Abstract
Background: Generally Recognised Accounting Practice (GRAP) 109 Standard on accounting by principals and agents became effective in the 2019 fiscal year. The Standard aims to enhance financial reporting through explicit guidance for identifying, recognising and disclosing principal and agent relationships. However, South African municipalities have continued to face challenges in complying with GRAP requirements.
Aim: The aim of this study is to investigate whether South African metropolitan municipalities consistently disclose principal–agent relationships as per the GRAP 109 requirements.
Setting: The study focused on the eight South African metro municipalities: large urban settlements with high population densities and complex and diversified economies.
Methods: The research followed a qualitative approach to analyse the principal–agent disclosure practices of eight metropolitan municipalities’ annual reports.
Results: The findings revealed disparities in GRAP 109 compliance among the eight municipalities. Six municipalities aligned with GRAP 109 requirements in their accounting policies, whereas two lacked explicit policies, affecting their ability to recognise and disclose principal–agent relationships accurately.
Conclusion: Municipalities are still struggling to comply with the disclosure requirement as evidence shows a lack of improvement.
Contribution: This study contributes to the post-implementation review of GRAP 109 by identifying trends and gaps in compliance across South African metropolitan municipalities.
Keywords: accounting policy; disclosure; GRAP 109; implementation review; metropolitan municipalities; principal–agent arrangement; public sector.
Introduction
The public sector entities use accounting standards to provide financial statements to demonstrate accountability to the public for funds utilised to provide services to their constituents (Kidwell & Lowensohn 2019). In terms of the Public Finance Management Act (PFMA) No. 1 of 1999, section 89, as amended, the Accounting Standard Board (ASB) has the responsibility to determine generally recognised accounting practice (GRAP). In line with this responsibility, the ASB issued GRAP 109 on accounting by principals and agents. This standard became effective in the 2019 fiscal year. The main aim of the standard is to account for principal–agent arrangements. The ASB (2015) issued this new standard because there was no authoritative guidance from the International Public Sector Accounting Standards Board (IPSASB) or the International Accounting Standards Board (IASB) for identifying principals and agents’ relationships.
Generally Recognised Accounting Practice standards are currently applied by constitutional entities, public further education training colleges, municipalities and municipal entities (Lubbe & Mkubukeli 2016). It is anticipated that the primary benefit of GRAP 109 will be improving the quality, comparability and consistency of financial reporting in the public sector by GRAP users (ASB 2024; Scott, Wingard & Van Biljon 2016). It is crucial to correctly identify principal–agent relationships to have the relevant transactions reported by the appropriate entity to prevent double reporting and underreporting of revenues, expenses, assets and liabilities (ASB 2022a; Du et al. 2023; South African Accounting Academy [SAAA] 2022). Moreover, the standard generally aligns with global objectives of openness and transparency in public financial management, especially as public attention and related audit findings turn to weaknesses in municipal financial reporting (Haustein & Lorson 2023; Rizki, Hali & Kusumawati 2024; Tawiah & Soobaroyen 202).
Notwithstanding the clear nature of the standard and the objectives it tried to meet, public entities, such as municipalities, have consistently struggled to apply GRAP 109 constructively (SAAA 2024). Fourie and Poggenpoel (2017) report that challenges in the public sector are yet to be successfully addressed. Post-implementation reviews (PIRs) by the ASB have indicated considerable difficulties in applying the standard in practice. These challenges include differentiating principal–agent relationships from other types of contracts, interpreting public disclosure directives and continuously using a generic accounting criterion that does not consider individual entity characteristics (ASB 2024). These challenges are further exacerbated by structural, systemic problems at the local government level, such as limited financial management capacity, high staff turnover and dependence on consultants for financial reporting (Abu Haija et al. 2021; Accountancy South Africa [ASA] 2023). Juanda, Setyawan and Inata (2023) also add that disclosure levels in municipalities are often limited.
The South African Law Reform Commission’s (2019) report indicated that municipalities hardly cope with reporting the Municipal Finance Management Act (MFMA) requirements. This report was released in the year in which GRAP 109 became effective. Ajam (2025) also notes that there is a failure in enforcing compliance with the municipal financial management regulatory framework in South Africa. The GRAP 109 did not become an exception, which was evident in the case Auditor-General of SA v MEC for Economic Opportunities, Western Cape and Another (2021); the Auditor-General of South Africa (AGSA) found that the Western Cape Provincial Department of Agriculture incorrectly classified the payments made to suppliers as transfers instead of as payments for goods and services because the suppliers received the payments as department agents. Therefore, the AGSA issued a qualified audit report for the department. The AGSA’s contention depended on principal–agent relationships between the department and the suppliers. The matter resulted in a court case where the court ruled against AGSA. Although this case involves departments, municipalities also struggle with preparing financial statements because of skills shortages (ASA 2023).
South Africa’s eight metropolitan municipalities, with high population levels, broad service delivery functions and complicated financial arrangements are critical to the country’s operation and funding (Municipal Demarcation Board [MDB] 2018; Republic of South Africa 2022). Because of their magnitude, financial clout and strategic role in public sector management, Scott (2008) proposes that the level of transparency and detail in the GRAP financial statements, and the well-defined and described GRAP results in world-class municipal financial reporting. Non-adherence undermines the credibility of the financial statements, affects stakeholders’ confidence and hinders effective supervision, among others, through the AGSA (2022b)
This study seeks to contribute to the PIR of GRAP 109 and raise awareness among policymakers and local government finance practitioners in South Africa about the shortcomings of the practical implementation and areas for improvement in interpreting and applying this standard. This article is an academic contribution as academics play an important role in the PIR and research indicates that they are often an underutilised but indispensable resource to the process (Ewert & Wagenhofer 2012).
Problem statement
Implementing new accounting standards brings multiple challenges (PWC 2018). Generally Recognised Accounting Practice 109 has proven no different. As a new standard purporting to enhance identifying and disclosing principal–agent relationships, GRAP 109 requires a degree of technical interpretation and professional judgement that most municipalities have found challenging to consistently apply (Ajam 2025). Financial statement disclosure is a fundamental part of public accountability; it is a means by which a society, including citizens and oversight bodies, determines how public funds are used (Dewi, Azam & Yusof 2019). Clear and standard disclosures facilitate comparability between reporting entities, enhancing trust in the public financial management system (AGSA 2022; Sari 2023). However, various reports prepared by the Auditor-General and ASB have identified ongoing failures to adhere to disclosure requirements, such as those in GRAP 109.
This article adds to this discussion by examining whether GRAP 109 serves its intended purposes or whether its complexity has inadvertently given rise to new compliance issues. This question is particularly relevant, given the few independent, academic-led assessments of implementing GRAP in the South African public sector. Therefore, the following research question was formulated: Are the South African metropolitan municipalities consistently disclosing principal–agent relationships as per the GRAP 109 requirements?
Literature
In June 2015, the ASB issued GRAP 109 on Accounting by Principals and Agents (ASB 2022). This standard applies to all entities preparing their financial statements following the GRAP standard (SAAA 2022). Generally Recognised Accounting Practice 109 was developed to help assess the arrangement and determine whether it is a principal–agent arrangement before applying other GRAP standards (National Treasury 2021). The principal–agent arrangement assessment ensures that the correct entity recognises the rights and obligations (SAAA 2022). Principal–agent arrangements arise because entities must work together or with other external parties to fulfil their mandated roles and responsibilities (AGSA 2021). Engaging with another entity or external parties will not automatically be a principal–agent arrangement. Thus, GRAP 109 must ensure a proper assessment of the arrangement (SAAA 2022).
Obtaining financial statements is done by identifying transactions or information related to finance or having economic value and then recording, compiling and processing based on the standards made, in this case, GRAP 109 (Nareswari 2017). Generally Recognised Accounting Practice 109 explains the recognition, measurement and disclosure requirements. Determining whether an entity acts as a principal or agent requires judgement and considering all relevant facts and circumstances (IPSAS 2001). An entity uses this standard to determine whether it is a principal or agent and, in doing so, determines the revenue and expenses that qualify for recognition in its financial statements by the applicable GRAP 109 (2015) standards. However, GRAP 109 does not prescribe new recognition and measurement requirements for revenue, expenses, assets and liabilities (ASB 2022a).
When an arrangement meets the principal and agent arrangement criteria, the disclosure requirement of GRAP 109 should be adhered to in the financial statements of the implementing agent and principal entity (AGSA 2022). Regarding the disclosure, GRAP 109 requires an entity to disclose its role in the arrangement and its judgement when making the assessment, purpose, terms and conditions of the arrangement, risks and benefits of the relationship, including whether there were any changes during the reporting period, and finally, the transaction from the arrangement (ASB 2022a).
Section 122(1) of the MFMA 56 of 2003 requires municipalities to prepare financial statements. According to Narastri (2022), financial reports provide quantitative and qualitative information on an entity. Financial statements have long stages, from identifying transactions to publishing comprehensive information. The parties who present the financial report must include as much information as possible. It is the public’s right to know how the public sector managers have spent their money when fulfilling their duties and accountabilities (Abu Bakar & Saleh 2011). Ferlie and Pollitt (2005) state that disclosing information to the public is the primary means to provide broader and better accountability. The ASB must improve financial reporting in the public sector by maintaining and enhancing existing GRAP standards and developing new standards where gaps are identified, thus developing GRAP 109 (ASB 2020b).
Effective service delivery requires accountability and sound financial management (Ngwenya & Majam 2011). Financial disclosure mirrors the pattern of accountability in government and the political system (Rayegan et al. 2012). Bagwandeen (2010) states that disclosure is a feature of transparency. Accounting Standard Board (2022a) mentions the following about accountability:
In discharging its accountability, an entity that is a party to a principal–agent arrangement provides information enabling users to decide whether principal–agent arrangements effectively meet their purpose in delivering services. GRAP 109 requires information on principal–agent arrangements and related transactions in the financial statements to meet users’ needs. (p. 4)
Accounting is the art of recording transactions as best as possible to enable the reader to arrive at judgements and conclusions. Therefore, set guidelines are critical, and these guidelines are generally called accounting policies (Mahajan & Baburao 2016). Accounting policies are the assumptions, methods and practices entities apply when preparing financial statements (IASB 2016). The quality of financial statements depends on the accounting policies (Raičević 2021). Levine and Smith (2011) opine that for the disclosure of accounting policies to be informative, it cannot be generic. The usefulness of financial statements might be tainted because of disclosed accounting policies, including boilerplate and generic accounting policy disclosures (Van Zyl 2017).
According to Enache et al. (2022), new accounting standards are becoming more complex than their predecessors, and the labour cost of implementing such standards is high because of the need for accountants with relevant expertise. Morais (2019) states that the complexity of the standards is also because of continuous revisions and amendments, making it challenging to understand over time. This complexity presents a new challenge to the entities because they still fail to comply with the old GRAP standard. The 2022–2023 MFMA general audit report from the AGSA (2023) reported that the quality of financial reporting has not yet improved because municipalities still rely on audit processes to identify misstatements for correction. The 2021–2022 PFMA general audit report from the AGSA (2022) reported that credible financial statements enable accountability and transparency. Still, more than half of the auditees continue to submit poor-quality financial statements for auditing. This inconsistency points to systemic issues within compliance with established standards, which are essential for enhancing stakeholder accountability and trust.
Fourie and Poggenpoel (2017) researched public sector inefficiencies. They express that compliance with financial regulations is also a constant challenge and add that there were no or very few consequences when regulations were contravened, resulting in the continual recurrence of non-compliance findings. Implementing a new accounting standard can create significant challenges for companies that must adapt to changes in accounting and financial reporting systems, train staff and update information systems (Guerreiro, Rodrigues & Craig 2008).
The AGSA (2017) found that South Africa does not fully comply with the GRAP standard, resulting in significant problems with the quality of its public sector accounts. According to Abu Haija et al. (2021), one reason for non-compliance with the accounting standards in South Africa is the lack of resources and skills. This lack has been evident in the municipalities’ high use of consultants to address skills shortages. Auditor-General South Africa (2017) also indicates that inadequate or missing documentation for accounts disclosed in the financial statements is the primary reason for the audit report’s qualified, adverse disclaimer opinion. However, in research on the determinants of accounting changes around International Financial Reporting Standards (IFRS) adoption, Christensen et al. (2015) conclude that the quality of financial reporting and compliance improves over time because of experience and a better understanding of the standard.
The ASB (2022b) conducted a PIR, which was undertaken in two phases. The first phase was to identify issues with the application and the second phase included receiving feedback from the preparers, auditors and users. The following are observations from Phase 1:
- Accounting policies were found to be generic and included the exact wording from GRAP 109 rather than explaining how the principles were applied to the entity’s circumstances.
- Entities struggle the most to apply GRAP 109 when identifying principal–agent arrangements. Entities have difficulty distinguishing principal–agent arrangements from other arrangements and are unsure of the Standards to apply when an arrangement is not a principal–agent one. Economic substance over legal form is not applied. Entities incorrectly interpret various aspects of defining principal–agent arrangements, including the role of third parties and the types of transactions with third parties that could be principal–agent arrangements.
- Entities are unsure whether materiality should be applied to principal–agent arrangements and, if so, how to apply it.
- Agents are unsure when it is appropriate to recognise assets and liabilities from the principal’s transactions with third parties and question the value of the information to users in the agent’s financial statements. Other stakeholders view the information as crucial to hold the agent accountable for the resources of the principal that are in the agent’s custody.
- Disclosure of information required by GRAP 109 is incomplete in the financial statements of principals and agents.
The ASB (2024) review of the PIR of GRAP 109 reports many issues with disclosure requirements. Two such issues were that the information is not always available and that some disclosure requirements are unclear. Accounting Standard Board further states that these issues lead to entities’ non-compliance with GRAP 109 disclosure requirements.
The ASB (2024) reviewed principal versus agent considerations. Among other reported challenges, the research respondents also reported application challenges relating to the disclosure requirements. Therefore, applying the disclosure requirements has been challenging for the public and IFRS users, primarily in the private sector, leaving GRAP users with no reliable reference point.
In the IFRS (2024) review on principal versus agent considerations, the research respondents also reported application challenges relating to the disclosure requirements, among other reported challenges. The research shows that applying the disclosure requirements has been challenging for the public sector and IFRS users, mainly in the private sector, leaving GRAP users with no appropriate reference point.
This study academically contributes to the review already conducted. Barth (2018) argues that research is based on theory and the scientific method and, thus, is conceptually sound and internally consistent. Academics are also unbiased because they have no stake in the outcome. Ewert and Wagenhofer (2012) state that academics are crucial in the PIR, and research indicates they are often underutilised but indispensable to the process.
Research methods and design
The study employed a qualitative research method comprising an inductive content analysis. Basri (2014) defines qualitative research as a process of inquiry that draws data from the context in which events occur to describe these occurrences. According to De Villiers, Dumay and Maroun (2019), qualitative studies provide an overview of the theoretical framework, explain how the theory was used in the research context and offer data to support the resulting conclusions. This study adopted a content analysis and inductive theory approach. The content analysis method was selected because it seeks to analyse published information systematically and objectively (Guthrie et al. 2004:287). The inductive approach is also recommended if there is not enough former knowledge about the phenomenon or if this knowledge is fragmented (Elo & Kyngäs 2008). The researcher used content analysis to examine the text to comprehend the meaning and message (Krippendorff 2013:18).
A purposive sampling technique was used because all eight metropolitan municipalities were selected as study sample. Municipalities are chosen because, according to the National Treasury (1999), they are the sphere of government closest to the people and are responsible for delivering basic services and infrastructure to households. According to Etikan, Musa and Alkassim (2016), purposive sampling uses participants’ qualities. They also claim that total population sampling (TPS) is one method that can be used under purposive sampling. The TPS is a technique where the entire population that meets the criteria is included in the research. As all eight metropolitan municipalities are included, this is called a census. Krippendorff (2004) refers to the census as a body of text that includes all its kinds.
A recent study by Daruhadi and Sopiati (2024) indicates that data collection involves systematically gathering, measuring and analysing information to tackle a research problem. Successful data collection ensures that research findings possess credibility, reliability and validity, enabling researchers to derive significant conclusions (Dewi 2021). The researcher downloaded the audited Annual Financial Statements (AFSs) of the metropolitan municipalities from the previous 4 years to assess their application of the requirements. The AFSs were used as the primary data source. The researcher downloaded these reports from the official websites of all eight metropolitan municipalities covering the past 4 years. Cuny et al. (2021) posit that annual reports represent critical information sources in documentation analysis because they consolidate practice regarding financial disclosure. These reports provide objective, publicly available data to analyse and allow the analysis of longitudinal disclosure trends (Brown & Weber 2022).
The research employed thematic analysis to determine patterns and prevailing themes after Braun and Clarke’s (2006) and Bryman’s (2016) step-by-step approach. This methodological approach ensured a systematic, rigorous and reproducible analysis according to qualitative research best practices. A structured comparative table was developed to assess compliance with GRAP 109 accounting policies systematically. Included in the table were all categories needed in an accounting policy according to GRAP 3.
In compliance with the institutional r elements. The most frequently observed esearch guidelines, the metropolitan municipalities analysed in this study were assigned pseudonyms to maintain anonymity and adherence to qualitative research best practices. Each South African metropolitan municipality was assigned an alphabetical identity, from Municipality A to H. This method was implemented to enable unbiased comparison analysis.
A content analysis was conducted to investigate the disclosure of principal–agent connections by metropolitan municipalities in their AFSs. The analysis of the annual reports commenced with data familiarisation, during which the reports were examined to comprehend financial disclosures. Open coding was performed to categorise the data into significant classifications (Daruhadi & Sopiati 2024). The recurring patterns from the data analysed were categorised into themes and developed through iterative review and cross-validation, assuring rigour and reproducibility in the findings. The identified themes were further studied by analysing accounting policy disclosures to determine whether they were addressed. They were represented in a comparative table.
The GRAP checklist from the National Treasury was downloaded and used as a benchmark for evaluating municipal disclosures to assess compliance with national disclosure requirements. The analysis followed a structured table format, where the first column contained the 15 key disclosure requirements. Each municipality’s disclosure notes were examined, and compliance was recorded in a table. All eight municipalities were systematically analysed (Appendix A to Appendix H). The results were summarised graphically using average compliance scores to provide a comparative overview of municipal adherence to GRAP regulations.
Ethical considerations
Ethical approval to conduct this study was obtained from the Economic and Management Sciences Research Ethics Committee (EMS-REC) on 03/09/2024 (No. NWU-01792-24-A4).
Results and discussion
The study used content analysis of the AFSs from 2019/2020 to those of 2022/2023 financial years to explore whether South African metropolitan municipalities are disclosing principal–agent relationships as required by GRAP 109 to achieve the research objective of the study. The analysis analysed the disclosure of notes, which included the principal–agent arrangement accounting policy and the disclosure of accounting by principals and agents, as contained in the municipal annual report, to identify whether they align with the disclosure requirements per the GRAP 109 standard. In this study, the first analysis investigated whether the accounting policies align with GRAP 109 requirements, and the second stage evaluated the detailed note disclosures on real principal–agent relationships.
This two-tier approach aimed to evaluate the extent to which the formal policy aligned with GRAP 109, practical application and disclosure consistency. This differentiation is crucial because research established that local authorities often make formal compliance when implementing boilerplate accounting policies without necessarily inculcating the standard into practice (ASB 2024; Van Zyl 2017). Comparing these policies and actual disclosure content, the study finds evidence of strengths and gaps in GRAP 109 implementation and patterns of improvement or continuing non-compliance over time. The findings presented in the following sections provide evidence of the differences among municipalities and year-to-year variations, all of which add to our general understanding of financial transparency and accountability at the local level of government in South Africa.
Accounting policies: Accounting by principals and agents
Accounting policies describe how an entity has elected to account for similar transactions in preparing and presenting its financial statement (National Treasury 2020). The guideline by the National Treasury (2020) further states that the following basic principles must be addressed at a minimum when developing the accounting policies: initial recognition, initial measurement, subsequent measurement, impairment, derecognition and presentation (where relevant). However, GRAP 109 primarily deals with guidance that must be followed in assessing the nature of the principal–agent arrangement before considering other GRAP standards. Principles analysed for accounting policy were the definition and identification of the principal–agent arrangement, revenue and expenses, and accounting of the principal–agent arrangement using other standards, analysed in Table 1.
| TABLE 1: Results of the analysis of the accounting policy disclosed by municipalities. |
Table 1 shows that six municipalities (A, C, D, E, G and H) disclosed an accounting policy aligned with the GRAP requirements. The findings show that Municipalities B and F did not disclose the policy in line with GRAP requirements. The policies disclosed did not meet the requirements because they described the actual principal–agent arrangements between the municipality and one agent and one principal. The policy did not explain the principles followed in analysing the arrangement as expected. The data for Municipality F, the lack of an accounting policy, also resulted in the municipality being unable to appropriately identify a principal–agent arrangement. For the reporting periods 2019/2020 and 2020/2021, Municipality F identified its arrangement with a third party as a principal–agent arrangement. However, in the 2021/2022 reporting period, the municipality concluded that the same arrangement was not a principal–agent one. The lack of an accounting policy resulted in undefined reporting criteria that the municipality employs to recognise and create a principal–agent relationship.
Table 1 illustrates the analysis results of the accounting policies revealed by municipalities, revealing that Municipalities B and F are classified as ‘Not compliant’ on ‘Overall compliance’. In addition, under the section ‘Definition and identification of principal/agent relationship’, both municipalities are designated with an X, indicating their failure to establish precise criteria for identifying these connections. The comments column states ‘No fundamental element of the standard’ for both municipalities, signifying non-compliance with GRAP 109 standards. Furthermore, the ‘Change in accounting’ column is designated as ‘No’, indicating that these municipalities did not execute any official modifications to their rules despite the reclassification. This result also shows the municipalities’ difficulties in applying the principles of the standard, as seen in their failure to meet key compliance elements outlined in Table 1.
The difficulty in applying the principles of this standard is also not limited to municipalities B and F, as evidenced by the court case between AGSA and the Western Cape government discussed in the introduction. In the court case, the Western Cape Provincial Department of Agriculture incorrectly classified the payments made to suppliers as transfers instead of payments for goods and services because the suppliers received the payments as department agents.
At a minimum, other municipalities indicated the following in their policy disclosure: identifying the principal–agent arrangement, identifying whether an entity is a principal or an agent and recognition. The identification was based on the principal–agent arrangement definition based on GRAP 109. Recognition is per the relevant GRAP standard. It was also found that the accounting policies were clear in this regard, and no significant change was noticed over the 4 years of the disclosed policies. This result shows that, at minimum, they had addressed the basic principles as expected by the National Treasury.
The ASB (2024) observed that accounting consistency improves financial performance and position comparability between various entities. The concept is critical in ensuring financial statements present a trustworthy foundation for making decisions. According to the ASB (2024), consistency involves applying identical accounting principles and approaches from one period to the next to make informed comparisons. The research results identified that most municipalities were consistent in their accounting principles, and no change was detected within the 4-year observation period. This result concurs with the ASB’s (2024) assertion that consistency in accounting practice improves comparability.
However, the results indicate that Municipalities B and F failed to disclose relevant accounting policies, contravening the guidelines provided in the literature. Moreover, Morais’s (2019) study maintains that a breakdown of proper accounting policies leads to financial reporting anomalies, inhibiting assessing an entity’s financial position and operational performance. Similarly, Abu Haija et al. (2021) maintain that ineffective policy disclosures compromise financial transparency, resulting in non-compliance with accounting standards and reduced comparability between entities. The data revealed that the municipalities have been consistent because there was no change in accounting policies over the 4 years analysed. The lack of accounting policies leads to misrepresenting the municipality’s financial performance and results in a lack of comparability, as evident in the two municipalities that did not disclose the proper accounting policy.
Notes to the Annual Financial Statements: Accounting by principals and agents
Generally Recognised Accounting Practice 1 requires disclosures on the face of a statement and/or in the notes to the financial statements. The principal–agent relationship is disclosed in the notes in the financial statements. The AFSs of all eight metro municipalities were analysed for four reporting periods from 2019/2020 to 2022/2023, as shown in Figure 1. The following is a summary of the average compliance of all eight municipalities (complete analysis in Appendix A to Appendix H).
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FIGURE 1: Average compliance with disclosure requirements of the GRAP 109. |
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The analysis was based on the GRAP 109 disclosure requirements to see whether they complied. As stated in the literature review, the AGSA (2017) found that South Africa does not fully comply with the GRAP standard, resulting in significant problems with the quality of its public sector accounts. The results in figure 1 shows that most municipalities are not fully complying with the requirements. However, the analysis shows that the average compliance for all municipalities overall increases. It was 59% in the first year of application (2019/2020) and 73% in 2022/2023. This result indicates an improvement and potential improvement going forward. This result is consistent with Christensen et al.’s (2015) view that financial reporting and compliance quality improves over time because of experience and a better understanding of the standard.
Although there is an upward trajectory in the overall compliance, in 2023 it dropped from 75% to 73%, caused primarily by the slight dip in Municipality G. In 2023, Municipality G had a disclosure by the principal, which was the first time they made such a disclosure. The municipality did not comply with the disclosure requirements of the principal (refer to Appendix A). This municipality is the only one with no principal–agent disclosure in 2021 and 2022, and the compliance level in 2020 was at 50%. This result indicates that their learning phase was not at the same level as other municipalities because nothing was disclosed in the other 2 years. As the ASB suggested, it can also be an issue of requirements not being clear enough, resulting in difficulties understanding and following such requirements. Specifically, the municipality did not disclose significant terms and conditions of the arrangement, and they also struggled with disclosure by principals, where the following was not disclosed: resources of the entity that are under the custodianship of an agent, whether agent has recognised the resources and the fee paid as compensation to the agent.
Municipality D has been maintaining 100% compliance with GRAP 109 disclosure requirements. Municipality E also demonstrates a consistent compliance of 70%, an example of good practice. However, the concern is that they are not improving on non-compliance aspects. Municipality E specifically struggled with disclosure by agent, where they did not disclose the description of the resources that are held on behalf of a principal, the amount of revenue received or to be received, as well as the expenses paid or to be paid and the Reconciliation of the carrying amount of receivable or payable. Municipalities B and F have significantly improved compliance from 2020 to 2023, starting with a compliance of 33% and 29%, respectively, and in 2023, the compliance was at 80%. Positive change can mainly be attributed to the improvement they made on disclosing description of any resources that are held on behalf of a principal, the amount of revenue received or to be received, as well as the amount of expenses paid or accrued on behalf of the principal, reconciliation of the carrying amount of the receivable or the payable at the beginning and end of the period and fee paid as compensation to the agent. Guerreiro et al. (2008) state that implementing a new accounting standard can create significant challenges for companies that must adapt to accommodate changes in accounting and financial reporting systems, train staff and update information systems. These municipalities could adjust to the new changes.
Municipality C shows fluctuations in compliance levels. The analysis shows that the struggle in the disclosure of principals in 2022 caused the fluctuation. Municipality G had a disclosure by the principal in 2022, which was the first time they made such a disclosure. The municipality did not comply with the principal’s disclosure requirements.
In most municipalities, the prevalent causes for not fully complying with the disclosure requirements were derived from the data provided in the Annexures, which detail each municipality’s compliance levels across several disclosure elements. The most frequently observed gaps in disclosure, as evidenced in Appendix A to Appendix H, include the following:
- Not mentioning significant terms and conditions of the arrangement and whether any changes occurred during the reporting period: This non-compliance was observed from the data across multiple municipalities, including Municipalities A, B and C, all of which failed to report on this aspect from 2020 to 2023 (Appendix A, Appendix B and Appendix C).
- No description of any resources held on behalf of a principal: Municipalities B, C and E consistently omitted this disclosure throughout the reporting period (Appendix B, Appendix C and Appendix E). This result indicates that municipalities either lack adequate records of resources held on behalf of principals or do not prioritise reporting such details.
- No reconciliation of the carrying amount of the receivable or the payable at the beginning and end of the period: Municipalities A, B and E failed to provide this disclosure consistently across all 4 years analysed (Appendix A, Appendix B and Appendix E). The absence of this reconciliation affects financial transparency and comparability, making it difficult to track financial obligations over time.
The findings in the Annexures (Appendix A to Appendix H) identify a pattern of overall non-compliance, specifically where local governments must present detailed explanatory disclosures instead of mere figures of financial information. These observations confirm previous research indicating that public sector organisations have difficulty complying with requirements because of insufficient technical expertise, inadequate financial controls and irregular policy enforcement (Abu Haija et al. 2021; AGSA 2023). Municipalities must increase GRAP 109 compliance to foster transparency, simplify financial reporting practices and maintain accountability within the public sector.
The non-compliance areas were predominantly related to disclosures where the municipality acted as an agent rather than a principal. This finding is significant because GRAP 109 imposes more extensive disclosure requirements for agents than for principals. There are eight distinct disclosure requirements that an organisation would be required when acting as an agent, whereas there are only three requirements if acting as a principal. The material complexity of disclosures relating to an agent indicates that government agencies would have severe challenges interpreting and enforcing these regulations, leading to inconsistencies in implementation. Thus, remedying these problems will necessitate special training, enhanced financial monitoring and more precise guidelines on reporting requirements for agents to bridge the existing compliance gap.
Recommendations
- Adoption of the GRAP compliance checklist:
- Municipalities should systematically use the GRAP checklist provided by the National Treasury to ensure their disclosures are complete and aligned with the requirements of GRAP 109. Preparing financial statements within the municipality and the internal audit division should ensure that the checklist is implemented. This checklist should be integrated into the annual financial reporting process, serving as a compliance verification tool to identify gaps in disclosure. Internal audits can ensure that this is being used as a control measure.
- Benchmarking against fully compliant municipalities:
- The municipalities that fully complied with GRAP 109 should be identified and used as case studies or reference models for those still struggling with implementation. This can be the responsibility of provincial treasuries, as they consolidate all AFSs within their jurisdictions.
- The adoption of a detailed AFS specimen by the National Treasury:
- Furthermore, the National Treasury should fully implement the comprehensive AFS specimen, which has been tailored for municipalities using GRAP 109. Adopting the specimen would include detailed guidance on accounting policies and disclosure examples, providing practical illustrations on accurately recognising and disclosing principal–agent relationships. The specimen should be regularly updated to reflect new interpretations, common challenges and emerging best practices, ensuring municipalities have clear reference material to support compliance.
These recommendations aim to improve compliance with GRAP 109, strengthen financial transparency and accountability, and support municipalities in achieving accurate and comprehensive financial reporting.
Limitations
This research provides critical evidence of the impact and disclosure of GRAP 109 regarding its adoption by the metropolitan sub-sector of local government in South Africa, but it is not without limitations. Firstly, the study was confined to the eight metropolitan municipalities, a small sample considering that the Republic of South Africa comprises 257 municipalities. While metros were selected for their financial complexity, population size and central role in service provision, their performance might not accurately reflect local or district municipalities. Secondly, the study did not include other entities that must also comply with GRAPs. These entities range from trading entities to parliament, provincial legislatures and public further education and training colleges. Thirdly, the review was limited to publicly available audited AFSs of the 4 years between 2019/2020 and 2022/2023. Therefore, the study exclusively used secondary data, and it might not encapsulate the internal processes, rationale and struggles involved in the disclosure decisions of each municipality.
Future research should extend the analysis of GRAP 109 principal–agent disclosures beyond the current municipal focus to include a broader range of GRAP users, such as district municipalities, local municipalities, trading entities, parliament and provincial legislatures, and public Further Education and Training (FET) colleges and also focus on quantitative disclosure analysis, measuring the extent, frequency and completeness of principal–agent disclosures across various GRAP users.
Conclusion
The ASB issued GRAP 109, which is effective since the 2019 fiscal year. This standard was issued because of a gap the ASB observed, wherein no guidance was available for addressing accounting for principal–agent relationships. This standard is meant to close that gap. Municipalities still struggle to implement the GRAP. The new standard brings a new challenge of unfamiliarity, which is added to the existing challenges. The research analysed South African metropolitan municipalities’ disclosure of the principal–agent relationship. The research analysed the note disclosure, including the accounting policy disclosure and other principal–agent arrangement disclosures.
The findings from the accounting policy analysis indicated that six municipalities disclosed principal–agent arrangement accounting policies in line with the GRAP 109 requirements. The accounting policies disclosed addressed a critical element of GRAP 109. Municipalities without accounting policies followed no specific principles or bases when identifying and recognising a principal–agent arrangement. This result also shows the difficulties municipalities face while applying the principles of the standard. This was clear from their struggle to identify an agent in year 1, and in the following year, they concluded that there was no principal–agent arrangement. The municipalities could not properly identify and disclose principal–agent arrangements.
The analysis of the principal–agent disclosure revealed an upward trajectory in overall compliance. Year 1 of disclosure started with an average compliance of 59%; by year 4, the average compliance was 73%. The more the municipalities become familiar with the standard, the better their disclosure. One municipality had an average compliance of 100% for all 4 years. Some municipalities showed slight fluctuations because of new arrangements they entered.
Acknowledgements
Competing interests
The authors declare that they have no financial or personal relationships that may have inappropriately influenced them in writing this article.
Authors’ contributions
G.M. was responsible for the research proposal, formal analysis and writing the first draft. B.S. was the supervisor responsible for review and editing.
Funding information
This research received no specific grant from any funding agency in the public, commercial or not-for-profit sectors.
Data availability
The authors confirm that the data supporting the findings of this study are available within the article and its references.
Disclaimer
The views and opinions expressed in this article are those of the authors and are the product of professional research. The article does not necessarily reflect the official policy or position of any affiliated institution, funder, agency or the publisher. The authors are responsible for this article’s results, findings and content.
References
Abu Bakar, N.B. & Saleh, Z., 2011, ‘Public sector accounting research in Malaysia: Identifying gaps and opportunities’, IPN Journal of Research and Practice in Public Sector Accounting and Management 1, 23–52. https://doi.org/10.58458/ipnj.v01.02.02.0009
Abu Haija, A.A., AlQudah, A.M., Aryan, L.A. & Azzam, M.J., 2021, ‘Key success factors in implementing international public sector accounting standards’, Accounting 7, 239–248. https://doi.org/10.5267/j.ac.2020.9.012
Accountancy SA (ASA), 2023, The use of consultants in the public sector and the need for review, viewed 02 July 2024, from https://t.ly/ZyTE7.
Accounting Standard Board (ASB), 2015, viewed 10 May 2024, from https://www.asb.co.za/wp-content/uploads/2023/08/GRAP-109-Accounting-by-Principals-and-Agents.pdf
Accounting Standard Board (ASB), 2020a, Standard of generally recognised accounting practice: Accounting by principals and agents (grap 109), viewed 15 September 2023, from https://www.asb.co.za/wp-content/uploads/2020/11/New-newsletter-October-2020-format.pdf.
Accounting Standard Board (ASB), 2020b, Strategic plan for the financial years 2020 to 2025, viewed 15 August 2024, from https://static.pmg.org.za/ASB_-_Strategic_Plan_2020-2025.
Accounting Standard Board (ASB), 2022, viewed 10 Nov 2024, from https://www.asb.co.za/wp-content/uploads/2019/09/Executive-summary-ED-200-GRAP-109-PIR.pdf.
Accounting Standard Board (ASB), 2022a, viewed 17 August 2024, from www.asb.co.za/wp-content/uploads/2022/04/GRAP-109-Accounting-by-Principals-and-Agents-1-April-2022.
Accounting Standards Board (ASB), 2022b, Post-implementation review of GRAP 109 on accounting by principals and agents (ED200), viewed 25 April 2023, from https://www.asb.co.za/wp-content/uploads/2019/09/Executive-summary-ED-200-GRAP-109-PIR.pdf.
Accounting Standard Board (ASB), 2024, Consistency vs Comparability, viewed 05 November 2024, from www.asb.co.za/wp-content/uploads/2023/08/Consistency-vs-Comparability-1.
Auditor-General of SA v MEC for Economic Opportunities, Western Cape and Another (671/2019) [2021] ZASCA 133 (4 October 2021) Supreme Court of Appeal.
Auditor-General of South Africa (AGSA), 2017, Municipal Finance Management Act Consolidated General Report on Audit Outcomes for 2015/2016, viewed 21 April 2023, from https://www.agsa.co.za/Reporting/PFMAReports/PFMA2015-2016.aspx.
Auditor-General South Africa (AGSA), 2021, Post-implementation review of GRAP 109 accounting by principals and agents (ED 200), viewed 17 August 2022, from https://www.asb.co.za/wp-content/uploads/2019/09/ED-200-presentation-GRAP-109-PIR.pdf.
Auditor-General South Africa (AGSA), 2022a, Frequently asked questions, viewed 29 August 2024, from https://www.agsa.co.za/Portals/0/Repository/12/MFMA%20FAQs%20-%2010%20November%202022.54401c2e-22cb-49bd-b307-a35334721289.docx.
Auditor-General South Africa (AGSA), 2022b, The consolidated general report on national and provincial audit outcomes: PFMA 2021-22, viewed 20 April 2023, from https://www.agsa.co.za/Portals/0/Reports/PFMA/202122/2021-22%20PFMA%20general%20report%20(print)%20-%20FINAL.pdf?ver=2022-12-01-094427-850.
Auditor-General South Africa (AGSA), 2023, Consolidated general report on local government audit outcomes for 2022-23, viewed 15 August 2024, from https://mfma-2023.agsareports.co.za/.
Ajam, T., 2025, ‘The administrative burden of implementing municipal financial management regulation: A case study of five compliant South African municipalities’, Public Law and Environmental Law 1, 131–150. https://doi.org/10.5117/PULE2025.1.010.AJAM
Bagwandeen, L., 2010, ‘A critical analysis of the role of disclosure in strengthening corporate governance and accountability’, Master’s thesis, University of KwaZulu-Natal.
Barth, M.E., 2018, ‘How international accounting research influences policy and standard setting’, Journal of International Accounting Research 17(2), 1–11. https://doi.org/10.2308/jiar-10634
Basri, H., 2014, ‘Using qualitative research in accounting and management studies: Not a new agenda’, Journal of US-China Public Administration 11(10), 831–838.
Braun, V. & Clarke, V., 2006, ‘Using thematic analysis in psychology’, Qualitative Research in Psychology 3(2), 77–101. https://doi.org/10.1191/1478088706qp063oa
Brown, E. & Weber, N., 2022, ‘Councils in action: Automating the curation of municipal governance data for research’, Proceedings of the Association for Information Science and Technology 59(1), 23–31. https://doi.org/10.1002/pra2.601
Bryman, A., 2016, Social research methods, 5th edn., Oxford University Press, London.
Christensen, H.B., Lee, E., Walker, M. & Zeng, C., 2015, ‘Incentives or standards: What determines accounting quality changes around IFRS adoption?’, European Accounting Review 24(1), 31–61. https://doi.org/10.1080/09638180.2015.1009144
Cuny, C., Li, K., Nakhmurina, A. & Watts, E., 2021, ‘The information content of municipal financial statements: Large-sample evidence’, SSRN Electronic Journal. https://doi.org/10.2139/ssrn.4186418
Daruhadi, G. & Sopiati, P., 2024, ‘Research data collection’, International Journal of Social Service and Research 4(7), 1–18. https://doi.org/10.46799/ijssr.v4i7.863
De Villiers, C., Dumay, J. & Maroun, W., 2019, ‘Qualitative accounting research: Dispelling myths and developing a new research agenda’, Account Finance 59(3), 1459–1487. https://doi.org/10.1111/acfi.12487
Dewi, N., Azam, S.M. & Yusof, S., 2019, ‘Factors influencing the information quality of local government financial statement and financial accountability’, Management Science Letters 9(9), 1373–1384. https://doi.org/10.5267/j.msl.2019.5.013
Dewi, I., 2021, ‘Understanding data collection methods in qualitative research: The perspective of interpretive accounting research’, Journal of Tourism Economics and Policy 1(1), 23–34. https://doi.org/10.38142/jtep.v1i1.105
Du, K., Schmidt, B., Wang, S. & Louis, H., 2023, Principal-versus-agent considerations in revenue recognition and the impact of ASC 606, viewed 25 July 2025, from https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4111573.
Elo, S. & Kyngäs, H., 2008, ‘The qualitative content analysis process’, Journal of Advanced Nursing 62(1), 107–115. https://doi.org/10.1111/j.1365-2648.2007.04569.x
Enache, L., Huang, Z., Moldovan, R. & Srivastava, A., 2022, ‘Labour costs of implementing new accounting standards’, Accounting Horizons 39, 1–8.
Etikan, I., Musa, S.A. & Alkassim, R.S., 2016, ‘Comparison of convenience sampling and purposive sampling’, American Journal of Theoretical and Applied Statistics 5(1), 1–4. https://doi.org/10.11648/j.ajtas.20160501.11
Ewert, R. & Wagernhofer, A., 2012, ‘Using academic research for the post-implementation review of accounting standards’, A Journal of Accounting, Finance and Business Studies 48(2), 278–291. https://doi.org/10.1111/j.1467-6281.2012.00362.x
Ferlie, E. & Pollitt, C., 2005, The Oxford handbook of public management, Oxford University Press, Oxford.
Fourie, D. & Poggenpoel, W., 2017, ‘Public sector inefficiencies: Are we addressing the root causes?’, South African Journal of Accounting Research 31(3), 169–180. https://doi.org/10.1080/10291954.2016.1160197
Guerreiro, M.S., Rodrigues, L.L. & Craig, R., 2008, ‘The preparedness of companies to adopt international financial reporting standards: Portuguese evidence’, Accounting Forum 32(1), 75–88. https://doi.org/10.1016/j.accfor.2007.11.001
Guthrie, J., Petty, R., Yongvanich, K. & Ricceri, F., 2004, ‘Using content analysis as a research method to inquire into intellectual capital reporting’, Journal of Intellectual Capital 5(2), 282–293. https://doi.org/10.1108/14691930410533704
Haustein, E. & Lorson, P.C., 2023, ‘Transparency of local government financial statements: Analysing citizens’ perceptions’, Financial Accountability & Management 39(2), 375–393. https://doi.org/10.1111/faam.12353
International Accounting Standards Board (IASB), 2016, ‘International accounting standard 8: Accounting policies, changes in accounting estimates and errors, in international accounting standards board’, A guide through international financial reporting, pp. A914–A928, SAICA, London.
International Public Sector Accounting Standards (IPSAS), 2001, Revenue from exchange transactions, viewed 25 April 2023, from https://www.ifac.org/system/files/publications/files/A11-IPSAS_09_2.
International Public Sector Accounting Standards (IPSAS), 2016, ‘International Accounting Standard 8: Accounting policies, changes in accounting estimates and errors’, in IASB (ed.), A guide through international financial reporting, pp. A914–A928, SAICA, London.
International Financial Reporting Standard (IFRS), 2024, IFRS accounting: Staff paper. Post-implementation review of IFRS 15, viewed 17 Aug 2024, from https://www.ifrs.org/content/dam/ifrs/meetings/2024/february/iasb/ap6b-ifrs-15-pir-principal-vs-agent-considerations.pdf.
Juanda, A., Setyawan, S. & Inata, L.C., 2023, ‘Analysis of local government accounting disclosure based on international public sector accounting standards (IPSAS)’, Journal of Accounting and Investment 24(2), 487–501.
Kidwell, L.A. & Lowensohn, S., 2019, ‘Participation in the process of setting public sector accounting standards: The case of IPSASB’, Accounting in Europe 16(2), 177–194. https://doi.org/10.1080/17449480.2019.1632466
Krippendorff, K., 2004, Content analysis: An introduction to its methodology, 2nd edn., Sage, Thousand Oaks, CA.
Krippendorff, K., 2013, Content analysis. An introduction to its methodology, 3rd edn., Sage Publications, California, CA.
Levine, C.B. & Smith, M.J., 2011, ‘Critical accounting policy disclosures’, Journal of Accounting, Auditing & Finance 26(1), 39–76. https://doi.org/10.1177/0148558X11400579
Local Government: Municipal Finance Management Act (MFMA), 2003, Government Gazette.
Lubbe, I. & Mkubukeli, W., 2016, ‘The impact of using different accounting frameworks in the public sector’, in Accounting Perspectives in Southern Africa, viewed 23 April 2023, from https://www.researchgate.net/publication/314204861_The_impact_of_using_different_accounting_frameworks_in_the_public_sector.
Mahajan, S. & Baburao, W., 2016, Disclosure of accounting policies, viewed 02 June 2025, from https://www.researchgate.net/publication/304354693_Disclosure_of_Accounting_Policies.
Morais, A.I., 2019, ‘Are changes in international accounting standards making them more complex?’, Accounting Forum 44(1), 35–63. https://doi.org/10.1080/01559982.2019.1573781
Municipal Demarcation Board (MDB), 2018, Municipal demarcation board seminar report: Categorisation of municipalities into metropolitan (metros) municipalities, viewed 23 April 2023, from https://www.demarcation.org.za/wp-content/uploads/2021/07/Seminar-latest-Report-31Jan2018-final.pdf.
Narastri, M., 2022, ‘Principles and agents: The phenomenon of agency theory in the business sector and the public sector’, in 4th International Conference on Business and Banking Innovations (ICOBBI) 2022, Universitas Hayam Wuruk Perbanas, Surabaya, Indonesia, pp. 105–109.
Nareswari, S.H., 2017, ‘Menelusuri jejak kearifan lokal budaya etnik jawa dalam laporan keuangan sektor publik’, Jurnal Ekonomi dan Manajemen 11(2), 2614–1345.
National Treasury, 1999, Division of revenue, viewed 29 October 2024, from https://www.treasury.gov.za/documents/mtbps/1999/5.pdf.
National Treasury, 2020, Accounting guideline GRAP 1: Presentation of financial statements, viewed 29 October 2024, from https://ag.treasury.gov.za/org/tss/Shared%20Documents/Generally%20Recognised%20Accounting%20Practice%20Reporting/Accounting%20Manuals/Accounting%20Guideline%20on%20GRAP%2001%20Issued%20February%202020%20updated%20March%202022.pdf.
National Treasury, 2021, viewed 03 October 2024, from www.asb.co.za/wp-content/uploads/2022/04/Standard-on-a-page-GRAP-109.
Ngwenya, S. & Majam, T., 2011, ‘Assessing the financial viability of metropolitan municipalities in Gauteng’, Administratio Publica 19(1), 169–187. https://doi.org/10.10520/ejc-adminpub-v19-n1-a11
PricewaterhouseCoopers (PWC), 2018, New standards – Some of the challenges of implementation, viewed 04 July 2023, from https://www.pwc.com.au/assurance/ifrs/assets/new-standards-some-of-the-challenges-of-implementation.
Public Finance Management Act No 1 of 1999, Government Gazette, viewed 21 August 2024, from https://www.treasury.gov.za/legislation/pfma/PFMA%201999%20as%20amended%20March%202017.pdf.
Raičević, J., 2021, ‘Accounting policies in the function of quality assessment of financial statements’, Economic Themes 59(3), 357–373. https://doi.org/10.2478/ethemes-2021-0020
Rayegan, E., Parveizi, M., Nazari, K. & Emami, M., 2012, ‘Government accounting: An assessment of theory, purposes and standards’, Interdisciplinary Journal of Contemporary Research in Business 3(9), 521–531.
Republic of South Africa, 2022, Local government, viewed 01 July 2024, from https://www.gov.za/about-government/government-system/local-government.
Rizki, P., Hali, A. & Kusumawati, A., 2024, ‘The influence of transparency, governance, and financial accountability in managing financial reporting in the public sector’, International Journal of Educational and Life Sciences 2, 1165–1180. https://doi.org/10.59890/ijels.v2i10.2571
Sari, R., 2023, ‘Accountability and transparency in public sector accounting: A systematic review’, Amkop Management Accounting Review 3(2), 90–106. https://doi.org/10.37531/amar.v3i2.1440
Scott, D., 2008, ‘GAMAP/GRAP on the financial performance and financial position of a municipality’, Southern African Business Review 12(3), 1–23.
Scott, D., Wingard, C. & Van Biljon, M., 2016, ‘Challenges with the financial reporting of biological assets by public entities in South Africa’, South African Journal of Economic and Management Sciences 19(1), 139–149. https://doi.org/10.4102/sajems.v19i1.1339
South African Accounting Academy (SAAA), 2022, Guidance on principal–agent arrangements, viewed 17 August 2024, from https://accountingacademy.co.za/news/read/guidance-on-principal-agent-arrangements.
South African Accounting Academy (SAAA), 2024, ASB Review Report: PIR of GRAP 109 Accounting by Principals and Agents, viewed 29 May 2025, from https://accountingacademy.co.za/news/read/asb-review-report-pir-of-grap-109-accounting-by-principals-and-agents.
South African Law Reform Commission, 2019, Report on activities of the South African law reform commission, viewed 20 October 2024, from https://pmg.org.za/files/SALRC_Annual_Report_-_2019-2020.pdf.
Standard of Generally Recognised Accounting Practice (GRAP) 109, 2015, Accounting Standard Board, South Africa, viewed 21 March 2024, from http://www.asb.co.za/wp-content/uploads/2019/08/Recording-GRAP-109.pdf.
Tawiah, V. & Soobaroyen, T., 2022, ‘The relationship between the adoption of international public sector accounting standards and sources of government financing: Evidence from developing countries’, Accounting Forum 48(2), 307–330. https://doi.org/10.1080/01559982.2022.2151073
Van Zyl, H.A., 2017, Accounting policy disclosure: Practice in South Africa, viewed 02 June 2025, from https://scholar.ufs.ac.za/server/api/core/bitstreams/b5a9ba3c-1185-4adb-b2c3-cee712b6979d/content.
Appendices
| Appendix A: Municipality A compliance with disclosure requirements. |
| Appendix B: Municipality B compliance with disclosure requirements. |
| Appendix C: Municipality C compliance with disclosure requirements. |
| Appendix D: Municipality D compliance with disclosure requirements. |
| Appendix E: Municipality E compliance with disclosure requirements. |
| Appendix F: Municipality F compliance with disclosure requirements. |
| Appendix G: Municipality G compliance with disclosure requirements. |
| Appendix H: Municipality H compliance with disclosure requirements. |
|
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