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A third line that actually works

The internal audit function, and the review of it.

Audit charterRisk-based planExternal quality reviewOutsourced internal audit
09 / Services

Internal Audit

Internal audit assesses governance, risk management and internal control throughout the year, for the board and management. A financial statement audit assesses one year of figures, for outside parties. Both are called audit, which is precisely how they get confused.

Article 3(3) of Law No. 5 of 2011 on Public Accountants permits a public accountant to provide services other than assurance where they relate to accounting, finance and management. Article 28(2)(c) of the same law identifies providing assurance and other services to the same client for the same financial year as a form of conflict of interest. This line is therefore offered to entities whose financial statements we do not audit for that year.

Engagements
  • Establishing the functionstructure, reporting line to the board, competency requirements, and a realistic first year.
  • Charter and risk-based plana charter that sets the mandate and authority, then an annual plan built from a risk assessment.
  • External review of internal audit performancethe independent assessment required of commercial banks, covering an opinion on the work, conformance with standards, and improvement proposals.
  • Outsourced engagementsperforming specific engagements for entities whose function is not yet complete, with responsibility remaining with management.
  • Methodology and working papersaudit universe, risk assessment, work programmes, findings, and follow-up tracked to closure.
Internal Audit

What the regulator requires

Commercial banks: a charter is mandatory

OJK Regulation No. 1/POJK.03/2019 on the Internal Audit Function at Commercial Banks, Article 10(1), requires banks to have an internal audit charter. Article 10(5) requires that charter to be reviewed at least once every three years.

01

The reviewer is appointed by the Board of Commissioners

Article 13(2)(c) of the same regulation requires the Board of Commissioners to appoint an independent external quality reviewer to review the internal audit unit’s performance, taking the Audit Committee’s recommendation into account.

02

Once every three years, reported to OJK

Article 21(1) sets the review at once every three years for the July to June period of the third following year, signed by the president director and president commissioner, and submitted within two months of the end of the review period.

03

Rural banks have their own regime

Governance for BPR and BPRS is set by OJK Regulation No. 9 of 2024. Its detailed requirements differ from those for commercial banks and must be read against core capital thresholds.

04

Outside financial services, the driver differs

For state-owned enterprises, listed issuers and government bodies, the internal audit obligation arises from their own sector rules rather than the OJK regulations above.

05

It starts with one conversation

The initial consultation is free of charge. Tell us where your company stands and we will help map the next step.

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