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Government Command Center 13 items

Purchasing Card (P-Card) Internal Controls Checklist

Helps a finance or internal audit function evaluate purchasing-card program controls including issuance, limits, transaction review, and prohibited uses.

GFOA Best Practices2 CFR 200.302GAO Green Book

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Program Governance

  • Is there an adopted p-card policy defining eligibility, limits, and responsibilities? *
  • Has each cardholder signed a cardholder agreement acknowledging the rules? *
  • Is a program administrator designated to manage issuance and terminations? *

Card Issuance & Limits

  • Are single-transaction and monthly credit limits set appropriate to the cardholder's role? *
  • Are merchant category code (MCC) restrictions applied to block prohibited categories? *
  • Are cards promptly cancelled upon employee separation or role change? *

Transaction Review & Approval

  • Is each transaction supported by an itemized receipt? *
  • Does a supervisor independent of the cardholder review and approve statements? *
  • Are split purchases (to evade single-transaction limits) monitored and flagged? *
  • Is sales/use tax exemption applied where the entity is exempt? *

Prohibited Uses & Monitoring

  • Are personal purchases, cash advances, and gift cards prohibited and monitored? *
  • Are exception/analytics reports run to detect misuse and unusual patterns? *
  • Is a rebate/refund program reconciled and periodic audits conducted? *

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