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Implementation of whole of government reports in

Australia
a
Ron Day
a
University of Sydney
Published online: 29 May 2009.

To cite this article: Ron Day (2009) Implementation of whole of government reports in Australia, Public Money &
Management, 29:4, 229-234, DOI: 10.1080/09540960903034992

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Implementation of whole of
government reports in Australia
Ron Day
The 20-year history of whole of government reports (WGR) implementation in
Australia has some important lessons for other countries. These include factors
that need to be considered regarding the process, the positive influences that
contributed to successful implementation that are worth replicating, and negative
influences and pitfalls to avoid. Effective implementation requires commitment to
realistic objectives, timetables and scale.
Australia, along with New Zealand, has been a
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leader of public sector financial reform and a
pioneer in the preparation of whole of
government reports (WGR) (see Funnell and
Cooper, 1998; Guthrie, 1998; Pallot, 2001;
Carlin, 2005; Newberry and Pont-Newby,
2009). The UK is currently in the process of
implementing a whole of government
accounting (WGA) project, but has experienced
considerable delays and implementation
difficulties (Chow et al., 2007, 2008, 2009; Heald
and Georgiou, 2009). Indeed, ten years after
the project was first adopted by the Treasury,
it has still not published a single WGA report.
In light of this experience, Chow et al. (2008)
questioned whether the UK had learnt from
the implementation experiences of early
adopters, such as Australia and New Zealand.
Accordingly, they suggested that ‘it would be
prudent for countries considering the
implementation for similar consolidated public
sector accounting systems to ensure that they
have absorbed the lessons from “pioneer”
countries’ (Chow et al., 2008, p. 5).
While Newberry and Pont-Newby (2009)
have examined the pioneering efforts and
evolution of WGRs in New Zealand, this article
focuses on the lessons to be learnt from the 20-
year history of implementation of WGRs in
Australia. This includes an analysis of the
implementation process, and what has
facilitated and what has hindered it, during
this time.
Events and challenges impacting on the
development of WGRs in Australia
Although New Zealand was the first sovereign
government to implement accrual accounting
for its public sector and produce a WGR in
1991–92 (Christensen, 2003), the New South
Wales State government first prepared
consolidated WGRs in December 1989
© 2009 THE AUTHOR
JOURNAL COMPILATION © 2009 CIPFA
229
(covering the years 1987–88 and 1988–89), in Ron Day is a lecturer
response to recommendations by the NSW in accounting and a
Commission of Audit in 1988 (Funnell and PhD student at the
Cooper, 1998). These were formally published University of Sydney.
from 1989 and subject to full audits from 1993
(Walker, 2009).
Until 1997 these reports were on a modified
cash basis and included the budget sector and
statutory authorities, but thereafter they were
prepared on a full accrual basis with their scope
expanded to encompass all entities in the
general government sector, public trading
enterprises and non-commercial public
financial enterprises. They excluded local
government bodies, universities and other
entities not controlled by the state (Funnell and
Cooper, 1998). From the mid to late nineties,
some other Australian government
jurisdictions, such as Western Australia,
Queensland, Victoria and the ACT, began the
process of developing and publishing their
first WGRs
Commonwealth (federal) government
Recommendations for consolidated accrual-
based WGRs for the Commonwealth
government were made by the Joint Committee
of Public Accounts (JCPA, 1995) after a review
of developments of WGRs in pioneering
Australian states and in New Zealand. A
timetable and review process was established
for implementation, a model set of exemplar
annual reports for 1994–95 were presented, a
trial set of un-audited statements prepared for
1995–96, a full audited set of statements in
1996–97, before publication of full accrual-
based reports in 1999–2000.
These WGRs included a consolidation of
entities controlled by the Commonwealth
government, rather than representing a single
WGR for the nation overall. This was because
the Australian constitution only conferred
DOI:10.1080/09540960903034992
PUBLIC MONEY & MANAGEMENT JULY 2009
 230
certain powers and responsibilities to the
Commonwealth, with residual powers and
responsibilities remaining under the
jurisdiction of the state governments. Whereas
some state governments introduced WGRs for
their jurisdictions earlier than the
Commonwealth, it was not until 2002–03 that
all the Australian states and territories had
adopted accrual-based consolidated WGRs
(Wise, 2006).
Accounting concepts and standards
Standard-setters had an important influence on
these developments. The Australian Accounting
Standards Board (AASB) and the Public Sector
Accounting Standards Board (PSASB) jointly
issued Statement of Accounting Concepts No. 1
(SAC 1) in August 1990. This required all
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reporting entities to prepare general purpose
financial reports (GPFRs), based on relevant
Australian Accounting Standards (AAS). It
defined ‘reporting entities’ (those that had to
comply with it) as: ‘all entities (including economic
entities) in which it is reasonable to expect the
existence of users dependent on GPFRs for
information which will be useful to them for
making and evaluating decisions about the
allocation of scarce resources’ (SAC 1, para. 40).
So SAC 1 had implications for the
Commonwealth, state and territory governments
because (by definition) each was a reporting
entity.
The PSASB was active in the development
of Exposure Draft ED 62 (AARF, 1995), which
specified the consolidation of the entities
controlled by each government reporting
entity jurisdiction. This proposed standard
was influential on the thinking of the JCPA
(Barrett, 1996, p. 56) and was used as the
basis to prepare trial WGRs (Funnell and
Cooper, 1998, p. 196). ED 62 was later issued
as AAS 31 Financial Reporting by Governments
in June 1998 requiring and guiding the
implementation of WGRs on a full accrual
basis for the Commonwealth and each state
and territory government.
The aim for WGRs under AAS 31 was for
each government to provide a comprehensive
summary of all of its financial activities,
including its assets, liabilities, revenues and
expenses, regardless of whether these arose
directly or through separate entities
controlled by the government, such as
government departments and government
trading enterprises. It required the
presentation of consolidated statements
showing operating performance, financial
position, cash flows, and notes to the accounts,
PUBLIC MONEY & MANAGEMENT JULY 2009
based on relevant accounting standards. In
addition, it required disclosure of
disaggregated information about each sector,
and suggested that these be based on the
definitions of the Government Finance
Statistics (GFS) framework. These included
the general government sector, the public
financial corporations sector and public non-
financial corporations sector.
Implementing AAS 31
While Micallef (1997, p. 39) claimed that AAS
31 would put Australia at the forefront of
developments in public sector reporting, and
that it represented an international benchmark,
Barrett (2001) said that right from its
introduction there were ‘difficulties in
implementing some aspects of the originally
envisaged financial reporting framework
[which] led to amendments to, and extension
of, some transitional provisions contained in
the standard’. These difficulties impacted the
quality and consistency of financial reporting
(Miley and Read, 1999), and resulted in
repeated qualified audit opinion reports on
the financial statements for several government
jurisdictions (Barrett, 2001) For example, a
study by Wise (2006) found that of Australia’s
nine WGRs for the period 1999–2000 and
2003–04, four in 1999–2000 and five in 2003–
04, received audit qualifications for ‘the failure
to include all assets or obligations or the failure
to value these items appropriately’ (Wise, 2006).
These problems ranged from procedural
failures, uncertainty or different interpretations
in applications of the concept of control, and
issues of valuation.
Changes in the regulatory environment
There were major changes to the Australian
regulatory environment from 2000 to 2005,
which influenced how WGRs were
implemented and developed. In the first
significant change in June 2000, a new AASB
was formed from a merger of the previous
AASB and PSASB (Ryan et al., 2007). The new
AASB was given the power to set standards for
both the corporate and not-for-profit sector
and adopted a ‘sector neutral’ policy issuing
one series of accounting standards, applicable
to both the profit and not-for-profit entities.
Further, a Financial Reporting Council (FRC)
was established to oversee the AASB, including
the role of setting its strategic direction. In
2002, the FRC issued two strategic directives to
the AASB which would have a major influence
on public sector accounting and WGR
reporting.
© 2009 THE AUTHOR
JOURNAL COMPILATION © 2009 CIPFA

Sector neutral reporting
The first FRC directive, in June 2002, required
the AASB to adopt Australian equivalents of
International Financial Reporting Standards
(AIFRS) from 1 January 2005. The AASB made
these applicable to both profit, and not-for-
profit entities, by continuing its ‘sector neutral’
policy, notwithstanding the IFRSs having been
developed by the International Accounting
Standards Board (IASB) for the for-profit
sector. In an attempt to overcome this issue, to
assist with the application of this policy, the
AASB inserted separately identified Aus
paragraphs into Australia’s version of the IFRSs.
These contained requirements and guidelines
on how they were to be implemented by not-
for-profit, including public sector and
government, reporting entities.
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Application of ‘control’ to public sector reporting
entities
AASB 127—Consolidated Accounts and Separate
Financial Statements—was first issued in July
2004 as part of the suite of new standards
introduced prior to the adoption of IFRS in
2005. It was reissued in 2008. AASB 127
provides an example of how the decision to
apply private sector concepts in IFRS standards
to government and public sector reporting
entities was operationalized. It specified
‘control’ as the criterion requiring and
authorizing the preparation of consolidated
financial statements, defining it as ‘the power
to govern the financial and operating policies
of an entity, so as to obtain benefits from its
activities’ (AASB 127, para. 4). Therefore,
preparing consolidated WGRs for government
reporting entities involves applying
consolidation techniques to its departments,
directly-funded agencies, and all other entities
that it controls, to report its overall whole of
government performance and financial
position.
Guidance on the application of control for
public sector entities was provided in the Aus
paragraphs in AASB 127 and through relevant
paragraphs of AAS 31. (Later, all such guidance
was provided in the Aus paragraphs.) Therefore
while AASB 127, para. 13 outlines the settings
in which ‘power to control’ normally exists in
the private sector; Aus 17.1–17.10 describes
factors indicating control and when a group
constitutes a public sector reporting entity.
Aus 17.2 explains that control could be
established for a government reporting entity
where:
•The other entity is accountable to parliament,
© 2009 THE AUTHOR
JOURNAL COMPILATION © 2009 CIPFA
231
or to the executive, or to a particular minister.
•Where the government has the residual
financial interest in the net assets of the
other entity.
Aus 17.8 also states that, for a government to
control an entity, it must have the power to
require the entity’s assets to be deployed towards
achieving government objectives. However, Aus
17.9 outlines circumstances where this does
not apply, such as where this power is presently
not exercisable—as in the case of state
governments over elected local governments,
or if acting as a trustee and it cannot benefit
from the resources or residual net assets.
Convergence of GFS and GAAP
A second FRC strategic directive was
announced in December 2002. It was to develop
a standard to converge the GAAP and the GFS
framework in a single WGR for each
government jurisdiction. The background to
this directive was that governments were
historically required to report financial
information on a Government Financial
Statistics (GFS) basis to meet specific needs—
such as presenting budgets and compiling the
national account statistics. Since 1991 this
information had been reported to accord with
an agreed Uniform Presentation Framework
(UPF) to provide a common core of comparable
financial information relating to each
government’s results and projections. In 1988,
a Charter of Budget Honesty Act was
introduced requiring Commonwealth
government budget outcome reports to be
based on external reporting standards, and
for any departures to be disclosed. This resulted
in it producing GFS cash-based reports in
addition to accrual-based reports based on
GAAP and AAS standards (including AAS 31).
In 2002, the Australian Bureau of Statistics
developed an accrual-based GFS framework
which became the primary format for
governments to present their budgets and
outcome reports even though they were also
preparing WGRs based on GAAP, in
accordance with accounting standards.
This duality of government accrual
financial reports caused confusion for users,
and increased the potential for
opportunistically reporting headline results
based on the different frameworks (Challen
and Jeffrey, 2003; Wines and Scarborough,
2006). A further problem was that GFS outcome
reports were not required to be audited as they
were not based on Australian accounting
standards.
PUBLIC MONEY & MANAGEMENT JULY 2009
 232
AASB 1049: whole of government and general
government sector financial reporting
The Heads of Treasuries of the various
government jurisdictions proposed in 2003
that a specific standard be issued harmonizing
the GAAP and GFS frameworks for the
preparation of WGRs. In response, the AASB
implemented a staged approach, by first issuing
AASB 1049—Financial Reporting of General
Government Sectors by Government—in September
2006. The scope of the report would include all
government units and non-profit institutions
controlled and mainly financed by the particular
Commonwealth, state or territory government.
The balance sheet allowed for a partial
consolidation by including the proportional
interests in other sectors as investment assets,
valued at ‘fair value’. It also required that the
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outcome statements be directly comparable
with relevant budget statements, and that a
reconciliation of differences be provided.
The second stage was implemented by
reissuing the standard as AASB 1049—Whole of
Government and General Government Sector
Financial Reporting in October 2007—and
making it applicable from 1 July 2008. This
reissued standard expanded the scope of the
WGR to include the general government sector,
the public non-financial corporations sector,
and the public financial corporations sector. It
required a separate presentation of the general
government sector report, which was deemed
to be a reporting entity, and a WGR for the total
public sector (although still excluding local
government). To avoid confusion, it also
required that the general government sector
report not be published before the WGR. While
a third stage including local government was
originally envisaged, the AASB reconsidered
and adjusted its plans, claiming that there was
no need, as the standard had met the
requirements of the FRC directive.
So the development of WGRs in the
Australian context was far from smooth. In
particular, the changes in the regulatory
environment that influenced and shaped WGR
implementation were somewhat unpredictable.
These presented difficult challenges to the
AASB in terms of maintaining the sector neutral
policy that it had steadfastly embarked on since
2000.
Lessons
Implementation is an evolving process over time
The outline of events in the development of
WGRs in Australia reveals that implementation
was a process requiring continuous adaptation
and refinement in response to problems, issues
PUBLIC MONEY & MANAGEMENT JULY 2009
and challenges as they arose over time. That is
evident in the planning stage of WGR
development involving a series of trial runs
and a continual review process (Funnell and
Cooper, 1998, p. 159). Latent traps and hurdles
are also evident in the attempt to implement an
accounting standard on government financial
reporting (AAS 31) which proved to be
problematic, and resulted in a number of
amendments and extensions of transitional
provisions (Barrett, 2001). In addition, a
number of qualified audit opinions on WGRs
over the years highlighted issues and generated
debates on the application of the notion of
control and on the valuation of some public
sector assets (Wise, 2006). Many of these issues
are ongoing and have yet to be resolved.
Changes in the regulatory environment
also required the AASB to make major decisions
and adapt to its circumstances. For example, it
responded to the FRC directive to adopt IFRS,
by its decision to continue with its sector neutral
policy by inserting special Aus paragraphs into
AIFRS standards, to guide the application of its
for-profit concepts to not-for-profit reporting
and public sector entities. In addition, the
confusion caused by the existence of a duality
of government financial reports based on
different frameworks led to a second FRC
directive to harmonize the GFS and GAAP
frameworks in a single WGR, culminating in
the issue of AASB 1049.
Realistic and achievable scale and timetable
Given that WGRs have been produced, and
nearly all within their scheduled timetables,
the Australian implementation process can be
considered to be relatively successful. One
explanation for this is that the implementation
projects were spread across nine separate state
government jurisdictions, and took place at
different times between 1989 and 2002. In
addition, the first WGR, developed for New
South Wales, was relatively simple, given that it
was on a cash rather than an accrual basis.
Although the Commonwealth and other states
later adopted accrual accounting reports, none
of the consolidations have included local
governments and trusts. This has kept the
implementation to a small and achievable scale.
In addition, it was also possible for some
governments to learn from the implementation
experiences of others.
Accounting systems need to be ready and able to cope
with the collecting the information required
Although the scale of the consolidation projects
for the various government may have been
© 2009 THE AUTHOR
JOURNAL COMPILATION © 2009 CIPFA

relatively small, there were still a number of
implementation problems for the various
government jurisdictions. For example Moll et
al. (2004, p. 16) cite Barrett (1997) noting that
‘claims that eliminating inter-entity transactions
has been problematic, largely because many of
the agencies did/do not have systems in place to
collect such information’.
The timing of implementation should avoid
implementation of other reforms
A positive aspect of the Australian experience
has been that most of the government
jurisdictions had adopted accrual accounting,
and a number of other budgeting and reporting
reforms, before the implementation of WGRs.
As a result, many of the related issues had
already been confronted. Difficulties were
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caused, however, by FRC Directive 1 and FRC
Directive 2 being issued just six months apart.
This put pressure on the AASB to work on
harmonization of GFS and GAAP for WGRs
while it was busy trying to meet the adoption of
IFRS by 2005.
Use accounting standards for WGRs
One of the distinguishing features of the
Australian implementation of WGRs was the
early issue of AAS 31—Financial Reporting by
Governments—to guide the preparation of
WGRs, and to address anticipated problems of
using private sector reporting concepts in the
public sector context. Later, in planning to
adopt IFRS, the AASB chose to issue AIFRS
standards with additional Aus paragraphs that
it deemed necessary to guide not-for-profit
entities to apply the standards. With respect to
consolidated financial statements, this policy
enabled it to maintain its conceptual basis of
‘control’ for consolidation decisions, as well as
its sector neutral policy. Critics may argue that
these modifications meant that Australia did
not truly adopt IFRS or maintain a true sector
neutral policy. However, this approach
provided a more effective guidance, authority
and consistency, than would otherwise have
been the case.
Applying the private sector concept of ‘control’ to the
public sector creates difficulties
Determining control and applying the
reporting entity concept to the general
government sector and total public sector posed
several problems in the Australian experience.
Barrett (2001) and Wise (2006) provide
examples of qualified audit opinions arising
from the omission of entities that governments
claimed they did not control. One reason
© 2009 THE AUTHOR
JOURNAL COMPILATION © 2009 CIPFA
233
suggested for these differences in interpretation
was that the concept was originally designed
for private sector group arrangements not for
public sector and governments. For example,
Challen and Jeffery (2005, p. 76) argue that:
‘AAS 31 contrives to apply the control test to
require fully consolidated whole of government
general purpose financial statements [however]
there is no specific government entity which
exercises control over government businesses
and other statutory bodies in the normal sense
in which the term ‘control’ is used in the for-
profit sector’. Of course such a comment is
contestable—for what is normal and the way
control is exercised in the for-profit sector is far
from unequivocal.
Avoid confusion over GFS and GAAP reports
The duality of government financial reports
caused confusion, and it was argued that they
‘may encourage governments to indulge in
presentation shopping’ (Challen and Jeffrey,
2003) and the opportunistic use of GFS or
GAAP based figures to report headline results
(Wines and Scarborough, 2006). This issue was
seen as an urgent priority by the FRC, requiring
the AASB to issue an accounting standard that
attempts to harmonize both frameworks into a
single WGR report.
Conclusion—progress despite tensions
This examination of the implementation and
development of WGR in Australia has exposed
the underpinning tensions surrounding the
key events, and the decisions made by
governments, standard-setters and auditors,
in response to issues, challenges and changes to
the regulatory environment. The lessons from
the history of the development of WGRs in
Australia relate to those difficulties and
challenges in the process—which is still to
achieve a practice that is uniform and
comparable across its nine government
jurisdictions. It is not surprising, therefore,
that the UK’s more ambitious and broader
ranging WGA project, over a shorter timeframe,
is experiencing difficulties and delays.
It is clear from the Australian experience
that effective implementation requires
commitment to realistic objectives, timetables
and scale. Further, those involved in the
process have to make effective and timely
responses to problems and issues as they
arise. A final observation is about the role
that can be played by the accounting
profession and standard-setters in guiding
the implementation process. In the
Australian context, they were instrumental
PUBLIC MONEY & MANAGEMENT JULY 2009
 234
in the development of WGRs from the
beginning with their exposure drafts and
then issue of accounting standards on
government financial reporting (for example
AAS 31). Importantly, they made timely
responses to the major challenges that arose
in their domain from (possibly unanticipated)
changes to the regulatory environment. ■
Acknowledgements
The author would like to thank participants at
the 2008 ‘Whole of government financial
reporting: international trends workshop’ and
the two anonymous reviewers for their helpful
comments and feedback.
He also gratefully acknowledges the receipt
of a research grant from the Faculty of
Economics and Business, the University of
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Sydney, and assistance from his supervisor,
Professor James Guthrie, and from Professor
Susan Newberry, as well as editorial help from
Fiona Crawford.
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