Internal control, or accounting without errors. Internal control is an urgent need for any company Rules for internal control of accounting

"Autonomous institutions: accounting and taxation", 2013, N 7

In each autonomous institution, as part of the accounting policy, a provision on internal financial control is developed. However, accountants still often have the question of how to properly draw up and conduct an audit. This article gives recommendations on the organization and execution of control measures, checking the facts of economic life reflected in the accounting records and correcting the identified errors.

The need to exercise internal financial control in an autonomous institution is provided for by the Accounting Law<1>and Instruction N 157n<2>.

<1>Federal Law No. 402-FZ of 06.12.2011 "On Accounting".
<2>Instructions for the use of the Unified Chart of Accounts for Accounting for State Authorities (Government Bodies), Local Self-Government Bodies, Management Bodies of State Extra-Budget Funds, State Academies of Sciences, State (Municipal) Institutions, approved. Order of the Ministry of Finance of Russia dated 01.12.2010 N 157n.

In accordance with paragraph 6 of Instruction N 157n, the procedure for organizing and ensuring (implementing) internal financial control is approved as part of the accounting policy. As a rule, internal control is carried out through preliminary, current and subsequent control. Preliminary and current financial control is carried out respectively before or at the time of the business transaction by the persons who are entrusted with such duties. Subsequent control is carried out by a commission specially created for these purposes based on the results of transactions by checking and analyzing accounting documents and reporting. Next, we consider some issues related to the organization and conduct of follow-up control.

Note. An economic entity is obliged to organize and exercise internal control over the facts of economic life (Article 19 of the Accounting Law).

Organization of the check

Subsequent control is carried out in the form of scheduled and unscheduled inspections. Scheduled inspections are carried out with a certain frequency in accordance with a pre-approved plan, as well as before the preparation of financial statements in accordance with clause 9 of Instruction N 33n<3>. Unscheduled inspections are organized as needed, for example, if there is information about any violations of financial and economic activities.

<3>Instructions on the procedure for compiling, submitting annual, quarterly financial statements of state (municipal) budgetary and autonomous institutions, approved. Order of the Ministry of Finance of Russia dated March 25, 2011 N 33n.

When a decision is made to conduct an audit, an administrative document (order, instruction) of the head is drawn up, which indicates:

subject of verification;
type and form of verification;
period under review;
the period of the inspection;
composition of the commission for internal control;
other necessary information.

Simultaneously with such a document, an audit program may be prepared. Below is a sample of it.

I approve

director of GAU "FOK "Zarya"

A.P. Petrov

The program for checking the financial and economic activities of the State Autonomous Institution "Sports and Health Complex "Zarya"

Grounds for the audit:

Plan of control activities of GAU "FOK "Zarya" for 2013, order of GAU "FOK "Zarya" dated 06.21.2013 N 16.

Checked period: from 01/01/2013 to 06/30/2013.

Checking times: from 07/01/2013 to 07/05/2013.

establishing compliance of activities with the requirements of the legislation of the Russian Federation, regulatory legal acts of the Nizhny Novgorod region, internal regulatory acts of GAU "FOK "Zarya";
control over the reasonable and efficient use of subsidies allocated for the implementation of the state task;
control over the targeted use of subsidies allocated for other purposes;
control over the legitimacy of receiving and using funds received from income-generating activities;
verification of the correctness of the commission of the facts of economic life before the preparation of financial statements for the first half of 2013

Items of control:

title documents of the institution;
internal regulations of the institution;
civil law contracts concluded by the institution with suppliers, contractors and performers, personnel documents, primary accounting documents, accounting registers;
plan of financial and economic activities and other documents necessary to achieve the purpose of the audit.

Check questions:

Availability of documents regulating the organization of accounting (accounting policy of the institution, regulations on the accounting service, job descriptions).
The movement of financial flows in the period under review by sources of financial support. The legitimacy of the formation and spending of funds in accordance with the plan of financial and economic activities of the GAU "FOK" Zarya "for 2013 (plan FCD).
Compliance with the procedure for approval and amendments to the FCD plan.
Availability of a license and full use of accounting software.
The correctness of accounting in accordance with the law and other regulatory legal acts, the completeness of the reflection of the facts of economic life in the accounting registers for all areas of accounting.

5.1. Compliance with the procedure for conducting accounting transactions with non-cash funds:

documented validity of transactions in the journal of transactions with non-cash funds;
availability of supporting documents for an extract from the personal account.

5.2. Compliance with the procedure for conducting cash transactions:

completeness and timeliness of posting cash and monetary documents to the cash desk, the correctness of their issuance (write-off);
compliance with the requirements for the execution of cash orders and documents attached to them;
the correctness of accounting for operations on the movement of cash and monetary documents in the cash book, journals of operations on the account "Cashier" and on the account "Money documents";
observance of the established limit of the balance of funds in the cash register;
implementation of measures aimed at the safety of cash and monetary documents at the cash desk;
conducting an audit of cash and cash documents, as well as strict reporting forms during the audit period.

5.3. Compliance with the procedure for accounting for settlements with accountable persons for advances issued to them:

compliance with the procedure and established norms for the issuance of funds and monetary documents under the report;
timeliness and completeness of submission by accountable persons of advance reports on the spent advance amounts, completeness of documents confirming the expenses incurred;
documented validity of accounting transactions in the journal of transactions of settlements with accountable persons.

5.4. Checking settlements for obligations:

correctness and documentary validity of keeping records of settlements with suppliers for the supplied material assets and services rendered, with contractors for the work performed, as well as settlements on the advances transferred in the journal of transactions of settlements with suppliers and contractors;
the correctness of accounting for the transferred payments to the budgets in the journal for other operations and the card for accounting for funds and settlements;
reconciliation of general ledger data on accrued and paid insurance premiums to off-budget funds with reports submitted to the relevant funds;
the reality of receivables and payables at the end of the reporting period, the presence of overdue debts, the measures applied to the collection of receivables and repayment of payables, the validity of the debt write-off;
timeliness of transfer by tenants of rent payments and consumed utility and maintenance services;
organization of accounting for funds received from tenants and subtenants for reimbursement of operational, communal and administrative services;
observance of the proportionality of allocation of utility costs by sources of financing.

5.5. Checking payroll settlements with employees:

compliance of the actual number of employees with the approved staffing table and the standard number;
the correctness of payroll for employees in accordance with the legislation of the Russian Federation, orders and local documents of the institution;
the correctness of the calculation of remuneration to persons under civil law contracts;
the correctness of accounting for payroll settlements and settlements with the budget for taxes withheld from payroll in the journal of operations of payroll settlements and in the cards for accounting for funds and settlements.

5.6. Verification of transactions with non-financial assets:

completeness and timeliness of execution of documents on capitalization of fixed assets, intangible assets and inventories on the relevant accounting accounts;
correctness of conducting analytical accounting of non-financial assets in accounting registers;
the correctness of accounting operations for the consumption (disposal) of objects of non-financial assets, transfer within the institution, as well as the amount of depreciation deductions for fixed assets, intangible assets in the journal of operations for the disposal and transfer of non-financial assets;
reconciliation of the indicators of the accounts of the general ledger with the indicators of the accounts of the turnover sheets in the context of analytical accounts;
the presence of facts of unjustified write-off of property, as well as shortages of material assets by conducting a selective inventory of non-financial assets, the correctness of their reflection in accounting and taking measures to recover losses from the guilty parties;
the correctness of registration of inventory cards of accounting for fixed assets;
analysis of changes in the value of fixed assets, the presence of unused equipment.

5.7. Accounting on off-balance accounts, reflection of transactions in accounting registers.

Other questions arising during the audit.

Responsible for the preparation of the audit, the auditor Shishkin P.V. (signature).

As a rule, verification is carried out by studying documents, information contained in the accounting program, inspecting property, recalculating it, control measurements, interviews with employees related to a particular verification issue. Also, the commission has the right to demand from the manager and employees the documents necessary to achieve the purpose of the audit (certificates, written explanations, etc.).

Control measures can be carried out in a continuous or selective way. The decision on the use of one or another method of conducting control actions on each issue is made by the Audit Commission.

The persons responsible for conducting the inspection analyze the identified violations, determine their causes and develop proposals for taking measures to eliminate them and prevent them in the future.

Employees of the institution who have made shortcomings, distortions and violations provide explanations in writing on issues related to the results of the audit.

Formulation of test results

The results of the audit are drawn up in the form of an act that includes all sections that contain answers to the questions of the approved program for the audit. The act should describe the state of activity in the areas tested, outline the identified violations and shortcomings in the work of the institution, and reflect the general results of the audit. The act does not allow conclusions, proposals not supported by evidence, blots, erasures and other corrections. On the basis of this act, the chief accountant of the institution (or another person authorized by the head) develops an action plan to eliminate the identified shortcomings and violations, indicating the deadlines and responsible persons, which is approved by the head of the institution.

The act of checking the financial and economic activities of GAU "FOK" Zarya "

"05" July 2013 Nizhny Novgorod

In pursuance of the plan of control activities of GAU "FOK "Zarya" for 2013, the order of GAU "FOK "Zarya" dated 06.21.2013 N 16, in accordance with the Audit Program by members of the internal control commission (surnames, initials, positions of all participants in the control group) a scheduled audit of the financial and economic activities of the institution was carried out.

The purpose of the control measure:(according to the Test Program).

Checked period: With...

Checking timeframe: With...

Check method: solid.

Items of control:(documents that have been verified).

Full and abbreviated name of the institution.

Legal and actual address.

Information about licenses for the implementation of the relevant types of activities.

List and details of all accounts (including accounts closed at the time of the audit, but active in the audited period) with credit institutions, including deposit accounts, as well as personal accounts with the Federal Treasury.

Head of the institution: ___________ (Full name) appointed ________ (date and document number).

Chief Accountant: _____________ (full name, date and number of the appointment order).

Surnames, initials and positions of persons who had the right to first and second signature of financial and settlement documents.

By whom and when the audits were carried out in the audited period, by whom the previous audit of financial and economic activities was carried out, as well as information on the elimination of violations identified by the audits.

Other data necessary, in the opinion of the head of the control group, to fully characterize the object of financial control.

As a result of the audit, it was found:

The descriptive part of the audit report (certificate) should contain a description of the work done and the violations identified for each issue of the program.

The volume of verified documentation is indicated: documents were checked for the first half of 2013, etc. In the audit reports (certificates), when describing each violation identified during the audit, the provisions of the legislative, regulatory legal acts that were violated, to which period the violation relates, what the violation was expressed, and the documented amount of the violation should be indicated.

The appendix to the act draws up a list of legislative, regulatory legal acts, in accordance with which the activities of the institution were carried out in the audited period. The list indicates the full and short name of legislative and normative acts, in the text of the act - the short name of the legislative, normative act.

The final part of the audit report should contain summarizing information on the results of the audit, including the violations found, grouped by type, indicating for each type of financial violations the total amount for which they were detected. Recommendations for elimination and prevention of violations.

Head of control group Head of institution
______________ (full name) _______________ (full name)
Control group members:
______________ (FULL NAME.)
______________ (FULL NAME.)

(test end date)

Correction of errors based on the results of the check

Errors found in accounting registers are corrected in accordance with clause 18 of Instruction N 157n in the following order:

Error detection period	Procedure
Error found during the reporting period until the presentation financial statements and not requiring change. data in registers accounting (transaction logs)	Corrected by strikethrough thin dash of wrong sums and text so that could read the crossed out and writing over the strikethrough corrected text and amount. At the same time in the register accounting, which bug fix, on margin vs. the corresponding line signed by the chief the accountant makes the inscription "Corrected"
Error found until the presentation financial statements and requiring changes to the accounting register accounting (operations log)	Reflected on the last day of the reporting period the nature of the error)
Error found in accounting registers accounting for the reporting period, for which the accounting reporting in the prescribed already presented	Indicated by the date the error was discovered additional accounting entry or an accounting entry made in the manner "red storno", and additional accounting entry (depending on the nature of the error)

Additional accounting entries for the correction of errors, as well as corrections by the "red reversal" method, must be drawn up with a certificate of f. 0504833, containing information on the rationale for making corrections, the name of the corrected accounting register (transaction journal), its number (if any), and the period for which it was compiled.

If errors are found in the primary documents, it is allowed to make corrections to some of them, if they are made in agreement with the persons who compiled and signed these documents, which is confirmed by the signatures of the same persons, indicating the inscription "Corrected believe" ("Corrected") and the date of introduction fixes. At the same time, it is not allowed to make corrections to the documents that process transactions with cash or non-cash funds (clause 10 of Instruction N 157n).

O. Sizonova

Editor in Chief

"Autonomous Institutions:

accounting and taxation"

At present, the issues of organization and implementation of internal control are of particular relevance. So, in Art. 19 "Internal Control" of the Federal Law of December 6, 2011 No. 402-FZ "On Accounting" states that:

An economic entity is obliged to organize and exercise internal control over the facts of economic life.

An economic entity whose accounting (financial) statements are subject to mandatory audit is obliged to organize and exercise internal control over accounting and preparation of accounting (financial) statements (except for cases when its head has assumed the responsibility for accounting).

We also note the list of cases of mandatory audit, since the Federal Law of December 30, 2008 No. 307-FZ “On Auditing Activities” emphasizes that it is these organizations that are required to carry out control of accounting and reporting. Cases of mandatory audit are noted, first of all, in Art. 5 307-FZ, according to which a mandatory audit is carried out in the following cases:

if the organization has the organizational and legal form of an open joint stock company;
if the organization's securities are admitted to circulation at organized auctions;
if the organization is a credit institution, a credit history bureau, a professional participant in the securities market, an insurance organization, a clearing organization, a mutual insurance company, a trade organizer, a non-state pension or other fund, a joint-stock investment fund, a management company of a joint-stock investment fund, a mutual investment fund or a non-state pension fund (with the exception of state off-budget funds);
if the volume of proceeds from the sale of products (sales of goods, performance of work, provision of services) of an organization (with the exception of state authorities, local governments, state and municipal institutions, state and municipal unitary enterprises, agricultural cooperatives, unions of these cooperatives) for the previous reporting year exceeds four hundred million rubles or the amount of assets in the balance sheet as of the end of the previous reporting year exceeds sixty million rubles;
if an organization (with the exception of a state authority, a local government body, a state non-budgetary fund, as well as a state and municipal institution) submits and / or publishes summary (consolidated) accounting (financial) statements;
in other cases established by federal laws.

Therefore, these organizations are required to internal control of accounting and reporting.

It is also necessary for an economic entity to carry out internal control over the effectiveness of long-term decisions, the basis of which is the calculation and evaluation of static and dynamic indicators. At the same time, the most relevant are methods that take into account the time value of money - dynamic (discounted) methods (Table 1).

Table 1. Static and dynamic methods for evaluating investment projects

Internal control over the achievement of operational and financial performance

To organize internal control over the achievement of operational and financial indicators, it is necessary to compare with the planned indicators of the organization's budget in the context of the operational and financial budgets (Fig. 4).

Figure 4. System of budgets for internal control of achievement of indicators

The analysis must be carried out by the methods of comparison listed above, as well as by the methods of factor analysis by searching for the causes of the identified deviations from the planned indicators.

Internal control of accounting and reporting

The general sequence of internal control of accounting, reporting, according to the author, "technically" and methodologically does not differ from the principles of external control and can be represented by the sequence shown in Figure 5.

Figure 5. Internal control of accounting, reporting

As with an external audit, an internal audit must be carefully planned, an array of information to be verified must be formed (it is not economically feasible to carry out an audit in a continuous manner). For different purposes, it is necessary to form the maximum allowable error for different user groups in the form of materiality.

When performing an audit, it is necessary to test internal controls and substantive procedures in relation to each financial statement assertion.

The formation of reports (composition, structure, frequency of presentation) should be regulated by the internal documents of the economic entity. We will dwell on the formation of control procedures in more detail when describing the elements of the internal control system.

Internal control of compliance with the law

Internal control of compliance with the law, which consists in monitoring compliance with regulatory legal acts, cannot be considered separately from the control of accounting of an economic entity, since almost all business transactions are reflected in it.

Therefore, when exercising this area of control, it is necessary to check whether the organization complies with the four-level system of accounting and reporting of an economic entity, laws, codes, PBU, chart of accounts, methodological recommendations, explanations, local regulations.

Bibliography:

Federal Law No. 402-FZ of 06.12.2011 "On Accounting".
Federal Law No. 307-FZ dated December 30, 2008 “On Auditing Activities”.
Federal Law of 07.08.2001 No. 115-FZ “On counteracting the legalization (laundering) of proceeds from crime and the financing of terrorism”.
Decree of the Government of the Russian Federation of June 30, 2012 No. 667 “On approval of the requirements for internal control rules developed by organizations engaged in transactions with cash or other property (with the exception of credit institutions) and individual entrepreneurs, and on the invalidation of certain acts of the Government of the Russian Federation ".
Information of the Ministry of Finance of Russia No. PZ-10/2012 “On the entry into force on January 1, 2013 of the Federal Law of December 6, 2011 No. 402-FZ “On Accounting”.
Information of the Ministry of Finance of Russia No. PZ-11/2013 “Organization and implementation by an economic entity of internal control of the facts of economic life, accounting and preparation of accounting (financial) statements”.
Letter of the Federal Tax Service of Russia dated July 16, 2013 No. AS-4-2/12705 “On recommendations for conducting in-house tax audits”.
FPSAD No. 8 "Understanding the activities of the audited entity, the environment in which it is carried out, and assessing the risks of material misstatement of the audited financial (accounting) statements."
FPSAD No. 11 "Applicability of the assumption of business continuity of the audited entity".
FPSAD No. 20 "Analytical procedures".
FSAD 5/2010 "The Auditor's Responsibilities for Considering Fraud in an Audit".
Bakhrushina M.A. Accounting management accounting. Proc. for university students studying in economic specialties. 8th ed., rev. Moscow: Omega-L, 2010.
Egorova I.S. Peculiarities of professional language formation in audit activity / I. Egorova // Auditorskie Vedomosti. 2014. No. 4.
Egorova I.S. Application of CVP-analysis to assess the continuity of the audited entity // International Accounting. 2014. No. 12.

Basic requirements for internal control

According to the Law of 06.12.2011 No. 402-FZ "On Accounting" (hereinafter - Law No. 402-FZ), an organization is obliged to organize and exercise internal control over the facts of economic life, and if its accounting (financial) statements are subject to mandatory audit, then it is obliged to organize and carry out internal control of accounting and preparation of accounting (financial) statements (except for cases when its head has assumed the responsibility for accounting).

Law No. 402-FZ does not describe how and to what extent internal control should be carried out. However, it is clear that it should be sufficient to ensure the reliability of the facts of economic life and the accounting (financial) statements of the organization.

For example, issues of internal control in economic entities are regulated by the rules establishing the establishment of audit commissions for the financial and economic activities of the company:

Art. 85 of the Federal Law of December 26, 1995 No. 208-FZ "On Joint Stock Companies";

Art. 47 of the Federal Law of February 8, 1998 No. 14-FZ "On Limited Liability Companies".

The requirements of these federal laws must be observed.

This document introduces the concept of internal control as a process aimed at obtaining reasonable assurance that the organization ensures:

A) the efficiency and effectiveness of its activities, including the achievement of financial and operational indicators, the safety of assets;

B) reliability and timeliness of accounting (financial) and other reporting;

C) compliance with applicable law, including when committing the facts of economic life and maintaining accounting records.

Elements of internal control

The main elements of internal control of an economic entity are:

A) control environment;

B) risk assessment;

C) internal control procedures;

D) information and communication;

E) assessment of internal control.

The control environment is a set of principles and standards for the organization's activities that define the overall understanding of internal control and the requirements for internal control in the organization as a whole. It reflects the management culture of the organization and creates the appropriate attitude of the organization's personnel to exercise this control.

Communication as an element of internal control is a way of disseminating information necessary for making management decisions and exercising internal control. For example, each employee of the organization should be aware of the risks related to their area of responsibility, their role and tasks in exercising internal control and informing management.

Setting control over the facts of economic life is very important for the organization. Control is traditionally divided into preliminary, current and subsequent. It is optimal when these stages are divided between different employees of the organization. If authorization and control over the performance of business transactions are entrusted to one official, this can lead to errors and possible abuses on his part - after all, he completely controls economic life, from "a" to "z". If different employees participate in different stages of control, this increases the independence and effectiveness of control measures. For their implementation, it is advisable (not mandatory, but desirable) to create an internal control commission. Its members will be independent auditors.

Risk assessment and management is also an important component of the internal control system. Risk is understood as a combination of the probability and consequences of failure by the economic entity to achieve the goals of the activity. Risks can be grouped into the following types: financial, legal, country and regional, reputational, etc. Information about the risks of economic activity is necessary for an organization to fully understand its financial position, financial performance and changes in its financial position2.
#ATTENTION#
To achieve its financial stability, an organization may apply the following internal control procedures:

A) documentation (for example, making entries in accounting registers on the basis of primary accounting documents, including accounting statements; including significant estimated values in accounting (financial) statements solely on the basis of calculations);

B) checking the execution of primary accounting documents for compliance with the established requirements when accepting them for accounting.

D) reconciliation of data;

E) delimitation of powers and rotation of duties of personnel;

E) procedures for monitoring the actual presence and condition of objects, including physical security, access restriction, inventory;

G) supervision over the correctness of the implementation of transactions and operations, the implementation of accounting operations, the accuracy of budgeting (budgets, plans), compliance with the established deadlines for compiling accounting (financial) statements;

H) procedures related to computer processing of information and information systems (rules and procedures governing access to information systems, data and directories, rules for the implementation and support of information systems, data recovery procedures, etc.).

In any case, if the basic procedures for controlling the facts of economic life are not observed formally, but are well developed, then they will ensure high efficiency of the internal financial control of the organization as a whole.

Documentation of internal control

The procedure for organizing and implementing internal control must be documented on paper and (or) in electronic form. The provisions relating to the organization of internal control are part of the constituent and internal organizational and administrative documents of the organization (orders, orders, regulations, job and other instructions, regulations, methods, accounting standards).

With regard to accounting, including the preparation of accounting (financial) statements, the control environment can be described by the regulation on the accounting service, the accounting policy of the organization, the qualification requirements for accounting personnel and other documents that establish general requirements for the environment in which accounting is organized and maintained. accounting, the order of interaction between divisions and personnel of the organization and decision-making on accounting issues.

Documents establishing the rules of communication can be: regulations, schedules for providing data and reporting, job descriptions.

Documentation on the organization of internal control must be updated regularly. The need to update it should be assessed at least once a year. The basis for updating the documentation may be, for example, the results of continuous monitoring of internal controls, organizational changes, changes in the processes and procedures of the organization.

Organization of internal control

The procedure for organizing internal control, including the duties and powers of the divisions and personnel of the organization, are determined depending on the nature and scale of its activities, the features of its management system.

When organizing internal control, it is necessary to proceed from the fact that:

A) internal control should be carried out at all levels of management of the organization, in all its divisions;

B) all employees should participate in the implementation of internal control in accordance with their powers and functions;

C) the usefulness of internal control should be comparable with the costs of its organization and implementation.

Internal control, as a rule, is carried out by:

A) the governing bodies of the organization;

B) the audit commission (auditor);

C) the chief accountant or other official of the organization who is responsible for accounting;

D) internal auditor (internal audit service);

E) special officials, a special division of the organization responsible for compliance with the rules of internal control provided for by other federal laws;

E) other personnel and departments of the organization.

When organizing and exercising internal control over the facts of economic life, the organization must be guided by the requirement of rationality.

Let us give an example of documenting the procedure for the distribution of powers and functions in the organization of internal control in an organization.

I approve
General Director (Director) of VECTOR LLC

REGULATIONS ON THE DISTRIBUTION OF POWERS AND FUNCTIONS
ON ORGANIZATION AND IMPLEMENTATION OF INTERNAL CONTROL

VECTOR LLC

Board of Directors* Vector LLC:

establishes general principles and requirements for internal control;

approves the standards, methods of organization and implementation of internal control at the level of the organization as a whole;

makes decisions to improve the efficiency of internal control;

oversees the process of ensuring compliance with the law and the organization's code of business conduct (ethics).

Audit Commission (Auditor) of Vector LLC:

monitors the effectiveness of internal control, the independence of the internal control service;

analyzes reports of the organization on the state of internal control.

General Director (Director) of Vector LLC:

responsible for the organization and implementation of internal control of the committed facts of economic life;

responsible for accounting and preparation of accounting (financial) statements in general;

holds regular meetings with the heads of departments of the organization to review significant risks, internal control issues and related plans;

analyzes the results and quality of implementation of measures (corrective steps) developed by the heads of organizational units to improve internal control;

examines cases of abuse and assesses the adequacy of the measures taken by the heads of departments to prevent such cases.

The chief accountant is responsible for the organization and implementation of internal control of accounting and preparation of accounting (financial) statements.
#FOOTNOTE#
Heads of departments and other personnel of Vector LLC, in accordance with their powers and functions, defined by job descriptions and the Regulations on Document Flow (Document Flow Schedule):

conduct a risk assessment;

draw up and update the documentation, which is an integral part of the Regulations on the internal control of the organization;

carry out internal control in accordance with the established procedure;

carry out an assessment of internal control.

___________________________

A board of directors may be established in a company regardless of whether the company has a single member or the company has a larger number of members.

The procedure for organizing and conducting internal financial control in an institution should be fixed in its accounting policy. The article considers the structure and main sections of the provision on internal control in an organization as an example.

By virtue of Art. 19 of the Federal Law of December 6, 2011 No. 402-FZ “On Accounting” and clause 6 of Instruction No. 157n, institutions of law enforcement agencies are required to organize internal control of the facts of economic life. Internal financial control is aimed at creating a system for complying with the legislation of the Russian Federation in the field of financial activity, internal procedures for the preparation and execution of the budget, improving the quality and reliability of budget reporting and budget accounting, as well as improving the efficiency of using federal budget funds. The procedure for exercising such control must be approved when the institution forms its accounting policy. We will talk about what such a provision should contain in the article.

Once again, we note that the procedure for organizing and conducting internal financial control in an institution should be fixed in its accounting policy. In this case, the institution can form its accounting policy by issuing separate regulations.

The procedure for organizing and conducting financial control may be issued by a separate order.

Internal financial control can be exercised in the following ways:

a structural unit is created in the institution (an internal financial control department with subordination to the head of the institution) or the position of an auditor is introduced (also with direct subordination to the head of the institution);
a permanent commission is created in the institution, which will be entrusted with the implementation of this control;
the implementation of internal financial control is assigned to employees of structural divisions of the institution (for example, employees of financial and personnel services). In such a situation, internal control will be carried out as part of preliminary and ongoing control activities.

The choice of control construction option depends on the expected scope of work, the financial and organizational capabilities of the institution (it is not always possible to introduce additional rates), the structural features of the institution, the competence of specialists, etc.

At the same time, internal financial control should include the following types of it.

Type of control	Description
Preliminary control	Such control should be carried out before the performance of business transactions. It allows you to determine how appropriate and legitimate this or that operation will be. Thus, the control measures related to preliminary control are the analysis of the compliance of the concluded contracts with the approved plan of financial and economic activity, the verification of budgetary, financial, statistical, tax and other reporting before its approval or signing, etc.
current control	This type of control consists in conducting a daily analysis of compliance with budget execution procedures, compiling budget (accounting) reports and maintaining budget (accounting) records, assessing the efficiency and effectiveness of spending money to achieve goals, objectives and target forecast indicators by departments of the institution (branches and representative offices)
Follow-up control	This control is carried out on the basis of the results of business transactions by analyzing and checking accounting documentation and reporting, carrying out inventories and other necessary procedures.

Thus, preliminary and current control will be carried out directly by the employees of the institution as part of their official duties, and subsequent control can be carried out both by the control department (auditor) and the internal control commission.

Ideally, it is necessary to ensure that all types of controls are carried out in the institution:

establish procedures for the approval of certain documentation both with legal services and other interested departments, and with the relevant deputy heads of the institution;
impose on employees of financial and other services the obligation to exercise current control over the financial documentation they draw up;
create a department of financial control in the institution (introduce the position of an auditor) or a commission for the implementation of financial control.

Structural divisions of the institution organize internal financial control at the following levels:

employee level - control functions are performed within the framework of official duties in accordance with the principles of consistency, continuity, efficiency and mass character;
structural unit level - regular operations and internal financial control procedures are carried out by department employees, senior employees, and heads of departments.

The chosen method of exercising control must be fixed in the regulation on the procedure for exercising internal financial control, while the activities of the internal control department (auditor) will also be regulated by the regulation on the internal control department.

For your information

This document is approved by the order of the head of the institution and is an important legal act that determines the formation procedure, legal status, responsibilities, and organization of the work of the internal control department (auditor).

The division of powers and responsibilities of the bodies involved in the functioning of the internal control system is determined by the internal documents of the institution, including the provisions on the relevant structural units, as well as the organizational and administrative documents of the institution and job descriptions of employees.

When developing these documents, it is necessary to establish the rights and obligations of the inspectors and employees of the departments who will be affected by the inspections.

I approve

Head of institution

________________ / I. I. Ivanov /

Regulation on internal financial control

1. General Provisions

1.1. This Regulation has been developed in accordance with the legislation of the Russian Federation (Federal Law No. 402-FZ of 06.12.2011 “On Accounting”, Order of the Ministry of Finance of the Russian Federation of 01.12.2010 No. 157n “On Approval of the Unified Chart of Accounts for Accounting for Public Authorities (State Bodies) , local self-government bodies, management bodies of state non-budgetary funds, state academies of sciences, state (municipal) institutions and Instructions for its application") and the charter of the institution. The regulation on internal financial control establishes uniform goals, rules and principles for organizing and conducting internal financial control measures in an institution.

1.2. The objectives of internal financial control are to confirm the reliability of the budgetary accounting and reporting of the institution, compliance with the current legislation of the Russian Federation, which regulates the procedure for carrying out financial and economic activities. The internal control system is designed to ensure:

accuracy and completeness of accounting documentation;
timely preparation of reliable financial statements;
prevention of errors and distortions;
execution of orders and orders of the head of the institution;
implementation of plans for financial and economic activities (budget estimates) of the institution;
safety of the property of the institution.

1.3. The tasks of internal control are:

establishing the compliance of ongoing financial transactions in terms of financial and economic activities and their reflection in budget accounting and reporting with the requirements of regulatory legal acts;
establishing compliance of ongoing operations with regulations, powers of employees;
compliance with established technological processes and operations in the implementation of functional activities;
analysis of the institution's internal control system, which makes it possible to identify significant aspects that affect its effectiveness.

1.4. Internal control in an institution should be based on the following principles:

the principle of legality - the steady and exact observance by all subjects of internal control of the norms and rules established by the regulatory legislation of the Russian Federation;
the principle of independence - the subjects of internal control in the performance of their functional duties are independent of the objects of internal control;
the principle of objectivity - internal control is carried out using actual documentary data in the manner prescribed by the legislation of the Russian Federation, by applying methods that ensure the receipt of complete and reliable information;
the principle of responsibility - each subject of internal control for the improper performance of control functions is liable in accordance with the legislation of the Russian Federation;
the principle of consistency - the implementation of control measures of all aspects of the activity of the object of internal control and its interrelations in the management structure.

1.5. When carrying out internal control measures, the persons conducting it may use:

general scientific methods of control (analysis, synthesis, induction, deduction, reduction, analogy, modeling, abstraction, experiment, etc.);
empirical methodological methods of control (inventory, control measurements of work, control launches of equipment, formal and arithmetic checks, counter check, countdown method, method of comparing homogeneous facts, internal investigation, examinations of various types, scanning, logical verification, written and oral interviews, etc. .);
specific methods of related economic sciences (methods of economic analysis, economic and mathematical methods, methods of probability theory and mathematical statistics).

1.6. Internal control in an institution can be exercised by:

2. Organization of internal financial control

2.1. Internal financial control in an institution is carried out in the form of preliminary, current and subsequent control.

2.1.1. Preliminary control is carried out before the start of a business transaction. It allows you to determine how appropriate and legitimate this or that operation will be. Preliminary control is carried out by the head of the institution, his deputies, and employees of the legal department. As part of the preliminary control, the following actions are carried out:

control over the preparation of financial and planning documents (calculations of the need for financial resources, a plan for financial and economic activities, etc.). These actions are carried out by the head, chief accountant;
their sighting, coordination and settlement of disagreements;
verification and endorsement of draft agreements (contracts) by specialists of the legal service and the chief accountant;
preliminary examination of documents (decisions) related to the expenditure of financial and material resources, carried out by a financial and economic consultant, chief accountant, heads of departments, the internal control commission.

2.1.2. Current control consists in conducting a daily analysis of compliance with budget execution procedures, compiling budget (accounting) reports and maintaining budget (accounting) records, monitoring the targeted spending of regional (federal or municipal) budget funds by subordinate institutions, assessing the efficiency and effectiveness of spending budget funds to achieve goals, objectives and target forecast indicators by management units, subordinate institutions.

During the current control, the following activities are carried out:

verification of expenditure monetary documents prior to their payment (payroll statements, payment orders, invoices, etc.). The fact of control is the permission of documents for payment;
checking the availability of funds in the cash register;
verification of the completeness of the posting of cash received from the bank;
verification of the availability of accountable persons received under the report of funds and (or) supporting documents;
control over the collection of receivables and repayment of accounts payable;
reconciliation of analytical accounting with synthetic accounting (turnover sheet);
verification of the actual availability of material resources.

Current control is carried out on an ongoing basis by specialists of the accounting and reporting departments of the institution, the economic department, the deputy head of the institution responsible for the financial and economic unit, and the internal control commission.

2.1.3. Subsequent control is carried out on the basis of the results of business transactions. It is carried out by analyzing and checking accounting documentation and reporting, conducting inventories and other necessary procedures. To conduct follow-up control in the institution, an internal control commission is created, the composition of which is determined in the appendix to this Regulation. The composition of the committee may change.

Follow-up methods are:

sudden audit of the cash register;
verification of the receipt, availability and use of funds in the institution;
documentary checks (audits) of completed operations of the financial and economic activities of the institution.

The system for monitoring the state of budgetary (accounting) accounting includes checking:

compliance with the requirements of the legislation of the Russian Federation regulating the procedure for carrying out financial and economic activities;
accuracy and completeness of the preparation of documents and accounting registers;
prevention of possible errors and distortions in accounting and reporting;
execution of orders and instructions of the management;
safety of financial and non-financial assets of the institution.

2.2. Follow-up control is carried out by conducting both scheduled and unscheduled inspections. Scheduled inspections are carried out at intervals established by the inspection plan approved by the head of the institution.

The main objects of scheduled inspection are:

compliance with the legislation of the Russian Federation, which regulates the procedure for conducting accounting, and the norms of accounting policy;
correctness and timeliness of reflection of all business transactions in budget accounting;
completeness and correctness of documenting transactions;
timeliness and completeness of inventory;
reliability of reporting.

During an unscheduled inspection, control is carried out on issues in respect of which there is information about possible violations.

2.3. The persons responsible for conducting the inspection analyze the identified violations, determine their causes and develop proposals for taking measures to eliminate them and prevent them in the future.

The results of the preliminary and current control are drawn up in the form of memos addressed to the head of the institution, which may contain a list of measures to eliminate shortcomings and violations, if any, as well as recommendations to avoid possible errors.

2.4. The results of the follow-up control are drawn up in the form of an act, which is signed by all members of the commission and sent with an accompanying memo to the head of the institution. The verification report must include the following information:

verification program (approved by the head of the institution);
the nature and condition of accounting and reporting systems;
types, methods and techniques used in the process of conducting control activities;
analysis of compliance with the legislation of the Russian Federation, which regulates the procedure for the implementation of financial and economic activities;
conclusions about the results of the control;
a description of the measures taken and a list of measures to eliminate the shortcomings and violations identified during the subsequent control, recommendations for avoiding possible errors.

Employees of the institution who have made shortcomings, distortions and violations, in writing, provide the head of the institution with explanations on issues related to the results of the control.

2.5. Based on the results of the audit, the chief accountant of the institution (or a person authorized by the head of the institution) develops an action plan to eliminate the identified shortcomings and violations, indicating the deadlines and responsible persons, which is approved by the head of the institution.

After the expiration of the established period, the chief accountant shall immediately inform the head of the institution about the implementation of measures or their non-fulfillment, indicating the reasons for the non-fulfillment.

3. Subjects of internal control

3.1. The system of subjects of internal control includes:

head of the institution and his deputies;
commission for internal control;
managers and employees of the institution at all levels;
third-party organizations or external auditors involved for the purpose of checking the financial and economic activities of the institution.

3.2. The division of powers and responsibilities of the bodies involved in the functioning of the internal control system is determined by the internal documents of the institution, including the provisions on the relevant structural units, as well as the organizational and administrative documents of the institution and job descriptions of employees.

4. Rights and obligations of subjects of control

4.1. In the course of internal financial control, subjects of control have the right to:

for access to documents, databases and registers directly related to the issues of conducting a control event;
to receive information on issues included in the control program;
to receive written explanations from officials of the institution on issues included in the program of control measures;
for unhindered access (in compliance with the established procedure) to all office premises of the subject of internal control;
to expand the range of areas (questions) of verification if such an expansion is necessary when performing the main task.

4.2. Subjects of control are obliged to:

possess the necessary professional knowledge and skills;
perform the duties stipulated by the job descriptions and the regulation on the structural unit;
comply with the requirements of the legislation of the Russian Federation in the course of its activities;
ensure the safety and return of the original documents received in the object of internal control;
observe the confidentiality of the information received in connection with the performance of official duties;
prepare audit materials in accordance with established requirements.

5. Responsibility

5.1. Subjects of internal control, within their competence and in accordance with their functional duties, are responsible for the development, documentation, implementation, monitoring and development of internal control in the areas of activity entrusted to them.

5.2. Responsibility for the organization and functioning of the internal control system rests with the deputy head of the institution responsible for the financial and economic unit.

5.3. Persons who have committed shortcomings, distortions and violations shall bear disciplinary responsibility in accordance with the requirements of the Labor Code of the Russian Federation.

6. Assessment of the state of the financial control system

6.1. Evaluation of the effectiveness of the internal control system in an institution is carried out by the subjects of internal control and is considered at special meetings held by the head of the institution.

6.2. Direct assessment of the adequacy, sufficiency and effectiveness of the internal control system, as well as control over compliance with internal control procedures are carried out by the internal control commission.

Within the specified powers, the internal control commission submits to the head of the institution the results of inspections of the effectiveness of existing internal control procedures and (if necessary) proposals developed jointly with the chief accountant for their improvement.

7. Final provisions

7.1. All changes and additions to this Regulation are approved by the head of the institution.

7.2. If, as a result of a change in the current legislation of the Russian Federation, certain articles of this Regulation come into conflict with it, these articles lose their force and the provisions of the current legislation of the Russian Federation take precedence.

Annex 1

Internal Control Commission

Annex 2

to the Regulation on internal financial control

Plan for audits and audits of financial and economic activities

Name of the issue to be checked (object of verification)	Checked period	Deadline	Responsible person
Checking the safety of funds and strict reporting forms
Checking the correctness of settlements with the budget, tax authorities, extra-budgetary funds and counterparties		Monthly on the last business day of the month	Chairman of the Internal Control Commission
Compliance with the established procedure for issuing advances for the report		Quarterly on the last business day of the month	Chairman of the Internal Control Commission
Checking the availability of acts of reconciliation with suppliers and contractors	half year		Chairman of the Internal Control Commission
Asset Inventory		Annually before compiling annual reporting forms	Chairman of the Internal Control Commission

Instructions for the use of the Unified Chart of Accounts for Accounting for State Authorities (Government Bodies), Local Self-Government Bodies, Management Bodies of State Extra-Budget Funds, State Academies of Sciences, State (Municipal) Institutions, approved. Order of the Ministry of Finance of the Russian Federation dated December 1, 2010 No. 157n.

The organization is obliged to organize and exercise internal control of the committed facts of economic life. And if its reporting is subject to mandatory audit, then it is obliged to conduct internal control of accounting and reporting. Such requirements are established by Article 19 of the Law of December 6, 2011 No. 402-FZ. Question: What regulatory acts should the organization prescribe the conduct of internal control? Who should be responsible for internal control? Should there be a separate provision on internal control? How often is the audit carried out and what document is this documented? Is there a model regulation on internal control in accordance with 402-FZ?

1) until 2013, the issue of creating an internal control service was the right of organizations. From January 1, 2013, in accordance with Article 19 of the Law of 06.12.2011 No. 402-FZ, all economic entities must exercise internal control over the facts of economic life, and those that are subject to mandatory audit, also internal control over accounting and preparation of financial statements. However, the Ministry of Finance of Russia has not yet developed recommendations on the organization and implementation of internal control of accounting and financial reporting by organizations. There is no standard provision on internal control in the legislation. A sample Regulation on internal control over financial and economic activities is presented in the materials in the full answer;

2) to exercise control over compliance with the procedure for maintaining accounting records and compiling financial statements, an internal control (audit) department may be organized;

3) the organization independently determines the frequency of conducting and reporting the results of inspections (for example, this may be an internal audit report). The legislation of the Russian Federation on accounting does not establish any restrictions on the order, methods, procedures for exercising internal control.

The rationale for this position is given below in the materials of the "Glavbukh System" commercial version.

1. Article:Internal control clause that protects against fraud

IVAN BORODIN, financial director of the Ankor personnel holding

Due to which: an internal control department was created, control procedures and quarterly inspection schedules were developed, complete inventories of fixed assets are regularly carried out.

The RusTorgInvest company specializes in the wholesale of car rims, tires, and auto parts. The company's plans for 2012-2013 include an increase in sales by 30 percent, including through expansion into regional markets. The business owners plan to attract financing for these purposes through the debut issue of bonds or the sale of a stake in the company to a strategic investor.

Top management thought about increasing the transparency and investment attractiveness of the business in advance. In 2011, a reorganization was carried out, a clear and transparent legal structure was built. Within the framework of the financial department, two departments have been created: international accounting and internal control. In addition, an accounting policy and an additional chart of accounts under IFRS were approved.

The next step was the regulation of the work of new departments. In particular, the Regulations on Internal Control over Financial and Economic Activities have been developed, which clearly spell out the main principles and control procedures, as well as list the duties and powers of employees and the head of the internal control department.*

The main task of the document is to protect the company from fraud and mistakes of its own employees. To this end, a number of control functions have been transferred to the structural divisions of the company, they independently monitor risks in their areas of activity.

In accordance with the main clauses of the provision, control procedures involve not only checking concluded contracts for compliance with the budget and selective control of primary documents, but also analyzing the indicators given in the company's statements for compliance with reality.

Special attention in the document is given to non-standard operations. For example, RusTorgInvest works with all new clients on the terms of the 100th prepayment, deviation from this rule is allowed in exceptional cases. Then the decision to grant a deferred payment is made only after agreement with the head of the internal control department, who analyzes the creditworthiness of a potential buyer.

The implemented control methods allow RusTorgInvest to mitigate existing risks and protect the company from abuse by employees.

comments
Alevtina Yashkina,
financial director of the company "RusTorgInvest"

Regulations on internal control over financial and economic activities (extract)*

You can download the full version of the Regulations on internal control over financial and economic activities developed by RusTorgInvest using the link at the end of the article.

1. General Provisions

1.1. This Regulation on internal control over the financial and economic activities of RusTorgInvest LLC (hereinafter referred to as the Regulation) is approved in accordance with the Civil Code of the Russian Federation, the charter of RusTorgInvest LLC (hereinafter referred to as the Company).

1.2. This regulation is an internal document of the company that defines the rules and approaches to ensuring internal control over the financial and economic activities of the company (hereinafter referred to as "internal control").

1.3. This regulation defines the goals and objectives of the internal control system, the principles of its functioning, the directions and procedures of internal control, the entities responsible for the implementation of internal control procedures, as well as the entities responsible for control over the implementation of internal control procedures.

2. Basic terms and definitions

For the purposes of this provision, the following terms and definitions are used.

"Internal control" is a process designed to provide reasonable guarantees for the achievement of the company's goals and the effective use of the company's resources, the safety of assets, compliance with legal requirements and the submission of reliable reports, and to prevent possible abuse by the company's officials.

Internal control procedures mean not only analysis of financial and economic indicators, but also existing business processes.

"Internal control procedures" - a documented set of measures to ensure effective internal control over the financial and economic activities of the company, identify and perform non-standard transactions, prevent, limit and prevent financial and operational risks and possible abuses by the company's officials, as well as measures on the interaction of subjects of internal control among themselves in the process of implementing internal control procedures.

"Subjects of internal control" - the board of directors, the general director, the division of the company authorized to exercise internal control, as well as other structural divisions and employees of the company responsible for the implementation of the internal control functions assigned to them (internal documents of the company).

4. Functions and powers of the internal control department

4.1. The internal control department is created on the basis of the order of the general director of the company (hereinafter referred to as the "director").

4.2. The department is created to exercise control over:

To determine the reliability of reporting historical performance data and forecasts for the future period provided by the financial department and divisions of the company are used.

the main directions of financial and economic activity;
observance of financial discipline;
ensuring the safety of funds and the validity of spending money and material assets;
completeness and reliability of accounting, tax and management accounting of the company
compliance of contracts with third parties and organizations with the financial and economic interests of the company;
compliance with the requirements of regulations, as well as internal documents of the company;
execution of the company's budget;
implementation of plans for financial and economic activities;
compliance with the requirements of current regulations and internal procedures established in the company.

In addition, the tasks of the department include:

carrying out measures for the protection of property;
assistance in creating an optimal organizational structure of society;
prevention and limitation of financial and operational risks, as well as possible abuse by officials.

When necessary for inspections employees of departments or external consultants may be involved.

4.3. The head of the department conducts inspections in accordance with the annual or quarterly plan developed by him - the schedule of inspections, which is subject to agreement with the board of directors of the company and is approved (corrected) by the director of the company (another person on his behalf), as well as unscheduled inspections by decision of the director of the company or a person authorized by him.

4.4. Organizational support and submission of the necessary documents for inspections are carried out by the heads of the structural divisions of the company within three working days, at the request of the head of the department or the director of the company.

The inspection report must be accompanied by explanatory notes, as well as copies of documents evidencing the elimination of identified violations, signed by the head of the audited unit.

4.5. The results of inspections carried out by the department are documented in an inspection act, which is signed by the members of the commission being created and the heads of divisions, branches and representative offices of the company whose activities were inspected.

4.5. The head of the department quarterly informs the board of directors of the company about violations in financial and economic activities identified as a result of inspections, including facts of non-performance, improper execution of internal documents approved by the company, and makes proposals for their elimination.

5. Duties and powers of the head of the internal control department

5.1. Head of Internal Control Department:

Before each test a program for its implementation is being developed, which contains the deadlines, procedures and instructions for what and how exactly will be checked.

distributes duties among the employees of his department, plans and organizes his work;
for each inspection planned by the department, forms and approves a program for its implementation;
convenes and holds meetings and meetings to discuss issues within the competence of the department;
requests from the management bodies and structural divisions of the company the documents and information necessary for carrying out internal control procedures;
has the right of unhindered access to all premises of the inspected structural divisions of the company;
has the right to organize complete or partial inventories of fixed assets, inventory items, cash and settlements with counterparties;
has the right to receive explanations and comments from the company's employees necessary for carrying out internal control procedures;
has the right to demand from the employees of the company to provide information on the execution of decisions of the management bodies of the company;
has the right to involve employees of other structural divisions of the company in conducting inspections and internal investigations;
has the right to make proposals on the application of material and non-material incentive measures to the employees of the company;
has the right to make proposals on the issues of bringing to responsibility for the committed violations of the guilty employees of the company;

9. Management bodies and subdivisions of the company responsible for internal control

9.1. The board of directors of the company determines the internal control policy and carries out a general assessment of the effectiveness of internal control procedures, as well as measures taken to eliminate identified violations.

9.2. The general director of the company is responsible for the functioning of the internal control procedures of the company.

9.3. Internal control is carried out in the main areas of the financial and economic activities of the company, including:

financial activities;
economic activity;
investment activity;
in other areas of the company's activities.

9.4. Heads of divisions of the company, within their powers, approved by local regulations, are responsible for the development, documentation, implementation, monitoring and development of internal control in the structural divisions entrusted to them.

9.5. In order to ensure the systemic nature of control over the financial and economic activities of the company, internal control procedures are carried out by the department of the company in cooperation with other bodies and divisions of the company.

2. Information of the Ministry of Finance of Russia No. PZ-10/2012 "On the entry into force on January 1, 2013 of the Federal Law of December 6, 2011 No. 402-FZ "On Accounting"

"INTERNAL CONTROL

In accordance with Article 19 of Federal Law No. 402-FZ, an economic entity is obliged to organize and exercise internal control over the facts of economic life. An economic entity, the accounting (financial) statements of which are subject to mandatory audit, is obliged to organize and exercise internal control over accounting and preparation of accounting (financial) statements (except for cases when the head of the economic entity has assumed the responsibility for accounting).

The legislation of the Russian Federation on accounting does not establish any restrictions on the procedure, methods, procedures for exercising the said internal control.”*