Standards and terms

Findings that hold before a public accounts committee.

This page is for the officer who has to defend the procurement. It sets out the standard we report under, the method in outline, and the terms we work to.

ISRS 4400 Method Terms

ISRS 4400 is a reporting standard, not a software product. A proposal that says a tool "runs ISRS 4400", or promises fraud ratings inside an agreed-upon procedures report, will not survive review by a supreme audit institution. Neither would ours, so we do not write them.

Reporting standard

Two reports, never merged.

An agreed-upon procedures report must not carry opinions. A government still needs estimates to act on. They arrive as separate documents, so the factual findings hold when an operator challenges them.

Report 1 · ISRS 4400 (Revised)

Agreed-upon procedures

Factual findings: what was compared, with what, and the difference
The engaging party confirms in writing that the procedures fit the purpose
Named intended users and restricted distribution
Each finding stated with its population, sample and source
No opinion, no conclusion, no assurance

Report 2 · Advisory

Analytics and exposure

Inferred obligations as ranges, with the assumptions stated
Operator risk tiers and where to look next
Recommendations on systems, data sharing and enforcement
Marked as not assurance and not part of Report 1

Method in outline

Every tax, fee and levy is a fixed charge or a rate on a revenue base. So we test the base.

Each operator-year comes down to three questions, answered in this order.

Step 1
Rebuild the base

Revenue reconstructed from sources outside the operator's control. One operator's outbound traffic is a check on another's inbound. Settlement records, foreign carrier statements and regulator registers do the rest.
Step 2
Apply the law

Gazetted rates applied to the rebuilt base for each obligation and period, including the details that decide real money. For example, whether interconnect paid out sits inside or outside a levy base.
Step 3
Compare with the record

What was declared and paid, taken from the authority's and regulator's own ledgers. The difference is a finding, stated with its population, sample and source.

The review period matches the statutory reassessment window. A finding outside that window cannot be assessed, so you should not pay for it.

Terms we work to

Written to be procured, audited and handed over.

No success feesWe are never paid a share of revenue recovered. That would compromise independence, and in most jurisdictions it is not allowed.
Payment against deliverablesMilestones follow issued reports and working environments, never a kick-off meeting.
Declared independenceNo team member has acted for an in-scope operator in the past three years, and none will for two years after.
The auditor stays freeThe supreme audit institution observes and does not steer, so it can still audit the engagement itself.
Sovereign dataProcessing stays in-country. The government holds the keys, the code and the data from day one. Subscriber identifiers are masked before analysis.
Sealed working papersEach stage is hash-sealed with a recorded chain of custody, then handed over at close.
Data by lawful directionEach regulator directs its own licensees under its own statute. We never ask an operator for data directly.
Capability left behindBefore we leave, your staff re-run a full procedure without our help.
A paid feasibility stage with a real exitA small first award that is simple to procure. You decide on the next stage with pilot evidence in hand.
A named teamSenior practitioners are named in the contract, with independence declarations for every in-scope operator.

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