Database of Precedents

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	procedure for handling complaints
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“12. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard due to the unclear procedure for handling complaints. From the report, the Committee learned that Unibasq now has a well established complaints procedure noted in the agency’s regulations of the Ethics and Guarantees Committee and the Code of Ethics.

13. Following the changes made by the agency, the Committee was able to follow the panel’s conclusion that the agency complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Distinction between ESG aligned and consultancy activities
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“14. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard as it did not make a clear distinction between its ESG aligned and consultancy activities (i.e. the evaluation of “títulos propios”). At the time, the agency removed the information regarding the evaluation of “titulos proprios” from its website; the Committee, however, could not verify whether the new method of communication brought clarity for all stakeholders.

15. From the external review report, the Committee has learned that the agency “ has made...efforts to request from higher education institutions [involved in the consultancy activities] not to use misleading information on their websites and has succeeded as far as the panel could determine through an internet search”.

16. The Committee therefore followed the panel’s conclusion and found that the agency now complies with the standard. The Committee, however, shared the panel’s view that the agency could improve the distinction between these two group of activities by creating a separate section on its website where it showcases clear information to the public.

17. 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	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	operational independence, decision-making
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision, the Register Committee noted the strong role the German Bishops’ Conference (DBK) plays in the governance of the agency.

9. Despite the changes made by the agency to further its operational independence, the Register Committee noted that DBK maintains a significant role in the organisational structure of AKAST.

10. The Committee underlined the possible influence that may be exerted by the DBK Episcopal Commissioner in the decision making of the Accreditation Committee. Although the Episcopal Commissioner is present in the Accreditation Committee (AC) of the agency in an advisory capacity, there is still the possibility of undue influence considering the fact that the Episcopal Commissioner still issues a separate consent impacting the programme.

11. Furthermore as noted by the panel, it also seems possible for the episcopal commissioner to express, even unintentionally, a preliminary opinion on particular study programmes, not necessarily based on the findings of the expert panel during the AC meeting.

12. The Committee noted the concentration of power in one place, i.e., the current Chairperson of the Executive Board of AKAST holds the position of Chair of the Accreditation Committee and Chair of the Advisory Board of AKAST. Furthermore, the DBK nominates the Chairperson of the Executive Board.

13. Considering the strong influence of one main stakeholder in the running of the agency, the Register Committee underlined the risk to the agency’s operational independence, as well as to its independent decision-making. The Register Committee therefore concurred with the panel’s view that AKAST complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.4 Thematic analysis
Keywords	publication, analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“14. In its last decision, the Register Committee welcomed AKAST plans for further development of its thematic analysis after an appropriate number of programme accreditation procedures have been carried out.

15. The Register Committee noted that while AKAST has taken some steps in preparing thematic analysis since its last review, i.e., initiating a process for evaluation of the peer review processes carried out by AKAST, since 2022 at the time of the review, no thematic analysis have been made available nor any kind of such analysis have been published.

16. Considering the limited progress made since the inclusion on the Register and the limited development of thematic analysis, the Register Committee concurred with the panel that AKAST complies only partially with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality assurance, mechanisms
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee, noted in the analysis by the panel the gaps and shortcomings in the implementation of the agency’s Internal Quality Assurance (IQA) Regulations.

18. Furthermore, the Committee underlined that the mechanisms for fostering continuous improvement within the agency are weak and unsustainable on the long-term, i.e., the heavy responsibility of AKAST administrator for all of the IQA processes, the lack of systematic approach in gathering feedback and lack of evidence and example of enhancement based IQA.

19. The Register Committee further noted the lack of commitment in timely addressing the issues previously noted under ESG 3.3 and ESG 3.4 which impacts the overall effectiveness of the agency’s internal quality assurance arrangements.

20. In light of these concerns, the Register Committee could not follow the panel’s judgement of compliance and found that AKAST complies only partially with ESG 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	Internal quality assurance
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“7. The review report showed that the coverage of the particular standards is ensured with guiding questions for institutions and for review teams. However, the evaluation reports are still not checked with a specific focus on how ESG is covered by the IEP Secretariat.

8. While the Register Committee concurred with the panel’s judgement and found the agency to be compliant with the standard, it highlighted the panel’s recommendation on importance of systematic signposting of ESG Part 1 criteria in the evaluation reports.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.3 Implementing processes
Keywords	Implementing processes
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“9. In the last review, the agency was found to be partially compliant with the standard as the follow-up model did not ensure a consistent follow-up for all evaluated higher education institutions.

10. The Register Committee noted from the panel’s analysis IEP’s efforts in addressing the shortcomings with the standards. Furthermore, the Committee noted that IEP took further measures to increase the rate of submission of follow-up reports by evaluated higher education institutions. .

11. The Register Committee therefore concurred with the panel's conclusion that IEP complies with the standard.”

Full decision: see agency register entry

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	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.3 Implementing processes
Keywords	follow-up, online procedures,
Panel conclusion	Partial compliance
Clarification request(s)	Panel (04/10/2023)
RC decision	Compliance

“12. The Register Committee noted that PKA does not have separate follow-up mechanisms in place, but that they are part of the re-accreditation process i.e., after a conditional two year period (or longer depending on the length of the study cycle) the agency monitors the implementation of recommendations, while in case of a six year accreditation cycle, the agency monitors if the recommendations for improving the quality of education are addressed.

13. The Register Committee finds this approach completely reasonable and in line with the requirement of the standard

14. The Register Committee noted that all of PKA’s evaluation procedures (with some exceptions) are being carried out remotely. In its clarification call the review panel explained that PKA is following clear regulations regarding its remote procedures, regulations that have been updated following wide consultations with the sector. The panel was reassured with PKA’s approach in its online accreditation procedure i.e., PKA carries out observations of classes, institutions are asked to provide a video of the learning facilities and during the remote visit PKA experts also meet with different stakeholders to verify the facts in the review report.

15. The Register Committee further noted concerns from the review panel’s analysis regarding the factual accuracy-check of review reports, as this practice was not clear for those the review panel interviewed. The Register Committee however noted that the possibility for the higher education institution to comment on the assessment report is given to all higher education institutions (as confirmed by the panel) and that this is part of the procedure of the agency in the consideration of the report. The Register Committee nevertheless underlines the panel’s recommendation to further clarify the stage of factual accuracy check in PKA’s procedures.

16. Having considered the clarification of the panel and PKA’s statement to the review report, the Register Committee could not concur with the review panel’s decision of partial compliance, and found that the agency is in fact compliant with ESG 2.3.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.4 Peer-review experts
Keywords	students
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“17. In its past decision, the Register Committee noted PKA’s intention to ensure students are part of the peer-review expert groups in the opinion-giving process and to contribute as equal partners.

18. In its 2023 review report, the panel noted improvements related to the wider engagement of different stakeholders’ groups. In the case of opinion-giving procedure, panels are now composed of members of relevant sections or experts appointed from the academic teachers expert group and a student.

19. The Register Committee thus concluded that the agency has addressed the issues raised in the previous report and therefore can follow the panel’s judgment of compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.6 Reporting
Keywords	publication of reports
Panel conclusion	Compliance
Clarification request(s)	Panel (04/10/2023)
RC decision	Partial compliance

“20. In the past decision, the Register Committee noted that reports of its initial (ex-ante) programme evaluation/opinion-giving process were not published. In its recent review, the panel confirmed that all “expert reports and resolutions of the opinion giving process are now published and available on PKA’s website”.

21. While the Committee noted that PKA has published all decisions from the initial (ex-ante) programme evaluation/opinion-giving process, the Register Committee however found that such decisions did (in particular after July 2020) not include full reports. Given the missing number of a large number of full reports the Register Committee sought further clarifications from the review panel. The panel explained that they understood there was a delay in the publication of reports but that the statutory requirement is for PKA to publish all reports. This reassured the panel that the earlier concern regarding the publication of reports was resolved.

22. Given that PKA has not published all reports from its opinion giving process, the Register Committee found that the earlier concern has not been addressed.

23. In its representation, PKA provided information on the planned changes in its provisions to ensure publishing all reports from its opinion-giving processes. PKA explained that it would be possible to publish all reports from its opinion giving process without the need to wait for information from the Minister regarding their final decision through these changes.

24. Furthermore, in its additional documentation provided on 2024-03-28 PKA informed of its statutory changes where the planned changes have been done.

25. The Register Committee welcomed the actions taken by PKA. However, these changes in the provisions remain to be considered and reviewed by an external review panel to determine whether the changes have been properly implemented.

26. The Register Committee therefore could not concur with the review panel’s conclusion, and found that PKA complies only partially with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	organisational independence, minstry,
Panel conclusion	Partial compliance
Clarification request(s)	Panel (04/10/2023)
RC decision	Partial compliance

“27. In its decision of the Substantive change report decision (of 28-06-2022) the Register Committee concluded that the dismissal of the President casts serious doubts on whether PKA remains able to “act autonomously” and to assume “full responsibility for [its] operations”, as required by ESG standard 3.3.

28. The Register Committee considered that the law and regulations on PKA provided insufficient safeguards against an infringement on the agency's independence by allowing for such a decision to be taken discretionary by the Minister. The Committee found that its earlier conclusion that PKA complies with ESG 3.3 might have been flawed, and based on a positive external review report that did not allay such concerns.

29. In its current review the panel confirmed the concerns of the Register Committee i.e., the panel “could not gauge the extent to which the looming possibility of dismissal without reason may affect the behaviour and performance of the President…”. The panel also noted that there are no clear rules and procedures for the dismissal of PKA’s President, thus the Minister can continue to use discretionary power to dismiss the President of PKA.

30. Following the review panel’s recommendation, the President of PKA submitted a letter, dated August 2, 2023, to the Minister of Education and Science, articulating the recommendations delineated in the ENQA’s review report. In its response letter (Annex 1 of Statement), the Minister showed readiness for a discussion that would determine the criteria for dismissing the PKA President.

31. The Register Committee considered that the Minister was willing to recommend a change in the Law and that would remove the question mark over the independence of PKA (as noted in the Review Report and PKA’s Statement to the Review Report). The Committee nevertheless found that since its Change Report (of 2022-06-28) and the review panel’s review report of June 2023, no change or new evidence in the form of a policy, protocol, procedure or similar, specifying reasons/rationale for the dismissal of the President regulating the Minister’s discretionary power was developed and adopted.

32. The Committee further noted existing possible conflict of interest in PKA’s decision making bodies (see further under ESG 3.6), which raises concerns related to the integrity and independence of the agency’s formal outcomes.

33. The Register Committee finds the above issues of significance given the powers conferred in the position of the PKA’s President (expressed mainly in article 7, 8, 9 & 11a of PKA Statutes) and the controlling stake laid in the hands of the Minister, who has already employed its discretionary power to dismiss the President of PKA at any point (see Change Report Decision of 2022-10-25).

34. In its additional representation, the agency provided a declaration from the new Minister of Science of Poland, where he shows willingness to initiate an amendment on the provisions of the Act of Higher Education and Science in order to limit the Minister’s powers and remove their right to dismiss the President of PKA. Furthermore, the declaration states that the proposed amendment it would empower PKA to be responsible for the dismissal of the President.

35. The declaration of the Minister also informed the Register Committee, that until the legislative framework is changed, he shall introduce an internal procedure in case the President needs to be dismissed, in order to eliminate any further doubts of the Register Committee.

36. The Register Committee welcomed the proposed changes by PKA and the Polish Ministry of Science. Nevertheless, the presented changes have not been implemented in practice yet and at the moment are promises that have yet to be implemented. Therefore, once adopted it remains to be considered and reviewed by an external review panel to determine whether the changes have been properly implemented.

37. The Register Committee therefore concurs with the panel that PKA complies only partially with ESG 3.3. The agency is expected to submit a Substantive Change Report informing the Register Committee once the changes have been made.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.5 Resources
Keywords	resources
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“38. In its past review, the Register Committee noted concerns related to the lack of resources, the high turnover of the Bureau staff and the agency’s capacity to perform thematic analysis.

39. The Register Committee noted from the findings of the latest review (review report of 2023) that the agency now benefits from an increase in support and resources, a decrease in staff turnover, an improved focus on thematic analysis and a legislative recognition for this activity. The panel also found that staff, managers and stakeholders were satisfied with the current resources of the agency.

40. Based on the findings of the review panel, the Register Committee was able to concur with the judgement of compliance with standard 3.5.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal QA,
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“41. In its Change Report Decision (of 2022-11-25), the Register Committee considered the reported change on the newly established body, the Quality Council, and expressed concern with the current proposal of an open-ended regulation that would affect the operability and independence of the Quality Council.

42. While the panel was unable to address concerns with the current proposal of an open-ended regulation that would affect the operability and independence of the Quality Council, it noted that the PKA’s President maintains a supervisory role in the internal quality management system of the agency (by being responsible for supervision of the internal quality management system (IQMS) and in appointing a Quality Management System.

43. The Register Committee found that the current proposal for Quality Council (based on Statutes articles 11a & 15a) could have far reaching consequences, while also noting the organisational issues highlighted under ESG 3.3.

44. The Committee was also made aware of possible conflict of interest scenarios (1) where the Chairs of Section may participate in the discussion of the Presidium, even if they have been part of assessments they have previously prepared and (2) where the Chair of the Appeals Body may vote on resolutions adopted by the Presidium which may be later considered by the Appeals Body. The Register Committee found that this setup lacks the appropriate checks and balances and may affect the integrity of PKA’s activities. The Committee could not understand why PKA has not set up a system that would allow the recusal from the discussion or the possibility for restricting the participation (to no voting rights) of those that could be in a conflict of interest scenario.

45. In its additional representation, PKA informed that the responsibility for establishing the Quality Council will be with the Presidium and no longer solely with the President.

46. Furthermore, PKA committed to introduce provisions stipulating that members of the Presidium participating in programme evaluation procedures or preparing a review in the opinion-giving processes, shall be excluded from voting on those procedures.

47. In its additional representation, PKA clarified that the participation and voting rights of the Chair of the Appeals Body in the Presidium is based on the provisions of the Higher Education Act and PKA’s Statutes. PKA clarified that the Chair of the Appeals Body participates only in the part of the meetings where motions for reconsideration of assessment of opinions are discussed and votes only on this matter.

48. Furthermore, PKA clarified that the Chair of the Appeals Body does not take part in the proceeding assessments of opinions that may become object of applications for reconsideration, nor do they vote on such matters.

49. In the additional documentation (of 2024-03-28), PKA reported that the following statutory changes have been made: (a) The responsibility for establishing the Quality Council will be with the Presidium rather than solely with the President; (b) The members of the Presidium participating in the programme evaluation procedures or preparing a review in the opinion-giving processes, shall be excluded from voting on the decisions resulting from those procedures.

50. While the Register Committee welcomed the changes taken by PKA, it underlined that the issues outlined before remain to be addressed and subsequently to be considered and review by an external review panel in order to determine their implementation in practice.

51. The Register Committee therefore could not follow the review panel’s judgment of compliance and found that PKA complies only partially with ESG 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	2.6 Reporting
Keywords	reports sometime lacking depth of analysis, expert reports not always publlshed
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. The Register Committee noted from the panel’s analysis that the central part of the agency’s reports appears to be merely a check list “occasionally lacking depth of analysis and evidence-based material”. The panel further raised concerns with regards to the accessibility of reports on the ARACIS website, which the panel found somewhat challenging to navigate.

8. The Committee further noted that in the case of doctoral study programmes, study domain accreditation and study domain authorisation ARACIS does not publish the experts’ final proposals for decision. The Committee does not understand why the final proposal for decision/expert conclusion is left out, in particular since this is included in all other external quality assurance activities of ARACIS. The Register Committee underlined that this approach affects the transparency of the agency’s decision making processes in the case of third cycle reviews.

9. The Committee also found that for some of its external QA activities the agency had changed its approach from publishing the full expert report to only publishing a short excerpt of the expert report i.e., the second cycle study domain accreditation reports only include up to a one page excerpt from the expert review report. The Register Committee underlined that it can be of public interest to know the basis on which the final reports are being developed, and that the publication (at least as annex) of the full reports is important to ensure the transparency in the decision-making of the Council.

10. Based on the above raised concerns, the Register Committee could not follow the panel’s conclusion of compliance and therefore concluded that ARACIS complies only partially with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	2.7 Complaints and appeals
Keywords	Lack of transparency in the agency’s appeals processes, accessibility of Appeals Procedure
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“11. In its past decision, the Register Committee raised a concern regarding the lack of transparency in the agency’s processes concerning the members nominated to act in the Appeals Committee. The Committee also noted at that time that the appeals procedure was not easily accessible on ARACIS’s website.

12. The Register Committee noted from the analysis of the panel that ARACIS has appointed a Permanent Appeals Commission for a four-year term and published the composition of the commission. The Committee also learned that as of October 2022, ARACIS has a new, integrated and simplified Appeals and Complaints procedure that can be easily retrieved from the website1.

13. The Committee welcomed the newly updated procedure, and while noting that the procedure is rather generic in what concerns handling of complains, that it satisfies the requirements of the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality assurance (IQA) system not implemented
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. In its past decision the Register Committee found that the internal quality assurance (IQA) system had not been implemented at that time. In particular it found that the IQA had yet to prove its role in supporting the internal activity of its speciality commissions and in providing the agency with a sound basis for reviewing and improving the effectiveness with which it works.

16. The Register Committee noted from the detailed analysis of the review repot that ARACIS has set up a functional internal QA system including relevant documentation, structures and personnel. Having considered the evidence presented, the Committee can follow the panel’s conclusion that ARACIS now complies with the requirements of standard 3.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.6 Reporting
Keywords	publication of reports
Panel conclusion	Partial compliance
Clarification request(s)	Agency (28/11/2023)
RC decision	Compliance

“9. The panel reported that it could not identify any clear links where the decisions and the evaluation reports of the review panels are being published on the agency’s website.

10. The Register Committee sought further clarification from the agency (see minuted clarification) in order to understand the agency’s practice regarding the publication of reports and decision.

11. The agency explained (and presented) how the reports are being published on its website i.e. via links within a document uploaded on its website each time a new report is finalised. SAAHE further explained that the agency also publishes, the applications and self-assessment reports of higher education institutions undergoing review procedures. The agency is aware that the current way of publishing reports and decision is not ideal but explained that it was hesitant in making any changes during its review process.

12. The Register Committee sought further clarification on the lack of published reports in 2022 and

2023.

13. The agency explained that following a change in legislation, in 2021, all higher education institutions are required to undergo institutional accreditation and had to apply for such a review by the end of

2022. The agency clarified that while all 33 higher education institutions are have applied for an institutional accreditation, at the moment no procedure has yet been finalised. A pending decision by SAAHE’s Executive Board is expected in February

2024. (see minuted clarification)

14. Having considered the report and the clarification by the agency, the Committee concluded that despite the difficulty in accessing the links of published reports, that SAAHE has been publishing full reports and decisions on its website. The Register Committee underlined the recommendation by the panel to ensure the publishing of reports and decisions in a more accessible and informative way than the current practice.

15. The Register Committee noted that the agency is expected to inform the Register once it has concluded its first institutional accreditation procedure.

16. Having considered the review report and the clarification by the agency, the Register Committee was unable to concur with the panel’s judgement of partial compliance, and concluded that SAAHE complies with ESG 2.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student, stakeholder involvement
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee noted the panel’s concerns in terms of a lack of student perspective in the Executive Board of the agency. While the agency has two nominated student representatives in the Executive Board, neither one is a student or a recent graduate of a higher education institution.

18. Furthermore, the Committee noted the unrealistic requirements for one of the two student representatives to hold a third-level university degree and have at least 15 years of academic or professional experience.

19. Considering the lack of diverse stakeholder representation within the governance of the agency i.e., the limiting conditions in allowing the representation of a student or employer perspective the Register Committee could not follow the panel’s judgement of compliance and found that SAAHE complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	ministry involvement, organisational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. The Register Committee noted the panel’s analysis that the members of the Executive Board, of the Board of Appeal, the agency’s auditor and the Head of Office are all appointed by the Ministry (following a public selection procedure).

21. The Committee further noted the panel’s concerns regarding a high involvement of the minister in oversight of the agency i.e, in appointing the Chair of the Executive Board, in maintaining authority to dismiss the Chair and all members of the Executive Board (if there are any infringements of legislation or internal rules of the agency).

22. Taking into consideration the panel’s analysis, the Register Committee expressed its concern that the organisational independence of the agency is constrained by its close link and dependency on the Ministry. The Committee underlined the panel’s recommendation to ensure that the agency becomes fully independent and is able to act autonomously without any influence from the Ministry or other authorities. The Register Committee concurred with the panel that SAAHE complies only partially with ESG 3.3.”

Full decision: see agency register entry