영국 국가감사제도에 대한 고찰 ― 소위 Westminster형 국가감사제도의 문제점과 시사점 ―

This paper examines the UK’s state audit system, the Westminster type, where the supreme audit institution (SAI) is considered as a part of the parliament under a parliamentary system. The UK state audit system has evolved to accommodate changes in national functions. As the function of the government has expanded, the UK state audit system has broadened the understanding of accountability; thus the focus of the audit is shifting from whether the state finances were used correctly to whether the national finances were used wisely. As a result, the UK state audit system, which started from a simple financial audit, evolved into a regularity audit and has evolved into a Value for Money (VFM) audit. Of course, VFM study can be used for political control of the executive branch. Therefore, the executive does not suspect that VFM audits can be a political or a policy audit, and it tends to pressure the National Audit Office by intervening in the VFM study. For this reason, the National Audit Office is trying to secure substantive independence from the executive branch in relation to audit work, especially VFM audit. Despite these reform efforts, the UK National Audit Office still has limitations that must be overcome in the course of carrying out audits. If we adopt the Westminster type national audit system under the parliamentary system in conjunction with the Korean constitutional amendment, the experiences of the UK could help us to anticipate the following problems. First, given the power structure peculiar to the parliamentary system, the new Supreme Audit Institution will not have strong powers of performance or policy audits. Second, if a committee to supervise the supreme audit institution within the National Assembly cannot protect SAI from external influences, the state audit work will be vulnerable to party politics.