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Annual Audit Report·2025·Qualified · Opinion·Somali

FY 2025 Annual Audit Report (Xisaab-Xirka 2025), Somali Version

Puntland State Government (Whole of Government) · Published June 30, 2026

Executive Summary

Warbixinta Baarista Xisaab-Xirka Guud ee Dowladda Puntland ee sannad-maaliyadeedka 2025 — the official annual audit report of the Puntland State Government accounts for fiscal year ended 31 December 2025, published 30 June 2026 (Somali version, reference TIX: XHG/DPL/052/2026). The Auditor General issued a Qualified Opinion (Aragti Cillad Leh), citing unsupported expenditure totalling $21,390,477.60: $5,876,195.55 recorded in PFMIS as transiting the Government Bank without direct beneficiary identification, and $15,514,282.05 lacking complete supporting documentation (of which $7,360,743.00 had no payment request and $8,153,539.05 had incomplete signatures or approvals). Key audit matters include incomplete government debt registration — debts formally submitted to audit totalled $16,354,587.86, with additional unregistered obligations identified (Hantaara, electricity, water, internet and Gondogooye companies) — and material weaknesses in PFMIS and PUNTCAS system reconciliation against actual cash balances. The Emphasis of Matter section highlights $466.84M in budget-related funds that did not flow through the Government Central Treasury. Compliance findings cover non-compliant procurement of $7,098,793.00 (missing competition and evaluation documentation), withholding tax gaps, and regional revenue decline (Raas Caado: –61%, Mudug: –11%, Nugaal: –6%). Of the eight FY 2024 audit recommendations, six remained unimplemented and two were only partially implemented. Total expenditure executed via the Central Treasury was $107,832,303.55 against an approved budget of $124,542,106; domestic revenue collected was $101,926,831.01 (99.9% of the domestic revenue target of $102,000,420). The detailed findings on this page are drawn from the Somali edition; an English edition of this report is also available (see FY 2025 Annual Audit Report, English Version).

Audit Findings

F-001

Incomplete Supporting Documentation of Expenditures ($21.39M)

High Risk
Criteria

All government expenditure must be fully supported by complete documentation identifying the correct beneficiary, per Articles 11(2) and 33(4) of the Public Financial Management Law No. 09 of 15 August 2023.

Condition (What we found)

Expenditures totalling $21,390,477.60 were not fully supported. Of this, $5,876,195.55 was recorded in PFMIS as transiting the Government Bank for onward transfer to the beneficiary — the system did not show the final recipient. A further $15,514,282.05 lacked complete documentation: $7,360,743.00 was paid without the required payment or expenditure request, and $8,153,539.05 was paid on incomplete requests missing required signatures and approvals.

Cause (Why it happened)

Weak controls over expenditure authorisation, documentation requirements, and PFMIS data entry discipline.

Effect (Impact)

The existence, accuracy, and purpose of the affected expenditure could not be fully verified — the primary basis for the Qualified Opinion.

Recommendation

Enforce complete supporting documentation and beneficiary identification for every payment before processing. PFMIS entries must reflect the direct recipient, not an intermediary bank account.

F-002

Incomplete Government Debt Registration ($16.35M)

High Risk
Criteria

Government must maintain a complete and accurate register of all public debt obligations in accordance with Articles 36, 40, and 42 of the PFM Law.

Condition (What we found)

Debts formally submitted to audit totalled $16,354,587.86 (construction contracts: $4,907,423.17; personnel rights arrears: $12,273,115.69). However, additional obligations not recorded in official debt registers were identified during audit, including amounts owed to Hantaara, electricity, water, internet service providers, and Gondogooye company.

Cause (Why it happened)

Absence of a unified, comprehensive debt register and weak controls over recognising and recording all government liabilities.

Effect (Impact)

The financial statements do not fully present all government liabilities, understating actual public debt and limiting debt management oversight.

Recommendation

Establish a single, regularly updated debt register covering all government obligations. Conduct a full liability survey and reconcile against contractor and creditor records.

F-003

PFMIS and PUNTCAS System Reconciliation Weaknesses

Medium Risk
Criteria

Financial management information systems must produce data that accurately matches actual cash balances, revenue collected, and expenditure paid.

Condition (What we found)

The audit found that PFMIS and PUNTCAS data did not fully reconcile with actual revenue, expenditure, and bank balances. The financial statements rely heavily on outputs from these two systems, making their accuracy critical.

Cause (Why it happened)

Insufficient system controls, incomplete data entry, and lack of regular automated or manual reconciliation between system records and bank statements.

Effect (Impact)

Reduced reliability of financial reporting; potential for undetected errors or misstatements in government accounts.

Recommendation

Strengthen PFMIS and PUNTCAS controls, perform monthly reconciliations between system data and bank statements, and invest in system upgrades to improve accuracy and integration.

F-004

Non-Compliant Procurement Procedures ($7.10M)

High Risk
Criteria

Government contracts must be awarded through competitive open bidding with full documentation (planning, competition, evaluation, selection committee reports) per Article 5(1) of Procurement Law No. 8 of 16 August 2000.

Condition (What we found)

Contracts totalling $7,098,793.00 related to infrastructure development and government services were processed without the required procurement documentation — no planning records, competition evidence, evaluation reports, or selection committee minutes were available.

Cause (Why it happened)

Non-application of procurement rules and insufficient oversight of contracting processes across ministries.

Effect (Impact)

Reduced value for money, elevated corruption risk, and legal non-compliance in public contracting.

Recommendation

Subject all qualifying contracts to open competition and maintain complete procurement files. Establish central oversight to verify compliance before contract award.

F-005

Tax Withholding Non-Compliance and Revenue Management Gaps

Medium Risk
Criteria

Required withholding taxes must be deducted from applicable government payments per Tax Law No. 11 of 20 December 2023. Revenue must be fully documented and deposited promptly per Revenue Law No. 10 of 1 October 1999.

Condition (What we found)

Withholding taxes were not deducted from some government payments. Revenue documentation for a portion of collected revenue was incomplete. Some government revenue was held in cash beyond the legally permitted period before being deposited into government accounts.

Cause (Why it happened)

Gaps in payment processing controls, incomplete enforcement of revenue regulations, and inadequate supervision of revenue collection officers.

Effect (Impact)

Loss of government revenue, non-compliance with tax legislation, and reduced accountability over collected funds.

Recommendation

Enforce withholding tax deduction at point of payment. Require full documentation for all revenue collected and mandate timely deposit into the Treasury Single Account.

F-006

Significant Regional Revenue Decline

Medium Risk
Criteria

Government revenue collection should meet approved budget projections; significant shortfalls require investigation and corrective action.

Condition (What we found)

Revenue collected in Raas Caado (Raascasayr) declined by approximately 61% compared to the prior year. Mudug declined by approximately 11% and Nugaal by approximately 6%. Some districts had zero revenue recorded in FY 2025 despite having reported revenue in FY 2024.

Cause (Why it happened)

Possible combination of economic conditions, weaknesses in regional revenue administration, and gaps in oversight of district revenue collection.

Effect (Impact)

Material shortfall in regionally-sourced government revenue, reducing funds available for public services.

Recommendation

Conduct an urgent investigation into the causes of regional revenue decline. Strengthen oversight and capacity of regional revenue offices and introduce monthly revenue performance reporting.

F-007

Low Implementation Rate of Prior Year Recommendations (6 of 8 Not Implemented)

Medium Risk
Criteria

Management is expected to implement audit recommendations in a timely manner to strengthen financial controls and reduce recurring risks.

Condition (What we found)

Of the eight recommendations issued in the FY 2024 audit report, six were not implemented at all and two were only partially implemented. The unimplemented recommendations cover expenditure documentation, bank reconciliation, procurement compliance, Central Treasury channelling, and debt register completion.

Cause (Why it happened)

Insufficient prioritisation of audit follow-up, lack of accountability mechanisms for implementing recommendations, and capacity constraints.

Effect (Impact)

Recurring weaknesses in financial management — the same deficiencies identified in FY 2024 reappeared in FY 2025, compounding fiscal risk.

Recommendation

Establish a formal recommendation-tracking register with assigned owners and quarterly reporting to the Auditor General. Treat persistent non-implementation as an escalated governance concern.

Recommendations Tracker

RefAction RequiredStatus
R-001Enforce complete supporting documentation and direct beneficiary identification for every payment before processing; align PFMIS entries with final recipientsOutstanding
R-002Establish a unified, regularly updated debt register covering all government obligations including unrecorded creditor arrearsOutstanding
R-003Perform monthly reconciliations between PFMIS/PUNTCAS system data and bank statements; invest in system controls and upgradesOutstanding
R-004Subject all qualifying contracts to open competition with complete procurement files; establish central oversight before contract awardOutstanding
R-005Enforce withholding tax at point of payment; mandate full revenue documentation and timely deposit into the Treasury Single AccountOutstanding

Audit Details

Ministry
Puntland State Government (Whole of Government)
Audit Period
Fiscal Year 2025 (January – December 2025)
Published
June 30, 2026
Audit Team
Office of the Auditor General, Puntland
Expenditure Audited
$107.83M via Central Treasury

Findings Summary

High Risk
3
Medium Risk
4
Low Risk
0
Total Findings7

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