Procurement Anomalies
Section 36 Justification Quality
Scores the documented justification behind Treasury Regulation 16A6.4 / paragraph 36 deviations.
Why deviation justification is scrutinised
Treasury Regulation 16A6.4 and paragraph 36 of the SCM regulations permit deviation from competitive bidding only where it is impractical to invite competition, and the AGSA routinely disallows deviations whose justification is thin, generic or absent. A deviation is lawful only to the extent it is reasoned and recorded; a weak justification converts a permitted exception into irregular expenditure. AuditPro Core scores the documented rationale behind each deviation so accounting officers can see, and fix, the records that will not survive audit.
The Numbers
AuditPro Core renders this view from your tenant's live, tamper-evident records. The figures below are illustrative sample data.
Deviations Scored
412
full population
Weak Justification
147
35.7%
Boilerplate Reasons
89
▲ 18
Avg Justification Score
62/100
▼ 5
Deviations by Justification Score Band
Weakest Justifications by Value
| Deviation | Stated Reason | Score | Value (R'000) |
|---|---|---|---|
| DEV-3110 | Only supplier | 22 | 14200 |
| DEV-3144 | Time constraints | 31 | 9870 |
| DEV-3162 | Operational reasons | 28 | 7340 |
Figures shown are illustrative sample data for demonstration. AuditPro Core renders these views from your own tenant's live, tamper-evident records.
Impractical, not merely inconvenient
The test is whether competition was genuinely impractical, such as a sole-source proprietary need or a true emergency. Convenience, poor planning or time pressure created internally do not qualify.
The quality of the record
Justification must be specific to the transaction, signed by the delegated authority and dated before the commitment. A boilerplate reason reused across many deviations is a red flag in itself.
Reporting obligations
Deviations must be reported to the accounting officer and noted in the financial statements. A deviation that was approved but never reported remains irregular regardless of merit.
Scoring for triage
Assigning a quality score lets management focus remediation on the weakest justifications rather than re-reading every file, and gives oversight a defensible measure of control health.
How AuditPro Core Bridges the Gap
- Justification scoring: rates each deviation file on specificity, authority and timeliness to surface the weakest records.
- Exception workflow: low-scoring deviations are routed for additional motivation or write-up before reporting.
- Traceability to source: links every score to the signed deviation memo, approval and underlying order.
- Audit-ready export: compiles the deviation register with scores and evidence for the irregular-expenditure note.
Key Takeaways
- Deviation is lawful only where competition was genuinely impractical.
- Generic, reused justifications are the most common cause of disallowance.
- Approval without proper reporting still results in irregular expenditure.
- Score justifications to target remediation before audit, not after.
See This on Your Own Data
AuditPro Core renders this dashboard from your tenant's live, tamper-evident records — every figure traceable to source.