The Legal Framework of the Court of Accounts: A Comparative Study Between Algerian and French Legislation

Abstract

Supreme Audit Institutions (SAIs) play a pivotal role in ensuring the transparency, accountability, and legality of public financial management. This academic article provides a comprehensive comparative analysis of the legal frameworks governing the Court of Accounts (Cour des Comptes / مجلس المحاسبة) in the French Republic and the People's Democratic Republic of Algeria. By examining the constitutional foundations, organizational structures, and jurisdictional competencies of both institutions, the study highlights the divergent evolutionary paths of public audit systems. The French Cour des Comptes, established as an independent administrative court with quasi-judicial powers, represents a mature model characterized by extensive jurisdictional reach, including the certification of state accounts and a recent emphasis on citizen participation. Conversely, the Algerian Court of Accounts, while historically influenced by the French model, has developed a distinct legal identity tailored to its national context, focusing on strengthening its independence and expanding its role in evaluating public policies within an emerging economy. The article explores the legal mechanisms ensuring institutional autonomy, the scope of financial and performance audits, and the integration of international audit standards (INTOSAI). Ultimately, this comparative study identifies best practices and proposes recommendations for enhancing the efficacy and independence of SAIs in both developed and developing legal systems.