Regulatory Alerts2026-01-01
Added · Updated
SBP-DR-CIRCULAR-2026-0001: General Audit Plan and Special Reports - Agreement No. 4-2010 on External Audit of Banks
The Superintendency of Banks of Panama issued Circular SBP-DR-CIRCULAR-2026-0001 to establish specific submission timelines and documentation requirements for banks under Agreement No. 4-2010. Banks must transmit the approved General Audit Plan within five business days of Audit Committee approval and submit special reports, management letters, representation letters, and audit difference sheets within three months of the fiscal year-end. These documents must be filed via the TIDSO digital system in PDF format starting January 1, 2026, with mandatory signatures from approving authorities.
January 2, 2026 SBP-DR-CIRCULAR-2026-0001
To: General Manager City
Reference: General Audit Plan and Special Reports - Agreement No. 4-2010 on External Audit of Banks.
Dear General Manager:
We refer to Articles 7 and 9 of Agreement 4-2010 of August 10, 2010, on the external audit of banks, and its modifications introduced through Agreement 3-2025 of April 8, 2025, through which guidelines are established for banks regarding the submission to this Superintendency of certain information related to the General Audit Plan and Special Reports.
In this regard, regarding the General Audit Plan and its minimum content, for which the regulated entity must request its presentation from the auditor before the start of the audit fieldwork and send a copy to this Superintendency, we have deemed it appropriate that said copy be sent within five (5) business days following its approval by its Audit Committee, indicating in the transmittal note the date and number of the minutes in which it was approved.
Regarding the Special Reports and other additional information mentioned in Article 9 of Agreement No. 4-2010, this Superintendency requires that the obligated entity, in a separate document, within the term provided for the delivery of audited financial statements (that is, within three (3) months following the close of each fiscal year), send a copy of the following documentation:
- Special Reports prepared by the auditors, when during the course of the external audit they detect the existence of facts related to the aspects detailed in the first paragraph of the cited Article 9;
- Management Letter, through which the auditor sends its observations and recommendations to the management of the regulated entity regarding internal control and other deficiencies and irregularities;
- Representation Letter issued by the regulated entity to the external auditor;
- Adjusted and unadjusted audit difference sheets.
To facilitate the receipt of the information indicated in the previous paragraph, the system known as "Digital Information Transfer System for Obligated Entities" (TIDSO) will be used, which will allow banks to send documentation automatically, securely, and efficiently, significantly reducing delivery and receipt times.
"Strength and confidence: guarantors of banking consumers' rights" Av. Samuel Lewis, Panama Business Tower, ground floor - Tels.: (507) 506 7800 / (507) 506-7900 - Fax (507) 506-7700 / 506-7703 P.O. Box 0832-2397 W.T.C. Panama, Republic of Panama - www.superbancos.gob.pa - email: superbancos@superbancos.gob.pa Official document signed with Qualified Electronic Signature in the Document Transparency System – TRANSDOC of the Superintendency of Banks of Panama, in accordance with Law 83 of 09/11/2012 and Executive Decree No. 275 of 11/05/2018. Use the QR Code to verify the authenticity of the document or the URL: https://sigob.superbancos.gob.pa/consulta?id=GmRoujTBlcAQHItKyaOro6bmzHtSb86fXqXnaAW2ANQ%3D
Page 2 of 2 SBP-DR-CIRCULAR-2026-0001
Below, the information requirements that must be sent in the TIDSO system are detailed, from the "Supervised and Records" section, in the "Compliance Requirement" portal corresponding to "Supervision Documents":
Note: Each of these documents must bear the signature of the responsible persons for its approval.
Consequently, and for compliance with the requirements indicated in this circular, the bank must timely request from its external auditor the documents and reports referred to in the cited provision.
Through the email address soporte@superbancos.gob.pa, we remain at your disposal to receive any queries that may arise, citing the reference of this circular and including the name, position, email, and phone number of the person making the inquiry.
We thank the General Manager for issuing pertinent instructions to the personnel under their charge for the compliance with the present circular.
Sincerely,
Alexis Tejada Interim Superintendent ARV/vc
| Code | Description | Format | From |
|---|---|---|---|
| INF-ESPECIAL | Special reports on facts identified during external audit | January 1, 2026 | |
| CARTA-GER | Management Letter | January 1, 2026 | |
| CARTA-REPRE | Representation Letter | January 1, 2026 | |
| HOJA-DIFE | Adjusted and unadjusted Difference Sheet | January 1, 2026 |