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The Year-One Audit Plan: What to Audit First When Everything Is Unaudited

A year-one audit plan is the first annual plan of a newly established internal audit function, built for an organization in which nothing has been audited internally before, by a team that does not yet know the business, for a board that does not yet know what the function will produce. It differs from every later plan in three ways: the risk assessment behind it rests on interviews and documents rather than on audit history, so it is less reliable; the function’s credibility is still to be earned, so what the plan produces matters as much as what it covers; and the organization’s tolerance for being audited is untested, so where the plan goes first shapes whether the second year is welcomed or resisted. The textbook answer, audit the highest risks first, is right in principle and usually wrong in sequence, because the highest-risk area in a new function’s universe is often the one where the function has the least standing and the least knowledge.

This guide gives the sequencing wisdom. It covers the foundation audits that map the terrain and teach the function the organization, the early wins that build credibility with evidence, the political minefields to defer until the function has standing and how to defer them without hiding them, sizing the plan for a team that is still learning, the hours a first year actually has, presenting the plan so that the committee understands what is not covered and accepts it on the record, the traps that sink first plans, and three example year-one plans for a private manufacturer, a newly public software company and a community bank. It follows the first 90 days guide, which gets a new chief audit executive to the point of having a universe, and precedes the one-person shop manual for functions that start at one; the plan guide covers the mechanics every plan shares.

In this guide

Why the first plan is different

DimensionEstablished functionYear-one functionImplication for the plan
Risk assessment basisAudit history, incident data, prior findingsInterviews, documents, management’s own viewRatings are provisional; the plan should include engagements that test them
Knowledge of the businessDeepShallowEarly engagements double as learning; scope them to teach
CredibilityEarnedNilWhat the first reports look like matters as much as what they cover
Organizational toleranceKnownUntestedWhere the function goes first shapes how it is received later
Methodology and templatesIn placeBeing writtenThe first engagements build the templates; budget for it
RelationshipsEstablishedFormingThe plan is also a schedule of introductions
Committee expectationsCalibratedOften unrealistic in either directionThe plan presentation sets them

Inputs when there is no audit history

With no findings to draw on, the first risk assessment rests on what the listening tour produced (where executives and managers say things break), on documents (the strategy, the risk register if one exists, incident and complaint records, the external auditor’s management letters and any regulatory correspondence, the insurance claims history), on data the function can pull quickly (volumes by process, exceptions, write-offs, adjustments), and on the structural facts a new auditor can see in a week: single points of failure, acquisitions not integrated, systems past their life, functions with one person in them. The risk assessment method applies with a smaller factor set and an honest statement that the ratings are provisional; the universe is built at coarse granularity (30 to 60 entities for a mid-size organization) because the function cannot yet tell where the finer lines fall. The committee’s own view is an input, not an instruction: a chair who wants the plan to start with the area that worries the board is giving the function information about the board’s risk perception, which the plan should address, and about politics, which it should weigh.

Foundation audits: mapping the terrain

Foundation engagementWhy firstWhat the function learnsGuide
Entity-level controls and governanceShows whether the organization’s control environment can support process controls at all; introduces the function to every executiveWho decides what; where policies exist and where they are folklore; the board’s real oversightEntity-level controls
User access to the core systemsUniversal, objective, data-driven; findings are hard to argue with; access underlies every other controlThe systems, their owners, the leaver process, the administrators, how much the organization relies on a few peopleUser access review; IAM audit
The financial closeTouches every process’s output; the CFO cares; the external auditor’s letters give a head startThe accounting systems, the manual journal culture, the reconciliations, the spreadsheetsFinancial close
The core process (what the business does to earn money) at one site or unitTeaches the business; produces the function’s first operational findings; scoped to one unit so it finishesHow the product moves, where cash and inventory are exposed, who the operators areOrder to cash; procure to pay; inventory
Purchase-to-pay analyticsFull-population, cheap, finds recoverable money (duplicates, unverified vendors) in most organizationsThe vendor base, the payment controls, the data qualityAP analytics

Foundation audits are chosen because they teach the function the terrain while producing defensible findings, not because they are the highest risks; a year-one plan of three to four foundation engagements and one or two risk-driven ones is the common shape. The entity-level engagement is the most often skipped and the most valuable: a function that discovers in year three that the organization has no delegation of authority and no policy framework has spent two years auditing processes whose controls were never going to hold.

Early wins: credibility from evidence

Credibility in year one comes from findings that are specific, evidenced, agreed by their owners and fixed, and from the money and risk they demonstrably address. The engagements that produce such findings fastest share three features: a population the function can test in full or sample objectively (payments, access, payroll, expenses), criteria nobody disputes (policy, law, the organization’s own procedures), and an owner who benefits from the finding being fixed. Duplicate and unverified vendor payments, leaver access still active, payroll paid after termination, expense policy breaches by the senior population and uncollected receivables are the classic early wins, and the AP, payroll and travel and expense guides show the tests. The win is not the finding but the fix: a recovered $47,000 and a closed leaver process are what the committee remembers, and the life of a finding guide explains why the function should track and report the fixes as carefully as the findings in its first year.

Political minefields: defer without hiding

MinefieldWhy it is dangerous in year oneWhat to do instead
The chief executive’s pet project or divisionFindings will be read as an attack; the function lacks the standing to survive the reactionCover the division’s transactional processes (access, payments) in a foundation audit; schedule the strategic review for year two with the chair’s backing
A function whose head sponsored internal audit’s creationGratitude and dependence compromise objectivity; a hard finding ends the relationship the function still needsAudit it in year two, after the function reports to the committee in fact and not only on paper
Executive compensation and expensesPowerful auditees; findings embarrass the boardInclude the senior population in the expense analytics with the chair’s prior knowledge; report privately first
CultureJudgment-heavy; the function has no baseline and no credibility for soft findingsGather culture evidence in every engagement; a culture audit in year two or three (the culture guide)
Strategy and major decisionsRequires business knowledge the function does not haveDefer; note in the plan presentation as the year-two priority
A live crisis or investigationThe function is drawn in without a protocol or standingAgree the investigation protocol with counsel before anything happens; support, do not lead, in year one

Deferring is not hiding. The plan presentation names the deferred areas, their risk ratings and the year they are scheduled, so that the committee has decided to wait rather than discovering later that the function avoided them. A deferred area that produces a loss in year one is a committee decision; a hidden one is the function’s failure.

Sizing: fewer, better, finished

A first-year team works slower than it will: it is writing templates as it goes, learning systems, building relationships and discovering that every engagement needs a walkthrough of a process nobody has documented. Engagements take 30 to 50 percent longer than the same team will take in year three, and the plan should budget accordingly: five to seven engagements for a function of two or three people, four to five for one person, with 20 percent of capacity held in reserve for the requests a new function receives from executives testing what it is for. Every engagement is sized to finish inside a quarter, because a first-year engagement that drags across two quarters loses its owner’s attention and the function’s momentum. The committee is told the sizing logic, because a committee that expected twelve audits and received six will judge the function a failure unless it approved six, and a chief audit executive who delivers six of six approved has a record while one who delivers six of twelve has an excuse; the plan guide’s capacity model is where the arithmetic is shown.

The hours a first year actually has

Use of timeFunction of oneFunction of threeNote
Gross hours2,0806,240
Leave, holidays, administration−380−1,140Standard
Methodology, templates, tools setup−200−350Year-one specific; the manual and templates
Universe, risk assessment, plan−150−250Heavier in year one
Committee, board, charter work−150−200The charter and the committee relationship
Listening tour and relationship building−120−200Year-one specific
Training and professional activity−100−300Standards, systems, the business
Reserve for requests and investigations−200−60020 percent of what remains
Available for planned engagementsAbout 780About 3,200Four engagements of 150 to 250 hours; or ten to twelve of 250 to 350

The table is the honest version of a year-one capacity, and it is usually about 60 percent of what the same team will have in year three. Co-source hours add to the available line for the engagements the team cannot perform (technology, specialist areas), as the co-sourcing guide describes, and should appear in the plan as hours and dollars the committee approves.

A sequencing framework

QuarterEngagement typePurposeTypical choice
FirstFoundation: data-driven, universalLearn the systems; produce objective findings fast; first report to the committee within the quarterUser access to core systems; purchase-to-pay analytics
SecondFoundation: governanceUnderstand the control environment; meet every executive with a purposeEntity-level controls and policy framework; or the financial close
ThirdCore process, one unitLearn the business; first operational findingsThe main revenue or production process at one site
FourthRisk-driven, specialist, often co-sourcedAddress the committee’s top concern with the standing now earned; buy skills the team lacksCyber resilience; third-party; the regulatory program
ThroughoutValidation and reserveTrack and validate every action from the first engagements; absorb requestsThe issue log; the validation discipline

The framework is a default, not a rule. A function created because of a crisis (a fraud, a regulatory action) starts with the crisis area because the committee’s question cannot wait, and the pre-IPO readiness guide describes the version in which SOX deadlines dictate the first year. What the framework protects is the principle that the function should know the organization before it judges its strategy, and should have fixed something before it criticizes anyone powerful.

Presenting the plan to the committee

The year-one plan presentation sets the committee’s expectations for years, and it should contain five things the plan template carries: the universe and its provisional ratings, with the statement that they are provisional and will be tested; the engagements chosen, with the reason for each in terms of the framework above (foundation, early win, risk-driven); the areas not covered and the areas deliberately deferred, with their ratings and the year they are scheduled; the capacity arithmetic and the co-source budget; and the measures by which the committee should judge the year (engagements completed as planned, findings agreed and fixed, the first conformance statement). The committee approves the plan and, in the same decision, the gaps, which the annual agenda guide places in the fourth-quarter meeting with the charter‘s approval clause behind it. The presenting to the committee guide covers the delivery; the first-year specific point is to under-promise in writing, because the function will be judged against the document.

Template: the year-one plan summary page

Internal audit plan, year one, [organization]. Universe: [61] auditable entities, rated provisionally on [three] factors from interviews, documents and data; ratings to be tested by the year’s engagements and refined for year two. Capacity: [1,150] in-house productive hours and [400] co-sourced hours within a budget of [$]; reserve [180] hours for requests and investigations. Engagements: [five], listed with quarter, hours, type (foundation, early win, risk-driven, mandated) and the reason for each. Coverage: [the entities covered, their ratings]; high-risk entities not covered this year: [list with ratings], scheduled for [year two] and accepted by the committee as an open risk for the year. Deferred areas and reasons: [strategy and major decisions: knowledge; the finance function: standing; culture: baseline], scheduled for [year two or three]. Co-source: [firm, scope, hours, cost, the function’s scoping and review role]. Methodology: templates in place; manual by [month four]; first quality self-assessment with the annual report. Measures for the year: engagements completed as planned; findings agreed and actions validated; the first conformance statement; committee satisfaction. Approval: [committee, date]; gaps acknowledged in the same decision.

Traps that sink first plans

TrapHow it happensAvoidance
The textbook universe120 entities and twelve engagements copied from a larger organization’s planCoarse universe; five to seven engagements; reserve
Starting with strategyThe board’s biggest worry audited first by a team that does not know the businessFoundation first; the strategic review in year two with standing
Auditing the sponsorThe CFO who created the function receives its first hard reportDefer; report to the committee in fact first
No early winThree governance reviews and no recovered money or fixed controlOne data-driven engagement in the first quarter
Engagements that do not finishScopes too wide; reports issued two quarters lateSize to finish inside a quarter; narrow scope
Findings not fixedReports issued; actions untracked; year two finds the same thingsIssue log from day one; validation in the plan
Hidden deferralsDifficult areas left out without telling the committeeDeferred areas named with ratings and dates
Methodology written after the engagementsFiles inconsistent; the first quality review failsTemplates before the first engagement; the manual by month four
Co-source drives the planThe firm proposes what it sellsThe function scopes; the firm delivers

Example plan 1: a private manufacturer (Brightwater Foods)

Brightwater Foods is a $180 million food manufacturer with three plants and about 600 staff, used in examples across this site, whose board formed an audit committee and hired a first chief audit executive who worked alone in year one with a co-source firm, as the solo shop manual recounts. The universe had 61 entities; capacity was about 1,150 in-house hours plus 400 co-sourced.

QuarterEngagementTypeHoursWhy it was chosen
FirstProcure-to-pay analytics across all plantsFoundation; early win220Full-population, objective; found duplicates and unverified vendors; taught the function the ERP and the vendor base (the first run)
SecondCyber resilience review (co-sourced, scoped and reviewed by the CAE)Risk-driven; committee’s top concern250 co-source + 60The board’s stated worry; the firm had the skills; findings (41-hour restore against a 24-hour target) funded the backup program
Second to thirdPlanned maintenance at the three plantsCore process, operational280Taught the plants; criteria set with operations (the criteria guide); produced the first operational findings plant managers accepted
ThirdThird-party resilience: continuity-critical suppliersRisk-driven; co-sourced in part150 co-source + 120Followed from the cyber review’s dependency findings; found the sole-source closure supplier
FourthBusiness continuity programFoundation for resilience; governance300Pulled the two resilience reviews into a program finding; set up year two’s BIA and exercise agenda
Deferred to year twoEntity-level controls and policy framework; technology general controls; sales and customer concentration; HRNamed in the plan with ratings; the committee accepted the gap on the record

The plan broke the framework in one respect, deferring the entity-level engagement to year two, because the CAE judged that the charter and committee work of the first six months was itself the governance review and that the board’s concern about cyber could not wait; the plan presentation said so. Five of five engagements finished, every action tracked, and the second auditor was funded on the strength of the year.

Example plan 2: a newly public software company

The newly listed software company described in the pre-IPO readiness guide built its internal audit function in the year of its listing, with a head of internal audit and two auditors hired from external audit, a SOX program already run from finance with consultants, and a universe shaped by the listing’s deadlines: the first 404(a) assessment with the second annual report and the NYSE’s internal audit requirement. Capacity was about 3,000 in-house hours plus 500 co-sourced.

QuarterEngagementTypeHoursWhy it was chosen
FirstUser access and segregation of duties in the ERP and the production platformFoundation; data-driven350Underlies SOX ITGCs; objective; introduced the function to engineering
FirstEntity-level controls and the policy frameworkFoundation; governance300The listing created the committees and policies; the function tested whether they operated
SecondRevenue recognition and order-to-cash controlsCore process450The highest financial reporting risk for a software company (the guide); coordinated with the SOX program so controls were tested once
Second to thirdSOX program quality: independent assessment of the consultants’ control matrices and testingRisk-driven; assurance over management’s program400The committee needed an independent view of a 412-control matrix before the first assessment; internal audit assessed rather than performed the testing, preserving independence
ThirdCloud security and change management (co-sourced)Risk-driven; specialist500 co-source + 150The product runs in the cloud; the cloud program and pipeline guides
FourthEquity compensation and payrollEarly win; sensitive population300Stock administration errors are common after listing; the chair knew in advance that executives were in the population
FourthVendor management and spend analyticsEarly win; data-driven300Recoverable money; the vendor base had doubled
DeferredSales compensation; data privacy; strategy and M&A; customer success operationsNamed with ratings; privacy scheduled for year two with a specialist

Example plan 3: a community bank

A $1 billion community bank that had outsourced internal audit entirely for a decade hired an in-house audit manager and a staff auditor, keeping the outsourcing firm for BSA/AML independent testing and technology work, after examiners observed that the board’s oversight of the outsourced function was thin. The universe, built from the firm’s prior coverage and the bank universe example, had 54 entities; the banking guide‘s regulatory commitments fixed about 40 percent of the hours before any choice was made.

QuarterEngagementTypeHoursWhy it was chosen
ThroughoutRegulatory issue validation and examination supportMandated300Open matters from the last examination; the function’s first task was to validate what the firm had reported closed
FirstBSA/AML independent testing (outsourced, scoped and reviewed in-house)Mandated; specialist400 outsourced + 60Annual requirement; the in-house team learned the program by reviewing the firm’s work (the test)
FirstUser access to the core banking system and wire platformFoundation; data-driven250Objective; examiners always look; found leaver access and shared administrator credentials
SecondWire transfer and ACH operationsCore process; highest-velocity risk300The bank’s largest fraud exposure; the payment operations program; findings on callback procedures
Second to thirdCommercial lending: origination and servicing at one regionCore process; learn the business400The largest asset; scoped to one region to finish; coordinated with credit review
ThirdFDICIA support and financial closeMandated; foundation300Part 363 requirements; the external auditor’s reliance discussion
FourthBoard and committee governance; vendor management programGovernance; risk-driven250The examiners’ observation on oversight; the third-party program examiners test
DeferredDeposit operations; mortgage; interest rate risk and ALM (outsourced firm in year two); trustNamed with ratings and the regulatory cycle expectation stated

The bank plan shows the regulated version of the framework: mandated and validation work first because it is not optional, foundation access work alongside it, the core process (lending) at one region, and the governance engagement answering the examiners’ observation in the fourth quarter when the function had standing. The three plans differ in content and agree in shape: foundation and early wins before judgment, deferrals named, everything sized to finish, and in each the fourth quarter’s engagement was the one the committee had wanted first.

What year two inherits

A year-one plan done well leaves year two four things: a universe whose ratings have been tested by engagements and can be refined to finer granularity; a methodology and templates that exist because the first engagements needed them; relationships with every executive, formed through foundation audits rather than through confrontation; and an issue log with validated fixes that gives the function its first evidence of value. It also leaves the deferred list, which becomes year two’s risk-driven core: the strategic review, the sponsor’s function, culture, the areas that needed standing. The KPI guide‘s first-year measures (plan completion, findings fixed, committee satisfaction) are the record the function carries into the second plan presentation, and the Domain I purpose statement is the test of whether the first year produced what the function exists for: assurance, advice, insight and foresight the board did not have before.

Questions about year-one audit plans

What should a new internal audit function audit first?

Foundation areas that teach the function the organization and produce objective findings: user access to core systems, purchase-to-pay analytics, entity-level controls and the financial close, then the core business process at one unit, with the committee’s top risk-driven concern in the fourth quarter when the function has standing and can buy the skills.

How many audits should a first-year plan include?

Four to five for a function of one, five to seven for two or three people, each sized to finish inside a quarter, with 20 percent of capacity in reserve. First-year engagements take 30 to 50 percent longer than they will later.

Should the first audit be the highest risk?

Usually not first. The highest risk is often strategic or political, where a new function lacks knowledge and standing; it belongs in the fourth quarter or year two, named in the plan with its rating so the committee decides to wait rather than discovering the function avoided it.

How do I handle areas I am deferring?

Name them in the plan presentation with their provisional ratings and the year they are scheduled, and have the committee approve the gap in the same decision as the plan. Deferring openly is a committee decision; deferring silently is the function’s failure.

What is an early win and why does it matter?

A finding that is specific, evidenced, agreed by its owner and fixed, typically from a data-driven engagement over payments, access or payroll, that demonstrably recovers money or closes a risk. It is what gives the function the credibility to audit harder areas later.

How does a regulated company’s first plan differ?

Mandated work (regulatory validation, BSA testing, FDICIA or SOX support) fixes a large share of hours before any choice is made, and examiner expectations shape the cycle; the framework still applies to the discretionary hours, with foundation work alongside the mandated items.

When should the methodology be written?

Templates before the first engagement and the manual within the first four months, budgeted as year-one hours. Writing the methodology after the first engagements produces inconsistent files and a failed first quality review.

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