Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In the last review of the agency the Register Committee flagged for attention the publication of reports for evaluation of study programmes and monitoring reports of study programmes, which then were only communicated to the interested party.The review panel found that Unibasq published all reports, except for the ex-ante accreditation reports on programmes that have not been successful.In its additional representation Unibasq confirmed that it does not publish reports for the from ex-ante accreditation, arguing that it would be confusingfor readers to find information on a study programme that will never exist. Unibasq did not express any intention to change this practice in future.The Register Committee underlined that all reports should be published as required by the standard. The Committee underlined that even if a study programme will not be offered it can be of interest for the public to know which concepts were denied accreditation and why. In particular, such information is important if the same programme applies for accreditation by another agency, which needs to be able to find out that it was earlier denied accreditation by another agency.As the flag was largely, but not fully, addressed the Register Committee did not concur with the review panel’s conclusion of compliance, but concluded that Unibasq still complies only partially with ESG 2.6”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.6 Reporting
Keywords	acessibility and user-friendliness of th website
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its initial application for inclusion the Register Committee flagged AQ Austria’s publication of external QA reviews, as at that time only a few reports have been published. In the 2019 external review of AQ Austria, the panel’s analysis show that the agency has since published in full all its accreditations and audits related to its activities in Austria and abroad. The panel further commented that AQ Austria’s website however needs to be further improved in terms of accessibility and user-friendliness and recommended that the agency develops a database of reports to make the results of its quality assurance activities more accessible to its stakeholders.While the Register Committee concluded that the agency has addressed its flag, the Committee further underlined the panel’s recommendation.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	2.6 Reporting
Keywords	Publication of initial accreditation reports, involvement of experts in preparing the reports, no fact-check verification process
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that CAQA does not publish initial accreditation reports of higher education institutions and their programmes since another accreditation review in these cases is carried out after one year. While the panel considered this approach to some extent justifiable, the Register Committee underlined that, according to the standard, reports by the experts should be published in full. This applies to all types of reports, whether part of an initial or follow-up process. The review panel also found that the current reporting arrangements limit substantially the input coming from academic experts, students and labour market representative. The findings of the panel also showed that NEAQA’s reports are not sent to the institutions concerned for a factual check before the final version is published.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2019
Standard	2.6 Reporting
Keywords	experts involvement in drafting the report
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous decision to renew registration the Register Committee flagged for attention ARACIS’s involvement of expert panels in drafting and agreeing upon the review report for institutional evaluations.

To address the flagged issues the panel noted that ARACIS decided to prepare a comprehensive synthetic report in which each of the expert panel members have a contribution. The panel also commented that separate reports from students and international evaluators are still a feature of the agency’s reporting arrangements.

While the Register Committee welcomed the panel's recommendations on improving the accessibility, storage, organisation and presentation of review decisions and reports on its website, it considered that ARACIS technically fulfilled the requirements of the standard by publishing the reports on the web. The Register Committee however noted that the full accessibility of reports remains an issue as long as some reports are published in an archived or scanned format.

The Register Committee concluded that ARACIS largely addressed the flag and was therefore unable to concur with the review panel’s judgement of partial compliance, but concluded that ARACIS complies with standard 2.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	2.6 Reporting
Keywords	no guarantee that all reports are published
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (17/05/2019)
RC decision	Partial compliance

“The Register Committee noted that the reports and the formal accreditation decisions based on the assessment of degree programmes are published only on the website of NVAO; NQA does not publish these reports but provides a list of reviewed institutions. In its additional representation the agency stated that it has initiated a consultation with NVAO considering the possibility to create an online search-option linking NVAO’s database of degree assessment programme reports and decisions to the website of NQA. The agency added that its international assessments are also published by NVAO and that a web-link has been already added in the NQA website to the NVAO database. Concerning its publication policy, the agency reasserted that the owner of reports is the higher education institutions and it is up to the institution to use the assessment report for an accreditation by NVAO. If the institution decides to hold on to the report, no decision on accreditation is taken and therefore the report will not be published. While the Register Committee welcomed NQA’s intention to integrate a searchable database on its website, the Committee underlined that the agency itself bears the responsibility to follow the ESG and therefore needs to ensure (e.g. contractually) that it is in a position to publish all reports of its external quality assurance procedures.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/06/2018
Standard	2.6 Reporting
Keywords	No publication of consultative visitation reports.
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (02/06/2018)
RC decision	Partial compliance

“The Register Committee understood from the panel's report that all reports except those so-called “consultative visitations” are made accessible on the EAEVE website. The Register Committee sought clarification from the panel on the nature of consultative visitations. Based on the report and the panel's additional clarification the Committee understood that “consultative visitations” should be regarded as an additional step as part of the full/regular visitation. As EAEVE membership is an eligibility requirement and a “consultative visitation” is a prerequisite for non-EU establishments to become members, it is thus a prerequisite step for non-EU establishments seeking EAEVE accreditation. The Register Committee therefore considered that these reports are a part of the reasons underlying the final accreditation decision following the full visitation.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	11/09/2018
Standard	2.6 Reporting
Keywords	No publication of initial reports and only publication of summary reports for programme accreditation
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (09/06/2018)
RC decision	Partial compliance

“The panel stated that ANECA does not publish initial review reports prepared by the assessment panels (of 50-60 page long) and that the agency only publishes a final summary report (of 10 pages). he panel stated that publication of summary reports from programme accreditations is a national characteristic and that the panel confirmed during interviews that the AUDIT and DOCENTIA activities include full reports when published. The Register Committee could only verify the panel’s statement regarding the full publication of institutional evaluation reports for DOCENTIA, but not in case of AUDIT procedures. While the Register Committee understands the usefulness of providing summary reports, the Committee saw no reasons why ANECA would not be able to also publish the full results for all its external quality assurance procedures.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	2.6 Reporting
Keywords	Readability and publication of reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged for attention the readability of NVAO’s published reports considering its defined target audience (decision of renewal of 1/12/2012).The panel’s analysis show that NVAO does not have specific guidelines for organizing the content of the report. Whilst these reports can be considered clear by an expert readership, readability is generally hindered by the heterogeneity of style, which is less “user friendly” to a large public, in particular by students and employers.The Committee underlined the recommendation of the panel that NVAO should analyse the actual and potential readership of its reports and their needs, and to develop new means to reach its target readership among students and employers.The panel also noted that at least 10 percent of the reports and decisions made in 2016 were not publicly available. The agency explained that the publication of reports was delayed due to a temporary lack of personnel and that this issue has been fixed. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	2.6 Reporting
Keywords	Publication of ex-ante reports with negative decision
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its last renewal decision (of 1/12/2012), the Register Committee flagged for attention AQU’s policy of not publishing negative validation reports, as well as the readability of reports for their target audience, in particular students and potential students.The Register Committee noted that AQU has made efforts to offer consistent, structured, and helpful reports of its quality assurance activities to a larger public through a number of portals with outcomes translated in Spanish and English.The Register Committee further noted that AQU publishes all reports except those from ex-ante evaluations that result in a negative accreditation decision.AQU explained that publishing these reports would have a negative impact on universities and society. In its statement to the review report, AQU further added that, since these programmes can not be offered by universities, it would be confusing for readers to find information on a course that will never exist.The Register Committee considered the agency’s explanations, but underlined that according to its Policy on the Use and Interpretation of the ESG (p. 7) all reports should be published, including any formal decisions based on these reports, irrespective of the outcomes of such reports.While the Register Committee acknowledged AQU’s efforts to improve the readability and accessibility of reports for its target audience the Committee concluded that the flag has only been partially addressed, since AQU still does not publish all reports. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Publication of the reports of the pilot programme accreditations
Panel conclusion	Full compliance
Clarification request(s)	Panel (21/04/2025)
RC decision	Partial compliance

“The Register Committee noted that the reports of the pilot programme accreditations were not published on ANQA's website. The Committee sought clarification from the panel as to how it viewed the non-publication of those reports. The review panel noted that these pilots “were organised under supervision of other EQAR registered QA agencies and therefore the responsibility of these other QA agencies”, without, however, mentioning the agencies and addressing whether or not the reports were published by them. The Register Committee, however, noted that both ANQA's self-evaluation report and the external review report repeatedly state that ANQA had implemented the pilot accreditations. The Committee was therefore not persuaded by the panel's point of view that ANQA had no responsibility for the publication of these reports.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Publication of reports of initial accreditation
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision to admit ASHE to the Register, the Register Committee had flagged the accessibility and readability of ASHE reports. The Committee noted that ASHE took several steps to enhance the accessibility and readability of its report during the past five years, including the publication of summary reports. The Register Committee therefore concluded that the flag has been addressed. The review panel noted that reports of initial accreditation procedures are not published. The review panel considered that these reports “serve as a base for the ministerial decision to admit the HEI or programme to be established and that therefore these reports do not carry information directly addressed to the general public” (report p. 40) and that in case of a negative decision “the HEI or programme concerned will not be launched and so there is no tangible public interest in reading these reports” (idem). The Register Committee, however, considered that the standard clearly requires the publication of all external quality assurance reports. Even if the reports' addressee is the ministry, there is a clear public interest in the basis of ministerial decisions being public and transparent.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Publication of negative reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that IQAA’s regulations regarding the publication of results from accreditation reviews were not entirely clear and consistent. Whereas some provisions stated that all reports and decisions would be published, others stated that only reviews leading to a positive decision were being published. The panel found that in case of a negative decision on accreditation, neither reports nor outcomes are published. In addition, the panel noted that discrepancies exist between the information available on the Russian and English languages websites. In its statement on the review report, the agency announced that it had recently published all expert review reports and decisions of the Accreditation Council and that it had updated its regulations to explicitly outline that all review reports are published irrespective of their outcomes. The Register Committee could, however, not verify the statement of the agency that also negative decisions would be published, using the link provided.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	03/12/2016
Standard	2.6 Reporting
Keywords	Publication of negative reports
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (21/04/2025)
RC decision	Partial compliance

“The external review report pointed out that, based on the legal framework in Switzerland, AAQ considered that the publication of the full accreditation report, even with a positive result, would require the consent of the higher education institution concerned.The report considered that – thus far – AAQ was able to agree upon the publication of reports with the higher education institutions on an individual case basis, through corresponding passage in the contracts; it had the express support of the Board of swissuniversities in doing so.

The report further notes that “AAQ currently has no option to effect the publication of negative decisions” (p. 37-38).The external review panel took the view that nothing stood in the way of publishing all reports in full, given that the applicable law included an indirect reference to the ESG and, at the same time, no explicit provision that forbids the publication of full reports.[...]. The panel noted (see letter of 3/11/16) that the possibility of a report not being published was “at the moment a mere theoretical one”, and that AAQ seemed to “avoid discussions of legal theory as long as all works well”. The Register Committee considered that in practice all positive reports are published. It welcomed the agreement of swissuniversities to that effect, while noting that it constitutes a political and not a legally binding commitment.Considering the panel report, clarification and – most importantly – AAQ's own statement, the Register Committee found no evidence that AAQ would interpret the law as suggested by the panel, or refuse to enter a contract with a higher education institution that does not agree to the publication of the report.The Register Committee therefore concluded that there is a possibility – even though theoretical – that a higher education institution may refuse the publication of the accreditation report.

The Committee also noted that the existing arrangements do not affect procedures resulting in a negative decision.

The Register Committee therefore concluded that AAQ’s practice did not change compared to the time when it was admitted (then as OAQ) to the Register, and the issue of publication of reports was flagged for future attention.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.6 Reporting
Keywords	ex-post accreditation, Technical Committee, experts reports
Panel conclusion	Compliance
Clarification request(s)	Panel (13/02/2023)
RC decision	Partial compliance

“10. The Register Committee noted that the responsibility for the preparation of the external review reports for the monitoring and ex-post accreditation of study programmes is with the Technical Committees.

11. The Register Committee noted that the experts’ site-visit reports were not part of the final external review report and they were only available for the analysis of the Technical Committees. The Register Committee could not understand why the experts reports (in the case of the monitoring and ex-post accreditation of study programmes) is not published as well and therefore asked the panel for further clarification.

12. The panel explained (see minuted clarification 2023-02-13) that the practice of having a committee develop these reports is common among all Spanish QA agencies and it ensures the consistency of reports.

13. The Register Committee further asked the panel to clarify the forms of factual and non-factual allegations made by institutions on the reports of the Technical Committees. The panel explained (see minuted clarification) that the allegations have always been focused on the technical part of the reports (factual comments). However, the panel added that the agency should clearly differentiate within its procedure that the allegations deal only with factual errors and do not address diverging views and opinions on the statements and assessments taken in the report.

14. While the Register Committee welcomed the use of a Technical Committee to ensure consistency, the Register Committee could not follow the reasoning of not including or separately publishing such reports (i.e. as an annex). The Register Committee underlined that it can be of interest for the public to know the basis on which the final reports are being developed. In particular, such information is important to ensure the transparency in the Technical Committee’s decision making.

15. The Register Committee therefore could not follow the panel’s conclusion on the compliance with the standard, but concluded that ACCUEE complies only partially with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	2.6 Reporting
Keywords	readability of reports, delay in publication
Panel conclusion	Compliance
Clarification request(s)	Panel (10/02/2023)
RC decision	Compliance

“18. In its previous renewal decision, the Register Committee stressed the delay in NVAO’s publication of reports and noted issues related to the readability of reports.

19. The panel’s findings show that NVAO has since its last review introduced instructions and templates for reporting and that the readability of submitted initial assessment reports is also checked by NVAO. The panel further confirmed that the publication of reports was done without any more significant delays, but suggested setting up an automatic uploading system of NVAO-NL reports (as it is done for NVAO-FL).

20. The Register Committee welcomed the improvements in the agency’s reporting and concurred with the panel’s conclusion that NVAO now complies with the standard 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	2.6 Reporting
Keywords	reports, publication
Panel conclusion	Compliance
Clarification request(s)	Panel (17/02/2023)
RC decision	Partial compliance

“14. The panel reported that all reports from programme evaluations were now published on ANECA’s website in a more extensive format; for SIC, AUDIT and AUDIT INTERNATIONAL the agency published the full expert reports.

17. The panel further explained (see clarification) that in programme evaluations the external review reports are prepared by ANECA’s Committees, based on the initial experts’ reports and following the multiple-stage process that is described in the review report. For SIC, AUDIT and AUDIT international procedures the panel noted that ANECA did not have the same practice and specific committees preparing external review reports, but instead considered the full experts’ reports as final report.

18. Having thus considered the report and the clarification, the Committee concluded that the two step approach, where the external review reports are prepared by internal specialised committees, might mean that the full content of the reports prepared by the panel would not be publicly known. Further, the Committee could not, based on the evidence provided by the panel, identify "before" and "after" examples of programme evaluation reports, and hence understand what "more extensive" might mean in practice, and was therefore unable to concur with the panel assessment of compliance.

19. The Committee therefore concluded that ANECA is not living up to the intentions of standard 2.6 which states that "full reports by the experts should be published”. Therefore, the Register Committee concluded that ANECA only partially complies with ESG 2.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	2.6 Reporting
Keywords	Publication of Accreditation Decisions
Panel conclusion	Compliance
Clarification request(s)	Panel (15/02/2023)
RC decision	Partial compliance

“17. The Register Committee noted that the decisions of the Quality Assurance & Accreditation Committee’s (QAAC) are published only in the form of the accreditation period being presented on the web page listing accredited programmes (https://cce-europe.org/index.php/accredited-institutions.html). The list contains links to the expert review reports, but not to the QAAC decision as a separate document or similar.

18. The standard requires that “if the agency takes any formal decision based on the reports, the decision should be published together with the report”.The Register Committee assumed that a written record of the QAAC decision presumably exists in some form, either as a document sent to the accredited programme or as section in the QAAC minutes. The review panel clarified that it was not aware of the QAAC decision being available a separate document.

19. In its additional representation the agency stated that what is published on its website i.e., the dates of when the institution was first accredited, the most recent decision and the date of when the accreditation runs out represent, next to the generic statement on its website - that a programme meets ECCE’s criteria and standards for accredited status - represents its decision.

20. The Register Committee underlined that the standard aims to ensure reliable documentation and transparency of the agency's outcomes and the mere publication of the date of the accreditation does not suffice.

21. The Committee further disagrees with the agency’s claim that its objection are technical in nature. The Committee emphasised that QAAC decisions are not recorded in writing at all (beyond the dates cited on the web page) and that ECCE does not provide any information to the public on e.g., when such a decision was taken, the basis of QAAC’s decision making, the rationale for QAAC in agreeing/disagreeing with the findings of the panel or any recording of a possible conflict of interests with the institution applying for ECCE accreditation.

22. The Register Committee therefore could not concur with the panel’s conclusion that ECCE complies with the standard, but found ECCE to be only partially compliant.”

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	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.6 Reporting
Keywords	publication of decisions
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“23. The panel’s analysis shows that AIC does publish full reports of the experts panels for its procedures ‘Accreditation of higher education institution’, ‘Assessment and accreditation of a study field’, ‘Licensing of study programme’ and ‘Accreditation of study programmes abroad’.

24. The Register Committee further noted however, that these published reports and the decision letter do not reflect the additional elements which have been provided and taken into consideration after the site visit nor the additional tasks given to the higher education institution.

25. The Register Committee could not find any new supporting evidence to AIC’s position in the additional representation. Both from the panel’s report and the AIC website, it was clear that only the duration of accreditation terms is published, while the full decisions are not published together with the reports.

26. The Register Committee therefore concludes that there is no sufficient transparency in AIC’s reporting processes and therefore concurs with the panel’s conclusion of partial compliance.”

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