A comparative study of the public audit systems of the Republic of Korea and the Republic of Kazakhstan

Abstract

This study compares the public audit systems of the Republic of Korea and the Republic of Kazakhstan, focusing on institutional status, independence, governance, audit mandate, audit types, follow-up mechanisms, and relations with the executive, legislature, and citizens. The analysis uses a structured comparative-institutional method and qualitative content analysis of constitutions, audit legislation, official institutional materials, INTOSAI principles, and recent policy studies. Both countries place their supreme audit institution in a presidential institutional setting and combine financial and performance-oriented oversight. Nevertheless, their accountability designs diverge. Korea's Board of Audit and Inspection is a constitutionally established body under the President that is statutorily independent in the performance of its duties and uniquely combines account audit with inspection of public officials' duties. Kazakhstan's Supreme Audit Chamber, transformed in 2022, is directly accountable and subordinate to the President, concentrates on external state audit and financial control, and operates within a wider system that includes audit commissions and internal state audit bodies. The comparison demonstrates that formal location under the President does not by itself determine practical independence; appointment rules, collegial deliberation, audit-program autonomy, access to information, publication, legislative follow-up, and implementation monitoring are equally important. The study proposes reciprocal institutional learning: Kazakhstan may benefit from stronger publicly visible guarantees for operational autonomy and follow-up, while Korea may benefit from clearer differentiation between financial audit and personnel inspection and from more systematic performance-audit feedback. The findings contribute a functional framework for comparing presidentially situated supreme audit institutions.