Phase 5: Project Execution

False invoicing, overbilling and theft of materials during execution

Contractors, supervisors or officials enable overbilling, inflated quantities and theft of materials through weak measurement and poor inspection and inventory controls.

Red Flags & Indicators

  • Delivery notes, measurement records, or timesheets do not match site records or supervision reports.
  • Invoices contain repeated corrections, duplicate charges, or billing for the same work in different periods.
  • Inventory records show unexplained shortages, unusual waste, or missing high-value materials and fuel.
  • Payment certificates are approved with limited inspection evidence or by the same person across several contract packages.

Stakeholder Guidance

Stakeholder Exposure

Exposure includes invoice approval pressure; risk of being solicited to collude or accused of overbilling; cash leakage via theft and diversion; payment delays, increased risk of disputes and rework; and reputational risk.

Decision Point

For each payment request, submit a progress invoice and material claim for certification proceed, with reconciled measurement and stock records.

Mitigation Actions

• Maintain verifiable records for quantities, deliveries, and labour (measurement books, delivery notes, timesheets)
• Reconcile measurement records to site diaries and supervision logs
• Use three-way match for high-value materials and fuel
• Segregate invoice preparation, verification, and approval roles
• Require independent sign-off for corrections and duplicates
• Retain a complete audit file for each payment claim, including related to corrections and duplicates
• Use inventory and wastage controls (stock counts, issue registers, loss reports)
• Conduct internal investigation to clarify discrepancies, unexplained shrinkage or repeat variances before submitting payment claims, pausing payments pending investigation
• Use internal compliance escalation processes and whistleblower channels, where available, to report any pressure to certify false invoices or conceal theft

Mitigation Resources

Control invoices, quantities, delivery records, site receipts, payment support, and material movements through formal evidence requirements, independent verification, segregation of duties, and approval before claim submission, certification, or payment.

Change control, delivery verification, and payment integrity — https://toolbox.infrastructuretransparency.org/resource/change-control-delivery-verification-and-payment-integrity/

Assess fraud risks and apply prevention, detection, investigation, and corrective-action controls to invoices, quantities, delivery records, site receipts, payment records, and material movements, including unexplained variances, duplicate claims, or suspected theft.

Fraud control management — https://toolbox.infrastructuretransparency.org/resource/fraud-control-management/