The Whole of Government Accounts consolidates the accounts of over 10,000 public sector bodies, including central and local government and public corporations such as the Bank of England, to provide the most complete and accurate picture of the UK’s public finances.
HM Treasury has published the Whole of Government Accounts for 2023-24. Gareth Davies, the Comptroller and Auditor General (C&AG), has disclaimed his opinion on the financial statements, providing no assurance to Parliament on the financial statements. This is due to severe backlogs in English local authority accounts and audits.
Here we share highlights from his audit certificate. You can read the full certificate and report on the accounts in context in the Whole of Government Accounts.
Disclaimed opinion on financial statements
I do not express an opinion on the financial statements of the WGA. Because of the significance of the matters described in the basis for Disclaimer of Opinions section of my certificate, I have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on these financial statements.
Basis for disclaimer of opinion
I have been unable to obtain sufficient appropriate audit evidence in respect of material transactions and balances within the WGA owing to the following:
HM Treasury has included within the WGAs draft accounts data for 280 entities (227 entities in 2022- 23). Due to the number of entities consolidated based upon unaudited data, the level of outstanding work from component auditors and the unconfirmed impact of uncorrected misstatements within this unaudited data, I am unable to determine whether the financial information provided by these entities is free from material misstatement to the WGA. The majority of unaudited entities are English local government bodies.
HM Treasury have not consolidated 201 entities which they identified should have been consolidated but which did not submit data in 2023- 24. There is a similar level of non-submission this year to the previous (211 entities in 2022-23) which means that there are still significantly material balances missing from all sections of the accounts. Based on information available to us from the prior year financial statements and other sources, I expect that this will be material to the WGA but in the absence of submissions it is not possible to reach a conclusion on the non-consolidation of information from these entities. The majority of missing entities are English local government bodies.
The absence of consolidation data and completed component audits has meant that I was unable to obtain sufficient appropriate audit evidence that the financial statements are free from material misstatement. It was not practicable to obtain audit evidence from alternative sources.
Other matters which would have led to a modification to my opinion had it not been disclaimed
As per ISA (UK) 705 I am required to report any other matters of which I am aware that would have required a modification to the opinion, and the effects thereof. In my opinion, based on the work undertaken in the course of the audit, the following matters would have been raised:
- the definition and application of the accounting boundary: HM Treasury’s accounting policy regarding the basis of consolidation has not been applied consistently in the WGA. Significant bodies, including the English Further Education Institutions, have not been included in the accounts, even though they are classified by the Office for National Statistics as being in the public sector. I consider that these bodies should be included in the accounts in line with applicable accounting standards.
- the inconsistent application of accounting policies: The financial reporting framework that the WGA must follow is set out in the Government Financial Reporting Manual which applies International Accounting Standards (IAS), as adapted for the public sector context. However, a number of bodies consolidated in the WGA do not adopt the same framework. Accounting standards require that where the effect of such inconsistent accounting policies is material, adjustments should be made upon consolidation. HM Treasury has not provided a full analysis of these differences and has not been able to quantify fully the impact of the different accounting frameworks or accounting policies on the WGA, but that impact is known to be material. The most significant example is infrastructure assets held by local authorities.
- underlying qualifications within statutory audits: The external auditors of the financial statements of a number of bodies that are consolidated into the WGA qualified their audit opinions. Of these, one is significant to the WGA, the qualification of the accounts of the Department of Health and Social Care which impacts on the opening balances as at 1 April 2022 within the comparative information of the WGA.
- the consolidation of components with non-coterminous year ends: International Financial Reporting Standard 10 ‘Consolidated financial statements’ (IFRS 10) presumes that, in order to present a true and fair view, the accounting reference date for component bodies consolidated into group accounts should be no more than three months different from the date of the group accounts. HM Treasury has not complied with the requirements of IFRS 10 in consolidating the Academy Schools in 2023-24 or for the 2022-23 comparatives.
Links to accounts
Whole of Government Accounts 2023-24
- C&AG’s audit certificate and report (pages 288 to 292)
Press release
View press release (17 Jul 2025)