Secretary’s Circular No. 9 Of 2026

RE: Mandatory Regular Audits Of Government And Non-Government Schools By Internal And External Auditors Including The Engagements Audit Costs: Ministry Of Primary And Secondary Education.

1. Purpose and Legal Framework

Your attention is directed to the statutory requirements governing the financial administration and accountability of schools operating in Zimbabwe. In terms of Section 36, Section 38(5) and Section 66 of the Education Act [Chapter 25:04], as read with Section 36(1) of the Statutory Instrument 379 of 1998 and Section 22(1) of Statutory Instrument 87 of 1992, the Minister is mandated to approve or prescribe constitutions of the School Development Committee (SDC) and the School Services Funds (SSF), while the Secretary is legally mandated to subject and cause the auditing of the SDC Funds and the SSF for all Government established schools and all Non-Government registered schools. Such audits are hereby directed to be conducted on a mandatory regular basis by internal auditors and annual basis by external auditors unless otherwise when a school is granted authorised exemption upon request for a specified period of time.

2. Mandatory Annual Audits

All SDA, SDC and SSF Funds managed in terms of the above legal framework shall be subject to mandatory governance risk based regular internal and external annual audits in accordance with Section 121(1) of Statutory Instrument 144 of 2019.

a) Government Schools

School funds operating under Government SDC Funds and School Services Funds are classified as Statutory Funds under Section 18(1)(b) of the Public Finance Management Act [Chapter 22:19]. These Funds shall be audited by the Ministry’s Internal Auditors and or other Government Internal Auditors regularly based on risk, and External Auditors at least once every financial year. Responsible Authorities shall ensure that their schools submit management action plans accompanying the audit report for implementing the engagement audit recommendations at the time of the engagement completion and thereafter submit monthly updates on the registered progress implementation status (showing whether implemented 100%, not implemented, that is 0% implementation, or partially implemented within a range from 1% to 99% which should be specified) up to completion date stage. Any exception to the above shall need the approval of the Ministry — at the request of the School Head in liaison with the relevant Government Responsible Authority.

b) Non-Government Schools

All Schools under non-Government Responsible Authorities are to operate in line with their registration conditions under the Education Act. Therefore, they must subject their accounts to regular risk based internal audits and annual external audits by qualified independent auditors, and the resulting reports must be submitted to the Ministry supported with management implementation plans on the recommendations made by the auditors. Thereafter the school shall submit monthly updates of the registered progress implementation status (showing whether implemented 100%, not implemented, that is 0% implementation, or partially implemented within a range from 1% to 99% which should be specified) up to completion date stage. Any exception to the above shall need the approval of the Ministry at the request of the School Head in liaison with the relevant non-Government Responsible Authority.

3. Directives on funding of audit engagements

To ensure full compliance with the aforementioned legal frameworks, it is hereby directed that:

a) All established Government schools and registered Non-Government schools shall proactively budget for and fund their internal audit expenses and external audit fees, in close liaison with their respective Responsible Authorities.

b) For audits conducted by the Ministry’s Internal Auditors upon request, the Responsible Authorities shall ensure that funding covers only Travel and Subsistence (T&S) allowances. No audit fees shall be charged. The applicable T & S rates must strictly align with prevailing Government rates.

c) Responsible Authorities shall ensure that schools timeously submit all internal and external audit reports compiled by independent auditors to the District Office for formal monitoring, review and compilation of relevant Audit Review and Monitoring Returns to Provincial Office and Head Office on monthly basis for consolidation.

4. Audit compliance as a prerequisite for fees review

To enforce financial transparency and protect stakeholders, notice is hereby given that submission of a current, compliant audit report is now a mandatory prerequisite for any school fees or levies adjustment.

5. Strict enforcement notice

With immediate effect, the Ministry will not consider, process, or approve any application for a school fees review, adjustment, or maintenance of existing fees/levies from any school that fails to produce a current annual audit report. Non-compliant schools will automatically have their applications disqualified,

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