Supreme Audit Institutions, Audit Recommendation Implementation, and Public Sector Accountability: A Comparative Systematic Review of Ghana and South Africa

Abstract

Supreme Audit Institutions (SAIs) play a pivotal role in promoting transparency, strengthening public financial management, and enhancing accountability within the public sector. However, the effectiveness of public auditing depends not only on the production of audit reports but also on the successful implementation of audit recommendations. This study systematically reviews the literature on Supreme Audit Institutions, the implementation of audit recommendations, and public sector accountability through a comparative analysis of Ghana and South Africa. Guided by the Preferred Reporting Items for Systematic Reviews and Meta-Analyses (PRISMA 2020) framework, the review synthesized evidence from 39 peer-reviewed studies, policy reports, and institutional publications published between 2010 and 2025. The findings reveal that while both countries possess constitutionally established SAIs with broad mandates for financial, compliance, and performance auditing, substantial differences exist in institutional independence, organizational capacity, enforcement mechanisms, and audit follow-up practices. South Africa demonstrates comparatively stronger institutional autonomy, financial independence, and legally enforceable audit follow-up systems, contributing to higher implementation of audit recommendations. In contrast, Ghana continues to face recurring challenges associated with political interference, resource constraints, weak enforcement, and inadequate coordination among oversight institutions, resulting in persistent audit findings across public institutions. The review further identifies political commitment, effective parliamentary oversight, organizational capacity, digital audit management systems, and transparent accountability mechanisms as critical determinants of successful implementation of audit recommendations. The study concludes that the effectiveness of Supreme Audit Institutions should be assessed not merely by the production of audit reports but by their ability to facilitate corrective action and improve governance outcomes. The review contributes to the public sector auditing literature by integrating institutional effectiveness with audit recommendation implementation and offers practical policy recommendations for strengthening accountability systems in Ghana, South Africa, and other African countries.