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Resources - Pharma Internal Audit

Pharma internal audit checklist.

Pharma audits need financial controls and quality evidence to meet in the same file. The workpaper should connect licences, GMP documents, batch records, QC release, inventory expiry, samples, distributor credit notes, NPPA pricing, cold chain, calibration and ERP/LIMS/QMS access into one RCM.

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RCM map

Ten areas to test areas

Licences, product master and regulatory file

Risk: Manufacturing, loan licence, product approval, labelling, price-control or renewal records are incomplete, expired or not mapped to live SKUs.

Controls
  • Licence tracker
  • SKU-regulatory master mapping
  • Renewal escalation
  • Change-control approval
Tests
  • Match live SKU master to licence and product approval files
  • Check renewal dates and open notices
  • Review label/MRP control evidence
  • Trace regulatory changes to approved master updates
Evidence

Manufacturing licence, product permission, SKU master, label approval, renewal tracker, notice file and change-control record.

GMP documentation, SOPs and quality system

Risk: SOPs, deviations, CAPA, complaints, recalls, change controls or training records do not support the quality system relied on by operations.

Controls
  • Document control
  • Deviation and CAPA review
  • Complaint/recall escalation
  • GMP training tracker
Tests
  • Sample SOP version control and training acknowledgement
  • Age deviations and CAPA closures
  • Review complaint and recall logs
  • Check quality-review sign-offs
Evidence

SOP register, training records, deviation log, CAPA tracker, complaint/recall file, quality review and management sign-off.

Batch manufacturing and packing records

Risk: BMR/BPR entries, line clearance, yields, reprocessing, batch reconciliation or supervisor approvals are incomplete or inconsistent with ERP stock movement.

Controls
  • Approved BOM and process sheet
  • BMR/BPR review
  • Line clearance
  • Yield and reconciliation approval
Tests
  • Trace selected batches from plan to BMR/BPR and ERP issue/receipt
  • Compare actual yield to standard
  • Review rework/reprocessing approvals
  • Check batch closure and QA release
Evidence

Batch plan, BMR, BPR, BOM, material issue slip, production receipt, yield reconciliation, deviation note and QA release.

Raw material, packing material and QC release

Risk: RM/PM receipts, quarantine, sampling, QC release, rejection, retest or vendor qualification records do not support material use in production.

Controls
  • Approved vendor list
  • GRN quarantine control
  • QC sampling/release
  • Retest and rejection review
Tests
  • Match GRN to PO, COA, quarantine and QC release
  • Test rejected/expired material movement
  • Review vendor qualification files
  • Check retest-date blocks before issue
Evidence

PO, GRN, COA, quarantine label, QC report, release note, rejection note, retest list and vendor qualification file.

Inventory, expiry, slow-moving and stock count

Risk: Batch-wise stock, expiry, near-expiry, rejected goods, samples or slow-moving material are misstated or physically unavailable.

Controls
  • Batch-wise inventory ledger
  • FEFO issue control
  • Expiry ageing review
  • Stock count reconciliation
Tests
  • Perform batch-wise count for selected RM/PM/FG
  • Age near-expiry and slow-moving stock
  • Review write-off/destruction approvals
  • Trace samples and free goods movement
Evidence

Batch stock ledger, expiry report, count sheet, variance approval, destruction certificate, sample register and slow-moving provision.

Sales, distributor schemes, samples and credit notes

Risk: Primary sales, institutional sales, free goods, samples, schemes, returns, expiries and credit notes are misstated or used to override commercial controls.

Controls
  • Scheme approval
  • Credit-note approval matrix
  • Sample/free-goods register
  • Return and expiry claim review
Tests
  • Match invoices to dispatch and distributor ledger
  • Review credit notes by reason/user/distributor
  • Test sample/free-goods approvals
  • Trace sales returns and expiry claims to stock movement
Evidence

Invoice, dispatch proof, distributor ledger, scheme circular, credit note, sample register, return note, expiry claim and stock adjustment.

Pricing, MRP and NPPA/DPCO compliance evidence

Risk: Scheduled formulation ceiling prices, retail prices, MRP changes, price lists or non-scheduled annual increase controls are not monitored.

Controls
  • Price master maker-checker
  • DPCO/NLEM applicability review
  • MRP change approval
  • NPPA order tracker
Tests
  • Compare selected SKUs to approved price master and current NPPA/DPCO evidence
  • Review MRP change approvals
  • Test distributor price lists
  • Check overcharge notice/action files
Evidence

Price master, NPPA order or DPCO support, NLEM mapping, MRP approval, price list, invoice sample and notice/action tracker.

Cold chain, warehouse and logistics

Risk: Temperature-sensitive inventory, dispatches, PODs, cold-chain logs or transporter claims are not supported by reliable evidence.

Controls
  • Temperature log review
  • Transporter qualification
  • Dispatch/POD reconciliation
  • Excursion escalation
Tests
  • Review temperature logs and excursions
  • Match dispatch to invoice, e-way bill and POD
  • Test cold-chain transporter bills
  • Check rejected delivery and return controls
Evidence

Temperature log, excursion report, dispatch note, e-way bill, POD, transporter contract, return note and claim file.

Engineering, calibration, validation and EHS

Risk: Equipment calibration, preventive maintenance, process validation, cleaning validation, utilities or EHS records are overdue or unsupported.

Controls
  • Calibration schedule
  • Preventive maintenance plan
  • Validation protocol approval
  • EHS incident escalation
Tests
  • Age overdue calibration and maintenance
  • Sample validation protocols/reports
  • Review breakdown impact on batches
  • Check EHS incidents and statutory inspections
Evidence

Calibration certificate, PM log, breakdown record, validation protocol/report, utility log, EHS register and inspection evidence.

ERP, LIMS, QMS and access controls

Risk: Users can change BOM, batch status, QC release, price master, credit notes or regulatory master data without review.

Controls
  • Role-based access
  • Leaver review
  • Master-change approval
  • Audit-log monitoring
Tests
  • Review privileged ERP/LIMS/QMS users
  • Test leaver and shared IDs
  • Sample BOM, price, QC release and batch-status changes
  • Review interface and audit-log exceptions
Evidence

User list, role matrix, HR exit list, master-change log, audit log, interface exception report and access review sign-off.

Monitoring

Convert fieldwork into recurring tests rules

Batch yield variance

Actual yield or packing reconciliation variance exceeds approved tolerance by product, line or batch.

QC hold ageing

RM/PM/FG batches remain in quarantine or QC hold beyond ageing threshold.

Near-expiry exposure

Batch-wise inventory crosses near-expiry threshold without approved liquidation or provision action.

Credit-note spike

Credit notes, expiry claims or scheme claims spike by distributor, SKU, user or period.

Sample/free-goods spike

Samples or free goods exceed approved norms by product, territory, doctor/institution or sales user.

Calibration overdue

Critical equipment calibration, validation or preventive maintenance is overdue while equipment remains active.

Downloads

Use with these workpapers workpapers

Pharma Audit Workbook

Generate an Excel/PDF workbook for GMP documents, batch records, QC release, inventory, pricing, sales, logistics, calibration and access controls.

Open ->

Manufacturing Audit Workbook

Use for factory production, BOM, stores, WIP, job work, scrap, capex and ERP controls.

Open ->

Internal Audit Monitoring Rules

Download recurring exception rules for yield variance, QC holds, expiry, credit notes, samples and leaver access.

Open ->

ITGC Internal Audit Checklist

Use for ERP, LIMS, QMS, master changes, audit logs, privileged users and interfaces.

Open ->
Authority

Verify against current official sources sources

ICAI lists a Technical Guide on Internal Audit of Pharmaceutical Industry. CDSCO circulars, the Drugs and Cosmetics Act, NPPA/DPCO materials and state licence conditions should be checked for the exact product, plant, market and audit period before any compliance conclusion is issued.

ICAI IASB - Industry Specific Internal Audit Guides ->ICAI IASB - Compendium of Standards on Internal Audit ->CDSCO - Notifications and circulars ->India Code - Drugs and Cosmetics Act, 1940 ->NPPA - Proactive disclosure and DPCO price-control process ->
FAQ

Pharma audit FAQs questions

What should a pharma internal audit cover?

A pharma internal audit should cover licences, product master, GMP documentation, SOPs, deviations, CAPA, batch manufacturing and packing records, raw and packing material QC release, batch-wise inventory, expiry, samples, sales returns, distributor schemes, NPPA pricing evidence, cold chain, calibration, validation, EHS and ERP/LIMS/QMS access.

Is pharma internal audit the same as GMP audit?

No. GMP audit focuses on quality and regulatory conformance. Internal audit is wider: it connects quality evidence with financial reporting, inventory, procurement, sales, pricing, access controls, monitoring rules and management reporting. A GMP specialist should review technical GMP conclusions where required.

Which pharma audit checks are best for continuous monitoring?

High-value monitoring checks include batch yield variance, QC hold ageing, near-expiry inventory, rejected material ageing, credit-note spikes, sample/free-goods spikes, price-master changes, calibration overdue, deviation/CAPA ageing and leaver access in ERP, LIMS and QMS.

Is this checklist legal, regulatory or GMP compliance advice?

No. This is an internal-audit workpaper starter. Drug licensing, GMP, DPCO, NPPA, CDSCO, state FDA, labelling, product approval, tax, labour, environmental and safety requirements must be verified for the product, location, licence type and audit period.