Reporting Substantive Changes

All registered agencies are expected to notify EQAR about changes to their legal form and status, amendments to their statutes and substantial changes in their process or methodology. It is the registered agency’s responsibility to inform EQAR of substantive changes that have occurred or are going to occur.

Objectives

Registered agencies are requested to inform EQAR of substantive changes so that EQAR will become aware of situations where an agency’s current practice differs substantially from the situation when it was reviewed against the ESG and admitted to the Register.

The requirement to report substantive changes is not intended to discourage change and innovation among registered agencies, and EQAR aims to minimise the burden on registered agencies.

EQAR therefore suggests that registered agencies keep their information on substantive changes as brief as possible, while giving a comprehensive picture of the nature and impact of the changes.

Changes should be reported as soon as possible for agencies intending to apply for a Targeted Review. Registered agencies are only eligible for a targeted review if all substantive changes have been duly reported by the time the application is made.

Type of Changes and When to Report Them

Substantive changes include any type of change that may affect the registered agency’s substantial compliance with the ESG. In general, changes should be reported as soon as they are sufficiently clearly defined to allow providing comprehensive information on their nature and impact. This should however not be too much delayed, so as to ensure that your agency’s profile in EQAR is up to date and that any new activities within the scope of the ESG are covered by the agency’s registration in EQAR and that results can be immediately uploaded in DEQAR.

Find below an illustration of types of changes and when to report them:

Illustration: Type of Substantive Changes and When to Report Them
Type of change Possible examples When to report
Legal form and other organisational changes
  • merger with/into another body/entity, changes in the parent entity;
  • liquidation, bankruptcy or similar proceedings;
  • role or composition of governing or managing bodies (no need to report regular changes of individuals, e.g. when their terms end);
  • establishment or discontinuing of governing or managing bodies;
  • outsourcing of activities with significant relevance for the agency’s external QA activities.
 Once the decision has been adopted
New external quality assurance activity
  • review, audit, evaluation or accreditation of higher education institutions or programmes (including short cycle studies) that relate to learning and teaching in higher education;
  • other types of activities outside the scope of the ESG.
 After the design phase and before implementation:

once key documents such as procedural rules, handbooks, etc. were adopted.
Changes in an existing quality assurance activity
  • changes to the processes, criteria or methodologies of the agency’s external quality assurance activity(-ies)
 Once the revised methodology/procedure is adopted
Discontinuing of an existing activity
  • the external QA activity is no longer on offer
 Once it is clear that no further procedures will be launched

EQAR may also become aware of substantive changes in other ways. This may be either by third-party information received under the Complaints Policy, or on the basis of any information that is in the public domain. EQAR will then contact the agency for additional information or, if applicable, a change report.

If unsure whether or not a change should be reported, please refer to the questions in the Online Substantive Change Report Form for guidance. As a rule, if the answer is “yes” to either of the three main questions, a substantive change report should me made. If you are unsure whether the answer is “yes”, please refer to the examples for types of changes under each of the questions.

If you remain unsure whether a substantive change report is warranted or not, please seek advice from the EQAR Secretariat.

Process & Decision

Registered agencies are requested to submit Substantive Change Reports through the online form linked below.

The timeframe in which substantive change reports are considered by the Register Committee depends on the complexity of the substantive changes.

Should EQAR require clarification to fully understand the nature and impact of the substantive changes it may contact the registered agency.

EQAR will normally merely take note of substantive change reports (see here previous decisions) and update information on the Register, if necessary. Only in cases of serious concerns whether a registered agency continues to comply substantially with the Standards and Guidelines for QA in the EHEA (ESG), will the Register Committee consider further action.

How to Describe Changes

Please use the questions contained the on-line form to guide your submission (see also section above, on Types of Changes and When to Report them).

The nature of the changes should be described concisely. The key question for EQAR is how the current situation differs from the situation when the external review of the agency was carried out or when substantive changes were last reported regarding that aspect, respectively. The key consideration relates to the ways in which the changes impact on the agency’s substantial compliance with the ESG.

For changed or new external quality assurance activities, please comment briefly on all aspects listed in the form and provide references (as a hyperlink or as an attachment) to the formal documentation governing these activities (preferably in English).

Please also note the following:

  • Agencies are encouraged to include appendices related to the changes. These should be limited to what is absolutely necessary to provide comprehensive information. Appendices can be attached in PDF format (no other editable formats) or provided as a hyperlink.
  • Documents in another language than English will not be reviewed.
  • Change reports should be only submitted through our online form, not via regular mail, fax or otherwise.
  • There are no fees or other costs related to substantive change reports.

Mergers of Registered Agencies

EQAR has developed a specific policy to address the registration status of agencies in case of a merger.

Registration may be provisionally maintained for agencies established as a merger of agencies already registered on EQAR. This will allow the merged agency to remain on the Register for a limited timeframe of maximum 2 years under certain conditions. During that period the new, merged agency will have to undergo an external review against the Standards and Guidelines for the Quality Assurance of the EHEA (ESG).

The conditions, requirements and process are set out in the Merger Policy (see link below).

Online Reporting Form

Please use the following online form to make a Substantive Change Report: