Database of Precedents

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	Organisational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“12. In the previous renewal decision of IEP’s registration, the Register Committee noted that the agency’s organisational independence still continued to be compelled by the close link with the EUA.

13. The Register Committee understood that IEP has taken further steps to address the flagged issues raised in the previous decision. The Committee notes the panel’s analysis and the conclusion that while the EUA is providing resources to IEP, it does not have any role in the decision making processes within the IEP. Furthermore, the Committee notes that in order to better distinguish between EUA and the separate activities undertaken by the IEP, the agency has developed a new website and a distinguishable new corporate identity.

14. Furthermore, the Register Committee took note of the agency’s revised Terms of Reference in order to show the Steering Committee’s full ownership of the development and operation of the IEP.

15. The Register Committee therefore concurred with the panel's conclusion that IEP complies with the standard. The Committee, however, shared the panel’s view that the agency should make publicly visible the IEP Terms of Reference and other official documents that state the organisational independence of IEP from EUA.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	operational independence, methodologies
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. In the decision for inclusion of CYQAA on EQAR (of 2019-11-05), the Committee raised concerns regarding the shortcomings related to the operational independence of CYQAA and the close interlinkage between the agency and the responsible ministry.

16. Despite some progress being made by consultation with key stakeholders on the appointment of Council members and the Minister, the Register Committee noted that the Council members are still appointed by the Council of Ministers, upon recommendation by the Minister responsible for higher education.

17. The Register Committee took note of the panel’s concerns regarding the operational independence of the agency, The Committee understood that CYQAA cannot hire its own staff and is fully relying on secondments from the central Government and the Ministry of Education, Sport and Youth.

18. The Register Committee further noted, as underlined by the panel, that despite being fully independent in defining its evaluation methodologies, CYQAA is still challenged by the limits set in the provisions of the national legislation regarding engaging stakeholders in the development of methodologies (see issue raised under ESG 2.2 in the external review report).

19. Following the panel’s analysis, the Register Committee expressed its concerns that the operational independence of CYQAA remains constrained by the close link and dependence on the Ministry of Education, Sport and Youth regarding the appointment of the Council members, hiring of staff and engaging stakeholders in the development of methodologies. Therefore, the Register Committee concurred with the panel conclusion, and found that CYQAA remains to be partially compliant with ESG 3.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.3 Independence
Keywords	government involvement, organisational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“51. The Register Committee learned from the report that the members of the MFHEA Board are all nominated by the Minister responsible for

education and appointed by the Prime Minister of Malta. The Prime Minister also nominates the Chairperson and Deputy Chairperson of the Board, who undergo parliamentary scrutiny before being officially appointed. Furthermore, the dismissal and resignation of the Board members could be

only done by or via the Prime Minister.

52. Following the panel’s analysis, the Register Committee expressed its concerns that the organisational independence of the agency is constrained by its strong link and dependency on the government. This is reinforced by the small size of the higher education system.

53. The Quality Assurance Committee (QAC) of MFHEA is the body responsible for decision making on external quality assurance of further and

higher educational institutions. The MFHEA Board, on the other hand, is responsible for endorsement of the evaluation decisions taken by the QAC.

The panel noted inconsistencies regarding what accreditation procedures and which decisions are being endorsed by the Board. Further, as noted by the panel, the participation of the head of QAC, a body appointed by the Board, in the endorsement of QAC’s decisions as a Board member could create internal conflict of interest.

54. In its additional representation, the agency stated that “There are several layers to ensure the independence and suitability of the members of

the Board. These are nominated by the Minister for Education, however they are appointed by the Prime Minister and the Chairperson needs to be

approved by the Public Appointments Committee which is a Parliamentary committee made up of members from both sides of the House (Parliament) which conducts Parliamentary Scrutiny of the nominee. The law also lists the eligibility criteria for Board members, thus ensuring the objective suitability of person nominated by the Minister and appointed by the Prime Minister.”

55. Furthermore, the agency clarified that the current chairperson of the newly appointed QAC has not been appointed as a member of the Board and that the process for the required legislative changes to reflect this distinction are currently underway.

56. The Register Committee considered the additional representation and welcomed the distinction between the two bodies by excluding the

chairperson of the QAC in the Board. The Committee found that, however, this practice is yet to be codified as to ensure continuous prevention of

conflict of interest within the accreditation process. Furthermore, the committee maintains its concerns raised by the panel on the inconsistencies

regarding what accreditation procedures and which decisions are being endorsed by the Board.

57. Finally, the Committee maintains its concerns raised above about how the organisational independence of the agency is constrained by its strong link and dependency on the government.

58. Therefore, the Committee could not concur with the panel and found that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.3 Independence
Keywords	Lack of ability to independently design external QA procedures, lack of ability to autonomously determine organisational structure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“27. The Register Committee learned from the panel’s analysis that ANVUR’s ability to design its external QA procedures (i.e. operational independence) and to set up its internal organisational structure (i.e. organisational independence) is rather limited. In panel’s view, the Italian regulations stipulated very specific details on the agency’s external quality assurance procedures, methodologies and the evaluation standards, as well as the internal governance and organisational structure. This approach diminishes ANVUR’s ability to act autonomously regarding its internal regulations and structures.

28. In its additional representation, ANVUR argued that most of the issues outlined by the review panel stem from the Italian national context and legislation. In regard to the operational independence of the agency, ANVUR argued that it has sufficient autonomy in designing its external QA procedures because national legislation emphasises ANVUR’s responsibility to independently define the criteria, indicators, and requirements of its external QA, while in regard to organisational independence, ANVUR states that the national legislation prescribes collaborative relation between the Ministry and ANVUR, instead of a direct supervisory role of the Ministry.

29. The Register Committee took note of ANVUR's remarks. The Committee could still follow panel's view that ANVUR is facing obstacles regarding organisational and operational independence, as the review panel already considered these legislative acts and nonetheless outlined detailed reasons for their concerns about ANVUR’s independence.

30. Considering that the review panel presents convincing evidence and analysis that ANVUR faces obstacles in its organisational and operational independence, the Register Committee concurred with the panel that ANVUR complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	Independence, government representatives
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“18. The Register Committee understood from the analysis by the panel that the composition of the Board of Directors has dominant representation of the government and the UIB, and these two stakeholders appoint all six board members.

19. The Register Committee further learned that according to statutes, the Director of the agency is appointed by the Balearic minister responsible for university affairs. Since 2009, however, this position is vacant and the Technical Director, chosen with a public competition, manages the agency.

20. The Register Committee understood that to resolve the above mentioned issues new statutes of the Consortium of the Balearic Agency for Quality Assurance in Higher Education has been drafted. The statutes, however, are not yet in effect. Following this, the Committee concurred with the panel that AQUIB only partially complies with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	government,
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. The Register Committee learned from the panel analysis that the representation of stakeholders in the Governing Council has improved compared to the previous review and that the share of Government appointees in this body has been lowered.

17. The Committee, however, also noted that the regional minister, whose portfolio the agency is situated in, is acting as the President of the agency, chairs the Governing Council and has a casting vote.

18. Furthermore, the Register Committee noted, as underlined by the panel, that the agency is dependent on the Regional Government’s approval for hiring both temporary and permanent staff, which limits the agency’s operational autonomy.

19. Considering the significant level of involvement of the regional government in the governing of the agency and the potential constraints over the staff management and the operational independence of the agency, the Register Committee could not follow the panel’s judgement and concluded that ACCUA complies partially with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.2 Official status
Keywords	agency’s formal recognition
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that IEP itself does not have separate legal personality and therefore it is represented by EUA in all legal and contractual matters. The Committee acknowledged that the recognition of IEP as a quality assurance agency by public authorities is demonstrated by the numerous contracts that IEP (represented by EUA) signed with national authorities for conducting evaluations, or by the selection of IEP as an evaluating body through a public procurement procedure. [...] The Register Committee interprets the requirement of formal recognition in a broad sense and therefore concurred with the panel's conclusion that IEP complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Student involvement in decision making bodies
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“ANQA involves students in the review panels, but not in the body

responsible for making decisions on accreditation (i.e. the Accreditation

Council). The Committee highlighted the panel’s recommendation and

found it necessary that the agency improves the involvement of students in

the decision-making process.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	14/03/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of stakeholders in governing bodies; Lack of clear policy for separation of EQA and consultancy activities and preventing conflict of interest
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The governing body (i.e. the Managing Board) of the agency does not involve other stakeholders than academics. The agency has not published any policy or statements in regards to the separation of its consultancy activities and preventing conflicts of interest.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/10/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Weak involvement of stakeholders in the governance of the agency
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (28/09/2021)
RC decision	Partial compliance

“AI has no advisory or governing board, nor any other strategical decision making body (hence lacks stakeholder involvement in the governance of the agency).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	clarification of external QA carried abroad
Panel conclusion	Full compliance
Clarification request(s)	Agency (21/05/2019)
RC decision	Compliance

“In its confirmation of eligibility, the Register Committee noted that PKA is expected to also address activities carried out by the agency abroad i.e. in Lithuania. As it was unclear on whether such activities were addressed in the external review of PKA, the Committee asked PKA for further clarifications. PKA explained that the external QA activities carried out in Lithuania only extended to one foreign branch of a Polish higher education institution and that the procedures and criteria used were identical with those applied in the case of national HE providers.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/06/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholder involvement in the governance and work of the agency
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While the panel noted that a broader stakeholder involvement would require a change of the law on higher education and might have further implications for the overall functioning of the agency, the Register Committee underlined that the unbalanced composition of NEAA's governing bodies was already flagged as a matter requiring attention when NEAA was first admitted to the Register in 2009”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Agency lacks explicit goals and objectives; limited stakeholder involvement i.e. consultations only where specific topics are addressed
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that while NEAQA’s strategy could provide a comprehensive framework for the agency's daily operations, the agency does not have in place mechanisms for effective forward planning and reviewing progress towards its objectives. Considering the involvement of stakeholders, the panel’s findings show that, since its last review, NEAQA has improved the engagement with employer representatives in its quality assurance activities. However, stakeholder involvement is still limited in agency's work given that neither students nor employers are involved in NEAQA’s governance.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/06/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of students in agency’s decision making
Panel conclusion	Full compliance
Clarification request(s)	Panel (02/06/2018)
RC decision	Compliance

“The Register Committee understood that the reference to “consultative services” in the report in fact referred to so-called “consultative visitations”. These are, however, not consultancy activities, but a step in EAEVE's external quality assurance scheme. […] The Register Committee underlined the panel’s suggestion that EAEVE should involve students in the ECOVE and the appeals panels, even though students do not request membership at the moment.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholder involvement
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged in its decision of inclusion the effectiveness of the Accreditation Institution’s activities to engage with its stakeholders.The Committee noted that the involvement of stakeholders is generally ensured trough consultations by the Ministry and the Accreditation Council (Review Report, p. 29), while AI’s only formalised form of stakeholder involvement is related to the thematic analysis of reports. The Committee concurred with the panel’s conclusion that AI should further develop stakeholder involvement in its governance and work in order to meet the agency’s objectives of enhancement and further development of quality assurance.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clarity in activities and services; Conflicts of interest
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“10. While the Register Committee was able to follow panel’s conclusion that AQ Austria is compliant with the standard, it highlighted the panel’s recommendation that the agency should enhance the clarity on its ESG aligned activities and consultancy services for the public and add explanation on avoiding conflicts of interest on their website.

11. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategy not reflecting agency's central role, lack of broad discussions with stakeholders
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Partial compliance

“16. The panel considered that the lack of involvement of stakeholders beyond those individuals who are members of the agency bodies themselves might lead to a lack of critical distance. The panel thus saw a need for more and broader stakeholder feedback, and recommended more regular dialogues with stakeholder organisations on strategic and policy matters.

17. The panel further considered that GAC's strategic planning did not sufficiently reflect its central, pivotal role in the accreditation system (see also the comments under ESG 2.2 above). The panel saw a strong need for a broader discussion with agencies and all stakeholders on GAC’s role in the system and its strategy. In particular in view of the upcoming revision of the

Specimen Decree, the panel found such a discussion was urgent to define a strategy that describes clearly the role GAC plans to assume in the system and its mid-term priorities.

18. While the Register Committee appreciates that GAC has begun to plan a strategy process (see statement on the report), it considered that the panel's analysis under this standard points to important issues in GAC's governance and engagement with stakeholders; these are particularly important in light of GAC's pivotal role in the German system.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	stakeholder representation within the governance and separation of EQA within and outside the scope of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last decision, the Register Committee noted that ASIIN continued to use the term evaluation for type 2 evaluations against the panel’s recommendation, and thus the separation between activities within the scope of the ESG and those that are carried out as type-2 evaluations remained unclear. In its review report the panel considered that the difference made by ASIIN in various documents between type 1 evaluation and type 2 evaluation sufficiently differentiated between accreditation and consultancy. The panel further noted that ASIIN had a policy not to conduct accreditation for those institutions/ programmes at which consultancy activities were carried out, and that this was adhered to in practice (p.31). The Committee therefore concluded that this shortcoming has been addressed. The Register Committee noted that ASIIN’s Board of Directors consists exclusively of representatives of member organisations/institutions of ASIIN. The involvement of a diverse set of stakeholders (including students) in the governance of the agency is, however, ensured within the technical committees, Accreditation Commission and Certification Commission. Considering ASIIN’s expansion of its external QA activities to other areas the panel underlined that ASIIN should rethink its current structure and broaden its competences (p.16). The panel recommended a stronger involvement of the Board of Directors in the strategic direction of the agency and the monitoring of its strategic goals, while at the same time expanding its membership to also include external stakeholders (including a student member). The Committee underlined that recommendation of the panel.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of external QA and consultancy activities; possible conflicts between different types of reviews
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“16. [...] The report noted that it would be against EQ-Arts' principles to engage in paid consultancy work (p. 31), this was now explicitly ruled out in the Governance Framework.

17. The Register Committee considered that the issue has been addressed for consultancy in the classical meaning, i.e. paid services provided to institutions. The Committee therefore now concurred with the panel's conclusion that EQ-Arts complies with the standard.

18. The Register Committee nevertheless underlined that EQ-Arts needs to be mindful for all other current or future activities with individual higher education institutions – whether paid or unpaid – if they could be regarded as compromising its ability to make an independent assessment of that institution later on and, if so, to make adequate provisions to rule out carrying out a review of that institution.

19. In addition, the next external review of EQ-Arts should analyse whether any risk lies in the fact that the same higher education institutions might undergo an enhancement review first and request a formal assessment later, depending on whether such patterns occur in practice.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student involvement in governance, lack of periodic and multi-annual Strategic Plan, a clear distinction between external quality assurance and its other fields of work
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (20/04/2025)
RC decision	Partial compliance

“21. The panel found that in general stakeholders are involved in the work of the agency, but commented that there is no student representative on the Foundation Council and that FIBAA should consider broadening its stakeholders to include, for example, members of committees from outside of FIBAA’s circle of ‘customers’.

22. The panel also remarked that FIBAA does not have a periodic and multi-annual Strategic Plan but that the strategic goals are considered during the Council’s last meeting in the year. The review panel noted that the consideration of strategic matters takes place as and when necessary, but still in a highly informal process. The Committee concurs with the view of the panel that the current strategic planning process, should be further developed to ensure that it also considers the medium to long term future of the agency.

23. While the review panel confirmed that FIBAA has in place a strict separation between its consultancy services and external QA activities within the scope of the ESG, the Register Committee noted that this separation was not clear in the case of FIBAA’s Evaluation Procedures According to Individual Objectives (see also point 5 above).

24. The Committee underlined that agencies are expected to take appropriate precautions to prevent any conflicts of interest arising from the consultancy activities they carry out, as indicated in Annex 2 to the EQAR Policy on the Use and Interpretation of the ESG.

25. Considering the shortcomings of involving students in FIBAA’s governance and the lack of a comprehensive Strategic Plan and the separation of consultancy and external QA procedures, the Committee cannot follow the panel’s conclusion of (substantial) compliance but finds that FIBAA complies only partially with standard 3.1.”

Full decision: see agency register entry