Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee learned that IQAA now publishes in full the decisions from institutional and programme accreditations, including the

negative ones. Even though the bulk of reports is public, this is not the case for all of them - the reports from the initial accreditation and the post-accreditation monitoring are still not published.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.4 Thematic analysis
Keywords	Consistent publication of thematic analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee learned that IQAA has published several thematic analyses since the last review. The panel, however, could not see

any formal plan for drafting and publishing these analyses.The Committee considered that despite the absence of a more formal planning the agency has developed a practice and demonstrated a clear vision for conducting analyses based on its EQA processes.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.1 Consideration of internal quality assurance
Keywords	How ESG Part 1 is embedded in subject-specific label reviews
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its Change Report Decision of 02/11/2020, the Register Committee requested that the next external review of ASIIN considers how the agency ensures sufficient coverage of ESG Part 1 in its combined (“piggybacking”) procedures (ESG 2.1). The agency explained that ESG Part 1 is embedded as a standard procedure in every external QA activity carried out (Self Evaluation Report p. 35). Having considered how ESG Part 1 is mapped against ASIIN’s seals while also including the standards of the German Accreditation Council, the panel was convinced of the coverage and link to ESG Part 1 in all its activities. The documents confirmed that all subject-specific label requirements are assessed in addition to ASIIN's generic standards for degree programmes, which incorporate ESG Part 1. The panel also underlined that SAR templates for each review method were structured to follow ESG Part 1. The Register Committee was therefore satisfied that ESG Part 1 is sufficiently addressed in ASIIN’s combined (“piggybacking”) procedures.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.3 Implementing processes
Keywords	Implementation of procedures and transparency of CBQA procedures
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last review the Register Committee noted that ASIIN's policies were not always followed in practice, i.e. use of on-site visits in evaluations and use of evaluation results in programme accreditations. In its current review, the panel stated that it did not find any evidence of deviations from the prescribed procedures and that policies are implemented consistently. The panel, however, remarked that ASIIN could provide better guidance about the site visit schedule and ensure more transparency in the processing of requests deemed potentially problematic from countries of higher education institutions outside of the European Higher Education Area (see also under ESG 3.1).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.7 Complaints and appeals
Keywords	handling of appeals and complaints
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee considered the panel’s findings that show that ASIIN’s appeals and complaints processes are not well differentiated and as a result not consistently used, i.e. the institutional accreditation handbook discuss complaints procedure although what is described is the means to appeal a decision, whereas the handbooks for the programme accreditation and certification processes mention appeals procedure, the name of the Appeals/Complaints Committee appear to have four different permutation. The panel further comments on the agency’s lack of understanding of the two different concepts. In its response to the review report (19/07/2021) ASIIN’s stated that it has revised its documents and website, employing the right terminology. While the Register Committee welcomed ASIIN’s corrections, the Committee found the panel’s concerns have not been fully address, as the lack of understanding of the two concepts may affect the agency’s ability to effectively handle both appeals and complains for all its activities.”

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	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.3 Independence
Keywords	Integrity/conflict of interest
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that the members of ASIIN’s technical committees can simultaneously hold the position of an external reviewer for ASIIN’s review panels, which would put them in a conflict of interest when discussing the reports prepared by the same panel they were members of.

23. Considering the panel’s concern of a potential conflict of interest resulting from this arrangement, the Committee concluded in its initial decision that ASIIN complied only partially with ESG 3.3.

24. In its Appeal of 20/01/2022, ASIIN challenged the Committee’s conclusion and judgment arguing that the independent decision making of its Technical Committee was not compromised. The agency made the case that the involvement of active experts as members within ASIIN’s 14 Technical Committees ensured a consistent application of procedures and criteria in the preparation of accreditation reports. ASIIN further explained that ASIIN’s Technical Committees did not have any decision-making power as regards the accreditation decision. Moreover, the experts involved in the procedure would regularly abstain.

25. The Committee welcomed the abstention of the Technical Committee members, but could not determine if the practice of abstention was institutionalised in ASIIN’s procedure.

26. The Register Committee further underlined that the integrity of the review process could be better safeguarded by ensuring that members of the Technical Committees would not partake at all (i.e. by leaving the room) when their report is considered by the Technical Committee.

27. Having weighed the limited role of the Technical Committee in ASIIN’s decision making process and the fact that its members abstain from decision-making in such cases where they were involved as reviewers, the Register Committee concluded that ASIIN’s independent decision-making is not compromised and thus found that the requirement of the standard is met. The Committee therefore concurred that the agency complies with ESG 3.3”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.4 Thematic analysis
Keywords	thematic analysis conducted on a regular basis
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last renewal of registration on EQAR, the Register Committee noted that ASIIN only partially fulfilled the requirement of the standard, since ASIIN did not conduct such analysis on a regular basis and the prepared analysis and studies contained only elements of what is understood as thematic analysis. In its current review report, the panel commends ASIIN for its efforts in regularly developing thematic analysis through its impact studies which provide significant insights on the agency’s external QA activities. While the panel finds that ASIIN could improve the dissemination of its impact studies among stakeholders, the panel is satisfied that the requirement of the standard is met. Having addressed the earlier concerns in its compliance with ESG 3.4, the Register Committee concurred with the panel’s conclusion that ASIIN now complies with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	2.4 Peer-review experts
Keywords	student involvement
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“9. The review panel's report contained no analysis of the factors that led to that departure from EQ-Arts' own policies, but confirmed that all reviews since December 2018 have included students (8 reviews in 2019 and 1 in 2020); the panel further elaborated on EQ-Arts approach to recruiting and training experts.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	2.5 Criteria for outcomes
Keywords	consistency of decisions
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (16/03/2021)
RC decision	Compliance

“12. The panel was convinced that EQ-Arts had “developed a sound approach to guarantee fair and transparent decisions and judgments”; it noted that consistency was ensured by a template with guidelines, the executive officer supporting each expert team and the Board considering each report.

13. [...] In its response, the panel elaborated on the measures taken to ensure consistency and how reviewers are being familiarised with them in EQ-Arts' trainings. The panel explained how it triangulated the information received from the reviewers, the reviewed institutions and the EQ-Arts Board. The panel confirmed that there was a “consistent understanding of procedure and process”. Based on the increased amount of activities, the panel was satisfied that EQ-Arts criteria were applied consistently, irrespective of whether the process leads to a formal decision by the Board.”

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	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	3.3 Independence
Keywords	nomination of the Board members
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“21. The review panel noted that EQ-Arts' statutes were reviewed in order to reorganise its Board and allow for the inclusion of students. Moreover, the Board and Executive Group were merged. The Governance Framework defined the composition and responsibilities of the Board, as well as the criteria for Board membership (p.34).

22. The panel reported that a call for Board members was issued in May 2020 and addressed to relevant subject-specific stakeholder organisations; on that basis, the Board members were selected.

23. The Register Committee considered that the new arrangements improved transparency and therefore concurred with the panel's conclusion that EQ-Arts complies with the standard.

24. The Committee was unable to verify whether the nomination arrangements apply only to initial nominations or also to re-appointments. In the interest of assuring a regular link with the sector, the Committee encouraged EQ-Arts to ask for nominations also for re-appointments.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	3.5 Resources
Keywords	volatile resources
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“28. The 2018 external review discussed that EQ-Arts' financial situation was volatile. While the resources were sufficient to sustain the (currently) small number of reviews, the medium-term perspective was not clear.

29. The panel reported that staff increased to 1.3 FTE in 2019, then fell to 0.5 FTE as result of the Covid-19 pandemic and a drop in activities.

30. While the panel found that the “agile and collaborative approach” assured that workload could be handled, the Register Committee considered that the resources of EQ-Arts remain highly volatile; this has not changed since the initial review.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.4 Peer-review experts
Keywords	Lack of meaningful involvement of students in panels
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“ECAQA involves a variety of stakeholders in the composition of panels, including students. The Committee learned that, in practice, the student reviewers were not always offered the training provided for the other panel members – such conditions made their involvement in some of the reviews nominal in the panel's view.The Register Committee found that despite the formal involvement, ECAQA's approach did not ensure meaningful participation of students in all review panels”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	3.3 Independence
Keywords	Infringement of the organizational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Committee could not verify how the agency ensures its independence from its founder and found the distribution of power among stakeholders in the governing of the agency unequal. The Committee noted that the current arrangements include the possibility of

the founder or the Director General exercising their controlling stake in several regards, causing a substantial risk of an infringement on the

independence of the agency (see also interpretation 18).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	2.4 Peer-review experts
Keywords	training of experts & pool of experts limited
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that FIBAA uses several videos and Power Point presentations to provide training for the experts, but critically remarked that there is not a face-to-face training and no clear obligation for experts to undertake such a training (or supervision on it) prior to an accreditation or certification procedure. The training is done on a voluntary basis. The review panel also underlined that the training materials for the English-speaking experts may not be as comprehensive as those received by German-speaking experts.

In its analysis the review panel also noted that the number of international experts in the pool of experts to be rather limited given FIBAA’s international profile and that there is minimal rotation and renewal among the experts.

Considering the above mentioned shortcomings, the Register Committee cannot follow the panel’s conclusion on (substantially) compliant but finds that FIBAA complies only partially with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	2.6 Reporting
Keywords	publication of all reports
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“14. In its last decision, the Register Committee noted that a number of programme accreditation reports have not been published by FIBAA and concluded that the agency at that time complied only partially with ESG 2.6. In response to the recommendation made in the previous review, the Register Committee learned that FIBAA is now publishing both the positive and negative reports on accreditation and certification processes from national as well as international activities, on its website.

15. The Register Committee therefore agreed with the panel’s conclusion, that FIBAA complies with standard 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	2.7 Complaints and appeals
Keywords	Rudimentary nature of appeals procedure
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. In its last decision, the Register Committee underlined the panel’s observation that there is no clear indication on whether higher education institutions can issue a complaint regarding the course of the procedure. The Committee also remarked at that the appeals procedure is documented only rudimentarily, with little or no explanation on the issues that could be raised under the appeal, no provision on the expected timeline to process a complaint, publication policy etc.

17. In its review report, the panel stated that higher education institutions may submit complaints about the conduct of the process writing an email to FIBAA and that FIBAA has established a procedure for appeals.

18. The Register Committee learned that FIBAA’s appeals procedure only applies to the procedures where the agency is awarding its seal and it does not cover the reviews where GAC is the decision-making body. Since higher education institutions may have concerns related to the application of the criteria and the judgments also in the reports prepared for the GAC, these should equally be subject to appeal in line with the standard.

19. The Register Committee further noted that FIBAA’s appeals procedure date back to December 2016, and has not been updated since the agency’s last review. The Committee found it surprising that the review panel has not addressed any of the issues the Committee raised in its last decision regarding the rudimentary nature of FIBAA’s appeals procedure and only commented on the wording of the process for complaints and appeals (that should be clarified).

20. In light of the above observations the Register Committee cannot follow the panel’s judgement of (substantially) compliant, but find that FIBAA complies only partially with the standard.”

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 (18/04/2025)
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

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	3.4 Thematic analysis
Keywords	structured approach in carrying out of thematic analysis, limited work carried out
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“26. The panel critically remarked that FIBAA does not seem to collect in a systematic way information on programmes and institutions and that the agency does not produce an overview of the outcomes of it external QA activities.

27. The panel also noted that workshops on topics related to quality assurance and resulting studies are mainly organised by FIBAA Consult. While the panel is of the view that FIBAA should reconsider the assignment of such activities to FIBAA Consult, the Register Committee disagrees and underlines that the standard does not limit the carrying out of thematic analysis by a unit of the agency or the possibility to subcontract this work to an external body.

28. The Register Committee however agrees with the panel’s conclusion that FIBAA should ensure a structured approach and allocate more resources to the planning and carrying out of thematic analysis on a systematic basis.

29. Considering the limited work in producing thematic analysis, the Committee concurs with the panel’s conclusion that FIBAA complies only partially with ESG 3.4.”

Full decision: see agency register entry