop programme which addresses a wide range of topics
and strategic issues. Additional training was undertaken by Elected Members in relation to
the technology, knowledge and skills necessary to support the transition to a virtual
environment including webcasting of strategic Committee meetings and the operation of
meetings on a hybrid basis, enabling a mixed attendance of members being physically or
virtually present.             
Officer Development
The Council has frameworks in place to support officer development. These underpinned by
our corporate behaviours and delivered through the corporate training programme and
leadership development programmes.  In 2024/25 these frameworks are being redesigned to
better reflect the principles of Connect for Success. During 2024/25 Executive Coaching for
Chief Officers was introduced. While the corporate behaviours and Argyll and Bute Manager
programme are being redesigned all content from the previous courses are available on
LEON (the Councils eLearning platform). A new coaching conversations training programme
has also been added to the corporate training programme to support managers with
empowering team members and having coaching conversations.
6. Managing risks and performance through robust internal control and strong
public financial management. 
Internal Financial Control
Our standing orders, financial instructions, scheme of delegation and supporting procedure
notes/manuals clearly define how decisions are taken and the processes and controls in place
to manage risks. These are reviewed and updated on an annual basis. We ensure compliance
with relevant laws and regulations, internal policies and procedures, and that expenditure is
lawful. The Council’s Monitoring Officer advises on compliance with our policy framework,
ensuring that decision making is lawful and fair. Furthermore, the Council has a designated
Data Protection Officer and all services have Information Asset Registers along with
appropriate guidance on how data should be managed.
Our financial management arrangements conform to the CIPFA Statement on the Role of the
Chief Financial Officer and we ensure that our independent Audit and Scrutiny Committee
undertakes the core functions identified in CIPFA’s Audit Committees – Practical Guidance
for Local Authorities. 
The Council has a proactive, holistic approach to tackling fraud, theft, corruption and crime,
as an integral part of protecting public finances, safeguarding assets, and delivering services
effectively. It is based upon the national counter fraud standard CIPFA’s Code of Practice on
‘Managing the Risk of Fraud and Corruption’.
The Council has a system of internal financial control designed to manage risk to a reasonable
level. It is based on a framework of regular management information, financial regulations,
administrative procedures (including segregation of duties), management supervision, and a
system of delegation and accountability. 
Development and maintenance of the system is undertaken by officers within the Council and
the named bodies mentioned below. 
Internal Financial Controls and Prevention  Are these in Place?
Comprehensive budget systems 
Financial and budget monitoring systems 
Financial and Performance reporting systems 
Clearly defined Capital Expenditure guidelines 
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Project Management processes and disciplines 
An effective Internal Audit Section 
An effective Counter Fraud Team 
Internal controls cannot eliminate risk of failure to achieve policies, aims and objectives and
can therefore only provide reasonable and not absolute assurance of effectiveness. 
This annual review also covers the other bodies whose activities are incorporated into our
Group Accounts and reliance is placed on the formal audit opinion contained in the financial
statements of each individual body.
• Dunbartonshire and Argyll and Bute Valuation Board
• Live Argyll
• Argyll and Bute Integration Joint Board
The Council’s risk management processes are well developed. In particular the:
• Strategic Risk Register is updated twice a year and approved by the SMT
• Chief Executive presents the Strategic Risk Register to the Audit and Scrutiny
Committee on an annual basis
• Operational Risk Registers are updated quarterly by departmental management
teams.
• Internal Audit will perform an audit of compliance with risk management arrangements
every three years.
• The CIA performs an annual strategic risk assurance mapping exercise. 
7. Implementing good practices in transparency, reporting, and audit to deliver
effective accountability 
Internal Audit 
The Council and its Group bodies have internal audit functions, which operate to Public Sector
Internal Audit Standards. The work of internal audit is informed by an analysis of the risk to
which the Council and its Group bodies are exposed, with annual internal audit plans prepared
based on that analysis. The Council's Audit and Scrutiny Committee endorses the preparation
methodology and annual internal audit plan and monitors the performance of Internal Audit in
completing the plan. In addition, the Council has developed a hybrid meeting facility enabling
physical and virtual attendance at meetings with a public broadcast function so that members
of the public can see and hear meetings of the Council’s strategic committees’ live increasing
openness and transparency.
The Chief Internal Auditor (CIA) provides the Audit and Scrutiny Committee with an annual
report on internal audit activity in the Council and an opinion of the assurance can be taken
regarding the systems of governance and internal control and whether they are operating
effectively. This is an independent and objective opinion of the CIA based on work carried out
in conformance with the Public Sector Internal Audit Standards to fulfil statutory Internal Audit
provision.
Internal audit provides members and management of the Council with independent assurance
on risk management, internal control and corporate governance processes. External audit
has, and continues to, use the work of internal audit. 
The Annual Accounts and Report sets out the financial position in accordance with relevant
accounting regulations. 
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Review of the Adequacy of Effectiveness of the Council’s Governance
Framework 
The Council has appropriate management and reporting arrangements to enable it to satisfy
itself that its approach to corporate governance is adequate and effective in practice. The
legislative framework of local government defines a number of posts which are primary to the
Council’s governance arrangements.  These include the Chief Executive, Pippa Milne fulfilling
the role of Head of Paid Service. As Monitoring Officer, the Executive Director Douglas
Hendry: 
• oversees the implementation of the Code and monitoring its operation
• reports annually to the Council on compliance with the Code and any changes
required to maintain it and ensure its effectiveness.
Specific responsibilities are assigned to the Executive Director Kirsty Flanagan as the
Council’s Chief Financial Officer (S95 Officer), to ensure that public funds are properly
accounted for.  In recognition of the significant role that the Chief Financial Officer has in
relation to financial performance and the financial control environment, CIPFA has set out key
principles that define the core activities and behaviours that belong to the role.  These include,
being a key member of the Leadership Team, being actively involved in and influencing
decision making, and leading the delivery of good financial management across the whole
organisation. The Council have appointed a Data Protection Officer in line with the
requirements of the UK-General Data Protection Regulations and the Data Protection Act
2018. 
FINANCIAL SUSTAINABILITY 
It is anticipated that the Scottish public sector will continue to face a very challenging short
and medium term financial outlook with uncertainty over the level of Scottish Government
funding. The current one year only financial settlements provide very little medium term
budget certainty.  Furthermore, the continued ring-fencing of monies and additional policy
commitments, which are not always fully funded, limit financial flexibility and create
additional budget pressures. 
In addition to uncertainty around future funding levels, there are also prevailing levels of
economic uncertainty, with continued volatility in financial markets.  Against a backdrop of
historic real terms standstill/reducing Local Government Finance Settlements and the global
economic climate, the management of budget pressures in respect of pay and other
inflationary cost increases, together with increasing demands for key services, will continue
to be challenging. 
The Council undertakes financial planning to provide a longer term view of its financial
position over future years.  Financial estimates are provided within its medium term financial
outlook over a five year period, to provide a longer term view of the Council’s estimated
budget gap. The financial outlook is underpinned by planning assumptions in respect of
available funding, cost and demand pressures, pay and non-pay inflation, together with
potential measures to balance the budget. These assumptions are reviewed and updated on
an ongoing basis, with the outlook prepared to reflect best case, worst case and mid-range
scenarios. 
The Council has a strong track record in effective financial management, as recognised by
previous years’ annual external audit reports, and is well placed to manage future financial
challenges. The annual audit report for the year ended 31 March 2024 also recognises that
the Council has effective financial planning arrangements in place to support financial
sustainability.  In addition to its revenue budget outlook, the Council provides regular update
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reports on capital plans, reserves and balances, financial risks and treasury management
activity, in accordance with its approved strategies.   
The Council is taking a longer term approach to budget planning and recognises that
opportunities for budget savings will require to be delivered, whilst maintaining services, in
line with its key strategic objectives and within available budget resources.  Service
transformation, underpinned by robust financial planning, will continue to be a key focus, in
order to safeguard the financial sustainability of the council. 
HEALTH AND SOCIAL CARE INTEGRATION
The Argyll and Bute IJB has been established as a separate legal entity from Argyll and Bute
Council and NHS Highland, with its own board of governance.  The IJB comprises eight voting
members with four Elected Members nominated by Argyll and Bute Council and four Board
members from NHS Highland.  In addition, there are a number of non-voting appointees
representing other sectors and stakeholder groups, such as the Third Sector, Independent
Sector, Patients and Service Users, Carers and Staff.  
The arrangements for the operation, remit and governance of the IJB are set out in the Argyll
and Bute Integration Scheme which has been prepared and approved by Argyll and Bute
Council and NHS Highland. It has also been approved by the Scottish Government. The IJB,
via a process of delegation from the Health Board and Local Authority as outlined in the
Scheme of Integration has responsibility for the planning, resourcing and operational delivery
of all health and social care services within Argyll and Bute.
The Council places reliance on the IJB’s framework of internal controls and similarly the IJB
places reliance on the procedures, policies and operational systems of the Council and the
Health Board. The IJB operates within an established procedural framework. The roles and
responsibilities of board members and officers are defined within Standing Orders, the
Integration Scheme, Financial Regulations and Standing Financial Instructions.
The IJB has proportionate internal audit arrangements in place to provide independent
assurance on risk management, corporate governance and the system of internal control.   A
risk based internal audit plan developed and commissioned for 2024/25 and the IJB’s internal
auditor has issued a formal annual report providing their independent opinion on the
effectiveness of the IJB’s risk management, internal control and governance processes. The
overall conclusion of the Internal Auditor is to provide a reasonable level of assurance on the
adequacy of internal controls and governance arrangements within the IJB. 
During 2024-25 the IJB has progressed A number of areas for development in respect of
governance have been progressed and this has resulted in a marked improvement in the
way in which the IJB operates and is governed. The action plan is now fully implemented,
highlights included the development of the Workforce plan, the roll out of the Integrated
Performance Management System, the development of the engagement strategy and
training and development for IJB members. The IPMF is now subject to review. 
The operating environment going forward is very challenging as funding allocations have not
kept pace with cost and demand increases. The increase in the employer national insurance
rate and threshold is having a material impact on commissioned service providers is
increasing cost and service risk further. The impact of an increasing older population with on-
going recruitment constraints and workforce shortages is adding to the challenge. The HSCP
is working to address its workforce gaps throughout the area and across many professions in
a variety of ways. For example, it is seeking to address key worker accommodation shortages
in partnership with the Council, Shelter and the Social Housing Sector and is constantly trying
new approaches to attract workers from outside Argyll & Bute. The Health and Care Staffing
act is still in the early stages of its implementation and this will continue to impact upon staffing
models through 2025/26 along with reduction in the working week (NHS) and other
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implications from pay awards. The financial constraints are so severe that the HSCP will be
implementing its financial recovery plan and making reductions to its service offer. These risks
and challenges are particularly acute in many of our rural and island communities which are
experiencing increasing costs along with very small scale, lifeline services which are become
ever more difficult to sustain or operate in a financially efficient way. The HSCP will seek to
balance the financial pressures it, and its partners, are currently experiencing with the care
needs of the communities it serves. 
The IJB approved a budget for 2025/26 which indicates that financial recovery actions are
required to identify further savings in year and that additional funding from NHS Highland may
be required. The budget is also dependent upon the allocation of non-recurring pension fund
savings and use of remaining reserves, this approach means that the scale of the challenge
in 2026/27 is expected to be even more severe. The management of longer-term financial
sustainability is a priority and service change and transformation plans aimed at addressing
this require to be developed, consulted upon and implemented during the course of 2025/26.
The delivery of the short term savings and recovery plan is a priority for the HSCP particularly
as it seeks to manage down spend on expensive agency and locum staff whilst maintaining
the safety of services. 
UPDATE ON AREAS FOR DEVELOPMENT IDENTIFIED IN PREVIOUS ANNUAL
GOVERNANCE STATEMENTS
The 2023/24 Annual Governance Statement identified a number of areas for further
development. A summary update for each area is provided in the table below.
Area 2024/25 Update
Preparation for the implementation of
the Visitor Levy in 2026 - Work with
the Digital Office, improvement
Service, City of Edinburgh and
Highland Council on the development
of a new digital platform for the billing
and collection of the new levy. (Head
of Financial Services/Head of
Development and Economic Growth
– March 2025) 
The Council has completed its public consultation on the
visitor levy and is now analysing the 3300 responses
received prior to reporting back to the council for a
potential decision in August 2025 on whether to proceed or
not. Work also continues on creating a digital platform for
the billing and collection of the levy taking into account
issues raised through each councils’ respective
consultations with the public. A decision on whether or not
to proceed using this platform will be taken following
decision at Committee in August on the Visitor Levy.
Preparation for new processes being
implemented including the practice
around Initial Referral Discussions
relating to child protection, there will
be a need to audit and develop
practice further and the development
of an action plan based on the
findings will help improvement and
the need to consider the staffing
structures which support this vital
area of work. (Head of Children,
Families and Justice – March 2025)  
New IRD guidance has been developed and was
launched on 28th April 2025. Following this event on going
monitoring and auditing will be carried out to judge the
effectiveness of this new guidance.
.
Housing Emergency declared by the
Council in June 2023 - Utilise
outputs from the Housing Summit
held, to develop a multi-stakeholder
Action Plan, and synthesise the
relative elements of this into a
revised Local Housing Strategy
Action Programme. (Head of
A multi stakeholder action plan has been prepared and
approved by the council. This action planned has informed
a new housing strategy that has also been approved by the
council and forwarded to the Scottish Government. A new
housing delivery group has also been established to focus
on delivering the actions identified in the action plan.
Regular updates on progress are presented to the
Councils EDI Committee.
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Development and Economic Growth
– March 2025) 
The revaluation of properties for
building insurances purposes -
Estates will undertake a revaluation
programme for the general portfolio,
together with a programme of
recorded inspections of vacant
properties. (Head of Commercial
services March 2025
During 2024/25 Estates completed the revaluation of
general properties within MAKI and H&L areas and it is
intended to complete OLI and B&C areas in 2025/26.
Reports were also submitted to DMT in relation to vacant
property inspections and it was agreed on 24/3/25 that a
working group of officers would be set up to progress this
matter in conjunction with the council’s insurers
Publication of the Annual
Procurement Report for the Council
– This will promote our obligations
set out in the Procurement
Regulations. (Head of Legal and
Regulatory Support – March 2025) 
Complete – https://www.argyll-
bute.gov.uk/sites/default/files/2024-
08/Annual%20Procurement%20Report%202023-24.pdf 
The Licensing Board will undertake a
review of its Licensing Policy
statement as required in terms of the
Licensing (Scotland) Act 2005.
(Head of Legal and Regulatory
Support – March 2025) 
A review of the Licensing Policy is ongoing at the moment
with the intention of submitting a report to the meeting of
the Licensing Board in September on the outcome of the
review. Continued to March 26 – see below
The use of Cloud Storage –
Following results of the Internal
Audit, put in place actions to ensure
optimum, appropriate and secure
use of cloud storage is applied
across all applications. (Head of
Customer Support Services – March
2025)
The Audit of Cloud Computing Services was completed in
May 2024 with a substantial level of assurance. All actions
have been completed
Further enhance school engagement
with national programmes and
community partnership approaches
supporting young people to build
their confidence, increase mental
health awareness and promote
diversity. (Head of Education,
Performance & Improvement –
March 2025)
Education have engaged in a number of programmes and
approaches, e.g., Time for Inclusive Education (TIE), the
LGBT Youth Project Charter, the CORRA Foundation to
further develop an inclusive curriculum that celebrates
diversity, the Rights Respecting Schools programme which
raises the profile of rights across our schools, the Mentors
in Violence Prevention Programme (MVP) which is a peer
mentoring programme that uses and active bystander
approach to addressing gender based violence and the
ADP School Support Service to provide evidence based,
up to date Alcohol and Drugs education to pupils and
parents/carers. 
ISSUES FOR FURTHER DEVELOPMENT 
The review of governance and internal control has identified the following areas for
consideration during 2025/26, particularly in the context of continuous improvement within the
Council:
• An Internal Audit in Non-Domestic Rates (NDR) has identified that the current
appeal process needs to be improved to enhance independent decision making and
checking. A new independent panel of managers, separate from Finance, will be
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established to adjudicate on NDR appeals, improving impartiality and robustness of
decisions. (Head of Financial Services – March 2026)
• The Internal audit of IR35-Off Payroll Working compliance reported assurance as
limited. A comprehensive Policy and Procedures drafted for approval.  To be
implemented 2025-26 in order to minimise any risk to the council. (Head of Financial
Services – March 2026)
• Further embedding good governance and information management in the MS365
project and the roll out of Teams - Once the business case has been approved for
the next stage of the MS365 project and the roll out of teams the service will ensure
appropriate governance and information management arrangements are in place.
(Head of Legal and Regulatory Support – March 2026)
• Financial Recovery – pressures deriving from increasing demand, workforce
shortages and reduced real terms funding in Health and Social Care. Plans under
development to reduce expenditure and service provision. (Chief Officer – March
2026)
• Reduce risk in long term housing supply by identifying long term strategic expansion
sites at scale which will create better economies of scale in terms of servicing
infrastructure and site de-risking. Produce Strategic Development Frameworks for
the two main population and commerce centres, Helensburgh and Oban. (Head of
Development and Economic Growth – March 2026)
• The Licensing Board will undertake a review of its Licensing Policy Statement as
required in terms of the Licensing (Scotland) Act 2005. This will ensure that the
Policy Statement continues to reflect the Board’s current practice and policy and is
updated as necessary to ensure compliance with the statutory licensing objectives.
The review will include an extensive consultation exercise with internal and external
partners, agencies and the public. (Head of Legal and Regulatory Support – March
2026)
• Ensure continuing improvement in the quality of LTA and pupil learning experiences
across all schools. Expanded programme of observation, feedback and support
relating to Learning, Teaching and Assessment by the central team for targeted
schools. (Head of Education, Performance & Improvement – March 2026).
• Strengthen professional learning opportunities for Head Teachers and the Education
Central Team in line with the new Leadership Progression Framework. Plan and
create a suite of Professional Learning sessions for Head Teachers and system
leaders, focusing on key local priorities and involving external partners where
possible. Continue to develop the Newly Appointed Head Teacher programme.
(Head of Education, Performance & Improvement – March 2026).
• Single Authority Model - Continue exploring the potential for a single authority model
including elements such health and social care. (Chief Executive March 2026)
• Budget Planning - Develop a longer term savings plan enabling a more strategic
approach to transformation and service redesign. (Chief Executive March 2026)
• Agree option for continuity of waste service following the end of the PPP Contract
(Head of Roads and Infrastructure - September 2026).
• External residential placements for children - Strengthening the governance
arrangements of external placements even further. Monitoring commissioning visits,
goals of placements and discharge planning. (Head of Children, Families and Justice
- March 2026).
• Stabilisation of staffing - Addressing absences and vacancies. (Head of Children,
Families and Justice - March 2026).
• The council’s Insurers identified an issue around the revaluation of properties for
building insurance purposes. A phased approach of revaluations was implemented
with General properties for the OLI and B&C areas to be completed in 2025/26 -
Estates will complete a revaluation programme for the General portfolio. (Head of
Commercial Services - March 2026)
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• Succession Planning - 28% of Property Service staff are 55 or over Succession
planning essential to ensure continuity of service provision. (Head of Commercial
Services - March 2026) 
CONCLUSION 
The conclusion from the review activity outlined above and our opinion is that reasonable
assurance can be placed upon the adequacy and effectiveness of Argyll and Bute Council’s
systems of internal control and governance. Although areas for further improvement have
been identified, the annual review demonstrates sufficient evidence that the Council’s Local
Code of Corporate Governance is operating effectively and that the Council complies with
that Local Code in all significant respects. Systems are in place to regularly review and
improve governance and systems of internal control.
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Audit & Scrutiny Committee Work Plan 2025 
This is an outline plan to facilitate forward planning of reports to the Audit & Scrutiny Committee 
Report  Lead Service Regularity
12 June 2025 Reports to Committee Services by 19 May 2025
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal and External Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 2024/25
➢ Short Term Lets
➢ Asbestos Management
➢ Bridges Asset Management Plan
➢ Trading Standards
➢ External Placements
➢ IFRS 16 – Leasing
➢ Disclosure Checks – Live Argyll
Chief Internal Auditor Quarterly 
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny Committee   Quarterly
Internal Audit 2024-25 Annual Report  Chief Internal Auditor Annual
Scrutiny report on the Monitoring and Managing of Complaints Chief Internal Auditor (Scrutiny Panel) from March A&SC Annual
Annual Audit Plan for year ending 31 March 2025 Forvis Mazars – Mark Outterside Annual
Local Government in Scotland – Financial Bulletin 2023-24  Head of Financial Services Annual
Local Government Benchmarking Framework Report Chris Carr, OD Project Officer Annual
Treasury Management Annual Report 2024-25 Head of Financial Services Annual
Statement of Governance and Internal Control  Governance, Risk and Safety Manager Annual
26 June 2025 – Special Meeting 
Unaudited Annual Accounts for year ending 31 March 2025 Head of Financial Services Annual 
4 September 2025 – Hybrid Meeting Reports to Committee Services by 11 August 2025
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal and External Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 2024/25
➢ 
Chief Internal Auditor Quarterly
External Audit Progress Report Forvis Mazars – Mark Outterside Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny Committee   Quarterly
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Agenda Item
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Audit & Scrutiny Committee Work Plan 2025 
PSIAS Self-Assessment  Chief Internal Auditor Annual
Corporate Complaints Annual Report 2024-25  Governance, Risk and Safety Manager Annual
Freedom of Information Annual Report 2024-25  Governance, Risk and Safety Manager Annual
Audit & Scrutiny Committee 2024/25 Annual Report  Audit & Scrutiny Committee Chair Annual
Strategic Risk Register – Assurance Mapping Chief Internal Auditor Annual
Strategic Risk Register Update  Chief Executive Annual
16 December 2025 Reports to Committee Services by 21 November 2025
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal and External Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 2024/25
➢ 
Chief Internal Auditor Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny Committee   Quarterly
Performance Reporting Update (to include reference to LGBF) Chief Executive/Head of Customer Support Services/HR
& OD Manager – Carolyn Cairns/Jennifer Coyle
Quarterly
Council Annual Report 2025/26 Head of Customer Support Services Annual
Annual Auditors Report Forvis Mazars – Mark Outterside Annual
Draft Thematic Review Forvis Mazars – Mark Outterside Annual
2024-25 Audited Annual Accounts Forvis Mazars – Mark Outterside/Section 95 Officer/Head
of Financial Services
Annual
Treasury Management Strategy and Annual Investment Strategy –
Mid-year Review Report 2025/26 
Head of Financial Services Annual
12 March 2026 Reports to Committee Services by 16 February 2026
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal and External Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 2025/26
➢ 
Chief Internal Auditor Quarterly
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny Committee   Quarterly
Audit Progress Report Forvis Mazars – Mark Outterside Quarterly 
RIPSA Annual Report Governance and Risk Manager Annual
Internal Audit 2025/26 Plan and Internal Audit Strategy 2025-2028 Chief Internal Auditor Annual
2025/26 Unaudited Annual Accounts Preparation Plan and
Timetable
Head of Financial Services Annual
2025-26 Treasury Management Update as at 31 December 2025 Head of Financial Services Annual
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Audit & Scrutiny Committee Work Plan 2025 
2025-26 Treasury Management Strategy and Annual Investment
Strategy
Head of Financial Services Annual
Internal Audit Charter and Internal Audit Manual Chief Internal Auditor Annual
Scrutiny Manual and Framework Update Chief Internal Auditor Annual   
11 June 2026 Reports to Committee Services by 18 May 2026
Internal Audit and Counter Fraud Summary of Activities Chief Internal Auditor Quarterly
Internal and External Audit Report Follow Up Chief Internal Auditor Quarterly
Internal Audit Reports to Audit and Scrutiny Committee 2025/26
➢ 
Chief Internal Auditor Quarterly 
Verbal Update by Chair(s) of Scrutiny Panel Chair and Vice Chair of Audit & Scrutiny Committee   Quarterly
Internal Audit 2025-26 Annual Report  Chief Internal Auditor Annual
Scrutiny report on the Monitoring and Managing of Complaints Chief Internal Auditor (Scrutiny Panel) from March A&SC Annual
Annual Audit Plan for year ending 31 March 2026 Forvis Mazars – Mark Outterside Annual
Local Government in Scotland – Financial Bulletin 2025/26  Head of Financial Services Annual
Local Government Benchmarking Framework Report Chris Carr, PD Project Manager Annual
Unaudited Annual Accounts Head of Financial Services Annual
Treasury Management Annual Report for year ending 31 March
2026
Head of Financial Services Annual
Statement of Governance and Internal Control Governance, Risk and Safety Manager Annual   
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