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Accounts payable audit: the rent payments with no purchase order

Rent and CAM have no purchase order, so the three-way match cannot govern them. What replaces it, and the eight failure modes worth testing for.

Emma Sukenik9 min read
Lease accounting — Accounts payable audit: the rent payments with no purchase order

An accounts payable audit of landlord payments tests whether the rent, common area maintenance, and other recharges you paid were actually owed under the lease. It differs from a general AP audit in one structural respect: rent has no purchase order and no goods receipt, so the three-way match that governs nearly every other invoice does not apply to it.

Why the standard control cannot govern rent

The three-way match works because three independent artifacts agree: a purchase order, a goods receipt, and the invoice. Rent produces none of them. There is an executed lease, signed once and often amended, but no monthly confirmation that the company still occupies the space, and the invoice is often not an invoice at all, since many landlords bill nothing and payment runs from a recurring schedule set up when the site opened.

What replaces the three-way match

Standard AP controlWhat it provesThe lease-payment equivalent
Purchase orderSomeone approved this spend, at this amountThe executed lease and every amendment, abstracted
Goods receiptWhat was ordered actually arrivedEvidence the space is delivered, occupied, and not yet exited
Invoice matchThe billed amount equals the authorized amountThe rent schedule, escalation basis, and reconciliation terms
Vendor masterThe payee is a legitimate counterpartyThe current landlord of record, which changes when the building sells

What the control frameworks say

GAO’s revised Standards for Internal Control in the Federal Government, effective for fiscal year 2026, emphasizes prioritizing preventive control activities and adds documentation of a change assessment process for risks arising from significant changes. Lease portfolios generate significant changes constantly, including expirations, closures, assignments, amendments, and landlord sales, and each one should change a payment. The Green Book is a federal standard, cited here as a control reference rather than a requirement binding on a private company.

Eight failure modes worth testing

  1. 01Paying past exit or expiration, the most expensive item and the least dramatic
  2. 02Duplicate payment streams for one site
  3. 03Escalation applied early, or on the wrong basis
  4. 04Paying the prior landlord after a building sale
  5. 05Estimates still paid after the true-up settled
  6. 06Charges the lease excludes, paid because the invoice arrived
  7. 07Percentage rent calculated on the wrong basis
  8. 08Holdover rent at the wrong multiple

The change events that should stop a payment

  • Lease expiration, including an unexercised renewal option
  • Site closure or exit
  • Assignment or sublease
  • Landlord sale or change of ownership
  • Amendment execution
  • Reconciliation statement received
  • Space remeasurement

These are all knowable in advance. The failure is almost never that nobody knew; it is that the person who knew was not the person running the payment file. See our AP automation for lease payments and lease abstraction.

Frequently asked questions

What does an accounts payable audit cover?

In general practice, whether payments were properly authorized, correctly calculated, made once, and made to the right party. For lease payments specifically, it means comparing what was paid against what the lease obliges.

Why does the three-way match not work for rent?

Because two of its three legs are missing: no purchase order, since nobody raises one for a lease term, and no goods receipt, since nobody confirms continued occupancy monthly. The lease and occupancy record take their place.

How do companies end up paying rent on space they have left?

Usually because closure is an operations event and payment is a finance process, and no control connects the two. The recurring schedule keeps running until someone notices.

Is a recovery audit the same as an AP audit?

They overlap and differ in timing. A recovery audit looks backward to reclaim overpayments already made. An AP audit assesses whether the controls over payments are working, reducing how much needs recovering.

Emma Sukenik

Emma Sukenik is REAL’s Director of Business Development, focused on how enterprises recover spend across tax, lease obligations, and CAM reconciliations.

Director of Business Development, REAL

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