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Provisional Audit Planning Report
Year ended 31 March 2026
London Borough of
Hillingdon
30 April 2026
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Private and Confidential 30 April 2026
Dear Audit Committee members
Provisional Audit Planning Report 2025/26
We are pleased to attach our provisional Audit Planning Report for the forthcoming meeting of the Audit Committee. The purpose of this report is to provide
the committee with a basis to review our proposed audit approach and scope for the 2025/26 audit, in accordance with the requirements of the Local Audit
and Accountability Act 2014, the National Audit Office’s 2024 Code of Audit Practice, the Statement of Responsibilities issued by Public Sector Audit
Appointments (PSAA) Ltd, auditing standards, and other professional requirements.
This report is intended solely for the information and use of the Audit Committee and management, and is not intended to be, and should not be used, by
anyone other than these specified parties.
We welcome the opportunity to discuss this report with you on 28 May 2026 as well as understand whether there are other matters which you consider may
influence our audit.
Yours faithfully
Stephen Reid, Partner
For and on behalf of Ernst & Young LLP
Enc
Audit Committee
London Borough of Hillingdon
Hillingdon Civic Centre
225-226 High St
Uxbridge UB8 1UW
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Confidential — All Rights Reserved London Borough of Hillingdon Audit Planning Report 3
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Audit risks 2
Overview of our
2025/26 audit
strategy
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Value for money
Audit materiality Scope of our audit Audit team
Audit timeline Appendices
Public Sector Audit Appointments Ltd (PSAA) issued the ‘Statement of responsibilities of auditors and audited bodies’. It is available from the PSAA website (https://www.psaa.co.uk/managing-audit-quality/statement-of-responsibilities-
of-auditors-and-audited-bodies/statement-of-responsibilities-of-auditors-and-audited-bodies-from-2023-24-audits/). The Statement of responsibilities serves as the formal terms of engagement between appointed auditors and audited
bodies. It summarises where the different responsibilities of auditors and audited bodies begin and end, and what is to be expected of the audited body in certain areas. The ‘Terms of Appointment and further guidance (updated
October 2025)’ issued by the PSAA (Terms of appointment and further guidance from 1 October 2025 - PSAA) sets out additional requirements that auditors must comply with, over and above those set out in the National Audit Office
Code of Audit Practice 2024 (the NAO Code) and in legislation, and covers matters of practice and procedure which are of a recurring nature.
This report is made solely to the Audit Committee and management of the London Borough of Hillingdon. Our work has been undertaken so that we might state to the Audit Committee and management of the London Borough of
Hillingdon those matters we are required to state to them in this report and for no other purpose. To the fullest extent permitted by law we do not accept or assume responsibility to anyone other than the Audit Committee and
management of the London Borough of Hillingdon for this report or for the opinions we have formed. It should not be provided to any third-party without our prior written consent.
Confidential — All Rights Reserved London Borough of Hillingdon Audit Planning Report
Overview of our 2025/26 audit
strategy01
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London Borough of Hillingdon Audit Planning Report 5
As the Council’s body charged with governance, the Audit Committee plays a crucial role in ensuring assurance over both the quality of the draft financial statements prepared by
management and the Council’s wider arrangements to support a timely and efficient audit. Failure to achieve this will significantly increase the level of resources required to fulfil our
respective responsibilities.
As part of our responsibilities, we assess and report on the adequacy of the Council’s external financial reporting arrangements, as well as the effectiveness of the Audit Committee in
fulfilling its role within those arrangements as part of our Value for Money assessment. Our ability to complete the audit is dependent on the timely formulation of appropriately
supported accounting judgements, provision of accurate and relevant supporting evidence, access to the finance team and management’s responsiveness to issues identified during
the audit. Wherever necessary, we will consider invoking other statutory reporting powers to highlight any weaknesses in these arrangements. We direct Audit Committee members
and officers to the Public Sector Audit Appointment Limited’s Statement of Responsibilities (paragraphs 26-28) for expectations on preparing financial statements (see Appendix A).
The purpose of this report
We are now in Phase 2 of the implementation of the Ministry for Housing, Communities and Local Government’s (MHCLG) measures to address the backlog facing local government
audit. Throughout 2023/24 and 2024/25, we applied a structured, risk-based prioritisation approach to local government audits to support a return to unqualified audit opinions
wherever feasible, while still meeting statutory backstop requirements. Our approach recognises that recovery depends heavily on the Council’s own capacity and preparedness and
that audit effort must be targeted where it can deliver meaningful assurance.
Management has overall responsibility for leading and sustaining the Council’s recovery from a disclaimed audit opinion. This includes ensuring that the financial statements are
prepared in accordance with proper practices and supported by complete, accurate and timely audit evidence.
To deliver this, it is essential that management:
Strengthen the underlying control environment, particularly in areas linked to prior year disclaimers;
Provide high quality working papers and ensure that all audit evidence is complete, consistent and readily accessible;
Allocate sufficient, knowledgeable resources throughout the audit cycle;
Actively engage with auditors, promptly addressing findings and resolving weaknesses in financial reporting arrangements; and
Communicate transparently with the Audit Committee, as those charged with governance, ensuring that committee members have clear visibility of risks, progress and emerging
issues.
In line with the National Audit Office’s Local Audit Reset and Recovery Implementation Guidance (LARRIGs) - and specifically the guidance on rebuilding assurance following a
disclaimed opinion - management must support the restoration of reliable opening balances and enable a phased progression from disclaimed to qualified and ultimately unmodified
audit opinions. Achieving this requires sustained delivery of the “natural rebuild,” through the completion of all planned audit procedures across successive annual cycles, alongside
targeted work to rebuild assurance over historical balances, including both usable and unusable reserves, where cumulative gaps in evidence present the most significant challenges.
Our shared strategy to rebuild assurance
2025/26 audit strategy overview: Rebuilding assurance
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London Borough of Hillingdon Audit Planning Report 6
Appendix A explains the expected timeline to full assurance set out within the NAO’s LARRIG 01 guidance, along with our assessment of the Council’s status. During 2023/24 and
2024/25, the focus of the rebuild process has been on this “natural” rebuild, to complete all planned audit procedures for each respective audit year. As set out in our Audit Results
Reports dated 18 March 2025 and 27 February 2026, we were not able to complete all planned audit procedures for the following reasons:
• For 2023/24, we encountered difficulty in performing our audit procedures due to a combination of poor-quality working papers and supporting information being provided by the
Council and capacity limitations within the Council’s finance team. Due to the implementation of the backstop date of 28 February 2025 for the completion of that audit, we
agreed with management that both Council and audit resources would be prioritised on those account areas which contribute the most towards the rebuilding of assurance
following the disclaimed 2022/23 audit report. Consequently, we were not able to complete all of our planned procedures.
• For 2024/25, commencement of our year-end audit fieldwork was delayed as a result of the Council not publishing its draft Statement of Accounts until 22 September 2025,
nearly three months after the statutory deadline for commencement of the public inspection period of 1 July 2025. In addition, we again encountered difficulty in performing our
audit procedures due to delays in the provision of working papers and supporting information by the Council, including where such information is held outside of the Council’s
finance team, and capacity limitations within the Council’s finance team. Due to the implementation of the backstop date of 27 February 2026 for the completion of the audit,
during the execution of our audit we worked with management where progress was not satisfactory to prioritise the Council’s and audit resources on those account areas which
contribute the most towards the rebuilding of assurance following previous disclaimed audit reports and/or there was the highest probability of being able to complete our planned
audit procedures by the backstop date. Consequently, we were not able to complete all of our planned procedures.
As part of our interim audit procedures for 2025/26, we will undertake a detailed risk assessment to evaluate the risk of material misstatement in the opening reserves balances at 1
April 2025, and to assess management’s readiness to support the historic rebuild process over transactions and balances in 2022/23 that were not subject to audit. This work is
expected to be completed by 30 June 2026 and is essential to determining whether the pre-2023/24 gaps in assurance - particularly those relating to reserves and other cumulative
balances - can be sufficiently addressed to support future progression towards qualified or unmodified audit opinions.
We will discuss the outcome of our risk assessment over the opening reserves balances with management to confirm our planned approach for 2025/26. However, because we were
unable to complete all planned audit procedures for 2023/24 and 2024/25 for the reasons outlined above, it is unlikely that we will commence any rebuilding of assurance over the
historic position during the 2025/26 audit cycle. In line with our established prioritisation principles, we will focus our audit resources on rebuilding assurance for those bodies where
planned audit procedures were completed in 2023/24 and 2024/25, in order to support the sector wide objective of returning to unmodified audit opinions as quickly and sustainably
as possible.
It is therefore critical that management ensure they can provide high quality working papers, robust audit evidence, and resolve the underlying issues identified in prior years as part
of the 2025/26 audit cycle. This will be essential to avoid any further delay in the eventual process for rebuilding assurance over the Council’s historic position.
Our shared strategy to rebuild assurance continued
2025/26 audit strategy overview: Rebuilding assurance
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London Borough of Hillingdon Audit Planning Report 7
An audit timetable has been agreed with management. In Section 7 we include a provisional timeline for the audit. It is essential that all parties collaborate to ensure compliance with
this timeline.
Timeline
Our ability to complete the audit is dependent on the timely formulation of appropriately supported accounting judgements, provision of accurate and relevant supporting evidence,
access to the finance team and management’s responsiveness to issues identified during the audit. Our 2024/25 reporting included our assessment of the effectiveness of the
Council’s arrangements to support the external audit process across a range of relevant measures (reproduced in Appendix A). We concluded that the Council was not fully prepared
for the audit and that improvements were required in relation to:
the provision of a complete and high-quality draft Statement of Accounts to the agreed timetable;
the provision of working papers and other supporting information, including where such information is held outside of the Council’s finance team, in line with the agreed Client
Assistance Schedule and timetable; and
the availability of key finance personnel to support the execution phase of the audit in accordance with the agreed project plan.
We will continue to report on our assessment of the quality of the Council’s financial statements’ preparation and support, to support ongoing transparency of the audit process to
those charged with governance, and to facilitate benchmarking and tracking of progress in future years.
Please refer to Appendix B for our update on independence.
Our independence considerations
In accordance with the NAO Code, our primary objectives are to conduct work that supports the delivery of our audit report to the Council. Additionally, we aim to ensure that the
Council has established proper arrangements for securing economy, efficiency, and effectiveness in its use of resources, as mandated by relevant legislation and the requirements of
the NAO Code. We will issue an Audit Results Report that the summarises our opinion on the financial statements by 30 November 2026 and the results of other procedures required
by the Code. This includes our assessment of the control environment, including our follow up of the recommendations that we made in 2024/25 (refer to Appendix C). In addition,
our Auditor’s Annual Report will conclude on whether the Council has put in place ‘proper arrangements’ to secure economy, efficiency and effectiveness on its use of resources and
report a commentary on those arrangements.
Scope of our audit
Preparedness for audit
2025/26 audit strategy overview: Rebuilding assurance
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London Borough of Hillingdon Audit Planning Report 8
The purpose of our audit is to obtain reasonable assurance to express an opinion about whether the financial statements as a whole are free from material misstatement, whether due
to fraud or error. There is one significant change to the scoping for the audit of the 2025/26 financial statements, relating to the implementation of CIPFA’s Bulletin 22 in relation to
the valuation of Property, Plant and Equipment.
The following ‘dashboard’ summarises the significant accounting and auditing matters outlined in this report. It seeks to provide the Audit Committee with an overview of our initial
risk identification for the upcoming audit and any changes in risks identified in the current year.
DetailsChange from PYRisk identified Risk/area of focus
There is a risk that the financial statements as a whole are not free from material
misstatement whether caused by fraud or error. We perform mandatory procedures
regardless of specifically identified fraud risks.
No change in risk or
focus
Fraud riskPresumptive risk of management
override of controls
Under ISA 240 there is a presumed risk that revenue may be misstated due to improper
revenue recognition. In the public sector, this requirement is modified by Practice Note
10 issued by the Financial Reporting Council, which states that auditors should also
consider the risk that material misstatements may occur by the manipulation of
expenditure recognition.
We have assessed the risk is most likely to occur through the inappropriate capitalisation
of revenue expenditure.
No change in risk or
focus
Fraud riskRisk of fraud in revenue and expenditure
recognition, through inappropriate
capitalisation of revenue expenditure or
use of capital reserves
The valuation methods for land and buildings, including surplus assets, involve higher risk
estimates due to the significant assumptions and judgements involved, and for which the
Council uses external specialists. These estimates heighten the risk of material errors.
For the 2025/26 financial statements, the Council will be required to apply CIPFA Bulletin
22 which reassesses the current regime of valuation for non-investment assets across
the public sector. The guidance mandates a quinquennial revaluation or a five-year rolling
programme for formal valuations, supported by annual indexation in the intervening
years.
The Council has opted to perform revaluation of the entirety of the asset base to which
CIPFA Bulletin 22 applies as at 31 March 2026, to establish a baseline for indexation to
be applied in the following years. Given full revaluations will not be required again until
2030/31, with indexation applied in intervening years, it is even more important that
valuations as at 31 March 2026 are appropriate and that the Council is able to support
completion of audit procedures over these valuations.
No change in risk
Additional focus due to
implementation of
CIPFA Bulletin 22
Significant riskValuation of land and buildings, including
surplus assets
Audit risks and areas of focus
2025/26 audit strategy overview: Audit risks and materiality
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2025/26 audit strategy overview: Audit risks and materiality
London Borough of Hillingdon Audit Planning Report 9
Materiality
Planning
materiality
£15.4m
Materiality has been set at £15.4
million, which represents 1.5% of
gross expenditure on provisions
of services in 2024/25
(2024/25: £14.4 million, 1.4%).
Performance
materiality
£7.7m
Performance materiality has been
set at £7.7 million, which
represents 50% of materiality.
We will report all uncorrected
misstatements relating to the
Comprehensive Income and
Expenditure Statement and
Balance Sheet that have an effect
on the deficit on provision of
services, and misstatements in
the other comprehensive income
and expenditure, over £0.77
million. Other misstatements
identified will be communicated
to the extent that they merit the
attention of the Audit Committee.
Audit
differences
£0.77m
Audit risks and areas of focus continued
DetailsChange from PYRisk identified Risk/area of focus
Accounting for the Council’s participation in the Hillingdon Pension Fund involves
significant estimation and judgement, including financial and demographic assumptions.
There is a risk that the net pension asset/liability recognised is materially misstated, as its
recognition and measurement is subject to significant management judgement, including
the application of the IAS 19 asset ceiling and the assessment of the Council’s ability to
realise future economic benefits.
The Council engages an actuary to undertake the calculations on their behalf. ISAs (UK)
500 and 540 require us to undertake procedures on the use of management experts and
the assumptions underlying fair value estimates.
No change in risk or
focus
Risk of material
misstatement
Valuation of pension assets and liabilities
The carrying amount of Council dwellings represents a significant balance in the
Council’s financial statements and is subject to revaluation changes on an annual basis.
Management is required to make material judgmental inputs and apply estimation
techniques to calculate the year end balances recorded in the balance sheet.
Note: The changes to be implemented under CIPFA Bulletin 22 set out on the previous
page are not applicable to the valuation of council dwellings.
No change in risk or
focus
Risk of material
misstatement
Valuation of council dwellings
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London Borough of Hillingdon Audit Planning Report 10
Under the NAO Code we are required to:
Satisfy ourselves that the Council has made proper arrangements to secure economy, efficiency and effectiveness in its use of resources, having regard to NAO AGN 03.
Design work to provide sufficient assurance to support reporting against the Code’s specified reporting criteria outlined below;a n d
Apply a risk-based approach to our work, informed by sector knowledge, the Annual Governance Statement, evidence from the financial statements audit and relevant work of
other bodies.
In undertaking our risk assessment, we obtain an understanding of the key processes the Council has in place, including financial management, risk management and partnership
working arrangements. Our Auditor’s Annual Report, which will be issued before 30 November 2026, will include a summary of our commentary on the arrangements in place against
each of the three value for money criteria and recommendations raised as a result of any significant weaknesses identified. A key part of our work will be the follow up of previous
recommendations to provide the Committee with assurance on the pace of planned improvements.
Improving economy, efficiency and
effectiveness
How the Council uses information about its
costs and performance to improve the way
it manages and delivers its services.
Governance
How the Council ensures that it makes
informed decisions and properly manages
its risks.
Financial sustainability
How the Council plans and manages its
resources to ensure it can continue to
deliver its services.
No additional risks identified, however
we note that risks identified against
other reporting criteria have
implications for the effectiveness of
arrangements under this reporting
criteria.
Quality of Council Information (inc.
impact on ability to support the external
audit)
Capacity of the finance team
Financial sustainabilityRisks of significant weaknesses in
arrangements identified in 2025/26:
No recommendations were raised within
2024/25 specifically in relation to
improving economy, efficiency and
effectiveness.
Two recommendations issued as
statutory recommendations in July
2025; and
Two further recommendations issued as
part of our 2023/24 audit not
satisfactorily addressed during
2024/25.
Five recommendations issued as
statutory recommendations in July
2025; and
One further recommendation issued in
our Auditor’s Annual Report on 27
November 2025.
Recommendations identified in
2024/25 (refer to Appendix C):
2025/26 audit strategy overview: Value for money
Our risk assessment
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Audit risks02
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London Borough of Hillingdon Audit Planning Report 12
We have set out the significant risks (including f raud risks denoted by*) identified for the current year audit along with the rationale and expected a udit approach. The risks identified
below may change to reflect any significant findings or subsequent issues we identify during the audit.
Our response: Key areas of challenge and professional judgementWhat is the risk, and the key judgements and estimates?
In order to address the risks outlined we will carry out a range of procedures including:
Identifying fraud risks during the planning stages of our audit;
Inquiry of management about risks of fraud and the controls put in place to address those
risks;
Understanding the oversight given by those charged with governance of management’s
processes over fraud;
Discussing with those charged with governance the risks of fraud in the entity, including those
risks that are specific to the entity’s activities and financial position;
Considering whether there are any fraud risk factors associated with related party
relationships and transactions and if so, whether they give rise to a risk of material
misstatement due to fraud;
Considering the effectiveness of management’s controls designed to address the risk of fraud
and determining an appropriate strategy to address those identified risks of fraud;
Performing mandatory procedures regardless of specifically identified fraud risks, including
testing of journal entries and other adjustments in the preparation of the financial
statements;
Undertaking procedures to identify significant unusual transactions; and
Considering whether management bias was present in the key accounting estimates and
judgements within the financial statements.
Having evaluated this risk, we have considered whether we need to perform other audit
procedures not referred to above. We concluded that those procedures included under the risk
‘inappropriate capitalisation of revenue expenditure’ are required.
In accordance with ISA 240, the presumptive risk of management override of
controls is present at every entity and we design the appropriate procedures to
consider such risk.
Management has the primary responsibility to prevent and detect fraud. It
is important that management, with the oversight of those charged with
governance, has put in place a culture of ethical behaviour and a strong
control environment that both deters and prevents fraud.
Our responsibility is to plan and perform audits to obtain reasonable
assurance about whether the financial statements as a whole are free of
material misstatements whether caused by error or fraud.
Our response to significant risks
Presumptive risk of management override of controls*
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London Borough of Hillingdon Audit Planning Report 13
Our response: Key areas of challenge and professional judgementWhat is the risk, and the key judgements and
estimates?Financial statement impact
In order to address the risks outlined we will carry out a range of procedures
including:
Testing additions to Property, Plant and Equipment (PPE) to ensure that the
expenditure incurred and capitalised is clearly capital in nature;
Assessing whether the capitalised spend clearly enhances or extends the useful
life of asset rather than simply repairing or maintaining the asset on which it is
incurred;
Considering whether any development or other related costs that have been
capitalised are reasonable to capitalise, i.e., the costs incurred are directly
attributable to bringing the asset into operational use;
Testing transactions recorded as REFCUS, if material, to ensure that it is
appropriate for the revenue expenditure incurred to be financed from ringfenced
capital resources; and
Seeking to identify and understand the adjustments made between usable
reserves and unusable capital reserves to confirm they are appropriate, and
agreeing the value of such adjustments to other financial statement balances or
appropriate supporting evidence.
Under ISA 240 there is a presumed risk that revenue
may be misstated due to improper revenue
recognition. In the public sector, this requirement is
modified by Practice Note 10 issued by the Financial
Reporting Council, which states that auditors should
also consider the risk that material misstatements
may occur by the manipulation of expenditure
recognition.
We have assessed the risk is most likely to occur
through the inappropriate capitalisation of revenue
expenditure or use of capital reserves.
We have assessed that the risk of
misreporting revenue outturn in
the financial statements is most
likely to be achieved through:
Revenue expenditure being
inappropriately recognised as
capital expenditure at the point
it is posted to the general
ledger;
Expenditure being classified as
revenue expenditure financed
as capital under statute
(REFCUS) when it is
inappropriate to do so;
Inappropriate adjustments
between usable reserves and
unusable capital reserves.
If this were to happen it would
have the impact of understating
revenue expenditure and
overstating Property, Plant and
Equipment (PPE) and/or REFCUS in
the financial statements.
Our response to significant risks
Inappropriate capitalisation of revenue expenditure or use of capital reserves*
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London Borough of Hillingdon Audit Planning Report 14
Our response: Key areas of challenge and professional judgementWhat is the risk, and the key judgements and
estimates?Financial statement impact
In response to this risk we will carry out a range of procedures including:
Seeking to understand the Council’s approach to the valuation of land and
buildings, including surplus assets;
Reviewing and assessing management’s assessment and planned approach to
CIPFA Bulletin 22;
Reviewing and appraising the work performed by the Council’s valuer, including
the adequacy of the scope of the work performed, their professional capabilities
and the results of their work;
Sample testing key asset information used by the valuers in performing their
valuation (e.g. floor plans to support price per square metre);
Involving our EY internal specialists to challenge the work performed by the
Council’s valuers, focusing on more material assets assessed as posing higher
risk of material misstatement;
Assessing any changes to the useful economic lives against the most recent
valuer assessments;
Testing accounting entries have been correctly processed in the financial
statements;
Sample testing transfers from assets under construction to ensure timely
reclassification upon completion, and confirming for a sample of assets that
remain within assets under construction that development is still in progress; and
Reviewing and assessing management’s impairment assessment of ongoing and
completed capital projects to ensure assets are held at an appropriate value.
The valuation methods for land and buildings,
including surplus assets, involve higher risk
estimates due to the significant assumptions and
judgements involved, and for which the Council uses
external specialists. These estimates heighten the
risk of material errors.
For the 2025/26 financial statements, the Council
will be required to apply CIPFA Bulletin 22 which
reassesses the current regime of valuation for non-
investment assets across the public sector. The
guidance mandates a quinquennial revaluation or a
five-year rolling programme for formal valuations,
supported by annual indexation in the intervening
years.
The Council has opted to perform revaluation of the
entirety of the asset base to which CIPFA Bulletin 22
applies as at 31 March 2026, to establish a baseline
for indexation to be applied in the following years.
Given full revaluations will not be required again until
2030/31, with indexation applied in intervening
years, it is even more important that valuations as at
31 March 2026 are appropriate and that the Council
is able to support completion of audit procedures
over these valuations.
The relevant account balances in
the 2024/25 financial statements
were:
Other land and buildings:
£833.7 million
Surplus assets: £44.8 million
Our response to significant risks
Valuation of land and buildings, including surplus assets
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London Borough of Hillingdon Audit Planning Report 15
We have identified other areas of the audit, that have not been classified as significant risks, but are still important when considering the risks of m aterial misstatement to the financial
statements and disclosures.
Other areas of audit focus
Our response: Key areas of challenge and professional judgementWhat is the risk, and the key judgements and
estimates?Financial statement impact
Valuation of pension assets and liabilities
In response to this risk we will carry out a range of procedures including:
Liaising with the auditor of the Hillingdon Pension Fund to obtain assurances
over the information supplied to the actuary, including membership data supplied
in respect of the 2025 triennial valuation of the Hillingdon Pension Fund, and
confirm joint assurances in respect of employer and employee contributions;
Engaging our EY actuarial specialists to assess the work of the Council’s actuary,
including evaluating the reasonableness of the Pension Fund actuary’s
calculations by comparing them to the outputs of our own auditor’s specialist’s
model. This will involve a consideration of the net asset/liability and any
calculation of the asset ceiling in accordance with IFRIC 14 where relevant;
Assessing the work of PwC, who are appointed to consider actuarial assumptions
used at the year end for all local government sector bodies;
Reviewing and testing the accounting entries and disclosures made within the
Council’s financial statements in relation to IAS 19, as well as any asset ceiling
applied under IFRC 14; and
Assessing the valuation and disclosure of unfunded liabilities, for which there are
no plan assets to meet the pension liabilities.
The Local Authority Accounting Code of Practice and
IAS 19 require the Council to make extensive
disclosures within its financial statements regarding
its membership of the Local Government Pension
Scheme administered by the Council.
The Council’s pension fund deficit is a material
estimated balance and the Code requires that this
liability be disclosed on the Council’s balance sheet.
The information disclosed is based on the IAS 19
report issued to the Council by the Council’s actuary.
Accounting for this scheme involves significant
estimation and judgement and therefore
management engages an actuary to undertake the
calculations on their behalf. ISAs (UK) 500 and 540
require us to undertake procedures on the use of
management experts and the assumptions
underlying fair value estimates.
The Council’s net pension asset or
liability is measured as the sum of
the long-term payments due to
members as they retire against the
Council’s share of the Hillingdon
Pension Fund’s investments. At 31
March 2025, the Council’s net
asset totalled £40.3 million but
was constrained to a £100.4
million net liability by the
accounting requirements of IFRIC
14.
An unfunded liability of £20.1
million was also recorded on the
Council’s balance sheet.
Confidential — All Rights Reserved
Our response: Key areas of challenge and professional judgementWhat is the risk, and the key judgements and
estimates?Financial statement impact
Valuation of council dwellings
In response to this risk we will carry out a range of procedures including:
Seeking to understand the Council’s approach to the valuation of council
dwellings;
Reviewing and appraising the work performed by the Council’s valuer, including
the adequacy of the scope of the work performed, their professional capabilities
and the results of their work;
Sample testing key asset information used by the valuers in performing their
valuation (e.g. nature and number of beacons, valuations of units within
beacons);
Testing accounting entries have been correctly processed in the financial
statements; and
Ensuring that the social housing discount factor has been applied to the
valuations of any council dwellings acquired during the period under audit.
The carrying amount of Council dwellings represents
a significant balance in the Council’s financial
statements and is subject to revaluation changes on
an annual basis. Management is required to make
material judgmental inputs and apply estimation
techniques to calculate the year end balances
recorded in the balance sheet.
Council dwellings held on the
Council’s balance sheet at 31
March 2025 totalled £898.4
million.
London Borough of Hillingdon Audit Planning Report 16
Other areas of audit focus
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Value for money03
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London Borough of Hillingdon Audit Planning Report 18
Financial sustainability
How the Council plans and manages its resources to ensure it can continue to deliver its services.
Governance
How the Council ensures that it makes informed decisions and properly manages its risks.
Improving economy, efficiency and effectiveness
How the Council uses information about its costs and performance to improve the way it manages and delivers its services.
The Council is required to maintain an effective system of internal control that supports the achievement of its policies, aims and objectives while safeguarding and securing value for
money from the public funds and other resources at its disposal.
As part of the material published with the financial statements, the Council is required to bring together a commentary on the governance framework and how this has operated
during the period in a governance statement. In preparing the governance statement, the Council tailors the content to reflect its own individual circumstances, consistent with the
requirements of the relevant accounting and reporting framework and having regard to any guidance issued in support of that framework. This includes a requirement to provide
commentary on arrangements for securing value for money from the use of resources.
Under the NAO Code we are required to consider whether the Council has put in place ‘proper arrangements’ to secure economy, efficiency and effectiveness on its use of resources.
The Code requires the auditor to design their work to provide them with sufficient assurance to enable them to report to the Council a commentary against specified reporting criteria
(see below) on the arrangements the Council has in place to secure value for money through economic, efficient and effective use of its resources for the relevant period.
The specified reporting criteria are:
Value for money
Council’s responsibilities for value for money
Auditor responsibilities
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London Borough of Hillingdon Audit Planning Report 19
The NAO’s guidance notes require us to conduct a risk assessment that collects sufficient evidence to document our evaluation ofthe Council's arrangements, allowing us to draft a
commentary under the three reporting criteria. This involves identifying and reporting on any significant weaknesses in those arrangements and making appropriate
recommendations. In considering the Council’s arrangements, we consider:
The Annual Governance Statement;
Evidence of arrangements during the reporting period;
Evidence obtained from our audit of the financial statements;
The work of inspectorates and other bodies; and
Any other evidence that we deem necessary to facilitate the performance of our statutory duties.
We then evaluate whether there is evidence indicating significant weaknesses in arrangements. According to the NAO's guidance, determining what constitutes a significant weakness
and the extent of additional audit work required to address the risk is based on professional judgment. The NAO indicates that a weakness can be considered significant if it:
Exposes, or could reasonably be expected to expose, the council to significant financial loss or risk;
Leads to, or could reasonably be expected to lead to, significant impact on the quality or effectiveness of service or on the council’s reputation or unlawful actions;
Identifies a failure to take action to address a previously identified significant weakness, such as failure to implement or achieve planned progress on action/improvement plans.
When planning work identifies a risk of significant weakness, the NAO’s guidance requires us to consider the additional evidence needed to verify whether there is a significant
weakness in arrangements. This involves conducting further procedures as necessary. We are required to report our planned procedures to the Audit Committee.
If we determine that the Council has not made proper arrangements for securing economy, efficiency, and effectiveness in its use of resources, the NAO Code mandates that we
reference this by exception in the audit report on the financial statements.
Additionally, we are required to provide a commentary on the value for money arrangements in the Auditor’s Annual Report. The NAO Code specifies that this commentary should be
clear , readily understandable, and highlight any issues we wish to draw to the Council’s or the wider public’s attention. This may include matters that are not considered significant
weaknesses in arrangements but should still be brought to the Council’s attention. It will also cover details of any recommendations from the audit and the follow-up of previously
issued recommendations, along with our assessment of their satisfactory implementation. Our 2025/26 Auditor’s Annual Report must be issued in draft by 30 November 2026 to
comply with the requirements of the NAO Code.
Planning and identifying risks of significant weakness in value for money arrangements
Reporting on value for money arrangements
Value for money
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London Borough of Hillingdon Audit Planning Report 20
Value for money
Value for money risk assessment
We have completed our initial value for money planning, where we have considered:
Our entity level controls and understanding the business assessment;
The Council’s risk register;
Council meeting minutes and our planning meetings with management;
Key financial and budget information;
Key performance and internal audit reports; and
Findings of other inspectorates, review agencies and other relevant bodies.
As part of our initial planning work, we considered whether there were any risks of significant weakness in the body’s arrangements for securing value for money that we needed to
perform further procedures on. The risks we have identified are detailed in the table below, along with the further procedures we will perform. We will continue to review the body’s
arrangements and report on our observations to the Audit Committee.
2025/26 expected procedures to respond2025/26 risk assessment2024/25 judgements on arrangementsCriteria
We developed a detailed understanding of the Council’s
arrangements with regards to financial sustainability through to
February 2026 as part of the prior year audit. We will draw on our
observations of these arrangements to inform our conclusions on
the Council’s arrangements for 2025/26, as well as:
Reviewing the Council’s progress through to 31 March 2026
against its Financial Modernisation Programme.
Reviewing the Council’s final outturn for 2025/26 against
budget, including the extent to which the Council was able to
deliver the savings included within its 2025/26 budget;
Reviewing the Council’s 2026/27 Budget and Medium-Term
Financial Strategy, approved in February 2026, as well as the
accompanying Section 25 report of the Council’s Section 151
Officer;
Assessing whether the Council’s reporting during 2026/27 of
its performance against its 2026/27 budget provides evidence
of the reliability of the assumptions underpinning the Council’s
2026/27 Budget and Medium-Term Financial Strategy; and
Assessing the financial resilience of the Council against
external benchmarks.
A risk of significant weakness has been
identified relating to financial sustainability.
The prior year significant weakness is an
indicator of a risk in the current year. Based on
our current understanding we consider it likely
we will continue to report by exception in
2025/26.
The Council did not have proper
arrangements in place to identify and
manage risks to its financial
sustainability.
Financial
sustainability
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London Borough of Hillingdon Audit Planning Report 21
Value for money
Value for money risk assessment continued
2025/26 expected procedures to respond2025/26 risk assessment2024/25 judgements on arrangementsCriteria
We will respond to this identified risk by:
Reviewing the Council’s progress through to 31 March 2026
against its Governance Review Improvement Plan (GRIP);
Obtaining and reviewing the data quality audit the Council had
planned to take place during 2025/26;
Enquiring of management as to the actions taken to address
any findings and recommendations of the above data quality
audit, as well as reviewing any evidence available to support
the implementation of those actions;
Considering whether indicators of weaknesses in the quality of
the Council’s information are highlighted by other reviews,
including the annual opinion of the Council’s Head of Internal
Audit; and
Considering our observations over the quality of the Council’s
financial records and other supports for the financial
statements during the execution of our audit procedures.
A risk of significant weakness has been
identified relating to the quality of Council
information.
The prior year significant weakness is an
indicator of a risk in the current year.
The Council did not have proper
arrangements in place to ensure the
quality of Council information.
Quality of Council
information (inc.
impact on ability
to support
external audit)
We will respond to this identified risk by:
Reviewing the Council’s progress through to 31 March 2026
against its Financial Modernisation Programme.
Considering whether the Council is able to meet the statutory
deadline for commencement of the public inspection period of
its 2026/27 accounts by 1 July 2026;
Considering our observations over the quality of the Council’s
financial statements, and the Council’s ability to support the
execution of audit procedures, through the delivery period of
our audit.
A risk of significant weakness has been
identified relating to the capacity of the
Council’s finance team.
The prior year significant weakness is an
indicator of a risk in the current year.
The Council did not have proper
arrangements in place to ensure the
capacity of its finance team was
sufficient to support the level of activity
required of it.
Capacity of the
finance team
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Audit materiality04
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London Borough of Hillingdon Audit Planning Report 23
Materiality
Materiality
For planning purposes, materiality for 2025/26 has been set at £15.4 million. This represents 1.5% of the
Council’s 2024/25 gross expenditure on provision of services in the 2024/25 financial statements. It will
be reassessed throughout the audit process.
We have chosen gross expenditure on provision of services as we consider that this is of primary interest to
the users of the financial statements. We have chosen 1.5%, which is in the middle of the range of
percentages within our audit approach for comparable size councils, after consideration of a range of
factors such as the public profile of the entity and the level and nature of its borrowings.
We have marginally increased our materiality from the 1.4% of gross expenditure on provision of services
applied in 2024/25 as the Council’s receipt of exceptional financial support means the Council’s financial
position is not as precarious in 2025/26 as it was during 2024/25.
Planning
materiality
£15.4m
Performance
materiality
£7.7m
Audit
differences
£0.77m
Gross expenditure on provision of services
£1,031m
We request that the Audit Committee confirm its understanding of, and agreement to, these materiality
and reporting levels.
Key definitions
Planning materiality — the amount over which we anticipate
misstatements would influence the economic decisions of a user of
the financial statements.
Performance materiality — the amount we use to determine the
extent of our audit procedures. We have set performance
materiality at £7.7 million which represents 50% of planning
materiality. We have used 50%, which is at the lower end of the
range within our audit approach, after consideration of a range of
factors including the difficulties encountered in performing audit
procedures in prior years and the significant weakness in
arrangements we reported in relation to the quality of the Council’s
data and capacity of the Council’s finance team for 2024/25.
Audit difference threshold — We will report to you all uncorrected
misstatements over £0.77 million, relating to the Comprehensive
Income and Expenditure Statement and Balance Sheet that have an
effect on the deficit on provision of services, and misstatements in
the other comprehensive income and expenditure, over £0.77
million.
Other uncorrected misstatements, such as reclassifications and
misstatements in the Statement of Cash Flows or disclosures, and
corrected misstatements, will be communicated to the extent that
they merit the attention of the Audit Committee, or are important
from a qualitative perspective.
Specific materiality — we report all differences identified over
£5,000 for remuneration disclosures, and apply a lower
judgemental materiality to our audit work in this area to reflect our
understanding that an amount less than our materiality would
influence the economic decisions of users of the financial
statements in relation to this. We do not apply a specific lower
materiality to the disclosure of related party transactions;
however, we do consider the materiality of transactions as they
apply to both parties involved.
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Scope of our audit05
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London Borough of Hillingdon Audit Planning Report
In accordance with the NAO Code, our primary objectives are to conduct work that supports the delivery of our audit report to the Council. Additionally, we aim to ensure that the
Council has established proper arrangements for securing economy, efficiency, and effectiveness in its use of resources, as mandated by relevant legislation and the requirements of
the NAO Code. We will issue an audit report that covers:
1. Financial statement audit
Our opinion on the financial statements:
Whether the financial statements give a true and fair view of the financial position of the Council and its expenditure and income for the period in question; and
Whether the financial statements have been prepared properly in accordance with the relevant accounting and reporting framework as set out in legislation, applicable accounting
standards or other direction.
Our opinion on other matters:
whether other information published together with the audited financial statements is consistent with the financial statements.
Other procedures required by the Code:
Examine and report on the consistency of the Whole of Government Accounts schedules or returns with the body’s audited financial statements for the relevant reporting period
in line with the instructions issued by the National Audit Office.
2. Arrangements for securing economy, efficiency and effectiveness (value for money)
We are required to consider whether the Council has put in place ‘proper arrangements’ to secure economy, efficiency and effectiveness on its use of resources and report a
commentary on those arrangements.
Internal audit
We will review internal audit plans and the results of their work. We will reflect the findings from these reports, together with reports from any other work completed in the year, in
our detailed audit plan, where they raise issues that could have an impact on the financial statements.
In 2024/25, the Council’s Head of Internal Audit concluded that they could provide no assurance over the internal control, risk management and governance arrangements during
2024/25.
Audit process and strategy
Objectives of our audit scoping
25
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Audit team06
London Borough of Hillingdon Audit Planning Report 26
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London Borough of Hillingdon Audit Planning Report 27
The engagement team is led by Stephen Reid, who has overall responsibility for the
performance of the audit and for the auditor’s report issued on behalf of EY.
Stephen is supported by Chloe Wilkinson, who joins the audit team for 2025/26 as a
second partner.
Stephen Reid
Key Audit Partner
Mark Rutter
Senior Manager
Cameron Halliday
Manager
Diva Bhagi
Lead Senior
Specialist (PPE)
EY Real Estates
Specialist (Pension)
Specialist PWC consulting
actuary and EY Actuaries
When auditing key judgements, we are often required to use the input and advice
provided by specialists who have qualifications and expertise not possessed by the core
audit team. The areas where EY specialists are expected to provide input for the current
year audit are:
In accordance with Auditing Standards, we will evaluate each specialist’s professional
competence and objectivity, considering their qualifications, experience and available
resources, together with the independence of the individuals performing the work.
We also consider the work performed by the specialist in light of our knowledge of the
Council’s business and processes and our assessment of audit risk in the particular area.
For example, we would typically perform the following procedures:
Analyse source data and make inquiries as to the procedures used by the specialist
to establish whether the source data is relevant and reliable;
Assess the reasonableness of the assumptions and methods used;
Consider the appropriateness of the timing of when the specialist carried out the
work; and
Assess whether the substance of the specialist’s findings are properly reflected in the
financial statements.
SpecialistsArea
EY Real EstatesValuation of Land and Buildings
EY ActuariesPensions disclosure
Audit team leadership
Our approach to the use of specialists
Audit team
Chloe Wilkinson
Partner
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Audit timeline07
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Planning
Walkthroughs
Substantive testing
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Auditor’s Annual
Report
Audit opinion on the Council’s
financial statements and
Auditor’s Annual Report
summarising the results of our
2025/26 work at the Council
Audit Planning Report
Reporting our
independence, risk
assessment, planned
audit approach and the
scope of our audit
Audit Results Report
Reporting our conclusions
on key judgements and
estimates and
confirmation of our
independence
Below is a timetable showing the key stages of the audit and the deliverables we have agreed to provide to you through the audit cycle in 2025/26.
From time to time matters may arise that require immediate communication with the Audit Committee and we will discuss them with the Audit Committee Chair as appropriate. We
will also provide updates on corporate governance and regulatory matters as necessary.
London Borough of Hillingdon Audit Planning Report 29
Timetable of communication and deliverables
Timeline
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Appendices08
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London Borough of Hillingdon Audit Planning Report 31
As set out in Appendix B our fee is based on the assumption that the Council complies with PSAA’s Statement of Responsibilities of auditors and audited bodies. See
https://www.psaa.co.uk/managing-audit-quality/statement-of-responsibilities-of-auditors-and-audited-bodies/statement-of-responsibilities-of-auditors-and-audited-bodies-from-2023-
24-audits/. In particular, the Council should have regard to paragraphs 26-28 of the Statement of Responsibilities which clearly set out what is expected of audited bodies in
preparing their financial statements. We set out these paragraphs in full below:
Preparation of the statement of accounts
26. Audited bodies are expected to follow Good Industry Practice and applicable recommendations and guidance from CIPFA and, as applicable, other relevant organisations as to
proper accounting procedures and controls, including in the preparation and review of working papers and financial statements.
27. In preparing their statement of accounts, audited bodies are expected to:
prepare realistic plans that include clear targets and achievable timetables for the production of the financial statements;
ensure that finance staff have access to appropriate resources to enable compliance with the requirements of the applicable financial framework, including having access to the
current copy of the CIPFA/LASAAC Code, applicable disclosure checklists, and any other relevant CIPFA Codes.
assign responsibilities clearly to staff with the appropriate expertise and experience;
provide necessary resources to enable delivery of the plan;
maintain adequate documentation in support of the financial statements and, at the start of the audit, providing a complete set of working papers that provide an adequate
explanation of the entries in those financial statements including the appropriateness of the accounting policies used and the judgements and estimates made by management;
ensure that senior management monitors, supervises and reviews work to meet agreed standards and deadlines;
ensure that a senior individual at top management level personally reviews and approves the financial statements before presentation to the auditor; and
during the course of the audit provide responses to auditor queries on a timely basis.
28. If draft financial statements and supporting working papers of appropriate quality are not available at the agreed start date of the audit, the auditor may be unable to meet the
planned audit timetable, and the start date of the audit will be delayed.
As we have outlined in prior years, our ability to complete the audit is dependent on the timely formulation of appropriately supported accounting judgements, provision of accurate
and relevant supporting evidence, access to the finance team and management’s responsiveness to issues identified during the audit. We presented our views on the effectiveness of
the Council’s arrangements to support external financial audit across a range of relevant measures as part of our 2024/25 Audit Results Report.
We have repeated this assessment on the following page. Where we have been unable to undertake all planned procedures, this is likely to extend the timetable to recover assurance
on the Council’s financial statements, see page 34 for further details.
Appendix A – Rebuilding assurance: responsibilities
The Council’s responsibilities
Observations from 2024/25
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London Borough of Hillingdon Audit Planning Report 32
Appendix A – Rebuilding assurance: responsibilities
Factors impacting the execution of the 2024/25 audit
Explanation
Status
Area
GA R
The financial statements were published on 22 September 2025, nearly three months after the statutory deadline
for commencement of the public inspection period of 1 July 2025.IneffectiveTimeliness of the draft financial
statements
Ensuring the quality of the draft financial statements was one of management’s reasons for the delayed publication
of the draft financial statements. Compared to 2023/24, the draft financial statements were of a noticeably better
quality with significantly fewer internal inconsistencies or typographical and arithmetic errors, although our checks
did identify a small number of such points.
We did however note a number of incorrect restatements of the prior period comparatives within the draft financial
statements which management has agreed to revert in the final statements.
Requires
improvement
Quality and completeness of the draft
financial statements
The original timetable agreed with management for the delivery of supporting working papers was predicated on
the Council having draft financial statements prepared by 30 June 2025. The delays in finalising the draft financial
statements also resulted in delays providing the supporting working papers for audit.
Against revised timelines agreed with management,
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