Across the international audit and public governance literature, the OECD and the Institute of Internal Auditors (IIA) increasingly framed internal audit as a risk-based and continuous assurance function rather than a retrospective and compliance-checking exercise. In small-state local government systems such as Malta’s, however, this shift has not yet been matched by a comparable institutional transformation. This study examined the institutional position of the internal audit function in Maltese local governments within the framework of public financial management, internal control, risk management, and accountability, and then developed an internal audit model applicable to Malta’s administrative scale. A directed qualitative content analysis was adopted to examine official institutional documents, informed theoretically by agency theory and institutional theory, and combined with comparative institutional analysis. Documents were coded against eight core criteria, including institutional independence, risk-based audit capacity, and follow up of the findings, when applied uniformly to Malta and five comparator countries (the United Kingdom, the Netherlands, Sweden, Estonia, and Ireland), plus four supplementary criteria used only for the Malta case. The findings demonstrated that Malta’s core institutional weakness was not the absence of audit mechanisms, but insufficient integration of external audit, compliance review, internal control, and corrective action into a continuous internal audit cycle. The comparative analysis indicated that a centrally coordinated, locally connected, and risk-based hybrid model was more applicable to Malta than separate per-council internal audit units. The original contribution of the study lies in systematically linking National Audit Office Malta (NAO)’s recurring local-government findings to a structured and criterion-based comparison across five European models, thus translating this into an institutional design calibrated to Malta’s scale, and extending agency and institutional-isomorphism theory to small-state local government audit.