Scotland has confirmed a permanent change to how its two publicly funded rail operators are scrutinised. From 23 January 2026, the Auditor General for Scotland will audit the accounts of ScotRail Trains Limited and Caledonian Sleeper Limited, following an Order made on 22 January 2026 under section 483 of the Companies Act 2006. The Order was signed by Fiona Hyslop on behalf of the Scottish Government.

Practically, the companies move from the Companies Act’s private audit regime to Scotland’s public audit arrangements. In any financial year where the Auditor General for Scotland undertakes the audit, Part 16 of the Companies Act 2006 does not apply. Expect the emphasis to include regularity, propriety and value‑for‑money alongside the familiar true‑and‑fair view.

Ministers set out that both companies are entirely or substantially funded by a body whose accounts fall within the statutory test in section 483(3). That triggers the power to place the audits under the Auditor General for Scotland. For readers, this is a governance call: bring rail finances closer to the audit scrutiny applied across devolved public bodies.

For finance directors and audit committees, planning needs to adjust now. Public audit timetables can require earlier evidence packs, clearer trails on subsidy deployment and more granular reporting on performance targets. Documentation around major programmes-timetable reliability, fleet maintenance and ticketing systems-should be ready for sample testing beyond the financial statements.

For audit firms, commercial mandates may roll off, though the Auditor General for Scotland can use in‑house teams and, where appropriate, commission specific work from external providers. Opportunities are likely to shift towards specialist assignments such as complex asset valuations, pensions analytics and IT controls, commissioned within a public‑audit framework.

Suppliers will feel second‑order effects. Public audit typically examines procurement decisions, open‑book clauses, KPI reporting and payment practices. Tier‑1 and Tier‑2 contractors should keep bid files, change-control logs and delivery evidence orderly and accessible-particularly on rolling stock overhauls, station upgrades and customer service platforms.

For stakeholders-passengers, unions and local authorities-the change usually means clearer reporting lines. Public audit outputs are more visible and may be considered by parliamentary committees. That visibility can accelerate remedial action when auditors flag weaknesses in governance, risk management or contract oversight.

On timing, the Order takes effect on 23 January 2026. The first audits under the new arrangement will depend on each company’s financial year‑end. If those remain in March, the 2025/26 accounts are likely to be the first examined by the Auditor General for Scotland, with reporting following later in 2026.

Investors and lenders tracking rail finances should watch narrative disclosures on cost control, reliability metrics, and the accounting for government support. None of this alters operations day to day, but it can reshape perceptions of financial resilience and the policy appetite for future support.

The formal title is the Companies Act 2006 (Scottish public sector companies to be audited by the Auditor General for Scotland) Order 2026. It names Caledonian Sleeper Limited and ScotRail Trains Limited and confirms their exemption from Part 16 in any year the Auditor General for Scotland audits-resetting accountability from corporate audit to public audit.