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A campus buys many things at once: buildings and renovations, laboratory equipment, information technology devices, books and journal subscriptions, and consulting services. The values are large, the parties many, and the funding sources varied, from state budgets and service revenue to cooperation and grants. That is why procurement almost always makes the list of areas the SPI should look at.
This article covers the procurement rules that apply to each type of university, the principles that serve as audit criteria, risk points at each stage, and an example audit program. General discussion of procurement audits is in the article audit of procurement of goods and services. References were checked as of October 21, 2026.
Which Procurement Rules Apply to Each Type of University?
| Type of institution | Procurement rules | Notes for auditors |
|---|---|---|
| Work-unit PTN (state budget) | Presidential Regulation 16/2018 on Government Procurement of Goods/Services, as amended by Presidential Regulations 12/2021 and 46/2025 | The scope of the presidential regulation covers procurement at ministries, agencies, and other institutions that use the APBN. Check the latest version and LKPP implementing regulations. |
| PTN BLU | Exempt from the presidential regulation and governed by the BLU head's regulation (Presidential Regulation 46/2025 Article 61; Minister of Finance Regulation 129/PMK.05/2020 Article 125 as amended by Regulation 202/2022) | If it has no regulation of its own, a BLU follows the presidential regulation. The obligation to use domestic products and products of micro and small enterprises and cooperatives still applies. |
| PTN-BH | I did not find a provision in the regulations referenced in this article | Check the statute and the university leadership's regulations, as well as the terms of funding agreements if there are state funds. |
| PTS | Policy of the organizing body and the university | Funds from the government or grantors may carry their own procurement terms in their agreements. |
Article 125 of Regulation 129 states that the BLU exemption applies to procurement sourced from service revenue, unrestricted grants, cooperation or other business results, and state budget receipts (pure rupiah). The BLU head's regulation follows the principles of transparency, fairness and non-discrimination, accountability, effectiveness, efficiency, economy, and sound business practice, and covers planning, preparation, selection, and contract execution. For pure rupiah funds, the provisions on payment procedures charged to the APBN still apply.
Which Principles and Ethics Serve as Audit Criteria?
Article 6 of Presidential Regulation 16/2018 names seven procurement principles: efficient, effective, transparent, open, competitive, fair, and accountable. Article 7 sets the ethics all parties must follow, including:
- avoiding and preventing conflicts of interest, directly or indirectly;
- avoiding and preventing waste and leakage of state finances;
- avoiding and preventing abuse of authority and/or collusion; and
- not accepting, offering, or promising gifts, rewards, commissions, rebates, or anything known or reasonably suspected to be related to procurement.
Article 7 paragraph (2) also gives examples of conflicts of interest, such as a procurement official who directly or indirectly controls or runs a provider's business, or several companies in the same tender being controlled by the same party. For a BLU, the principles in Article 125 paragraph (4) of Regulation 129 serve as additional criteria. The auditor's own ethics are discussed in the article internal auditor code of ethics.
Where Are the Risk Points in Campus Procurement?
Article 76 of Presidential Regulation 16/2018 states that procurement oversight covers everything from planning, preparation, provider selection, and contract execution to handover of the work. The same stages can serve as an audit framework on campus. The table below is an illustration, not a standard list:
| Stage | Example risk | Example audit test |
|---|---|---|
| Planning | Needs do not match priorities, specifications point to a certain brand or provider, packages are split to avoid a tender | Compare the procurement plan with the budget and priorities, review specifications, check packaging. Article 20 paragraph (2) of Presidential Regulation 16/2018 prohibits splitting packages with the intent of avoiding a tender or selection. |
| Estimated price | The HPS is not based on accountable data | Trace the source of HPS data. Article 26 states that the HPS is calculated expertly with accountable data and is used to assess the reasonableness of bid prices. |
| Provider selection | Collusion, qualification documents not tested, panel conflicts of interest | Test the completeness of minutes, conflict of interest declarations, and conformity of the evaluation with the selection documents |
| Contract | Clauses do not protect the campus, contract changes without basis | Review the contract, addenda, guarantees, and approval of changes |
| Execution and payment | Payments do not match progress, late penalties are not imposed | Match physical or report progress with payment terms, compute penalties |
| Handover | Goods or work results do not meet specifications, not recorded as assets | Physical inspection, minutes, and asset recording |
Presidential Regulation 46/2025 amended Article 26: the HPS value is not confidential, while the HPS details are confidential. Auditors need to use the version of the presidential regulation in force when the procurement was carried out, because detailed provisions can change between versions.
What Do the Steps of a Campus Procurement Audit Program Look Like?
- Set the objective and scope. For example compliance of the current year's laboratory equipment procurement process, or construction services procurement above a certain value.
- Determine the criteria. The rules that apply to the type of campus, rector or leadership regulations, and contracts.
- Map the population. A list of all packages, values, methods, providers, and funding sources in the audit period.
- Analyze initial data. Look for patterns such as the same provider winning repeatedly, packages with close values, or repeated purchases just below the limit of a certain method.
- Select a risk-based sample. The method is discussed in the article audit sampling.
- Test documents and physical items. Trace documents from planning to handover, then check the existence and condition of the goods or work results.
- Formulate findings and recommendations. Describe the condition, criteria, cause, effect, and recommendation.
- Monitor follow-up. It is discussed in the article follow-up on audit findings.
Preparing detailed steps for each engagement is discussed in the article internal audit work program, and selecting objects based on risk in the article University SPI annual audit plan (PKPT).
How Does the SPI Maintain Independence from the Procurement Process?
The SPI should preferably not be a procurement actor, such as a commitment-making official, a selection working group, or a procurement official, because it would examine its own work. At a BLU, Article 263 of Regulation 129 prohibits SPI auditors from holding concurrent duties and positions in BLU operational activities, except in the compliance and risk management functions. If the SPI is asked to review documents before procurement proceeds, its role needs to be distinguished from approval, and that boundary recorded in the SPI charter as discussed in the article SPI internal audit charter.
How Does the SPI Relate to APIP Procurement Oversight and Complaints?
Article 76 of Presidential Regulation 16/2018 requires procurement oversight through government internal oversight bodies (APIP) and states that it can take the form of audits, reviews, monitoring, evaluation, and/or running a whistleblowing system. Article 77 governs public complaints submitted to APIP. For campuses, this means SPI audit results need to align with the schedules and findings of APIP and external examiners, as discussed in the article SPI coordination with the audit committee, board of trustees, inspectorate, and BPK. Reporting channels inside the campus are discussed in the article university whistleblowing system.
How Does Internal Audit Software Help?
Audithink helps the SPI carry out procurement audits through six main features: risk assessment to map risk areas, audit planning based on risk assessment, work program templates for each engagement, deadline notifications, monitoring of recommendation follow-ups, and automated reports. Audithink is not a procurement system and does not replace SPSE, SIRUP, or campus procurement applications. Campus audit needs are discussed on the page Audithink for Educational Institutions.
FAQ About Procurement Audits in Universities
Do all state universities use Presidential Regulation 16/2018?
Not always. Work-unit PTNs follow the presidential regulation, while BLUs are exempt and use the BLU head's regulation. For PTN-BH, check the statute and the university leadership's regulations.
Is BLU procurement free from all government procurement rules?
No. A BLU follows the BLU head's regulation, which is prepared with certain principles, refers to the presidential regulation if it has no regulation of its own, and remains bound by the obligation to use domestic products and products of micro and small enterprises and cooperatives under Article 61 of Presidential Regulation 46/2025.
What signs of package splitting should you watch for?
Several similar purchases with close values, close in time, to the same or related providers. Article 20 paragraph (2) letter d prohibits splitting procurement into several packages with the intent of avoiding a tender or selection.
May providers know the HPS value?
After the amendment by Presidential Regulation 46/2025, the HPS value is not confidential, while the HPS details are confidential. Check the provisions in force when the procurement is carried out.
May the SPI take part in a procurement committee?
Preferably not, because the SPI would examine the results of its own work. At a BLU, Article 263 of Regulation 129 prohibits SPI auditors from holding concurrent BLU operational duties, except in the compliance and risk management functions.
What is examined at the handover stage?
Conformity of the goods or work results with the contract and specifications, completeness of the handover minutes, and recording as an asset or inventory.
Conclusion
A campus procurement audit starts with one question: which rules bind this package. After that, the same principles and stages can be used to test planning, price, selection, contract, and handover, with risk-based samples and monitored follow-up.
If the SPI at your campus wants to plan procurement audits and monitor follow-up more neatly, schedule an Audithink demo.
