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The Scottish Public Finance Manual (SPFM) is issued by the Scottish Ministers to provide guidance on the proper handling and reporting of public funds.
The purpose of this note is to announce recent amendments to the Scottish Public Finance Manual (SPFM). The amendments are as follows:
1. Subsidy control
The section on EC State Aid rules has been replaced by a new section headed Subsidy control. This is to reflect that The EU State aid regime was effectively revoked from UK law from 1 January 2021. The purpose of this note is to highlight the key elements of this new chapter.
This guidance applies to all public authorities who grant subsidies and are responsible for ensuring they understand the UK’s commitments and comply with the obligations in relation to awarding subsidies from 1 January 2021.
The EU State aid regime was effectively revoked from UK law from 1 January 2021 except in limited circumstances (under the Northern Ireland Protocol and certain other cases set out in the UK-EU Withdrawal Agreement) and subsidy control provisions are now covered by the UK-EU Trade and Cooperation Agreement (TCA) and the UK’s international obligations including various Free Trade Agreements and those arising as a consequence of World Trade Organisation membership. This position may be subject if the UK Government establishing its own domestic subsidies control regime: a UK wide consultation on this is set to take place in the first half of 2021.
Subsidy control should be considered as early as possible in the policy development stage.
The Scottish Government’s Subsidy Control Team should be consulted on proposals being awarded under the new subsidy control regime.
This section of the SPFM relates to the assurance framework and the signing of the governance statements provided by Accountable Officers as part of the annual accounts process. The certificates of assurance guidance relates specifically to constituent parts of the Scottish Administration i.e. the core Scottish Government (SG), the Crown Office and Procurator Fiscal Service, SG Executive Agencies and non-ministerial departments.
The internal control checklist that underpins the assurances from Deputy Directors (or equivalents) to Directors (or equivalents) has been updated. The checklist still covers the same sections as previous versions but some questions have been reviewed, amended and guidance notes have been further developed across all questions. Please take the time to review the checklist to ensure you are aware of the amendments.
1. Risk management – The questions in this section have been fully reviewed but still cover previous requirements, However a further question 1.6 has been added asking areas to assess effective processes to ensure they are able to assess their appetite to key risks.
2. Business planning – Some of the questions have been reworded but content remains substantially the same with specific amendments to questions regarding alignment with National Performance Outcomes and Programme for Government.
5. Financial management – The section remains the same but with the replacement of one question 5.11 relating to the change noted above regarding the move from State Aid to Subsidy Control, teams should consult the Subsidy Control unit on all proposals that may have subsidy implications.
6. Fraud – Question 6.1 has been reworded to reflect teams responsibilities in prevention and detection of fraud. A further question 6.3 has been added asking teams if fraud prevention measures are built in their plans when new grant schemes or other spend programmes are being developed.
9. Equality and diversity – Some questions have been reworded but content remains substantially the same. 9.1 has been reworded to include legislative requirements or the impact on people with one or more of the Protected Characteristics listed in the Equality Act 2010.
10. Information – The majority of questions have been reviewed and amended with specific amendments to questions on, compliance with relevant legislation and processes in place for dealing with security incidents involving data. 10.4 has been amended to focus on the training of Information Asset Owners (IAO) and a new question at 10.5 has been created focusing on if supporting staff have an awareness of the role and responsibilities of an IAO.
11. Health and safety – The majority of questions have been reviewed and amended with specific changes to reflect the arrangements brought into place during the Covid-19 outbreak specifically in relation to risk assessment for essential workers, if staff are aware of the facility to request home working equipment, if teams have an appointed and trained Health and Safety Liaison Officer and if teams have mechanisms to keep in contact with staff who work for them if they are working from home.
12. Sponsored bodies – Some of the questions have been reviewed and amended with specific amendments to questions on, National Outcomes, Framework Documents, Effective boards, and procurement.
Update to the property section to change the approving Minister from Minister for Finance to Cabinet Secretary for Public Service Reform
Update to the model framework templates (in the documents section) and updating the Accountability secton to remove tables for accessibility
Update to the PAC section of the SPFM in line with the SPFM Strategic Review
Updates in ine with the SPFM strategic review to the following sections: Audit Committees, Certificates of Assurance, Delegated Authority, Fraud, Governance Statement and Procurement
Updatid an email in the VAT section.
Update to the contact page.
Updated links in the Internal Audit section and the Major Investment section.
Adding in Finance guidance note 2026/01 re 2025/26 CoA.
Updating the CoA checklist for 2025/26
Correcting a typo in the Major investment section.
Update to Major Investment section - removal of expired links to a Risk Potential Assessment (RPA) form.
Update to the Major Investment Section to remove 2 paragraphs re IIB.
Further text update to Annex 2 in the Counter Fraud section.
Text updates to the Counter Fraud section: Fraud, Annex 1, Annex 2 and Appendix 1. Also unpublished Annex 3 and Appendix 4.
Paragraph added at the start of Annex B: investment in businesses by Scottish Ministers, part of the Borrowing, lending and Investment section.
Updates to the Property, acquisition, disposal and Management section in line with the SPFM Strategic Review and request to take off line FGN 2024/03 AO Spend Control
Update to a link in the Major Investments section and the addition of FGN 2025/04 and FGN 2025/05.
Update to Major investment section - adding in a section on Digital Portfolio.
Updated links for all framework templates linked in the Accountability section.
Updates include the addition of annexes A, B, C and D. Annexes in the Delegated Authority section.
Update to footnote in the borrowing, lending, and investment section.
Updates to wording of Annex 2 Internal control checklist for Certificates of Assurance.
New FGN note added - FGN 2025/03 financial memoranda that accompany Scottish Government bills.
Updates to the following sections following SPFM Strategic Review: Foreword, Accountability (and annexes), risk and subsidy Control. Also the addition of FGN 2025/02 explaining the updates
Link in point 23 of Settlement, Severance, Early Retirement, Redundancy section updated.
numbering in Annex 2 Internal control checklist for Certificates of Assurance updated due to a typo
Updated Annex 2 Internal control checklist for Certificates of Assurance, added FGN 2025/01 re CoA checklist and added in a word version of the checklist.
updated missing text in document SPFM - Non-Ministerial Offices model framework document July 2024.
Adding in FGN 2024/03 re the updated AO Spend Control Template and Guidance.
Updating the SRO Appointment letter in the documents section to include a point on construction projects in the Annex.
Executive agencies model framework document updated.
Non-Ministerial Offices model framework document updated.
Updating the SRO Appointment letter in the documents section to this years dates
Updated link to 'On Board: A Guide for Members of Statutory Boards' within Governance statements chapter.
Updates made to model framework document templates.
Updates made to text within Procurement chapter.
Replaced non-ministerial office model framework document and advisory non-departmental public bodies model framework with updated versions.
Document updated with an additional date - Settlement Agreement supporting documentation - final confirmation of terms
Replaced Non-Ministerial Offices model framework document
Updates to the Settlement, Severance, Early Retirement and Redundancy section. The main section and Annex's A, B C have all been updated along with updated documents and a Finance Guidance Note to explain the changes
Updated the Certificates of Assurance chapter, Annex 2 with the CoA checklist questions for 2023/24 and added a Finance Guidance note outling the changes.
Updates made to proportionate due diligence wording, Accountable Officer tests guidance, risk exposure guidance, public bodies duties, monitoring and management, exit arrangements.
Procurement chapter updated.
Updated 'Major investment projects' paragraph 12 and the SRO appointment letter.
