Return Form Submission, Audit, Certification - National Newspapers

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Return Form Submission, Audit, Certification

The Return Form is a submission in which the circulation claim is reported to ABC for certification. Each circulation claim is subject to audit.

Principles

1. A Return Form must be submitted for the registered product for every applicable Reporting Period

2. The Return Form must be submitted by the Submission Deadline

3. ABC will issue a Certificate based on the Return Form

4. Each circulation claim is audited to verify it is in accordance with the applicable Reporting Standards

Requirements

1. A Return Form must be submitted for the registered product for every applicable Reporting Period

1. You must submit a Return Form for the applicable mandatory and optional Reporting Periods you have chosen to report.

2. We will advise you how to submit your Return Form. For example online via the ABC eReturn website. However if you have not heard from us at the appropriate time please contact us.

3. If you use ABC Staff Auditors you will submit your Return Form to us, authorised by an appropriate individual representing your organisation.

4. If you use a non-ABC Auditor then they must submit the Return Form to us, authorised both by an appropriate individual representing your organisation and your Approved Auditor.

5. Whilst our systems contain some arithmetic and logic validation processes, the accuracy of the Return Form remains your responsibility.

6. Estimates and assumptions must not be made on the Return Form unless the Reporting Standards allow for them, or we have authorised them.

2. The Return Form must be submitted by the Submission Deadline

1. We will publicise the applicable Submission Deadline.

2. It is your responsibility to ensure Return Forms are submitted by the Submission Deadline. Failure to do so can result in a penalty and/or cancellation of your product’s ABC registration under the ABC Byelaws.

3. ABC will issue a Certificate based on the Return Form

1. We will issue the certificate to you and make the certificate and/or data available in accordance with agreed timings and to the agreed eligible recipients for the sector.

2. You may opt for public or private reporting. If you opt for private reporting:

   1. The publication of your circulation figures is under your control.

   2. We will not publish the certificate on our website, but will show that that the publication is certified, the date of the most recent certificate issued, that you have chosen to manage the data yourselves and your contact from whom your certificate may be requested.

4. Each circulation claim is audited to verify it is in accordance with the applicable Reporting Standards

1. The audit must be carried out either by ABC Staff Auditors or, unless stipulated otherwise, an Approved Auditor appointed by you and approved by us.

2. Requirements in relation to the auditor and audits will be covered by the ABC Byelaws, ABC Audit Programmes and contractual arrangements.

3. Publications may opt to have their monthly certificates audited on a quarterly cycle. Known as ‘consolidated auditing’ this helps provide efficiencies through changing the timing of audit work across a set of certificates. Note:

   1. You must tell us in writing if you wish to use this option.

   2. As certificates are issued based on the member’s claim any subsequent material errors identified at audit will require an updated certificate be issued that identifies the changes. This replaces the member’s original Certificate and must be used in its place.

   3. We may withdraw the option to utilise consolidated auditing if certificates are repeatedly re-issued to correct material errors in claims.

4. We carry out inspections on all publications that are not audited by ABC Staff Auditors. The inspections are carried out by ABC Staff Auditors and all publications will be inspected at least once every two years on average and those publications with a publishing frequency of more than once a week will be inspected annually on average.

5. If following an audit or inspection we identify material problems with the Return Form or Certificate then we will propose to revise the claim. If a Certificate has already been issued we will issue a revised Certificate with an Audit/Inspection Report that identifies the changes. This replaces your original Certificate and must be used in its place. The process is as follows:

   1. We will send you a letter detailing the reason/problem giving rise to the amendment.

   2. You will have 10 working days from the receipt of this letter to provide any further information to us, or object to the revision of the claim.

   3. If you wish to object to the revision of the claim you must do this in writing to the Director of Audit who will investigate and provide a decision within 10 working days. If the objection is to a decision by the Director of Audit or the Chief Executive then the first level of appeal will be in accordance with the Review Procedure detailed in the ABC Byelaws.

   4. Subsequent Certificates may not be issued until we have resolved all queries on a previous audit and issued the revised Certificate, if applicable.

   5. We publish details of Audit/Inspection Reports.

Guidance Available

Guidance

G4. Each circulation claim is audited to verify it is in accordance with the applicable Reporting Standards

Consolidated auditing:

1. The publisher can opt to have audits of their monthly certificates conducted on a quarterly cycle (retrospectively, after certification)

   1. Circulation claims are submitted via the Return system and certificates are issued every month.

   2. Each month’s circulation claims will be analysed by the ABC auditor and any unusual changes, or new information about areas of high risk that have come to light, are followed up with the publisher at that point.

   3. Every three months a final audit will be conducted, rounding up the quarterly cycle of work.  This will include an on-site visit by the ABC auditor and a management letter on completion.

   4. Not all publishers will be audited on the same quarterly cycle.

   5. Audit work at third parties (e.g. Dawsons/Media on the Move) will be conducted with a similar quarterly cycle, and the conclusions fed into the formal audit.

   6. The quarterly final audit must be concluded before the issue of the following monthly certificate (subject to the provisions of the appeal process explained below).

2. There will be no change to our established materiality levels for all audit testing.  These are the thresholds which determine the level of detail to which we conduct elements of work, and the cumulative error that might require certificate data to be restated.

3. If the audit work reveals any material misstatement, this is raised with the publisher before certificate is updated.

   1. We will follow the standard procedures set out in the ABC Reporting Standards, which requires the ABC auditor to set out the proposed changes, followed by a 10 day period to agree to the changes, provide further information, or lodge an appeal with the Director of Audit.

   2. As with all ABC audit decisions, members have the right to request a review of the decision, internally within ABC and ultimately to an independent panel of ABC Board Members under certain grounds. These procedures are set out in the Reporting Standards and ABC Byelaws (section 13).

4. We envisage restatements to be very rare based on the history of data revisions.

   1. Where audits are conducted prior to formal submission of the return to ABC, publishers will sometimes take the opportunity to make minor changes to circulation claims following feedback from the ABC auditor.  Such non-material changes would not be made in the case of retrospective audits.

   2. If the publisher is concerned there is an increased risk of their reported figures being inaccurate then they should contact ABC as soon as possible, and may opt to have a full monthly audit, prior to certificate issue.

   3. If there are continuing issues that ABC considers may increase the likelihood of reported figures being inaccurate then we would need to revert to monthly full audits, possibly prior to certificate issue, to ensure that materially inaccurate figures are not certified by ABC for an extended period of time.

5. We will identify where data is revised as a result of an updated certificate.The certificate will include a statement summarising the changes made on the revised certificate.  Data in available tables will also be updated.

6. Audit fees for retrospective audits on a quarterly cycle are intended to be lower than for monthly audits prior to certificate issue, as efficiencies can be made such that costs will be lower.

7. Publishers who use external auditors rather than ABC auditors may make similar arrangements.  The publisher’s auditor should contact ABC if issued certificates require amendment following their audit.