Database of Precedents
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3.3 Independence – ACCUEE – Partial compliance (2023) regional government representation, Governing Board, Technical Committee
ACCUEE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 3.3 Independence Keywords regional government representation, Governing Board, Technical Committee Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “23. In regards to organisational independence, the Register Committee noted that the Governing Board, the body responsible for the approval of accreditation methodologies and criteria, has a strong regional government representation, with one third of the members nominated by the regional ministry The Committee further noted that the regional ministry is also responsible in appointing the president and vice-president of the Governing Board.
24. The Committee further noted that the regional government directly appoints the Director of the agency. The Committee found this problematic given the Director’s responsibility in ensuring the independent operations of the agency and in chairing all of the agency’s Technical Committees for ex-post accreditation of study programmes.
25. The Committee further noted that the agency is limited in its recruitment processes as this responsibility lies with the regional government (review report, p. 27).
26. Given the close link to the regional government, the Committee shares the panel’s view that ACCUEE should (in consultation with the regional Government) amend the current processes regarding the appointment of the Director as well as the legal frameworks definition on the composition and the proportion of governmental members in the Governing Board and ensure the recruitment processes are under the competency of the agency.
27. The Register Committee welcomed ACCUEE’s plans for addressing the panel’s concerns, but the Committee underlined that these changes are yet to be fully enacted. The Register Committee therefore concurred with the panel that ACCUEE only partially complies with ESG 3.3.”
Full decision: see agency register entry
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2.3 Implementing processes – HAKA – Compliance (2023) study programme groups
HAKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 30/06/2023 Standard 2.3 Implementing processes Keywords study programme groups Panel conclusion Compliance Clarification request(s) – RC decision Compliance “The Register Committee found the difference between the initial and re-assessments of study programme groups on the one hand and the phasing out of assessments of study programme groups on the other hand not to be completely clear.
The agency explained (see clarification of 2023-06-06) that the initial and re-assessment procedures remain compulsory for the opening of any new study programme groups. For existing study programme groups that have gone successfully through multiple assessment processes, the assessments of individual study programme groups are being phased out for a sample of these programmes, within the new model for institutional accreditations.
Having considered the agency’s explanation and the implementation of the new procedures, the Register Committee concurs with the panel’s conclusion of compliance.”
Full decision: see agency register entry
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3.5 Resources – HAKA – Compliance (2023) state budget
HAKA
Application Renewal Review Targeted, coordinated by ENQA Decision of 30/06/2023 Standard 3.5 Resources Keywords state budget Panel conclusion Full compliance Clarification request(s) Agency (06/06/2023)
RC decision Compliance “The Register Committee noted that the proportion of HAKA’s activities financed through state budget has been decreasing. This is caused by the fact that HAKA has taken on activities for other education levels/types not falling under the ESG, which are financed through projects.
The Register Committee understood from the agency’s clarification (see minuted response of 2023-06-06) that the financial concerns do not affect the agency’s ability to carry out its regular external QA activities.
The Register Committee therefore concluded that the agency continues to comply with ESG 3.5.”
Full decision: see agency register entry
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2.1 Consideration of internal quality assurance – NVAO – Compliance (2023) coverage of ESG Part1
NVAO
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.1 Consideration of internal quality assurance Keywords coverage of ESG Part1 Panel conclusion Compliance Clarification request(s) Panel (10/02/2023)
RC decision Compliance “11. The Register Committee noted that a protocol for the assessment of transnational education in the Netherlands (NL) came into effect in
2018. The Committee however could not find any information on whether NVAO-NL has addressed the standards of ESG Part 1 (ESG 1.1-ESG 1.10) in its new protocol and has therefore sought further clarification from the panel.
12. The panel explained (see clarification letter) that a transnational education programme may be provided on the condition that the programme abroad is equal to the one accredited in the Netherlands. This may only concern programmes that have already been accredited in the Netherlands. Given this condition, the review panel explained that the study programmes abroad follow the same accreditation protocol as the programmes accredited in the Netherlands.
13. The Register Committee understands that ESG Part 1 has been verified by the panel for the renewed 2018 NVAO-NL assessment framework and noted that a clear link between the institution’s internal and the NVAO’s external quality assurance procedures was ensured.
14. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standards 2.1.”
Full decision: see agency register entry
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2.5 Criteria for outcomes – NVAO – Compliance (2023) deviation from the outcome of a panel’s report
NVAO
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.5 Criteria for outcomes Keywords deviation from the outcome of a panel’s report Panel conclusion Compliance Clarification request(s) Panel (10/02/2023)
RC decision Compliance “15. The Register Committee noted that NVAO-NL may modify a recommendation for a positive outcome in a panel report, although it has never so far questioned this. The Committee was unclear on the situations that may lead to a deviation from the outcome of a panel’s report and whether such deviations are documented.
16. In its clarification response (of 10/02/2023) the review panel explained that NVAO-NL may occasionally seek additional information from panels and in a limited number of cases, and after due deliberation may expand conditions or deviate in a minor sense from the panel’s advice. Such changes may be done by NVAO-NL to reduce the subjectivity of reports and ensure the consistency of recommendations as well as of the final outcome. Deviations from the final recommendation of the panel have not happened yet, but according to the agency’s procedure these changes are documented in the final published decision by NVAO-NL.
17. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standard 2.5.”
Full decision: see agency register entry
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2.6 Reporting – NVAO – Compliance (2023) readability of reports, delay in publication
NVAO
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
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3.1 Activities, policy and processes for quality assurance – NVAO – Compliance (2023) separation between activities that are within and outside the scope of the ESG
NVAO
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 3.1 Activities, policy and processes for quality assurance Keywords separation between activities that are within and outside the scope of the ESG Panel conclusion Compliance Clarification request(s) Panel (10/02/2023)
RC decision Compliance “21. In its Terms of Reference for the review the Register Committee asked the panel to consider how the agency clearly separates between activities that are within and outside the scope of the ESG, in particular considering the ‘Assessment of Quality Agreements in the Netherlands’ and the ‘Assessment of the quality of Training Schools’. While the panel concludes that there is a clear separation between NVAO’s activities within and outside the scope of the ESG, the Committee could not find the argumentation to support the panel’s conclusion and has therefore sought further information.
22. In its response (see minuted conversation), the panel explained that the separation between the agency’s activities that are within and outside the scope of the ESG did not pose any concern.
23. Considering the Assessment of quality agreements in the Netherlands the panel stated that the activity does not address the teaching and learning aspects within higher education and that the focus of the assessment is on how institutions (plan to) spend the so-called study advance grants. The panel added that the agency’s protocol or description does not misrepresent the activity in any way (i.e. referring to ESG or EQAR registration).
24. Considering the evaluation procedure for teacher training schools, the panel clarified that the activity does not address or evaluate the teaching and learning in higher education, but it assesses the collaboration between schools for primary and secondary education and institutions for teacher training.
25. Having considered the clarification provided, the Register Committee can now follow the panel’s conclusion of compliance with the standard 3.1.”
Full decision: see agency register entry
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2.4 Peer-review experts – HAHE – Partial compliance (2023) Student involvement in panels
HAHE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 2.4 Peer-review experts Keywords Student involvement in panels Panel conclusion Non-compliance Clarification request(s) Agency (14/02/2023)
RC decision Partial compliance “Further efforts made by the
agency to engage students in the review panels - in particular
students have participated in the first reviews by the time the Register Committee analysed the application. While the panel’s
conclusion of non-compliance did reflect accurately the situation at the
February 2022’s site visit, the Committee concluded that the agency is now
partially compliant with the standard. The Committee, however, underlined
that further evidence of the actual involvement of the students in the panels
will be needed and has to be thoroughly analysed in the next review of HAHE”
Full decision: see agency register entry
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2.7 Complaints and appeals – HAHE – Compliance (2023) Independence of the appeal's body
HAHE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 2.7 Complaints and appeals Keywords Independence of the appeal's body Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “The panel argued that there was “no avenue available to have an
external review of a decision” and noted the “absence of external
adjudication in the mechanism used”. The Register Committee expects that
an appeal is considered by another body than the one whose
decision/report is appealed (see interpretation 13 of the ESG); this will
nevertheless normally be a body of the agency, as the standard requires an
internal appeals process (see also interpretation 12 of the ESG). As the
HAHE appeals committee consists of different persons than the (current)
EAC, this requirement is formally fulfilled, even if HAHE may reconsider the
practice of appointing only retired EAC members when it reviews its
appeals procedures as recommended by the panel, Further, the fact that the appeals' committee makes a recommendation to the
EAC is compatible with EQAR's expectations (see interpretation 14 of the
ESG).”
Full decision: see agency register entry
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3.4 Thematic analysis – HAHE – Compliance (2023) Content of the thematic analysis
HAHE
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 3.4 Thematic analysis Keywords Content of the thematic analysis Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “From several Annual reports of the agency from recent years, the Committee learned that the agency provides key figures on its work, but
also provides an in-depth overview of the compliance levels per standard in the undertaken accreditation procedures, summarises the good practices and obstacles observed in HEIs, and presents the most common recommendations by the panels.Following this, the Register Committee found that the current practice fulfils the minimum ESG criteria”
Full decision: see agency register entry
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2.5 Criteria for outcomes – ECCE – Partial compliance (2023) Methodology and criteria for the different re-accreditation period inconsistent
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 2.5 Criteria for outcomes Keywords Methodology and criteria for the different re-accreditation period inconsistent Panel conclusion Compliance Clarification request(s) Panel (15/02/2023)
RC decision Partial compliance “12. The Committee noted from the panel’s report that it is now clear what level of compliance a programme must achieve to receive the full 8-year accreditation period. At the same time, the definition of shorter accreditation periods remained unclear: the panel also confirmed in its clarification that there are no specific criteria or guidelines that determine by how much the period gets shortened.
13. In its additional representation the agency explained its methodology and criteria for the different re-accreditation period. While the Register Committee found a clear reasoning in the agency’s response, the Committee could not understand why the cited information (i.e. table and explanation provided) was not integrated in the agency’s procedures i.e., Accreditation Procedures and Standards. In particular, the Committee found the provided information on the length of the accreditation cycle i.e., of five years, to be completely missing from the agency’s procedure for re-accreditation (see Accreditation Procedures and Standards 5.3 – November 2019 Section 3.2.4.2.1).
14. Given the inconsistencies in the agency’s explanations and the presentation of ECTE’s criteria in its own procedures, the Register Committee was not persuaded that the agency ensured a consistent application of its criteria in its decision making.
15. The Committee also considered that this issue was amplified by the fact that there is no decision document (see also ESG 2.6), i.e., the Quality Assurance & Accreditation Committee’s (QAAC’s) considerations and argumentation on why a certain length of accreditation period was decided are currently not recorded in any public document.
16. The Register Committee thus remained unable to concur with the panel’s conclusion, but considered that ECCE only partially complied with the standard.”
Full decision: see agency register entry
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2.6 Reporting – ECCE – Partial compliance (2023) Publication of Accreditation Decisions
ECCE
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
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2.7 Complaints and appeals – ECCE – Partial compliance (2023) no possibility to appeal the formal decisions
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 2.7 Complaints and appeals Keywords no possibility to appeal the formal decisions Panel conclusion Partial compliance Clarification request(s) Panel (15/02/2023)
RC decision Partial compliance “23. The panel raised concerns about the slight unclarity and overlap between the “appeals and complaints procedure” and the separate “complaints procedure”. Even though the wording is unusual, the Register Committee considered that both appeals and complaints, as understood in the ESG, are generally possible.
24. The Committee obtained clarification by the panel on the composition of the Appeals Committee. Even though the members are different from the QAAC, the Committee shares the panel’s concern that all but one come from the rather small chiropractic community.
25. The Register Committee’s further noted that there is no possibility to appeal the formal decision by the QAAC, only the expert report. The Committee regarded this as problematic given that the QAAC alone decides on the accreditation term.
26. In its additional representation the agency explained that the judgement itself of the QAAC cannot be appealed solely on the basis of disagreement with the decision, but can be made based on incorrect procedures, or if it was executed in an unfair and discriminatory manner. The Committee thus understood that while ECCE makes possible appeals based on procedural error, errors of fact, mitigating circumstances where material was not available at the time and for situation where members of QAAC or ECCE behaved in a discriminatory or unprofessional manner, the agency does not allow for an appeal of QAAC’s judgement itself. The Committee thus finds that the appeals process is limited, given that the reviewed higher education institution may not challenge based on e.g., criteria that may have not been correctly applied or disagreements in how standards were interpreted by QAAC.
27. The Committee noted that the agency considered and upheld an appeal against a QAAC formal decision, but also noted that there is no public documentation on this appeal and that the agency does not have any information on its website on the composition of its Appeal’s Committee.
28. The Register Committee therefore concurred with the panel’s conclusion that ECCE only partially complies with the standard.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – ECCE – Partial compliance (2023) Involvement of student members in the governing/accreditation body
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 3.1 Activities, policy and processes for quality assurance Keywords Involvement of student members in the governing/accreditation body Panel conclusion Partial compliance Clarification request(s) Panel (15/02/2023)
RC decision Partial compliance “29. The panel clarified that ECCE had a clear strategy that guided its work; even if the official documents were sometime incoherent in wording, they were coherent in substance.
30. The panel further clarified that ECCE should have been more attentive and flexible as regards the appointment of a new student member to QAAC. The practice led to a student member being absent from QAAC for some time, which could have been avoided if ECCE had been more concerned to prevent this with priority.
31. Having considered the panel's clarification, the Register Committee was able to concur with the panel's conclusion that ECCE partially complies with the standard.
32. The review report explains that ECCE does not provide consultancy themselves but “offers the names and contact details of highly qualified independent educationalists to new chiropractic programmes to assist them with the development of their programmes” (report, p. 14).
33. While the Register Committee considered that these did not appear to be problematic, it found that this should be discussed in more detail in the next review of ECCE.”
Full decision: see agency register entry
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3.3 Independence – ECCE – Partial compliance (2023) Overlapping responsibilities between different bodies/ Lack of diversity
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 3.3 Independence Keywords Overlapping responsibilities between different bodies/ Lack of diversity Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “34. The panel raised issues related to the high involvement of representatives of accredited institutions, amplified by the small size of the chiropractic community, as well as the overlapping responsibilities between different agency bodies. In particular, the panel regarded critically the ex-officio mutual memberships of the Executive Committee and QAAC chairperson in the respective other committee, the involvement of both bodies in the QA process and the close involvement of the QAAC in pre-screening self-evaluation reports.
35. In light of these concerns, the Register Committee concurred with the panel’s conclusion that ECCE only partially complies with the standard.”
Full decision: see agency register entry
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2.5 Criteria for outcomes – SKVC – Partial compliance (2022) lack of consistency, unclear understanding of multi-level compliance scale
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 2.5 Criteria for outcomes Keywords lack of consistency, unclear understanding of multi-level compliance scale Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “8.The panel considered that SKVC's criteria are lacking clarity, especially with regard to the exact understanding of the 5-level scale used by SKVC. The panel recommended developing guidelines for interpretation of each level to enhance consistency of their use.
9.The Committee understood that the current situation as described and analysed by the panel might lead to a lack of consistency.”
Full decision: see agency register entry
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2.7 Complaints and appeals – SKVC – Compliance (2022) lack of internal appeals process for HEIs in exile
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 2.7 Complaints and appeals Keywords lack of internal appeals process for HEIs in exile Panel conclusion Compliance Clarification request(s) – RC decision Compliance “13. The Register Committee shared the panel's reservations that the inability for higher education institutions in exile to use SKVC's internal appeals process is a shortcoming.
14. Given that this only concerns one single institution at the moment and no accreditation has taken place so far, the Committee, however, did not consider this shortcoming material enough to influence the conclusion per this standard and concurred with the panel's conclusion that SKVC complies with the standard.”
Full decision: see agency register entry
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3.3 Independence – SKVC – Compliance (2022) involvement of ministry in accreditation of HEIs in exile
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 3.3 Independence Keywords involvement of ministry in accreditation of HEIs in exile Panel conclusion Compliance Clarification request(s) – RC decision Compliance “15. The review panel noted some concerns about the process of ex-post accreditation of higher education institutions in exile, especially given the direct involvement of the Ministry of Foreign Affairs in the evaluation, i.e. certain standards being assessed by the Ministry instead of the panel of experts.
16. The Register Committee considered that the rationale might lie in the obvious political and diplomatic dimensions involved and that this might justify distributed responsibilities in principle. The Committee, however, considered that it must be transparent to the public what is an assessment made by SKVC and its independent expert panels, and what part of the assessment is made by the Ministry, potentially taking into account political considerations. The Committee recommends that SKVC and the Ministry explore how to disentangle political/diplomatic considerations and quality assessments fully, e.g. by having the Ministry make a separate assessment and decision either preceding SKVC's quality assessment, or following a decision by SKVC.
17. Given the rare occurrence of these procedures and the brief analysis by the panel on the matter, the Register Committee was unable to draw a definitive conclusion; the independence and transparency in these procedures should thus receive close attention in SKVC's next review.”
Full decision: see agency register entry
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3.5 Resources – SKVC – Partial compliance (2022) reliance on temporary funding sources, state budget allocations insufficient
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 3.5 Resources Keywords reliance on temporary funding sources, state budget allocations insufficient Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “20. The panel discussed SKVC funding, relying on sources from several channels. In particular, SKVC's activities still partly depended on EU structural funds, which are temporary by nature. The panel further noted that the funding from Lithuania's state budget seemed to be insufficient to support the agency's activities sustainably.”
Full decision: see agency register entry
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2.4 Peer-review experts – ANECA – Partial compliance (2023) students, panel members
ANECA
Application Renewal Review Targeted, coordinated by ENQA Decision of 03/03/2023 Standard 2.4 Peer-review experts Keywords students, panel members Panel conclusion Compliance Clarification request(s) Panel (17/02/2023)
RC decision Partial compliance “10. The panel noted that the internal system of the agency generally aimed to have students in every expert panel, in each of ANECA’s procedure. The panel, however, found out that the majority of AUDIT INTERNATIONAL experts panels did not include students (see clarification of 2023-02-17).
11. According to the panel, ANECA found it challenging to ensure student participation in these experts panel due to the limited availability of the students. The Committee acknowledged that recruiting student experts might be more difficult for some reviews than for others, but underlined that this challenge has to be addressed by any agency and cannot serve as a reason to carry out reviews without student panel members.
12. Given the absence of students from most expert panels for AUDIT INTERNATIONAL, the Register Committee was unable to concur with the panel’s conclusion, but concluded that ANECA only partially complies with ESG 2.4.”
Full decision: see agency register entry