Internal Financial Controls Checklist
Internal Financial Controls Checklist
Internal Financial Controls Checklist
Contents
1. Self-assessment checklist 1
2. Some key issues, monitoring arrangements and risk of fraud 2
3. Income 3
4. Purchases and payments 5
5. Assets and investments 7
1. Self-assessment checklist
The questions in this checklist are designed to help charity trustees and their advisers evaluate the charity’s
performance against the legal requirements and good practice recommendations set out in the commission’s
guidance on internal financial controls for charities. Trustees should review their charity’s performance at least
once a year.
Each of the questions on the checklist links to a paragraph of the guidance, where further details can be found.
Not all the controls listed will be appropriate for all charities, for example, where a section of the checklist deals
with an area of activity that the charity does not undertake then that section of the checklist will not apply.
Charities must always comply with legal requirements and these requirements are identified in the checklist. A
‘yes’ answer for good practice recommendations does not mean there is no scope for further improvement. A
‘no’ answer does not always indicate a problem. It may be that the charity has not put in place a particular
control because the risk involved is small and the potential loss is acceptable, given the cost that would be
involved in putting in place stronger internal controls.
Finally, the answers in the checklist should be based on the trustees’ knowledge of what actually happens in
the charity and not what they expect to happen. Having an internal control in place is only part of the picture. It
must operate in practice to be effective.
Do the trustees carry out an annual review of the internal financial controls?
Are annual budgets of income and expenditure prepared, and approved by the
trustees?
Are the trustees provided with regular information about the financial performance
of the charity?
Do the trustees discuss the financial performance of the charity at each of their
meetings?
Are terms of reference in place for any finance sub-committee, or similar sub-group
of the trustee board?
Does any finance sub-committee report to the full board of trustees for final decision
making?
Have the trustees considered the need for a reserves policy and put in place a
reserves policy if one is needed? (legal requirement)
Do the trustees file the annual report and accounts and annual return on time?
(legal requirement)
2.6 and 2.7 Managing the risks of financial crime and abuse Yes No
Are trustees and staff made aware of why the charity is at risk from financial crime
and abuse and of typical examples of potential fraudulent activities?
Does the charity have an anti bribery policy, policies on the acceptance of hospitality,
the acceptance of donations and a register of interests in place?
Does the charity have policies and controls over access to and storage of electronic
information?
Does the charity have computer programmes to protect its data and systems from
external interference?
Does the charity have procedures for reporting suspicions internally, and to the
commission and the police?
3. Income
3.1 Income received in the post Yes No
• are collection boxes numbered and their allocation and return recorded?
• are all collection boxes regularly opened and counted by the charity and a record
kept of their locations and history of takings?
• are collections counted in the presence of the collector and a receipt given to
them?
• are two unrelated people involved in counting and recording the income?
• tickets pre-numbered?
• records kept of all persons issued with tickets to sell, and which ticket numbers
they have been allocated?
Does the charity maximise the lawful take-up by its donors of Gift Aid?
Are regular checks made to ensure all eligible tax repayments are obtained?
Does the charity keep the records required by HMRC for Gift Aid claims?
Does the charity identify and monitor the receipt of large legacies and ensure that
they are correctly included in the accounts?
Has the charity kept the necessary records to identify transactions with ‘substantial
donors’ for donations received up to April 2011? (legal requirement)
From April 2011, have the trustees put in place procedures to identify ‘tainted charity
donations’?
If the charity undertakes trading activities (either trading in furtherance of its objects
or non-charitable trading):
• does the charity have a pricing policy for the goods and services supplied?
• does the charity have invoicing procedures for goods and services supplied?
• are there procedures to reconcile amounts invoiced and cash received to outstanding
invoices?
Is insurance held to cover the contents of the safe or cash box and cash in transit?
Are regular checks made to ensure income records agree with the bank paying-in
books
and statements?
Are checks made by someone other than the person who made the entry in the
accounting records?
Are invoices received checked against orders confirming pricing and the receipt of
the goods or services ordered?
Does the charity make and monitor grants in accordance with the grant-making
policy?
Does the charity follow any stipulation in the governing document about who can
sign cheques?
Are cheque books etc kept in a secure place with access only by nominated
persons?
Is all cheque expenditure recorded in the cash book and noted with the relevant
cheque number, nature of payment and payee?
Are cheques signed only with documentary evidence of the nature of the payment,
eg invoice?
Does the charity communicate the policy for the use of cards to all trustees and staff
using them?
Are cards cancelled when the holder ceases to work for the charity?
Is all card expenditure supported by vouchers and invoices and recorded in the
accounting records each time the card is used?
Are card statements sent to the charity finance team and checked to supporting
records
and invoices?
Is the cardholder’s use of the card independently reviewed periodically to confirm its
use is consistent with the policy?
4.5 Payments by direct debits, standing orders and BACS direct credit Yes No
Are only named individuals authorised to set up direct debits, standing orders and
direct credits?
Does the charity use a dual authorisation system for BACS payments?
Does the charity monitor the arrangements to ensure that automatic payment
arrangements are cancelled when the goods and services are no longer being
supplied to the charity?
Are all payments by cash made from a cash float and not from incoming cash?
Are regular independent checks made of the petty cash float and records?
Are statutory deductions (tax and NIC) made from employees’ wages and salaries
and regularly forwarded to HMRC? (legal requirement)
Does the charity comply with minimum wage legislation? (legal requirement)
Are any other deductions from salaries made only where they are required or
authorised? (legal requirement)
Are the end-of-year returns (P60 and P11Ds) completed and filed with HMRC by
the deadline? (legal requirement)
If the charity employs staff are the required pension arrangements in place?
(legal requirement)
Are personnel records kept and held separately from wages records?
Is there a system of authorisation for recording and notifying starters and leavers,
changes of hours and other payroll changes?
Does the charity have a written policy to cover the payment and reimbursement
of expenses?
Are expenses reimbursed only where the individual incurred the expense in the
course of carrying out the charity’s business?
Does the expense claim include a self-declaration that the claim is accurate and
incurred on the business of the charity?
If the charity pays mileage rates for travel are the rates in accordance with HMRC
approved rates?
Does the charity have a repayment plan in place to repay the principal and any
interest due?
Are regular checks made to ensure expenditure records are accurate and agree with
the bank statements?
Are regular checks made to ensure no discrepancies between the payments made
and the original invoice or payment records?
Are checks made by someone other than the person who made the entry in the
accounting records?
Are assets checked regularly to ensure they are still in good repair and are of use to
the charity?
Is the use of fixed assets reviewed annually (to ensure put to best use and serving
the charity’s interests)?
Does this policy include the need to consider diversification of investments, including
bank accounts?
Does the charity inspect investment properties to ensure tenant covenants are
adhered to?
Are there controls to ensure that all investment income due is received?
Are secure records held of all bank and building society accounts?
Are bank statements regularly received and regular bank reconciliations carried out?
Do the trustees regularly review the costs, benefits and risks of their current and
deposit accounts?
If the charity uses electronic banking to make payments does the system used
require authorisation of transactions by two individuals?
Are PCs kept secure with up-to-date anti-virus and spyware software and a personal
firewall?
Are trustees and staff made aware of the need to ensure that the charity’s security
details (including the password and PIN) are not compromised?
Is the PIN and password regularly changed, for example to mitigate the risks of
compromising security when individuals leave the charity?
Does the charity maintain a list of persons (trustees and staff) who are approved to
have access to the PIN and password?
Have those using online banking facilities been trained in their use?
• are policies set and approved by trustees defining the circumstances when non-
traditional banking methods may be used?
• is the use of such methods limited to essential transfers where traditional banking
methods cannot be used?
• does the charity ensure that the controls that are in place for its traditional bank
transactions also operate with non-traditional banking transactions?
Are procedures in place to ensure that any restrictions put on the use of funds, by
the donor or through an appeal, are observed?
Does the charity ensure that the conditions attached to permanent endowments
are observed?