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The town board's annual records audit, in plain English

New York Town Law § 123 · Updated 2026-09-18 · ~7 min read

Every January, New York town boards owe an audit of the records of the officers who handled the town's money. It isn't optional, it isn't new, and the State Comptroller is checking. Here's what the law actually requires, why so many boards get flagged, and how to run an audit that holds up — in an hour, not two days of chasing paper.

What Town Law § 123 actually requires

The statute is short and specific. On or before January 20 each year, town officers and employees who received or disbursed money — the supervisor first among them — must account to the town board and produce all supporting books, records, receipts, warrants, vouchers, and cancelled checks. The board then examines those accounts and records.

A few details trip boards up:

The part that actually matters: the audit isn't finished when you've looked at the records. It's finished when the review is documented in the minutes. An audit nobody can point to in the minute book, to the Comptroller, did not happen.

Why so many boards fall behind

The obligation is clear. What "audit the records" concretely means is not. To a five-member board of neighbors, it reads like a two-day paper chase through a year of bank statements, abstracts, and vouchers — so it slips to "we'll get to it after the budget," and then a year goes by. It is one of the most common things a small town simply never gets around to, not out of any bad faith, but because nobody is sure what a defensible version of it looks like.

What the Comptroller is finding

This is not a theoretical risk. The Office of the State Comptroller runs a steady stream of town audits — "Supervisor's Records and Reports" reviews and, through 2025 and 2026, a wave of "Transparency of Fiscal Activities" audits — and the missing or undocumented annual audit is a recurring finding. The typical write-up reads the same way town to town: the board did not perform (or could not show it performed) the annual audit, records weren't complete, and nothing made it into the minutes. You can read the running list on the Comptroller's local government audits page.

What a defensible audit actually looks like

You do not need to re-add a year of checks by hand. You need a real, recorded review. A version that holds up runs in six steps:

  1. Draw a sample of the period's records. A documented, reasonable sample is defensible — you are testing the records, not re-keeping the books.
  2. Each member reviews and initials what they personally checked.
  3. Note every exception with a reason attached — a missing voucher, a receipt that didn't tie, a late remittance. Exceptions found and noted are evidence the audit was real.
  4. All members sign (minus anyone recused on their own account).
  5. Generate the minute entry. This is the step that makes it count.
  6. File it to the transparency record so a resident — or an examiner — can see it happened.

How to make it an hour, not two days

The paper chase exists because the records are scattered and reconstructed after the fact. Flip that, and the audit shrinks. When every dollar is already coded to a fund and a budget line as it happens, when the record is tamper-evident (nothing edited or deleted without a trace), and when it exports on demand, the "audit" stops being a reconstruction and becomes a review of a sample the system already assembled — draw it, sign it, minute it, file it.

This is exactly what Milepost is built to do. A guided annual audit draws the sample, records who reviewed what, captures exceptions with reasons, emits the minute entry, and posts to the transparency page — turning an unmet statutory duty into an hour at a meeting. See Milepost for public works.

A one-page compliance checklist

Not legal or accounting advice. This is general guidance to help a board understand its obligation. For your town's specifics, rely on the text of Town Law § 123, the Office of the State Comptroller's guidance, and your own counsel or CPA.

Frequently asked

When is the annual audit due?

On or before January 20 each year, under New York Town Law § 123. Officers who handled town money must account to the board by then, and the board examines the records.

Do we have to re-examine every transaction?

No. A documented, reasonable sample is defensible — what matters is a real review that is recorded in the minutes, not that every voucher was re-added by hand.

Can we hire a CPA instead of doing it ourselves?

Yes. A town that has a comptroller, or that engages a CPA to complete the audit within 60 days after the close of the fiscal year, is relieved of the board performing it. Otherwise the board must do it.

What if we've missed a year or two?

Catch up and document it. Perform and minute the audits you owe and build the annual habit. A recorded catch-up reads far better in a Comptroller review than a gap nobody can explain.

See the audit your board can actually finish

Milepost turns the annual records audit into a guided hour — sampled, signed, minuted, and posted. Bring last year's records and we'll show you.