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Research and community service funds flow into campuses from many directions: ministries, industry partners, funding institutions, and grantors from home and abroad. Each source brings its own agreement, rules of use, and reporting obligations. That is why these funds are often the object of examinations that demand care: not only whether the money was spent, but whether it was spent according to the contract and produced the promised outputs.
This article covers the rules underlying research funding in universities, the difference between grant funds and state budget funds at a BLU, risk points, and an example audit program. References were checked as of October 21, 2026.
What Is the Legal Basis for Research Funds and Grants on Campus?
| Reference | Relevant content |
|---|---|
| Law 12/2012 Article 46 paragraph (2) | Research results must be disseminated through seminars, publications, and/or patents, except those that are confidential or endanger the public interest. The elucidation of this article states that the obligation applies to research funded by the government and/or regional governments. |
| Law 12/2012 Article 89 paragraphs (6) and (7) | The government allocates at least 30 percent of PTN operational assistance funds to research funds at PTN and PTS, and those research funds are managed by the ministry |
| Minister of Finance Regulation 129/PMK.05/2020 Articles 69 to 69C, as amended by Regulation 76/2025 | Rules on grants received by a BLU: definition, registration, consultation, grant agreement, and use of restricted and unrestricted grants |
| Funding agreement or contract | The purpose, amount, period, conditions, reports, and sanctions that apply to a particular project |
| Current-year funding guidelines from the funder | Details of cost components, accountability evidence, and report deadlines. Guidelines can change every year, so take the edition that applies to the project being audited. |
I do not list the details of cost components from specific funding guidelines because their content differs between funders and between years. Auditors should treat the agreement and the guidelines in force as the main criteria.
What Is the Difference Between Grants and State Budget Funds at a BLU?
Article 69 paragraph (7) of Regulation 129, as amended by Regulation 76/2025, defines a BLU grant as income in the form of money, goods, services, and/or securities received from the public, other bodies, or entities outside the central government, without any obligation for the BLU to hand over money, goods, or services to the grantor. This means not all research funds received by a campus have grant status in this sense. Funds from the state budget through ministries follow budget management provisions, not grant provisions.
Some other provisions for grants received by a BLU, which can serve as audit criteria:
- grants may come from abroad or from within the country and are registered to obtain a register number (Article 69 paragraphs (8) and (9));
- restricted grants must be treated according to their purpose, while unrestricted grants are used for service operational activities and must not be used to pay remuneration (Article 69 paragraphs (10) to (12));
- grants to be received are consulted in advance with the Ministry of Finance in certain cases, for example receiving a grant for the first time or one that differs from before (Article 69A); and
- grants are set out in an agreement that at a minimum states the parties' identities, date, amount, period, purpose, and terms and conditions, and changes are made by written agreement (Article 69B).
The provisions above apply to BLUs. For work-unit PTN, PTN-BH, and PTS, the main criteria are the funding agreement, the statute or campus policy, and the regulations that apply to those funds.
Where Are the Risk Points in Research Funds?
| Stage | Example risk | Example audit test |
|---|---|---|
| Receipt and recording | Funds or grants not recorded, not registered, or mixed with other funds | Match the agreement with cash receipts, registration, and separate bookkeeping per project |
| Use of funds | Costs not in line with the budget or purpose, spending outside permitted components | Test a sample of transactions against the budget, contract, and funding guidelines |
| Accountability evidence | Fictitious, duplicate, or incomplete evidence, honoraria not matching activities | Verify receipts, attendance lists, activity records, and confirmations from payment recipients |
| Procurement within projects | Equipment or services bought without proper process, researcher conflicts of interest | Apply a procurement audit program according to the rules that bind those funds |
| Execution and outputs | Activities not carried out, outputs not matching the contract, or claimed twice under two funding sources | Check evidence of execution, output links, and possible overlap with other funding |
| Reporting and closure | Late reports, unspent funds not returned, project-derived assets not recorded | Check report dates, reconcile balances, and asset recording |
This table is an illustration. Preparing a suitable work program for an engagement is discussed in the article internal audit work program, and selecting the projects to audit based on risk in the article risk-based audit.
What Does an Example Research Grant Fund Audit Program Look Like?
- Set the objective and scope. For example compliance of grant fund use across a set of current-year research projects, or a single large grant.
- Collect the criteria. The grant agreement, the funding guidelines in force, campus policy, and for a BLU the provisions of Articles 69 to 69C.
- Map the project population. A list of projects, funders, values, periods, lead researchers, and report status.
- Select a risk-based sample. Prioritize high-value projects, researchers with many parallel projects, and projects with late reports.
- Test receipt and use. Match receipts, budgets, realization, and spending evidence.
- Test execution and outputs. Make sure the activities actually took place and the outputs match the agreement, including the dissemination of research results required by Article 46 paragraph (2) of Law 12/2012.
- Formulate findings and monitor follow-up. Including the return of funds where necessary. It is discussed in the article follow-up on audit findings.
How Does This Relate to Procurement Audits and External Examiners?
Many research projects buy equipment, materials, or services, so part of the testing takes the form of a procurement audit under the rules that bind those funds. Guidance for that part is in the article procurement audit in universities. Grantors and external examiners may also examine the accountability of funds. The same schedules and evidence should be prepared once and coordinated, as discussed in the article SPI coordination with the audit committee, board of trustees, inspectorate, and BPK.
Reports of alleged irregularities in research funds may come in through campus reporting channels. The division of channels is discussed in the article university whistleblowing system.
What Are Common Mistakes in Grant Fund Audits?
- Using the wrong criteria. Guidelines from an old edition are used for projects subject to a new edition.
- Only checking receipts. Execution of activities and outputs are not tested.
- Treating all funds the same. Grants, state budget funds, and cooperation funds are treated alike although their rules differ.
- Not explaining the purpose of the audit. Researchers see the audit as a personal inspection, so evidence is hard to obtain and working relationships worsen.
- Not following up. Findings recur in the next project because lessons are not monitored.
How Does Internal Audit Software Help?
Audithink is not a research management or project finance system. For the SPI, it helps through six main features: risk assessment to select risky projects, audit planning based on risk assessment, work program templates for each engagement, deadline notifications, monitoring of recommendation follow-ups, and automated reports. Campus audit needs are discussed on the page Audithink for Educational Institutions.
FAQ About Research Grant Fund Audits
What are the main criteria for auditing research grant funds?
The funding agreement or contract and the funding guidelines in force for that project. For a BLU, add Articles 69 to 69C of Regulation 129 if the funds count as grants.
Are all research funds received by a BLU grants?
No. Under Article 69 paragraph (7) of Regulation 129, a grant is a receipt from the public, other bodies, or entities outside the central government with no obligation to hand over anything to the grantor. State budget funds from ministries follow budget management provisions.
May unrestricted grants be used to pay remuneration?
At a BLU, Article 69 paragraphs (11) and (12) of Regulation 129 state that unrestricted grants are used for service operational activities and cannot be used for remuneration payments.
Must research results be published?
Article 46 paragraph (2) of Law 12/2012 requires research results to be disseminated through seminars, publications, and/or patents, except those that are confidential or endanger the public interest. Its elucidation states that the obligation applies to research funded by the government or regional governments.
How do you tell whether one output is claimed under two funding sources?
Compare the lists of outputs and researchers across projects running in the same period, including from different funders, then ask for an explanation of each funding source's contribution to that output.
How often should the SPI audit research funds?
There is no standard frequency. Decide based on the risk assessment in the annual plan, for example the fund value, number of projects, and previous findings.
Conclusion
A research fund audit is most effective when the criteria are clear from the start: the agreement and guidelines in force, whether the fund is a grant or state budget money, and the promised outputs. With risk-based samples and monitored follow-up, the SPI helps researchers and the campus maintain accountability without hindering research.
If the SPI at your campus wants to plan research fund audits and monitor follow-up more neatly, schedule an Audithink demo.
