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Limitations of internal control and recording control systems

ICAN Skills, Audit, Assurance and Forensics. Syllabus area B, the nature and use of internal control

10 min read · Updated 6 November 2026

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In this part

The owner of a small printing press in Ibadan approves every payment, signs every cheque, hires every worker and keeps the only set of books with one part-time clerk. There is no written procedure and no second pair of eyes. His honesty may be beyond doubt, yet the auditor cannot rely on his controls as she would on those of a bank with a hundred staff.

Every control system has limits, and small businesses have more of them. Auditors must know the limits, and must record what controls do exist in a form that can be reviewed and updated.

This topic covers why internal controls can fail, the special problems of small entities, why the auditor must record the system, and the three main methods of recording: narrative notes, flowcharts and questionnaires, including the internal control questionnaire and the internal control evaluation questionnaire. The next topic covers how the recorded controls are evaluated.

In 30 seconds

Limits: human error, cost, override by staff or management, and collusion. Small entities: segregation is hard; owner involvement is a partial substitute; expect more enquiry and more substantive testing. Record: because the understanding drives the approach. Methods: narrative notes (simple but long), flowcharts (visual but need skill) and questionnaires. ICQ: many yes/no questions looking for good news. ICEQ: a few key questions looking for bad news.

Key terms in plain English

TermWhat it means
CollusionTwo or more people acting together to avoid a control
OverrideIgnoring or bypassing a control
Narrative noteA written description of a system
FlowchartA diagram of the flow of documents and processes
ICQInternal control questionnaire
ICEQInternal control evaluation questionnaire

Syllabus check

This topic is in syllabus area B, the nature and use of internal control (20% of marks). It covers:

  • the limitations of internal control
  • how accounting systems and related controls are identified, recorded and analysed
  • the evaluation of internal controls

CAMA 2020 and recording controls

The Companies and Allied Matters Act 2020 (CAMA 2020) is the company law of Nigeria. The sections below apply to this topic.

SectionWhat it saysLink to this topic
s. 404(2)The report states whether proper books of account were keptRecording the system supports that opinion
s. 404(7)(d)The audit committee reviews the effectiveness of internal controlThe record is shared with the committee
s. 407(3)Right of access to books, accounts and vouchers and to information and explanationsHow the auditor obtains the information to record the system

The rules in more depth

Why internal controls may be ineffective

No internal control system is foolproof, however good it looks. The inherent limitations are:

  • Human error. People make mistakes, and a mistake in processing may not be caught by the control system.
  • Cost. It may not be cost-effective to set up some controls. A control that costs more than the loss it prevents is not worth having.
  • Override. Controls may exist, but employees or management may ignore or override them.
  • Collusion. Two or more people may work together to avoid a control, perhaps to commit fraud. Segregation of duties then fails, because the people who should check each other are acting together.

Modern auditing is built on testing systems and controls, but because of these limits the auditor never relies on control testing alone. The auditor always adds some testing of transactions and balances, called substantive testing, and the amount depends on how effective the controls are judged to be.

Other limits include controls aimed at usual transactions that do not catch unusual ones, changes in conditions that make controls out of date, and the judgement used in applying controls.

Problems for small entities

Many control activities found in a large company are too costly or impractical for a small one. Segregation of duties is the obvious case, because a company with a few staff cannot separate every task. The same person must do many things. Control often rests on the owner-manager, who personally authorises many transactions and reviews performance.

That involvement can reduce the risk caused by lack of segregation, so the attitude and actions of the owner become central to the auditor's risk assessment. There is usually no written code of conduct, so a culture of integrity shown by the owner's example is important. The auditor usually sees owner involvement as only a partial substitute for ordinary controls.

Problems arise when control depends too much on senior management:

  • there may be no evidence of how systems are supposed to work, so the auditor relies more on enquiry than on documents;
  • there may be no evidence that controls exist and operate;
  • management may override the controls that exist;
  • management may lack the expertise to control the entity; and
  • there is unlikely to be an independent person in management, as there would be among those charged with governance in a large entity.

The auditor must still understand and evaluate whatever controls exist, and plan the work accordingly. A lower level of reliance on controls is likely, and so a large amount of substantive testing.

Why the auditor records the system

The auditor must understand each of the five components of the control system. The understanding is needed to evaluate the system and assess audit risk, and the result decides whether the audit is systems-based or transactions-based. Work on controls is therefore an important part of gathering evidence, and, like other significant evidence, it must be documented in the working papers, probably on the permanent file.

Recording also lets the next year's team see what was found before, and lets a reviewer check that the evaluation was sound.

Recording methods

MethodWhat it isAdvantagesDisadvantages
Narrative notesA written description of the system and its controls, mainly of the control activities in processing transactionsSimple to prepare; needs no special skillCan become long; slow to prepare and to update when the system changes; weaknesses can be hard to see in long text
Systems flowchartA diagram that shows, for each type of transaction, the documents, the processes applied and the flow between departmentsImmediate visual impact; may show weaknesses more easily than narrative; shows who does whatNeeds expertise to draw and to use; best for standard systems; may not suit specialised areas
QuestionnaireA list of questions about controls in an area of operations or accountingStandard forms prepared in advance and used electronically; can be completed by juniors; also helps evaluationCan be long; may miss unusual features of the client's system

The internal control questionnaire (ICQ)

An ICQ is designed to establish whether appropriate controls exist to meet specific control objectives. Each question has a yes or no answer and deals with a particular control. Usually a yes shows a control strength and a no shows a weakness. For credit control, the questions might be: Are credit references taken on all new customers? Are credit limits set for customers?

To establish that the correct prices are charged on invoices, the question is: Is a check made to match the price on a sales invoice to the official price list? To establish that raw materials delivered are as ordered: Are raw materials counted and checked against the purchase order when delivered?

An ICQ records the system and helps the evaluation, since the yes and no answers give an overall picture of reliability. It is simple to complete, so a junior can do it. But it can be long and time-consuming.

Updating ICQs. Instead of drawing up new questionnaires each year, the auditor usually takes those from last year's file, checks them and updates them.

The steps are:

  • obtain last year's ICQs
  • look at the weaknesses they showed and find out whether the client has acted on them
  • check the accuracy of each ICQ by reviewing system documentation, interviewing staff and doing walk-through tests, and amend as needed
  • then, with an up-to-date set, assess whether weaknesses exist

The internal control evaluation questionnaire (ICEQ)

The ICEQ was developed in answer to the length of ICQs. It has a small number of key control questions designed to show whether major weaknesses may exist. With an ICQ the auditor looks for "good news", expecting to find particular controls. With an ICEQ the auditor looks for "bad news", the chance that controls are weak. A yes should again mean good control.

In the credit example, one ICEQ question might be: Is there reasonable assurance that goods can be dispatched only to authorised customers whose balance is within their credit limit? An ICEQ is shorter, but its questions are less precise and need more knowledge and experience to answer. The choice between them is the auditor's or the firm's. Both record and evaluate.

Choosing a method

Many firms combine methods: a flowchart for the main transaction flow, narrative notes for special features and a questionnaire to check that the usual controls exist. Whichever method is used, a walk-through test confirms that the record is accurate. For a small entity with simple processes, narrative notes may be enough. For a large, document-heavy system, a flowchart with a questionnaire is more efficient.

For computerised systems, firms use electronic questionnaires and may also use process-mapping software.

Worked examples

Example 1: limits. The accountant and the cashier of a company agree to hide cash shortages by altering each other's records.

  1. That is collusion, which defeats segregation of duties.
  2. It is an inherent limit, so the auditor still performs substantive tests.

Example 2: small entity. A shop has two staff, and the owner signs all cheques and reviews the sales summary weekly.

  1. The owner's involvement is a partial substitute for segregation.
  2. The auditor assesses the owner's integrity and the evidence that the review happens, and plans more substantive testing.

Example 3: write an ICQ question. The auditor wants to know whether payments are made only to approved suppliers.

  1. "Is every supplier paid from a list of approved suppliers? Yes/No."
  2. A yes is a strength; a no is a weakness.

Example 4: choose the method. The audit team must document a payroll process that passes through four departments, with many documents.

  1. A flowchart is suitable: it shows the flow of documents between departments.
  2. Narrative notes would be long, and a questionnaire alone would not show the flow.

How to score full marks

  • List the four limitations and explain collusion.
  • For small entities give the lack of segregation and the role of the owner.
  • Compare the three methods with a strength and weakness each.
  • Contrast the ICQ and the ICEQ: good news and bad news.

Common mistakes in the exam

  • Saying controls give absolute assurance.
  • Saying owner involvement removes the need for substantive testing.
  • Confusing the ICQ with the ICEQ.
  • Forgetting to document the system in the working papers.

Quick revision

  • Limits: error, cost, override, collusion.
  • Small entities: weak segregation, owner involvement, more substantive tests.
  • Record by narrative, flowchart, questionnaire.
  • ICQ: many questions; ICEQ: few key questions.

Practice questions

Questions 1 to 10 are multiple choice. Questions 11 to 13 are written. Try each before opening the answer.

Question 1. Collusion means:

  1. Two or more people working together to avoid a control
  2. A single error
  3. A computer fault
  4. A late report
Show the answer

A. It defeats segregation of duties.

Question 2. A reason a control may be missing is that it is:

  1. Not cost-effective
  2. Too cheap
  3. Required by tax law
  4. Free
Show the answer

A. Cost is a limit.

Question 3. In small entities, segregation of duties is:

  1. Hard to achieve
  2. Always achieved
  3. Illegal
  4. Not needed
Show the answer

A. Few staff.

Question 4. A partial substitute for segregation in a small entity is:

  1. Owner-manager involvement
  2. A bigger fee
  3. More staff
  4. A new logo
Show the answer

A. The owner authorises and reviews.

Question 5. Which is a method of recording internal control?

  1. Flowchart
  2. Tax return
  3. Share register
  4. Budget
Show the answer

A. Along with narrative notes and questionnaires.

Question 6. A disadvantage of narrative notes is that they:

  1. Become lengthy
  2. Need no skill
  3. Are visual
  4. Are always short
Show the answer

A. Slow to update.

Question 7. A flowchart shows:

  1. The flow of documents between departments
  2. Only totals
  3. The tax due
  4. The fee
Show the answer

A. A diagram of the system.

Question 8. An ICQ is designed so that a Yes shows:

  1. A control strength
  2. A weakness
  3. A fraud
  4. Nothing
Show the answer

A. Yes is a strength.

Question 9. An ICEQ looks for:

  1. Bad news about weak controls
  2. Good news only
  3. Tax errors
  4. Fees
Show the answer

A. A few key questions.

Question 10. The internal control record is normally kept on the:

  1. Permanent file
  2. Client's server only
  3. Tax file
  4. Registrar's file
Show the answer

A. It is of continuing significance.

Question 11 (10 marks). Explain the inherent limitations of internal control. (5 marks)

Question 12 (10 marks). Explain the audit problems of small entities whose controls depend on the owner-manager. (6 marks)

Question 13 (10 marks). Describe the three methods of recording internal control systems and compare the ICQ with the ICEQ. (9 marks)

Model answers

Show the model answer to Question 11

Human error; cost-effectiveness; override by staff or management; collusion. (1 each) The auditor therefore always supplements control tests with substantive testing. (1)

Show the model answer to Question 12

Lack of evidence of how systems should work, so more enquiry; lack of evidence that controls exist; management override; lack of expertise; no independent person; the auditor places lower reliance on controls and does more substantive testing. (1 each, to 6)

Show the model answer to Question 13

Narrative notes: simple but lengthy. (1.5) Flowcharts: visual and good for weaknesses but need skill. (1.5) Questionnaires: standard, easy to complete, can be long. (1.5) ICQ: many yes/no questions seeking good news; ICEQ: few key questions seeking bad news; less precise and needs more experience. (4.5)

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All Audit, Assurance and Forensics topics

You are reading topic 31 of 67.

  1. Meaning and objectives of audit, the need for audit and types of audit01
  2. Assurance engagements, levels of assurance and sustainability assurance02
  3. Statutory audit and the legal framework: CAMA 2020 and the FRC Act03
  4. International standards on auditing, assurance engagements and Nigerian standards04
  5. Obtaining and accepting a new audit engagement05
  6. Engagement letters: agreeing the terms of an audit engagement (ISA 210)06
  7. Fundamental ethical principles and the conceptual framework07
  8. Independence, objectivity and integrity of the auditor08
  9. Confidentiality in audit and assurance engagements09
  10. Conflicts of interest and resolving ethical conflicts10
  11. Non-compliance with laws and regulations (NOCLAR) and whistleblowing11
  12. Public interest and professional scepticism in audit and assurance12
  13. Rules-based and principles-based ethics, and ethics in governance13
  14. Internal audit: concept, role and its place in internal control14
  15. Internal audit compared with external audit15
  16. Operational and other internal audit assignments16
  17. Internal audit reports, regulation, ethics and outsourcing17
  18. Planning an audit (ISA 300)18
  19. Understanding the entity, its environment and its laws (ISA 315 and ISA 250)19
  20. Materiality in planning and performing an audit (ISA 320)20
  21. Audit risk and the auditor\u2019s response to assessed risks (ISA 330)21
  22. Fraud and the auditor (ISA 240)22
  23. Audit of not-for-profit organisations23
  24. Public sector audit24
  25. Audit evidence (ISA 500)25
  26. Audit documentation and working papers (ISA 230)26
  27. Audit sampling (ISA 530)27
  28. Importance, objectives and types of internal control28
  29. Control environment, the risk assessment process and monitoring of controls29
  30. Control activities and IT controls30
  31. Limitations of internal control and recording control systems31 here
  32. Evaluating controls and assessing audit risk32
  33. Risks of specialised IT systems and information security measures33
  34. Tests of controls and the main transaction cycles34
  35. The sales system: controls and tests of controls35
  36. The purchases and expenses system: controls and tests of controls36
  37. The payroll system: controls and tests of controls37
  38. The bank and cash system: controls and tests of controls38
  39. The inventory and non-current asset systems: controls and tests of controls39
  40. Management letters and reporting control deficiencies40
  41. Substantive procedures: role and approach41
  42. Analytical procedures (ISA 520)42
  43. Audit of tangible non-current assets43
  44. Audit of intangible non-current assets44
  45. Inventory: valuation and the physical count (ISA 501)45
  46. Trade receivables, prepayments and external confirmations (ISA 505)46
  47. Substantive procedures on bank and cash balances47
  48. Trade payables, accruals, provisions and contingencies48
  49. Non-current liabilities, equity and directors\u2019 emoluments49
  50. Key income statement figures50
  51. Written representations (ISA 580)51
  52. Evaluating misstatements (ISA 450) and the overall review of the financial statements52
  53. Purpose of the auditor\u2019s report and the audit expectation gap53
  54. The unmodified auditor\u2019s report (ISA 700)54
  55. Key audit matters (ISA 701) and reports prescribed by law55
  56. Audit reporting under CAMA 2020 and the audit committee56
  57. Going concern (ISA 570)57
  58. Modified opinions, emphasis of matter and other matter paragraphs58
  59. Information systems audit: risks, protection and the audit process59
  60. Vulnerability audit, data centre audit, banking transactions and IT audit reports60
  61. Data analytics, artificial intelligence, blockchain and other audit technology61
  62. Nature, objectives and types of forensic accounting services62
  63. Economic damage through contract and tort63
  64. Computer forensics, fraud investigation and litigation support64
  65. Hidden assets: how forensic accountants find them65
  66. Professional negligence in forensic investigations66
  67. The expert report and reporting in forensic engagements67
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