Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	2.7 Complaints and appeals
Keywords	Absence of a complaints procedure
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While the Register Committee noted that appeals’ procedures are well defined, accessible and handled adequately, the Register Committee noted that SKVC’s methodologies and principles do not cover complaints.The panel did not find how higher education institutions can raise issues of concerns or how they are handled by SKVC in a professional and consistent manner.The Committee underlined the recommendation of the panel for the development of a specific complaints procedure that should be made easily accessible to higher education institutions.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Absence of appeals procedure for initial accreditation and inadequate body to address the appeal.
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel considered that the body deciding on appeals should not be identical to the body that made the decision being appealed, but identified an overlap in the case of ASHE. It further noted that there is no appeals procedure (internal to ASHE) for initial accreditation, but only a possibility to appeal decisions in a court.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Conflict of interest: same members in the Appeals Commission and Accreditation Council
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that IAAR established a commission to handle appeals and complaints in late 2015 that consists of a number of members representing national representatives of employer bodies. The review panel formed the view that the membership of the Commission was not well aligned with its role and purpose, having the focus almost exclusively on employer representatives. The panel further added the potential conflict of interest considering the overlapping membership of the Appeals Commission that of the Accreditation Council. The panel recommended the broadening of the Commission’s membership and a separation from the members of the Accreditation Council”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	No possibility to appeal in cases where the review does not end in a judgment
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The Committee noted that for the accreditation procedures the appeals procedure is regulated in the statute and in the board of complaints’ rules of procedure but that there is no clearly defined appeals procedure for evaluations and other external QA procedures not resulting in a formal decisionIn the additional representation, ASIIN explained that it had clarified that its regular complaints procedures, applicable to accreditation procedures so far, is also applied to certification procedures and in type-1 evaluation procedures. The Register Committee confirmed that this is indeed clarified in public documents.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	03/12/2016
Standard	2.7 Complaints and appeals
Keywords	Limited scope of complaints
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that AAQ and SAR provide a formalised complaints process for higher education institutions. The external review panel was, however, “more critical of the limited subject scope of the complaints procedure because, (…), higher education institutions can currently only complain about SAR’s decisions and not about possible errors in the implementation of the procedure” (p. 41).”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.7 Complaints and appeals
Keywords	Definition of terms; Complaints; Appeals
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. The Register Committee noted that the Complaints and Appeals Policy is detailed, covering the potential causes for a complaint or an appeal and it is easily accessible on the agency’s website. However, the Committee noted the panel’s concerns on the need to clarify the terms ‘complaints’ and ‘appeals’.

16. The Committee, therefore, followed the panel’s conclusion that the agency continues to comply with the standard. The Committee, however, shared the panel’s view that the agency should clarify what is meant by the terms ‘complaints’ and ‘appeals’ in all its documents, including the name of the ‘Complaints Commission’.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	30/06/2023
Standard	2.7 Complaints and appeals
Keywords	Lack of formal complaints procedure
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“Partially compliant with the standard due to the lack of formal complaints’ procedure– the higher education institutions could express their dissatisfaction with the process only informally throughout the review process. The agency is yet to establish a clear

complaints procedure that is known by higher education institutions”

Full decision: see agency register entry

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	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.7 Complaints and appeals
Keywords	internal appeals system
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“10. In its last decision, the Register Committee raised concerns regarding the lack of an internal appeals system within the agency and as a result found the agency to be partially compliant with the standard.

11. The Register Committee noted that since the last review of ACCUA the agency has established a separate body within the agency responsible for appeals. Furthermore, the panel noted that the appeals procedure is clear, publicly available and ensures impartiality in decision-making by the Appeals Committee.

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

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee and limited coverage of appeals
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (07/12/2021)
RC decision	Compliance

“In its decision of rejection (of June 2020), the Register Committee noted that AKAST’s appeals and complaints procedure did not cover the peer institutional evaluation procedures and that the appeals were only considered by the same committee that also took the appealed decision. While AKAST agreed to revise its procedure and to establish a complaints committee consisting of independent members, the Register Committee remained unable to follow the panel’s judgment of compliance since the procedure was not yet in operation and the committee handling appeals has not been elected. 8. The panel notes that AKAST has now a revised complaints and appeals regulation and has elected a Complaints Committee at the AKAST General Meeting on 28/01/2021. In the description of the provisions for complaints (AKAST Complaints and Appeals Regulations as amended on 28/01/2021), the agency noted that the Complaints Committee’s statement is to be taken into account in the final decision of the Executive Board or the Accreditation Committee and that further details shall be regulated in the rules of procedure issued by the Complaints Committee and approved by the Executive Board.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	2.7 Complaints and appeals
Keywords	Board member in appeals committee, independence of decisions on appeals
Panel conclusion	Full compliance
Clarification request(s)	Panel (14/06/2022)
RC decision	Compliance

“28. In the last renewal of registration, HCERES was found to be only partially compliant with the standard since its appeals and complaints processes were only just set up and not yet reviewed by an external panel; a specific concern was whether the decision-making on appeals was fully independent from those in charge of the appealed report/decision.

29. The panel considered that HCERES' appeals and complaints processes were clearly defined and communicated. The panel noted that HCERES had not received appeals or complaints since 2016.

30. The panel clarified that it considered the appeals committee's composition suitable. While HCERES Board members indeed serve on the appeals committee, the Board does adopt neither evaluation reports nor accreditation decisions. In addition, one external expert is part of the committee.

31. The Register Committee agreed that the appeals committee was sufficiently independent given that the HCERES Board does not adopt the reports or decisions that are being appealed. The Committee therefore concurred with the panel's conclusion that HCERES complies with ESG 2.7.”

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 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	14/03/2022
Standard	2.7 Complaints and appeals
Keywords	requirement that appeals can be made against any report
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“25. The Committee underlined that any report is a formal outcome and thus needs to be open to appeal, even if it does not result in a yes/no decision.

26. In its additional representation, ZEvA clarified matters for evaluation reports. At the same time, it remained unclear whether and how institutions can appeal accreditation reports before submitting those to GAC. Even though GAC offers an appeals possibility, presumably GAC's process cannot fully investigate matters that are rooted in the report produced outside of GAC's direct control. Moreover, it would be unreasonable that institutions are forced to first submit to GAC a report against which they have strong objections before they can appeal against that report.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Impartiality in handling appeals (independence of the Appeals Committee). Coverage of all EQA activities by the appeals procedure
Panel conclusion	Full compliance
Clarification request(s)	Agency (20/04/2025)
RC decision	Partial compliance

“The Register Committee underlined that the current arrangements does not ensure an impartial process in AKAST’s approach of handling appeals, since the appeals are considered by the same committee that also takes the accreditation decisions and nominates the review panel members for the review. The Register Committee further noted that the appeals and complaints procedure only cover issues concerning two of AKAST’s activities and it does not address the agency’s peer institutional evaluation procedures. While AKAST has not yet carried out any such evaluation, the Register Committee underlines that, since the activity is on offer, the agency is expected to ensure that all corresponding procedures will be adequately updated, including the agency’s appeals and complaints procedure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.7 Complaints and appeals
Keywords	Implementation of an appeals process and information about the appeals committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ The Register Committee noted from the panel’s analysis that the agency’s appeals and complaints processes were not clearly defined. The panel stressed that as the agency moves towards an institutional accreditation process, it will need to reevaluate its current processes for both complaints and appeals.

The Committee further noted that the agency does not have a designated body to handle appeals, but that they are considered by the Council in consultation with the IEE Commission. In its additional representation, THEQC explained that it has developed and integrated the complaints process into its Feedback Management System. The Register Committee was able to verify that the new complaints process and form is easily accessible on THEQC’s website. With a view to appeals, the Register Committee welcomed the decision to establish a distinct Appeals Committee to handle appeals and took note of THEQC’s newly developed Directive of Complaints and Appeals. The Committee, however, noted that the Appeals Committee is not part of THEQC’s organisational chart and that no information is provided on the members of the Appeals Committee. The Register Committee asked the agency to elaborate on whether any other provisions have been added to its Complaints and Appeals regulation. The agency clarified in its response letter that the latest version of the Rules of Procedure of the Appeals Committee dated 19/05/2021was now in use and published on the agency’s website (only available in German) which include minor updates. The Register Committee noted that the additions to the updated procedure are in line with the expectation of the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	2.7 Complaints and appeals
Keywords	Scope of the appeals system, clarity, independent decision making body
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that MusiQuE’s appeals procedure only applies to the reviews that result in an accreditation decision, but does not cover the agency’s enhancement type of reviews. Since higher education institutions may have concerns related to the application of the criteria and the judgments also in the enhancement reports, these should equally be subject to appeal in line with the standard. During its site-visit the panel further learned that it is not always clear to stakeholders involved how a complaint will be approached and how exactly are responsibilities defined. The Register Committee noted that MusiQuE has an Appeals’ Committee, formed of one standing member and one individual appointed in response to each specific appeal. The panel remarked that the Board of MusiQuE is the decision-making body responsible for endorsing the judgement of the review team and also the body nominating the members of the Appeals’ Committee, which may raise a concern of potential conflict of interest. The Register Committee therefore underlined the panel’s recommendation of reviewing the procedure for appeals in order to guarantee a fair decision making and avoid such potential conflicts of interest. Considering the several above-mentioned issues the Register Committee could not follow the panel’s conclusion of (substantial) compliance but considered that MusiQuE complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	2.7 Complaints and appeals
Keywords	Absence of the body responsible for handling complaints (established in renewal)
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that QANU has revised its complaints and appeals procedure and established an independent committee to consider its appeals.The panel noted that institutions can now submit an appeal against all external quality assurance activities of QANU and the decisions are taken by an Appeals Committee, instead of QANU’s director.The panel’s analysis further show that QANU offers the possibility to institutions to express their dissatisfaction about the conduct of the external quality assurance activity carried out by QANU or misbehaviour of people acting on behalf of the agency. The agency has also established different processes in the handling of complaints i.e. if a complaint refers to the behaviour of a staff member of QANU this is processed by the director; if a complaint is about the director of the agency, the complaint is processed by the chair of the Board etc.Having considered the changes put in place by QANU since its last external review, the Register Committee was able to follow the panel’s judgement that QANU now complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee; Clarification of appeals’ procedure
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous decision for renewal, the Register Committee flagged for attention the appeals system, as the panel recommended that ACSUCYL should revise its appeals system so that a separate committee handles appeals. The external review panel confirmed in its external evaluation report that ACSUCYL established an independent body, the Guarantees Commission, that is responsible for examining appeals or complaints in areas where the agency is competent. For procedures where the final decision belongs to the University Council or Regional Ministry (i.e. verification/modification, accreditation renewal, evaluation to create, recognize, modify or withdraw university centres), the appeal is considered by the corresponding decision making body. ACSUCYL provides input into the consideration of these cases, but it does not decide. Within ACSUCYL, the request will be sent to the Guarantees Commission, which consults the relevant Assessment Commission, before preparing an answer. If the appeal is granted, ACSUCYL will be requested to review its earlier conclusion. The Register Committee underlined that ACSUCYL’s complaints policy should communicate better that higher education institutions have the possibility to raise matters about the conduct of the process or those carrying it out (i.e. complaints in the understanding of the ESG), even in such procedures where the final decision is taken by other bodies.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that appeals procedures are published together with every procedure on the agency’s website, except the independent accreditation at the institutional level. To date AKKORK has only received a complaint, but no appeals. The panel’s analysis show that AKKORK’s Appeals Committee involves members of the International Accreditation Council, the same body that is involved in the accreditation decision-making process in addition to the members of its Supervisory Board. The Register Committee underlined that in such cases the impartiality of the decision making in considering appeals is not ensured. In its further information to the review report, AKKORK stated that its regulation on appeals have been updated and that its new appeals body, appointed by AKKORK’s Supervisory Board, includes members from the agency’s partner organisations. In its additional representation the agency has further provided a link to its revised regulation on appeals. ”

Full decision: see agency register entry