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 formal complaints procedures
Panel conclusion	Partial compliance
Clarification request(s)	Panel (20/04/2025)
RC decision	Compliance

“In its analysis the panel found that the procedures on appeals against decisions are well designed but noted that the agency “lacked a solid and formal comprehensive complaints procedure, even if some elements of complaints-handling are there and informal handling of complaints by NVAO normally suffices”.The Register Committee sought further clarification from the panel concerning the extent to which the ability of NVAO to handle complaints might be affected.The panel explained in its response letter that the comments to NVAO were intended to highlight that the complaints procedure could be more clearly defined and communicated. The panel also learned that NVAO took the panel’s recommendation following the review and developed a comprehensive complaints procedure.The panel confirmed that NVAO’s regulations on governing principles include indications to both complaints and “remarks”. Stakeholders, such as panel members, staff or students, may report to NVAO matters arising during the assessment process that could affect the independence of the assessment.The Register Committee noted that NVAO’s system of appeals is well developed and that the review panel was satisfied with NVAO’s processes for handling complaints.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	Publishing of the criteria for international institutional accreditation
Panel conclusion	Partial compliance
Clarification request(s)	Panel (20/04/2025)
RC decision	Compliance

“The review panel noted that AQAS's criteria for international institutional accreditation were not published at the time of the review. The Register Committee took note of AQAS' statement on the review report and that AQAS now published the criteria for international institutional accreditation on its website. The Register Committee further noted that AQAS published the criteria without the additional “indicators”, which illustrates what is covered by a criterion. The Committee sought and received clarification by the review panel as to whether it considered publication without the “indicators” as sufficient. The Register Committee took note of the explanation that due to plagiarism and copyright infringements experienced in the past, AQAS published the criteria without additional, detailed material, while the “indicators” were made available to institutions applying for accreditation.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	distinction between accreditation and consultation not fully publicly documented
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“When confirming eligibility of the application, the Register Committee requested AQAS to clarify the relation between AQAS e.V. and AQAS ARCH, as well as the separation of external quality assurance procedures from consultancy services. The Register Committee took note of the clarification that AQAS ARCH did not engage in any activities within the scope of the ESG, but was engaging only in consultancy and project work, and welcomed the clarity provided. The Register Committee further welcomed AQAS' clear statement that it agreed “that the work of an accreditation agency in a particular procedure, be it programme or institutional accreditation, is incompatible with a preceding (or current) consultancy at the same university” and that “this incompatibility naturally includes organisations which are connected operationally with the agency” (statement on the review report); consequently, “AQAS e.V. cannot accredit the same organisation that received consultancy services through AQAS ARCH GmbH” (idem). The review panel, however, noted that these principles do not seem to be clearly documented in a published official policy document of AQAS and thus recommended that “AQAS should, in form of the formal resolution, define the distinction between accreditation and consultation, between ESG and non-ESG activities and between AQAS and AQAS ARCH” (review report, p. 12).

The Register Committee concluded that AQAS was able to explain that it appropriately separates its different areas of activity, while the details and consequences of this separation are not yet fully publicly documented.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	systematic approach to analyses and publishing
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“When AQAS last had its registration renewed, the publication of thematic analyses was flagged. Considering the review report, the Register Committee concluded that AQAS carried out a number of relevant internal analyses and produced relevant reports, e.g. the overarching report produced based on its accreditations in Moldova. These were, however, carried out on an ad-hoc basis, internal and not published as required by the standard. In its statement on the review report, AQAS explained that it had published a first set of thematic analyses on its website. While the Register Committee welcomed the efforts taken to date, it was not yet possible to conclude whether thematic analyses are produced regularly.”

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	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of QA and consultancy activities
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that AQU carried out one training activity in

2011. The review panel found that such activities should be considered as consultancy /support activities and that they should be differentiated more cautiously from the quality assurance activities which are provided by AQU Catalunya. (Review report, pg. 18).The Register Committee concurred with the panel that such consultancy activities should be clearly separated from external QA activities, in particular when those activities are carried out for the same higher education institution. The Committee drew AQU's attention to the guiding principles set out in Annex 5 to the Policy on the Use and Interpretation of the ESG and underlined that AQU is expected to make a substantive change report should it resume the same or similar consultancy-type activities offered to higher education institution.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.3 Independence
Keywords	organisational independence (overlap in the composition of the agency’s different bodies)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged for attention the independence of AQU from both government and higher education institutions. The panel found that the new legal framework (AQU Catalunya Bill adopted in 2015) has increased the agency's independence, whereby the government is no longer directly involved in the appointment of senior staff members in the agency.In its statement to the review report, the agency explained that the representation of higher education institutions was in line with existing legislation and that the role of the Governing Board is separated from the committees dealing with evaluation results. The agency further emphasised that the current composition does not allow for a partisan decision to be made by any stakeholder group and argued that the panel's concerns were based on conjecture and not evidence.The Register Committee noted the review panel’s concerns with regard to the lack of a clear separation between the composition of subject-specific committees and review panels that implement and monitor the procedures, which might create unwanted and unintended interference between the different roles. AQU stressed in its statement to the review report that this practice in fact ensures greater consistency in the application of the review criteria and since the decisions are made collectively the agency considers there is no undue influence.The Register Committee noted the agency’s clarifications. While it found that the flag on the independence of the Governing Board was largely addressed, the Committee underlined the concerns of the panel with regard to the overlap in the composition of the agency’s different bodies.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	lack of transparency in criteria for awarding the premium seal
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the decision of renewal of FIBAA’s registration, the Register Committee flagged for attention the lack of transparency in the agency’s criteria for awarding the “FIBAA Premium” seal to accredited programmes.The panel noted that FIBAA has made improvements to the transparency of its procedure, including to the criteria for awarding the premium seal. The panel, however, underlined that the weighing of the criteria is not sufficiently transparent as this information it is not made accessible for external parties (in particular to higher education institutions).

In its statement to the review report the agency stated that weighing for the criteria for awarding the premium seal (along with the other criteria) are published on the homepage of FIBAA. The Register Committee was able to verify this information and therefore concluded that the agency has addressed the flag. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Inconsistency in preparation of reports; publication of programme accreditation reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that the practice of sending review reports to higher education institutions for approval after decisions have been made should be reconsidered as this is not standard practice. To ensure consistency in the preparation of reports, the panel underlined the need for clearer manuals. The panel also referred to the results of an analysis carried out by the Accreditation Council, which showed that a number of programme accreditation reports have not been published by FIBAA. The Register Committee noted the intention of FIBAA to improve its practice of publishing reports and considered that improvements have not yet been externally reviewed.”

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	Lack of impartiality in the appeals process; lack of clear complaints procedures.
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel learned from its discussion with the agency that higher education institutions can point out faults in the procedure of the review in their statement to the review report. While higher education institutions are given the possibility to make a statement on the review report the panel underlined that there was not a clear indication on whether higher education institutions can issue a complaint regarding the course of the procedure. In its statement on the review report the agency stated the appeal procedure has been published on its website and also included in its quality management handbook. According to the procedure, once the appeal is lodged by a higher education institution it will be passed on – after consultation with the review panel – to the responsible Committee who can decide on whether to allow the appeal to go forth. In case this is granted the appeal will be submitted to the FIBAA Appeal’s Committee for examination. The Register Committee considered that the current procedure, whereby the Committee that issued the initial decision decides on whether the appeal of that institution will be passed to the Appeals Committee, might affect the impartiality of the process. The Register Committee further found the procedure to be 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.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	Systematic approach to analyses
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“When FIBAA ‘s registration was last renewed, the Register Committee flagged for attention the establishment of a systematic analyses of FIBAA's overarching reflections and observations from its accreditation, evaluation and audit activities. The panel showed in its analysis that FIBAA initiated a regular collection of information on the outcomes of the agency’s processes, such as conditions formulated, feedback from workshops and from staff. The findings are presented in FIBAA’s newsletters, workshop articles and academic articles. While the review panel noted an increase in the analytical publications prepared by the agency, the panel also recommended that such publications are extended so as to also cover fields of activity beyond programme and system accreditation. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.1 Consideration of internal quality assurance
Keywords	Part 1 reflected in ANQA’s criteria
Panel conclusion	Full compliance
Clarification request(s)	Panel (20/04/2025)
RC decision	Compliance

“The review panel provided a mapping table between ANQA's criteria (for institutional accreditation and for programme accreditation) and Part 1 of the ESG. The Register Committee requested the panel to elaborate on its analysis and findings as to how the different standards of ESG Part 1 are reflected in ANQA's criteria. The Committee appreciated the explanations provided, noted that the panel had reviewed ANQA's institutional accreditation reports and came to the conclusion that all standards were reflected in the same measure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	follow up (ineffective and not reviewed by the panel); implementation of programme accreditation was not analysed by the panel
Panel conclusion	Full compliance
Clarification request(s)	Panel (20/04/2025)
RC decision	Partial compliance

“The panel noted that it did not analyse the effectiveness of the monitoring process, normally taking place two years after accreditation, since it had not yet been implemented. The Register Committee sought and received clarification from the panel on the 6-monthly follow-up processes after conditional accreditations. The Committee understood that the panel did not consider the 6-monthly follow-up effective and, hence, recommended revisiting the 6-month period. The Register Committee further sought clarification from the panel concerning the programme accreditation process, since only pilot accreditations had been carried out so far. While the panel clarified that it had analysed how ANQA took into account the lessons learned from the pilots, it had not analysed the implementation of the pilots. While the Committee considered that the review report demonstrates that ANQA's process for programme accreditation includes the features required by the standard in theory, no statement could be made on actual practice at this point. One of the two follow-up processes appears to be considered ineffective by the panel, the other follow-up process was not reviewed by the panel and the implementation of programme accreditation was not analysed by the panel.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	criteria not published fully
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel noted that ANQA's evaluation protocols, containing additional details about its standards, and the decision rules, used by the Accreditation Committee to differentiate their different possible accreditation decisions, are not published; the panel recommended that they be published.”

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 (20/04/2025)
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	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Inadequate appeals process
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel noted that – while being clearly defined and published – “the process of appeals established by ANQA cannot be considered an appeal, but a second opportunity giving the institution time to improve its situation and then undergo one more evaluation and receive a new decision in a short period of time”. The Register Committee concurred with the panel that the ANQA process differs substantially from the common understanding of an “appeal” and considered that it was doubtful whether the process was fit to address the type of issues it is expected to address, i.e. “adversely assessed criteria and/or alleged procedural violations against the institution”. The Register Committee considered that the standard does not prescribe a specific appeals procedure and that the review report identified serious shortcomings in the appeals procedure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	cosultancy/training to HEIs
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In connection with ANQA's budget, the panel noted that ANQA is carrying out consultancy activities on a minor scale. As it was not specifically analysed in the report, the Register Committee sought clarification from the panel on potential conflicts of interest arising from consultancy work. The Register Committee understood from the panel's response that ANQA provides collective training opportunities to Armenian higher education institutions, but does not render services to individual institutions, and that, therefore, there is no specific potential for conflicts of interest.The Register Committee, however, underlined that in case ANQA provides consultancy to individual institutions in the future it would have to implement appropriate policies to prevent that ANQA accredits the same institution to which it rendered consultancy services.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.3 Independence
Keywords	operational independence
Panel conclusion	Full compliance
Clarification request(s)	Panel (20/04/2025)
RC decision	Compliance

“The Register Committee sought and received clarification from the panel as regards ANQA's independence in defining its own procedures and methods. The Committee appreciated the panel's explanation as to how ANQA developed its Manual independently.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to system-wide analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ In its decision for inclusion, the Register Committee flagged QANU’s systematic approach to system-wide analyses. While QANU has not produced thematic analysis in its strict sense, the panel noted that the agency published reports at the request of research universities and state of the art reports for programmes that are assessed in clusters. The panel noted that QANU did not have a systematic approach towards producing thematic analysis and that the agency views this activity to remain mainly in the responsibility of NVAO. In its additional representation, QANU's underlined that its core activity is to conduct assessments, and due to its limited size, financial resources and scope QANU’s ability to conduct thematic analyses in a systematic way was limited. The Board of QANU had nevertheless considered the recommendations of the panel and stated that it would adapt its approach to thematic analysis.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	follow up procedure for programmes accredited without condition
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In the review report (p. 28) the panel stated that if a programme is accredited with conditions, the programme is expected to submit an interim report on how it has fulfilled these conditions. The Register Committee was unclear if a follow-up is also implemented for programmes accredited without conditions and have therefore requested the panel to clarify this matter.The panel (response letter of 28/05/2017) stated that higher education institutions are expected to inform FINEEC of significant changes related to their programme organisation, implementation and development. The panel found no other evidence of a follow-procedure that would apply to programmes accredited without conditions. The Register Committee considered the design of the follow-up of programmes accredited without conditions to be minimal but nevertheless appropriate.”

Full decision: see agency register entry