Audit and parliamentary scrutiny play a vital role in holding the Scottish Government and public bodies to account for the use of public funds in, and the overall progress toward, tackling climate change. This blog looks at the role of the Public Audit Committee (PAC) and the work of the Auditor General for Scotland (AGS) with respect to climate change. It summarises the relevance of audit to Scotland’s climate response, key themes from audit and related scrutiny work on climate change, how it compares with audit work on climate change across the UK and globally, and future priorities for audit and related scrutiny of climate change.
This blog is one of a series that illustrate how climate change relates to policy areas covered by subject committees.
The role of the Scottish Parliament’s Public Audit Committee (PAC) and its relationship with the Auditor General for Scotland (AGS)
PAC examines how the Scottish Government and public bodies (including colleges, police, fire services and the NHS) spend and manage public money to ensure that it is spent efficiently and effectively. It mainly focuses scrutiny on issues covered in reports published by the AGS.
The AGS is responsible for the audit of all public bodies except local authorities, while the Accounts Commission is responsible for auditing councils and other local government bodies in Scotland. Audit Scotland (AS) supports both by conducting audits and publishing independent reports that inform PAC’s scrutiny.
Why is climate change relevant to audit of public bodies in Scotland?
Research and scientific advice suggests that a legal commitment to net zero alone will not drive the required transformation of our economy and society; clear and committed leadership and a people-centred approach and a strong and effective structure inside government capable of a whole-systems approach and ‘organising to deliver’ are needed.
Independent public audit has an important role in providing assurance to people about how the Scottish public sector is responding to the climate emergency and how public money is being used to help achieve Scotland’s climate change targets. Climate change is an audit priority for both the AGS and the Accounts Commission. AS’s strategy for auditing climate change, published in January 2025, states that responding to a challenge as complex as climate change, which spans most areas of public policy, requires a whole-systems approach and that “climate change considerations need to be central to public bodies’ decision-making and financial planning.” As well as examining value for money, AS consider a wide range of issues, from leadership and governance to alignment of spend across policy areas and implementation of plans and strategies.
Cross-cutting themes from AGS work on climate change
Over Session 6, the AGS has undertaken several performance audits – national reports that focus on efficiency and effectiveness in the use of public resources – that focus specifically on public sector action and spend on climate change. These include arrangements to support public bodies’ response to climate change and the implementation of policies and strategies to reduce emissions:
- Sustainable transport, January 2025
- Decarbonising heat in homes, February 2024
- How the Scottish Government is set up to deliver climate change goals, April 2023.
Audit Scotland state that they are also working to integrate climate considerations into their wider work. For example, considering the challenges in meeting net zero commitments within existing capital budgets in their reporting on the NHS and college sector.
This audit work suggests several overarching themes that cut across different areas of Scotland’s climate change response.
Ambition vs delivery gap
A consistent theme is the disparity between Scotland’s statutory target to achieve net zero emissions by 2045, and the actual pace of delivery on the ground. For example, in Decarbonising heat in homes, AS reported that “Unless the scale and pace of activity significantly increase the Scottish Government’s ambition will not be met.” AS also found that current progress was insufficient to meet stated goals in its Sustainable transport: Reducing car use report:
“In 2020, the Scottish Government set an ambitious but very challenging target to reduce car kilometres driven by 20 per cent by 2030. It still does not have a clear plan to achieve this. A lack of leadership has resulted in minimal progress against the demanding policy intention.”
Complexity of climate change policy and the need for coordination
Audit work highlights the complexity of climate change policy and emphasises the importance of strong coordination across central government, across and between levels of government, among various public bodies and with others in the private and third sectors. For example, in its report on Decarbonising heat in homes, AS found:
“The Scottish Government recognises that it cannot deliver its HIBS [Heat in Buildings Strategy] ambitions alone. It has a key role in coordinating and supporting activity in this complex area, working with a wide range of partners and stakeholders to secure investment, build infrastructure and develop a supply chain. Stakeholders include the public, delivery partners for HIBS schemes, private sector investors, industry and the UK Government. The Scottish Government has a complex role to coordinate activity across these stakeholders. It needs to create the right conditions to enable them to play their part and support people to make the changes needed to their home.”
Similarly, in its report on Sustainable transport, AS reported that “The challenges of reducing car use are wide-ranging and significant… national and local government and others in the private and third sectors need to work together effectively.”
Need for improved governance, reporting and accountability
The AGS has repeatedly pointed to weaknesses in governance arrangements. For example, in its report on How the Scottish Government is set up to deliver climate change goals, AS found informal and non-recorded meetings and unclear accountability lines, which created risks of poor oversight and decision-making, as well as lack of clarity over roles and responsibilities leading to duplicated efforts or gaps in delivery. They also found that “lack of frequent and consistent reporting”, alongside gaps in performance monitoring, make it difficult to gain assurance of overall progress.
Similarly, in its Decarbonising heat in homes report, AS recommended that the Scottish Government should finalise governance arrangements for the Heat in Buildings Strategy programme “as soon as possible and keep these under review to ensure they remain fit for purpose.” It also recommended that the Scottish Government should produce a delivery plan for the Strategy by the end of 2024, setting out clear actions, timescales for delivery, clarity on the roles of the Scottish Government and its partners and the anticipated impact of these actions.
In its report on Sustainable transport, AS reported that “the Scottish Government is now improving its climate change governance arrangements to provide oversight of programmes for which the Director General Net Zero is responsible for.” However, it reported that the Scottish Government and COSLA had yet to establish a joint governance group to oversee progress on the car kilometre target and that action on the car kilometre target “requires stronger leadership and clearer governance arrangements.” It also reported that:
“It is not clear if the Scottish Government remains committed to the target as key documents remain in draft form, there is no costed delivery plan or measurable milestones, and arrangements for monitoring and scrutinising progress are insufficient.”
The Scottish Government abandoned the car km reduction target in the months following the AS publication.
Workforce planning and future skills needs
The need for workforce planning is another recurrent audit theme. In its April 2023 report on How the Scottish Government is set up to deliver climate change goals, AS reported that there had been no workforce plan in place for the DG Net Zero area since it was established in November 2021, and that it was “unclear if the Scottish Government has enough staff with the skills needed to deliver on its climate change commitments.”
AS’s audit on Decarbonising heat in homes also reported concerns about staff capacity and capabilities, including that the Scottish Government had been initially slow to build capacity in the core programme team, and that “Given the pressing timescales it is working towards, the Scottish Government would have benefited from addressing its capacity needs sooner.” The audit also highlighted challenges in developing a wider supply chain and skilled workforce for decarbonised heat, and recommended that the Scottish Government prioritise work in this area given the long lead-in times required to undertake actions to address workforce gaps.
Data quality challenges and the need for transparent reporting
Reliable data are the foundation of effective audit and public accountability. However, AS has reported inconsistent data collection, poor data quality, and lack of transparency. For example, AS’s audit on Decarbonising heat in homes identified “some data gaps that will make reporting on some areas challenging, such as heat networks and skills.” Equally in its report on Sustainable transport, AS found “challenges in securing timely and reliable data to assess the impact of sustainable transport activities.” It noted that high quality datasets would allow the government and councils to make more evidence-based decisions. It also reported that Scottish Government and council spending on measures to reduce car use “is complex, fragmented and lacks transparency.”
Unclear funding strategies
Another recurrent theme is a lack of clarity about funding strategies and whether resources are effectively managed. For example in its report on How the Scottish Government is set up to deliver climate change goals, AS reported that:
“The Scottish Government does not know how much the policies proposed in the current Climate Change Plan Update will cost and so is uncertain whether sufficient money will be available to support the commitments it has made.”
In its Decarbonising heat in homes audit, AS noted Scottish Government estimates that it could cost the public sector, businesses and households £33 billion in total to deliver its full Heat in Buildings Strategy by 2045. It stated that given the competing spending priorities faced by the Scottish Government “it must carefully consider how much public money to invest in this area and how to maximise its impact and ensure value for money. It also needs to consider how it can help to enable the private sector to roll out funding and finance mechanisms.” The finding in the Sustainable transport report was that “the target was not accompanied by dedicated funding or a clear delivery plan with milestones to measure progress against.”
Insufficient focus on climate adaptation
Another theme is insufficient emphasis on adaptation compared to mitigation. While reducing emissions is critical, so too is preparing public services and infrastructure for inevitable climate impacts – and this is less advanced. For example, in its report on How the Scottish Government is set up to deliver climate change goals, AS reported that “although there is now increasing focus on adaptation within the Scottish Government, governance arrangements to help Scotland adapt to the impact of climate change are less developed than those for reducing emissions.” It also found that performance monitoring information for adaptation was not as well developed as for reducing emissions, and highlighted the lack of an indicator to monitor progress in relation to adaptation in the National Performance Framework.
Scrutiny by the Public Audit Committee on climate change
Audit can strengthen parliamentary scrutiny, through embedding audit findings systematically into committee work and promoting cross-committee collaboration. It can also strengthen parliament’s proactive governance oversight, requesting government responses to identified gaps and monitoring delivery plans over time.
PAC has scrutinised climate governance and delivery through public evidence sessions with government officials, the Auditor General and other stakeholders and correspondence with the Scottish Government to request information. It has also shared key issues with other parliamentary committees to support their scrutiny of substantive policy areas and legislation.
Sustainable transport: Reducing car use
PAC heard evidence from the Cabinet Secretary for Transport in April 2025, following an evidence session on the AGS report in February 2025. PAC subsequently wrote to the Cabinet Secretary for Transport in May 2025, requesting further information, including about financial governance in the delivery and monitoring of active travel funding. The Cabinet Secretary for Transport responded on 2 June 2025:
“…the Scottish Government accept, in principle, the recommendations made in the sustainable transport audit. We continue to work to address them with our key delivery partners in the updated context of confirming that we will revise the car use reduction target and set a successor target. This new, longer term target will be aligned with the timescales for the Climate Change Plan and support our target of net zero emissions by 2045.”
The Cabinet Secretary for Transport wrote to PAC again on 12 June 2025, providing an update on the progress of a renewed policy statement with COSLA on reducing car use. The letter confirmed a Renewed Policy Statement on achieving car use reduction in Scotland. The Statement sets out that a revised car use reduction target is being developed based on advice from the UK Climate Change Committee to the Scottish Government on carbon budgets, and further commissioned evidence. PAC work on this area is ongoing.
Decarbonising heat in homes
PAC took evidence from Government officials in March 2024, following an evidence session on the AGS report in February 2024. Following these, PAC wrote to the Local Government, Housing and Planning (LGHP) Committee and the Net Zero, Energy and Transport (NZET) Committee in April 2024 on the key issues from its work. It highlighted several areas for consideration for continued scrutiny to the LGHP and NZET Committees:
- Governance arrangements, including monitoring the Scottish Government’s progress in finalising its governance arrangements and publishing a delivery plan for its Heat in Buildings Strategy programme.
- Value for money, the extent to which the Heat in Buildings Strategy is delivering value for money.
- Public participation, including the effectiveness of the Scottish Government’s public engagement strategy as part of their scrutiny of the proposed Heat in Buildings Bill and the next Climate Change Plan (CCP).
PAC also highlighted several areas to the LGHP Committee, to consider in its scrutiny of the proposed Heat in Buildings Bill:
- Just transition and fuel poverty, including seeking assurances that the proposed legislation will address affordability, fairness, equality and feasibility.
- Private investment, including the progress made by the Scottish Government to secure private investment.
- Skilled workforce gap, including the progress being made by the Scottish Government to close the skills gap.
At the time of writing, the Scottish Government has not laid the proposed Heat in Buildings Bill or a draft of the next CCP, and has not published a delivery plan for its Heat in Buildings Strategy programme (a recommendation from the AS report).
How the Scottish Government is set up to deliver climate change goals
PAC took evidence from Scottish Government officials and the AGS in September 2023, following an evidence session on the AGS report in May 2023 and its scrutiny of the Major Capital Projects and Programmes. This comes under the “Enabling the transition to Net Zero emissions and environmental sustainability” theme of the Scottish Government’s Infrastructure Investment Plan (IIP) in June 2023.
Following these, PAC requested further information from the Scottish Government including on governance arrangements and monitoring data. Based on its work, PAC wrote to NZET in October 2023, to highlight key issues to inform NZET’s scrutiny of the draft CCP. These included:
- Governance arrangements, highlighting its concern that governance arrangements to support adaptations to climate change were not yet as fully developed as those in place to reduce emissions.
- Cross-government collaboration, noting progress had been made, but highlighting gaps and a need for greater transparency.
- Lack of assessment of the impact of policies and spending on emissions, noting a need for the next CCP to contain detail on the emissions that each policy will deliver, as well as costings based on informed assessments, alongside access to funding for net zero projects.
- Just transition, including that the Scottish Government must continue to actively promote the support available to ensure maximum public participation in schemes to help achieve its net zero targets.
- Risk management, highlighting concern that several risk registers contained actions which were vague and unclear.
- Workforce plan and workforce capacity, including exploring the steps that the Scottish Government is taking to ensure it has the workforce capacity and capability to deliver its climate change commitments in all directorates.
At the time of PAC’s work, the draft CCP was expected in November 2023; however it has not yet been laid. Notwithstanding the absence of the draft CCP, NZET has built on PAC’s work – using it to inform its Scottish Government climate change and environmental governance stocktake in May 2024. Between February and April 2025, NZET has also engaged directly with AS – as well as other auditors and regulators – in its work as lead Committee for the CCP, to proactively set out what a ‘good’ CCP would look like. NZET has shared this with all committees to support them to scrutinise relevant aspects of the CCP, and encouraged the Scottish Government to consider the advice in preparing the draft CCP.
PAC has continued to engage with the Scottish Government on the IIP, receiving periodic updates on major capital projects. However, scrutiny has been limited as the announced Scottish Government reset of the infrastructure pipeline was delayed until the UK Spending Review in June 2025.
Audit work on climate change across the UK and globally
The Scottish Parliament’s PAC and Audit Scotland’s work on climate change share significant common ground with the UK National Audit Office (NAO) and the House of Commons Public Accounts Committee. However, Scotland’s earlier net zero deadline, devolved powers over areas like heat and building standards, and focus on just transition shape audit priorities differently. Another difference is that AS supports both the AGS and the Accounts Commission to audit councils and other local government bodies, as well as the Scottish government and its agencies, whereas NAO audits the UK government, its agencies and other public bodies, with separate arrangements for local audit.
In October 2024, the NAO published an overview of the UK Government’s approach to the environment and climate change for the new Parliament 2023-24. It also published an insight on Achieving environmental improvement and responding to climate change: enablers for success in October 2024, drawing out learning from past NAO reports on how the UK government is organised to achieve net zero and its wider environmental goals, and the interventions it has established to help meet these goals. It highlights the critical leadership role of the centre of government and lead departments and the need to build its approach to culture, strategic direction and integration.
In 2023, AS, working jointly with NAO, Audit Wales and Northern Ireland Audit Office, published a report on Approaches to achieving net zero across the UK. It sets out the UK and devolved governments’ legislation, policy, strategy, governance and monitoring arrangements, relevant to achieving net zero greenhouse gas emissions. It stated that the UK government and the devolved governments “must act collectively to meet their objective of reducing greenhouse gas (GHG) emissions across the UK to ‘net zero’ by 2050.” It identified four key themes:
- The four nations have different emissions profiles and varied approaches to achieving net zero, but the choices they make must ultimately deliver net zero at the UK level.
- Given the different net zero targets, carbon budgets and policies across the nations, there will be opportunities for the governments to learn from each other.
- Achieving net zero in any one nation depends on UK-level action, and vice versa.
- Effective working relationships and close engagement between the UK and devolved governments will be vital to achieving the overall aim of net zero.
Worldwide, Supreme Audit Institutions (SAIs) – public oversight institutions which audit a government’s use of public funds – are increasingly recognising climate change as a critical risk for governments. In 2024, the International Organization of Supreme Audit Institutions (INTOSAI) Working Group on Environmental Auditing highlighted that climate change was a rising priority for SAIs, and that in addition to climate change mitigation, SAIs were increasingly auditing climate change adaptation and social aspects, as well as looking at the nexus between climate change and biodiversity. It notes that many of the audit findings on climate action are not much different from performance audits in other policy sectors; however:
“…some specific features of climate-related audits include the rapid development of the science base, the fact that climate risks appear in many sectors, the need for long-term considerations and risk assessments, as well as the difficulty in measuring some aspects, such as progress in adaptation.”
At the 26th United Nations/INTOSAI symposium on the role, contribution and experience of SAIs to SDG 13 on climate action in 2024, a number of recommendations were agreed. These included a need to prioritise oversight of adaptation actions as well as mitigation, to focus on climate change and the impact it poses to public financial stability in annual audit plans, to integrate climate change-related aspects in all types of audit as appropriate, and to consider the distributional impacts of climate policies, including potential effects on exacerbating inequalities.
Considering the findings of PAC scrutiny of the AGS work on climate change over Session 6 to date, priorities for future scrutiny and audit might include:
- Progress on key delivery programmes, including transparent data collection and reporting on how well priority initiatives, such as heat decarbonisation, are progressing against plans and delivering targets.
- Climate risk and adaptation integration, including the extent to which public bodies incorporate climate risks and adaptation planning into governance and operational frameworks, and how it is integrated into financial management.
- Financial transparency and funding clarity, including the transparency, adequacy, and governance of climate-related funding, identifying gaps between allocations and estimated needs.
- Embedding Just Transition principles, including how climate policies and programmes promote a just and equitable transition for workers and communities affected by decarbonisation.
- Cross-sector and multi-level coordination, including the effectiveness of collaboration between national government, local authorities, and other public bodies in delivering climate objectives.
The AGS recently sought feedback from the Scottish Parliament on their draft Work Programme, to refine the content of the pipeline of audit work for April 2025 to March 2026, as well as to identify priority areas for audit work in the longer term. Work currently scheduled to March 2026 and relevant to climate change includes audit work on resilience to flooding and briefing work on lessons learned on climate change. Longer term priorities set out in the draft Work Programme include environmental sustainability and climate change, such as the public sector’s approach to renewable energy and the development and implementation of agricultural policy following the exit from the EU.
Following an evidence session with the AGS on the draft Work Programme in April 2025, PAC wrote to all parliamentary conveners on 12 May 2025 to request feedback. NZET responded on 6 June 2025, welcoming work on lessons learned from audit work to date, and on resilience to flooding, and expressing interest in audit work on public funding on community-led climate action, as well as work on climate change adaptation and biodiversity, taking a place-based audit approach. Following gathering feedback from other parliamentary committees, PAC wrote to the AGS on 1 July 2025 to highlight specific areas for consideration.
Abbi Hobbs, SPICe Research
Niall Kerr, SPICe Research