RTI Compliance Audit Checklist for Public Authorities

CAG audits and Information Commission compliance reviews routinely flag the same patterns: outdated PIO pages, untracked appeal disposals, missing Section 25 returns, no Section 4 update log. An internal audit catches all of these before the external audit does. This checklist is designed for adoption by the public authority's vigilance / records committee.

• Annually, in April, after the financial-year close.
• Before any planned CAG audit.
• Before any Information Commission inspection.
• On change of head of office (handover).
• On any major adverse Commission order against the authority.

• Section 4 — disclosure and record management.
• Section 5 — designation of PIOs.
• Section 6 to 11 — applications, fees, exemptions, third-party.
• Section 19 — appeals.
• Section 20 — penalty (Commission's power; audit tracks adverse orders).
• Section 25 — annual return.

Each area is scored out of ten. The total is out of 120; convert to percentage.

• Office order designating PIO is current (4).
• Subject-wise PIOs designated where appropriate (2).
• APIOs at all field offices (2).
• Substitute PIO during PIO leave (2).

• Office order designating FAA is current (5).
• FAA is senior in rank to PIO (3).
• Substitute FAA during leave (2).

• All 17 sub-clauses published (5).
• Last-updated date within last quarter (2).
• Regional-language version (1).
• Mobile-friendly (1).
• Indexable (1).

• Master file index in place (3).
• Retention schedule applied (2).
• Active files digitised (3).
• Search-and-retrieval log maintained (1).
• Annual records audit (1).

• % applications acknowledged within 48 hours (3).
• % disposed within 25 days (3).
• % disposed within 30 days (2).
• % deemed refusals (negative score below 5%) (2).

• Receipts register reconciled with cashier (3).
• No unlawful additional-fee demands (2).

• % first appeals disposed within 30 days (3).
• % within 45 days (2).
• Speaking orders for all appeals (3).
• Orders despatched to both parties (2).

• Section 11 notice issued in 100% of relevant cases (5).
• Public-interest balance recorded (3).
• Third-party right of appeal communicated (2).

• Quarterly returns submitted on time (4).
• Annual return submitted by 30 April (3).
• Data reconciles with internal registers (2).
• Recommendations for reform recorded (1).

• PIO has attended at least one DoPT-recognised training in the year (4).
• FAA has attended training (3).
• APIOs trained (2).
• Refresher for dealing assistants (1).

• Feedback mechanism on website (3).
• Average response time to feedback (2).
• Citizen camps / awareness drives (2).
• Brochures available in regional language (3).

• No Commission direction outstanding more than 30 days (5).
• No Section 19(8)(a) direction unimplemented (5).
• No Section 20 penalty proceedings against PIOs (5).

1. Step 1. Constitute an audit team — nodal RTI officer, internal audit officer, IT, vigilance.
2. Step 2. Agree the score-sheet using the twelve areas above.
3. Step 3. Sample 5% of applications and 10% of appeals for evidence.
4. Step 4. Cross-verify with public-facing data (website, portal, Commission's records).
5. Step 5. Score each area with documentary evidence.
6. Step 6. Compile a draft report with scores, findings, recommendations.
7. Step 7. Discuss with the head of office; finalise.
8. Step 8. Place the report on the office's RTI page (with redactions for any sensitive personnel content).
9. Step 9. Track corrective actions to closure.

• RTI Receipt Register sample.
• Appeals Register sample.
• Fee Register sample.
• PIO/FAA office orders.
• Section 4 page screenshots with date.
• Section 25 returns submitted.
• Outstanding Commission orders.
• Training certificates of officers.
• Citizen feedback log.

• No internal audit at all — first time the public authority sees the gaps is during CAG audit.
• Audit by the same team that runs RTI — conflict of interest.
• Audit with no evidence — checking yes/no without documents.
• Audit findings not closed — same observations year after year.
• No publication of audit report — citizens don't see it; Commission has nothing to track.

The Act does not name an “audit” but the Section 25 return, Section 4 sign-off, and CAG performance audit collectively make internal audit a practical necessity.

External audit (CAG, peer-review by another department, civil-society audit) is funded by the audit authority's budget. Internal audit is by the public authority's own staff.

Two to three weeks in a small office; six weeks in a large ministry.

Yes — many ministries engage civil-society partners (e.g. CHRI, RAAG) for independent scoring.

The head of office must convene a review and produce a 30-day action plan.

Yes, with redactions for sensitive personnel matters.

Yes. Commissions look favourably on public authorities that maintain internal audit and produce findings.

• The Right to Information Act, 2005 — Sections 4, 5, 6 to 11, 19, 20, 25.
• Department of Personnel and Training, rti.gov.in — guidance.
• Comptroller and Auditor General, cag.gov.in — performance audits.
• Central Information Commission, cic.gov.in — illustrative directions.

• Section 4(1)(b) checklist
• RTI record management system
• Annual RTI return
• RTI cell SOP
• PIO and FAA details on website

Last reviewed: 9 May 2026.