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Parliamentary Budget Control: International Comparisons and Practices

A comparative study covering EU countries as well as Canada, Norway, Switzerland, the United Kingdom, the United States, and other nations provides an in-depth analysis of the organizational structure, operational processes, core mechanisms, and evolutionary trends of parliamentary budget control functions in these countries.

Detail

Published

22/12/2025

List of Key Chapter Titles

  1. Introduction
  2. Budgetary Control
  3. Structure and Responsibilities of Parliamentary Budgetary Control Committees
  4. Support Structures for Budgetary Control
  5. Interaction between Parliamentary Bodies, Supreme Audit Institutions, and Other Entities
  6. The Discharge Procedure
  7. Interaction between the Budget and the Budgetary Control Process
  8. The Evolution of Budgetary Control over Recent Decades
  9. Conclusion

Document Introduction

Commissioned by the European Parliament's Committee on Budgetary Control, this report provides a comprehensive international comparative analysis of parliamentary budgetary control practices across the 27 EU Member States and five non-EU countries: Canada, Norway, Switzerland, the United Kingdom, and the United States. The core objective of the study is to offer a comprehensive overview of how national parliaments exercise their budgetary control functions, the institutions and structures involved, and the similarities and differences in these practices. It aims to serve as a reference and a source of good practices for the European Parliament's oversight activities and its dialogue with national parliaments.

The report first clarifies the concept and objectives of parliamentary budgetary control, defined as the oversight, scrutiny, evaluation, and even approval activities undertaken by the legislature to ensure the lawful, efficient, transparent, and accountable use of public funds. The study reveals that while the fundamental principles of budgetary control are shared, the institutional arrangements, legal frameworks, political cultures, and informal practices vary significantly across countries, with no single "optimal model." The report provides a detailed comparison of the types of committees responsible for budgetary control in national parliaments (e.g., budget/finance committees, public accounts committees, audit committees), analyzing their composition, investigative powers, and the limitations of their oversight scope. Simultaneously, the report delves into the models of Supreme Audit Institutions (SAIs) in different countries (e.g., judicial, parliamentary, board models) and their crucial role in budgetary control, emphasizing that the independent audit they provide is a cornerstone of parliamentary democratic accountability.

A core chapter of the report focuses on the "discharge" procedure (or similar mechanisms) in various countries. The study finds that among the 32 countries examined, 24 have a formal parliamentary vote to approve the audited accounts of the previous year's budget (the discharge procedure), while eight countries, including Canada and Finland, rely on continuous oversight mechanisms rather than an annual vote. The analysis covers the legal basis for discharge, the responsible bodies, the approval criteria (ranging from mere financial compliance to performance evaluation), the exercise of parliamentary investigative powers, and the consequences of refusal to grant discharge (often carrying significant political weight but no direct legal penalties). The report also explores the interaction between budgetary control and budget planning, highlighting the increasing integration of "ex-ante" planning and "ex-post" oversight in modern budgeting. This trend is manifested in the promotion of performance-oriented budgeting and the feedback of audit findings and performance information into the next budget cycle through mechanisms like mid-year adjustments and evaluation reports.

Finally, the report examines the evolution in the field of budgetary control over the past two decades, particularly following the 2008 financial crisis and the eurozone crisis. Reforms during this period led to the establishment of numerous independent fiscal institutions and parliamentary budget offices, aimed at enhancing fiscal transparency, strengthening ex-ante scrutiny, and ensuring compliance with EU fiscal rules. Concurrently, audit practices expanded from traditional compliance auditing to performance auditing, assessing the economy, efficiency, and effectiveness of public fund usage. Digital transformation has also increased oversight efficiency through real-time financial monitoring and data-driven audits. The report concludes that effective budgetary control depends not only on formal procedures and institutional capacity but also on political will, institutional independence, and a culture that views planning, spending, and oversight as a continuous cycle.