Annex B - checklist of general areas of financial responsibility and delegated authority
The list below defines the main areas of financial responsibility and delegated authority associated with a written financial responsibility statement.
1. Policy Proposals, Reports and Reviews
You will ensure that you are following the SG guidance on Policy making and as part of that process you engage your Finance Business Partner (or equivalent) (and as necessary Internal Audit and Procurement) at the earliest possible stage in development of all policy proposals etc. which may have resource, control or other finance related implications and that they are kept informed of developments. The Finance Business Partner (or equivalent) is available to assist in development and must also be consulted on all responses to reports, reviews etc. with resource implications or which include issues of financial regularity, propriety, or accountability.
You will ensure that Risk Potential Assessment Forms are completed in respect of all policy proposals that meet the definition of a Major Investment in the Scottish Public Finance Manual, to determine whether they should be subject to Scottish Government Gateway Review. SG Internal Audit and Assurance directorate is the main source of advice on independent portfolio, programme and project assurance and these forms can be accessed from the - Portfolio, Programme and Project Assurance team.
2. Financial Memoranda - Scottish Government Bills
In preparing a Financial Memorandum to accompany a Scottish Government Bill, the Bill Team, in consultation with the Finance Business Partner (or equivalent) and other interested parties, will ensure full compliance with the requirements set out in the Standing Orders, in the Bill Handbook and in Finance Guidance Note 2025-03.
Bill Teams should engage with their Finance Business Partner (or equivalent) in good time and throughout the drafting process, and must clear Financial Memoranda before the draft Bill and accompanying documents are submitted for approval to Ministers, including the Cabinet Secretary for Finance.
3. Scottish Statutory Instruments
The Finance Business Partner (or equivalent) should also be consulted on any Scottish Statutory Instruments (SSIs) to ensure that the financial implications of the secondary legislation are considered and recorded.
4. Budget Planning, Budget Monitoring and Reporting
You will ensure you contribute effectively and in line with expected practice to public expenditure planning and monitoring exercises co-ordinated by DG Scottish Exchequer and the Chief Financial Officer supported by the Financial Management Directorate. Such exercises often underpin corporate reporting requirements to the Corporate Board and the Cabinet Secretary for Finance.
5. Certificates of Assurance
You will provide assurances (in the form of a signed Certificates of Assurance and an Internal Control Checklist) on the system of internal control within your business area. This enables you to provide the Portfolio Accountable Officer with the appropriate level of assurance. The Portfolio Accountable Officer will in turn provide an assurance to the Permanent Secretary as the Principal Accountable Officer for the Scottish Administration thereby supporting the signing of the governance statement provided as part of the Scottish Government consolidated accounts.
6. Risk Management
You will ensure that risks to the achievement of business objectives, regularity, propriety or value for money, are identified, assessed and that controls and actions (including any systems appropriate to the risks) are in place to manage them to an acceptable level and in line with the Scottish’s Government’s risk appetite approach.
You will also ensure that risks to your objectives are routinely reviewed, reported, and discussed throughout the year and in alignment with development and delivery of your business plan.
7. Fraud
If you suspect fraud or corruption, as part of your on-going management action, you should refer to the guidance on Fraud contained in the SPFM and follow the appropriate procedures.
8. Grant and Grant in Aid
You will ensure compliance with the principles on Grant and Grant in Aid as detailed within the SPFM and within specific SG guidance on the intranet.
9. Value for Money
You will seek to achieve value for money in relation to your allocated budget by ensuring that resources are used efficiently, effectively and economically as part of the broader principle of feasibility outlined in the SPFM Accountability section. The requirements of SPFM Appraisal and Evaluation section must be adhered to, particularly with regard to the need to prepare pre-expenditure assessments and business cases to demonstrate the value for money case and to evaluate the outturn of a project, programme or policy against its objectives.
Options appraisals, including financial appraisal and evaluation, are essential to good financial management, detailed policy development and design. They are also a key component to ensuring objective analysis is provided to support decision making. You will ensure that an appropriate appraisal has been carried out.
10. Best Value
You will ensure that arrangements have been made to secure Best Value from resources by pursuing continuous improvement and following the Best Value framework.
11. Business Planning/Performance Appraisal
You will ensure that delegated financial responsibilities are included, where appropriate, in Business Plans. For staff below Deputy Director level delegated financial responsibilities must be incorporated in job descriptions and objectives supporting the performance appraisal process as well as any local desk instructions.
12. New services or spending proposals
Any new services or spending proposals, which cannot be met from within existing agreed delegated Budgets, must be referred to Director level or Portfolio AO level as appropriate and to the relevant Finance Business Partner (or equivalent).
13. Novel or contentious spending proposal (including any ex-gratia payments)
Any proposals which might set a precedent or have repercussions elsewhere in the public sector must be referred for consideration to Director level or Portfolio AO level as appropriate and to the relevant Finance Business Partner (or equivalent).
14. Programme/Project Management
Effective management of major investment programmes and projects (as defined in the Major Investment Projects section of the SPFM) is essential to ensure that they deliver the specified outcome or output, to the agreed quality, timescale and budget. The Major Investment Projects section of the SPFM sets out the key steps and processes to be followed in managing a major investment programme or project. Projects which do not meet the thresholds for major investment should be managed in line with programme and project managment principles.
Portfolio Accountable Officers must be kept informed of progress on major investment programmes and projects and must inform Ministers if there are any developments that could undermine the planned budget or viability of the programme or project.
Where appropriate the involvement of the Investment Committee, which supports a consistent and sound evidence base for future financial commitments and projections, following the rules set out in the SPFM should also be considered.
15. Management of Assets
You will ensure that any assets within your command e.g. land, buildings, equipment are properly and well managed. Robust systems must be in place to ensure that the accuracy and integrity of information held on registers, databases and inventories is safeguarded and readily available for inspection.
Capitalised expenditure (PPE, Right of Use Assets, and Intangibles) must meet the approved corporate thresholds and definitions and be supported by Asset Addition forms. Any disposal of previously capitalised assets should be recorded correctly and supported by Asset Disposal forms. Business areas are responsible for maintaining records of attractive items, local investment registers and systems for the management of equipment.
16. Resource costs
Any proposal which has cost implications which cannot be managed within the funds or headcount available must be referred to Director level or Portfolio AO as appropriate and the Directorate Budget Centre Liaison Officer (DBCLO) or equivalent DG BCLO and to the relevant Finance Business Partner (or equivalent).
17. Public Sector Pay
Pay Policy/Pensions Team must be consulted on and agree any pay remit proposals or changes to pay and conditions of service. In addition, the relevant Finance Business Partner (or equivalent) should be consulted on affordability.
Public Sector Pay Policy (both staff pay remits and senior appointments) applies to those public sector bodies whose pay requires the approval of the Scottish Ministers. This includes the core SG, Non-Ministerial Departments who have their own pay bargaining units, Executive Agencies, Non-Departmental Public Bodies, Public Corporations, Tribunals, Appeals Boards, Advisory Committees and Inquiries, and ad hoc working groups.
18. Subsidy Control
You will consult the subsidy control team on all proposals which may have subsidy control implications. Subsidy control provisions are now covered by the UK Subsidy Control Act 2022 and the UK’s international obligations including various Free Trade Agreements and those arising as a consequence of World Trade Organisation membership. There are circumstances in which Subsidies are allowed however, Subsidy control issues must be considered as early as possible in the policy development stage. Any unlawful subsidies given in contravention of the UK Subsidy Control Act 2022, FTAs, and WTO – may result in infraction proceedings and the possible recovery, with interest, of the payment from the recipient. All relevant accounts may also be liable to qualification.
19. Debt Repayment
Any proposals regarding the early repayment of borrowing from Scottish Ministers will require the approval of Financial Management & Reporting.
20. Gifts
The prior approval of the relevant Finance Business Partner (or equivalent) is required for the making of any gift not covered by specific delegated authority. Gifts should, where practicable, be authorised by the Budget Act (as revised by Budget Amendment Order) and Budget Documents should be appropriately footnoted.
Any proposal to make a gift (or a prize in a competition) must be cleared at Director level and by the relevant Finance Business Partner (or equivalent). Gifts made or received by the SG must be reported in notes to the annual accounts. Individual gifts of more than £250,000 must be noted separately in the accounts.
21. Donations to Charity
Any proposal to make a donation to a charity from the approved budget must be authorised by the Portfolio Accountable Officer with appropriate advice from the relevant Finance Business Partner (or equivalent).
22. Disposal of Property
You must seek advice from the Property and Construction Division, PropertyandConstruction@gov.scot, when a disposal of property or an acquisition of property is being considered using the section Property acquisition, disposal and management of the SPFM. In addition business areas within the Scottish Administration, sponsored bodies and other bodies to which the SPFM is directly applicable must ensure that the Property and Construction Division and the relevant Finance Business Partner (or equivalent) are notified of any planned property disposal prior to the property being advertised on the open market.
Approval from the Cabinet Secretary for Finance is required for any transfers of land or buildings to a body outside the Scottish Administration. Property and Construction Division and the relevant Finance Business Partner (or equivalent) must be fully consulted on any proposals of this nature.
23. Financial Guarantee Contracts/Contingent Liabilities/Letters of Comfort
You must clear any proposals which will create a contingent liability with the relevant Finance Business Partner (or equivalent). All guarantees/indemnities/letters of comfort must be cleared by the Finance Business Partner (or equivalent) to ensure that appropriate accounting and budgetary implications are fully considered and that, if required, approval has been received from the Finance and Public Audit Committee before proceeding. A contingent liability includes any legally binding enforceable undertaking given in the form of a guarantee which would bind the SG into providing the resources in the event of the guarantee or indemnity maturing; or a general statement of comfort which could be considered to impose a moral financial obligation on the SG. It is an obligation based on a past event where it is either unclear if it will occur (future set of circumstances will set it in motion) or the amount of the obligation is unclear.
24. Resource Budget and Cash Management
As well as ensuring that consumption of the Budget Act resources for which you have responsibility is actively monitored against the approved Budget for the year, you will ensure also that budget managers provide Financial Management & Reporting, Health Finance or DG Scottish Exchequer, as appropriate, with accurate and robust profiles and forecasts of outturn for resource budget exercises (including for the medium-term). Additionally you will ensure monthly cash management forecasts are provided to Financial Operations Division, Treasury & Banking.
25. Payment Policy
You will ensure that staff, as far as possible (recognising that in certain instances invoices require some clarification) enable payments to be made promptly; where appropriate, in accordance with the SG target of payment within 10 working days of receipt of a valid invoice. In particular, you should ensure that purchase orders are raised accurately and receipted promptly once goods or services have been received.
26. Debt Management
You will ensure that your business areas follow the requirements outlined in the central Order to Cash Policy alongside the Income receivable and receipts requirements in the SPFM.
27. Divisional Procedures
You will ensure that your business areas follow the requirements outlined in the central Order to Cash Policy alongside the Income receivable and receipts requirements in the SPFM.
28. VAT
You will ensure that UK VAT legislation is complied with in all cases. In making any decisions on VAT the VAT guidance contained within the SPFM should be considered and complied with where applicable. In cases where there is any uncertainty with the correct VAT treatment to apply, advice must be sought from the VAT and CIS branch of Financial Operations Division.
Delegated Authority
1. Budgetary Authority
Budgetary authority is the authority to commit expenditure from a budget. Financial Responsibility Statements, from Portfolio Accountable Officers to Directors, will state clearly the budgets being delegated.
Directors, in sub-delegating to Deputy Directors, must similarly detail in writing the budgets being delegated. Sub-delegation from Deputy Directors, if deemed appropriate, must be in writing, and incorporated into job descriptions and if appropriate covered by appraisal objectives.
2. AO Spend Control Template process
All officials must comply with AO spending controls, with DGs, Directors and Deputy Directors having responsibility for promoting and supporting the processes within their teams. Spend control guidelines, including financial thresholds and what expenditure must follow the process, is subject to revision in year. Please refer to the Financial accountability and assurance section on the intranet for the current parameters.
Note that the AO spend control rules may be revised throughout the relevant financial year subject to achievement of the budget milestones. To note, AO templates are utilised in order to release expenditure and are not a substitute for other aspects of evidenced based policy making, such as business cases. It is essential that the SPFM is adhered to with respect to pre-expenditure assessments and business cases.
3. AO Assessments
An Accountabile Officer Assessment is separate to the AO spend control process and should be considered early and always be produced for all projects or programmes. It will build upon the work that the policy/implementation/budget-holder team have already done to produce advice to Ministers on the business case to proceed, initially in principle at an early point, then again as appropriate in more detail at suitable strategic points as the policy or proposal is developed. In practice, that means:
- Alongside the request for the Accountable Officer’s approval of the Outline Business Case
- at subsequent stages of the project if it departs from the AO standards or the agreed plan – including any contingency – in terms of costs, benefits, timescales, or level of risk, which informed the Accountable Officer’s previous approval.
- when looking to disinvest in a public sector asset or programme
- if the Senior Responsible Owner (SRO) of the project decides one is merited at any other stage of the project
SROs and AOs should be prepared to defend their decisions to Parliament if challenged, for example, if called to give evidence to the Public Audit Committee.
4. Losses and Write-Offs/ Special Payments (compensation, ex-gratia payments etc)
Directors require written delegated authority from the relevant Finance Business Partner (or equivalent) to write off losses or make special or other ex-gratia payments. The Finance Business Partner (or equivalent) must agree all proposals for delegation. Directors may, upon receiving a written delegation, sub-delegate authority in writing to Deputy Directors to facilitate business flow. However, the Director, the Finance Business Partner (or equivalent) and Financial Management & Reporting Team must be informed of all losses/write-offs and special payments in order to ensure that the appropriate accounting treatment is undertaken. In the absence of specific written agreement from the Finance Business Partner (or equivalent) there is no power delegated.
5, Delegated Purchasing Authority
Delegated Purchasing Authority (DPA) is the authority to enter into a contract for goods, services and works and oversee the process leading up to and including the award of a contract and any subsequent contract changes.
No SG member of staff can enter into a contract without written purchasing authority from the Director, Procurement and Property except using the electronic Purchasing Card (ePC) or a framework agreement awarded by Scottish Procurement and Property Directorate.
DPA is personal to an individual only whilst they occupy their current position. DPA does not automatically transfer to their successor should they leave their current post, nor does it transfer with them to another post. DPA is not reviewed annually. It is important therefore that DPA is incorporated into an individual’s job description and if DPA is to be withdrawn by the Director, Procurement and Property for any reason then this will be confirmed in writing.
DPA must not be confused with budgetary authority. Information on DPA is available on the Scottish Government Procurement Policy Manual.
6. Electronic Purchasing Card
The Electronic Purchasing Card (ePC) should be used for goods and services costing up to £5,000 per transaction excluding VAT. Using the card reduces the time required to raise and process large numbers of ad-hoc payments. Suppliers benefit by being paid a few days after despatching the goods or delivering the services.
Responsibility for the proper management and control of an ePC card must be incorporated into an individual’s job description and if appropriate covered by an appraisal objective.
It is the responsibility of business areas to ensure that VAT is recovered where possible and that they have a process in place to ensure this is covered.
7. Use of consultants
The use of business and management consultants can only be justified where the required knowledge and expertise is not available in-house. The SG Consultancy Procedures should be regarded as relevant good practice guidance. Specific prior approval levels for the SG are as follows:
Contracts up to £10,000 approved by a Deputy Director, between £10,000 and £50,000 approved by the relevant Director General and over £50,000 approved by the Cabinet Secretary for Finance.
8. Publication of Financial Transaction Data
Monthly reports of payments made by the SG in excess of £25,000 (over £25k reports) and electronic Purchasing Card (ePC) transactions of £500 and above (ePC500 reports) are published on the SG web site. Procedures, including timetables and deadlines, are in operation for pre-publication review of both over £25k and ePC500 reports. In both cases, designated contacts within business areas are responsible for initial pre-publication reviews. Affected business areas should ensure that initial pre-publication reviews are carried out timeously and accurately.
Page updated: July 2025