Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	2.3 Implementing processes
Keywords	light systematic follow-up approach (compliant)
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel noted that “actions taken by the institutions after the audit are not checked comprehensively”. While the panel noted that NOKUT provided an avenue for follow-up through seminars and conferences organised to discuss the audit findings and recommendation, it did consider those to be a systematic follow-up and noted that “the institutions do not feel obliged to implement the recommendations received”. The Register Committee considered that a very “light” approach to follow-up can be appropriate for (purely improvement-oriented) recommendations from an audit with an unconditionally positive outcome. Moreover, it considered that it was in the nature of a recommendation that there is no obligation to implement it.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2019
Standard	2.3 Implementing processes
Keywords	Consistency in implementation of EQA procedures
Panel conclusion	Full compliance
Clarification request(s)	Panel (26/02/2021)
RC decision	Compliance

“In its response letter the panel stated that it is the responsibility of each Permanent Speciality Commission to ensure that judgements in ARACIS reports are accurate and consistent and the panel was convinced that all processes defined in the Methodology are implemented consistently.

Having found limited information in the panel’s analysis on the functioning of provisional authorisation for programmes and higher education institutions, the Committee has asked the panel to confirm that the key features of ESG 2.3 (self-assessment, external assessment, site visit, review report, follow-up) are implemented by ARACIS in these reviews.

In its response letter the panel confirmed that following the detailed examination of ARACIS’s Methodology and Guide, the agency followed the same procedures for provisional authorisation as the ones employed for the evaluation of accredited programmes, which were addressed by the panel in its review report (p. 31).Having considered the panel’s clarification the Register Committee was able to concur with the panel’s conclusion that ARACIS complies with the standard.

The Committee nevertheless underlined the panel’s suggestion on the need to further develop the follow-up procedures of the agency and to consider how institutions have addressed the ARACIS’s recommendations in their evaluation reports.”

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 (23/04/2025)
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	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

Application	Renewal
Review	Full, coordinated by GAC
Decision of	03/12/2016
Standard	2.3 Implementing processes
Keywords	Not clearly defined processes for institutional audits offered in Austria
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review report demonstrates that ACQUIN's external quality assurance processes are clearly defined in public documents, except for institutional audits offered in Austria. The Register Committee concurred with the panel's view that the process should be clearly defined and published despite the low demand. The Register Committee took note of ACQUIN's statement on the external review report, which states that audits in Austria follow the same procedure as system accreditation in Germany. The Register Committee, however, understands from the review report that this is not stipulated in ACQUIN's public documentation. When ACQUIN's registration was last renewed, EQAR had flagged for attention whether ACQUIN’s international accreditation and evaluation activities take place on a clearly defined and transparent basis, within and beyond the EHEA. The Register Committee concluded that this flag has been resolved for ACQUIN's international accreditation activity in general, but not for audits in Austria”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	inconsistency in implementation of the process; unclear definition for cases where there is no site visit.
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review report noted that on-site visits are not mandatory in evaluations (type 1) and recommends that ASIIN should establish clear principles to state in which cases on-site visits are not necessary. Given the current absence of such principles, the Register Committee considered that ASIIN did not comply with the requirement to normally include a site visit. In its additional representation, ASIIN specified that site visits were a mandatory element in all type-1 evaluations. While the Register Committee welcomed the clarification, it underlined that the clear implementation in practice cannot be assessed at this stage; it should thus be subject of the next external review of ASIIN. The review report further identified cases where ASIIN did not follow the principles established in its own policy regarding the use of evaluation results for programme accreditation. The Register Committee took note of ASIIN’s statement on the report, which confirms that fact but does not include an explanation or rationale for departing from the policy. The Register Committee therefore considered that ASIIN did not implement its own processes consistently in all areas. Despite the fact that ASIIN stated in its additional representation that this was “one case among hundreds of procedures” and announced that it was planning to amend its own policy to the effect that a prior evaluation result could be used, provided is is not older than 2 years, the Register Committee noted that ASIIN's current policies were not always followed in practice, even if this was so in only very few cases.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	03/12/2016
Standard	2.3 Implementing processes
Keywords	Lack of transparency and precise roles in criteria and procedure for selection of experts and guidelines for decision-making process.
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (23/04/2025)
RC decision	Partial compliance

“While the external review report states that AAQ and SAR function well together as a unit, the external review panel considered that the “allocation of duties should be presented with greater transparency in the relevant guidelines” (p. 25). The Register Committee noted that further comments regarding a certain lack of transparency of the precise roles of AAQ and SAR were made by the panel with regard to the criteria and procedure for selection of experts (see 2.4) as well as guidelines for SAR’s decision deviating from the expert-recommended decisions (see 2.5).The Register Committee considered that transparency is crucial especially in a layered system such as that of AAQ and SAR.”

Full decision: see agency register entry

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

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

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

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

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

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

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

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.3 Implementing processes
Keywords	inconsistencies in the implementation
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. The Register Committee noted that there are inconsistencies in the implementation of the processes. The Register Committee underlines the panel’s recommendation that the agency should clearly communicate on the valid reasons behind multiple inputs to its accreditation process and decisions, by publishing them on the website as noted also in its Substantive Change Report Decision of 15 October 2021.

14. The Register Committee further noted the concerns raised by the review panel concerning the lack of relevant criteria and information integrated in AIC’s guidebook from the Law on Higher Education and Cabinet Regulations, as well as the updating of assessment methodologies, frameworks and the guidelines for institutions, as well as experts.

15. From the additional representation by the agency, the Register Committee understood that, when considering that different procedures would be considered as a package the Methodology for organising the assessment of higher education institutions and colleges could be seen as a follow-up procedure for the one-off procedure Accreditation of higher education institutions. While the panel noted that the agency is preparing a cyclical institutional accreditation, the Committee reiterates the need for clear follow-up measures.

16. The Register Committee concluded that AIC complies with ESG 2.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.3 Implementing processes
Keywords	no site visits, inconsistency,
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. The Register Committee learned from the analysis of the panel that only the EQA Audit process is clearly outlined in the audit manual. For the rest of the activities, both the information provided to the panel as well as the publicly available documents, were not always consistent.

21. The Committee noted the panel’s concerns on a number of shortcomings related to the programme and provider accreditation

procedures, such as short application forms instead of self-evaluation reports for some procedures, no site-visits (see also ESG 2.2) and lack of consistent follow-up.

22. In its statement on the report (of 2024-05-20), MFHEA informed that the discrepancies between the documents and the shortcomings related to programme and provider accreditation procedures have been further addressed in the revised manuals for programme and provider accreditation procedures, which have been in use as of January 2024 for provider accreditation procedures and will be, respectively, as of January 2025, for programme accreditation procedures.

23. The Register Committee took note of the revised manuals but could not confirm whether and how these changes are implemented in practice.

24. In its additional representation, the agency reaffirmed that the concerns raised by the Committee for provider accreditation procedures have been addressed in the new Provider Accreditation Manual and the concerns for programme accreditation procedures will be addressed in the new Programme Accreditation Manual.

25. The Register Committee took in consideration the actions taken by the agency in order to address the concerns raised by the panel and the Register Committee. The Committee, however, could not confirm how these changes have been implemented in practice without a panel insight and found that some of them are yet to be implemented. Therefore, the Committee could concur with the panel that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.3 Implementing processes
Keywords	Difficulties in verifying that all procedures are pre-defined and published
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“16. The Register Committee understood that although ANVUR generally implements all stages of the review (self-assessment, site visit, report, follow-up), there are certain exceptions: site visits are not mandatory in the initial (ex ante) accreditation while the follow-up of the newly accredited institutions is only conducted via the periodic assessments.

17. The Register Committee learned from the analysis of the panel that ANVUR is lacking a comprehensive and published description for each external quality assurance procedure that would serve as an overarching guide (see also ESG 2.2). Due to this, the agency cannot ensure that its external QA processes are pre-defined and published, which could further endanger the consistent implementation of these processes and of their individual phases.

18. In its additional representation, ANVUR demonstrated that since the site visit, the agency published a Manual which comprehensively compiles, describes and explains all external QA activities of the agency in detail.

19. The Register Committee could verify that now ANVUR’s procedures are pre-defined and published, and was able to concur with the panel’s conclusion that ANVUR complies with ESG 2.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/07/2021
Standard	2.2 Designing methodologies fit for purpose
Keywords	Using feedback for improving methodologies
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee welcomed the diverse methods used by the agency

for gathering feedback from different stakeholders, but could

not confirm that the reflections are efficiently and systematically used in the

improvement of the activities. The findings indicate that the

feedback is only sporadically used in the improvement of the agency’s

external QA activities.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	2.2 Designing methodologies fit for purpose
Keywords	stakeholder involvement in the development of methodology
Panel conclusion	Full compliance
Clarification request(s)	Panel (23/04/2025)
RC decision	Compliance

“The Register Committee was unclear how the agency has developed its accreditation criteria and whether stakeholders were involved in the design of AKAST methodologies and has therefore asked the panel for further clarifications. The panel explained that Germany’s new legal framework defines the procedures for QA agencies carrying out their accreditations within Germany and that the German Accreditation Council (GAC) is entrusted with overseeing this process. The GAC has issued reporting templates and defined the structure of review reports as well as self-evaluation reports for higher education institutions, following the criteria established in the Specimen Degree, which follow the ESG.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/06/2018
Standard	2.2 Designing methodologies fit for purpose
Keywords	flexibility of the accreditaiton system
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“While concurring with the panel's conclusion that NEAA complies with the standard, the Register Committee underlined the suggestion by the panel that NEAA should explore ways to make the accreditation system more flexible.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.2 Designing methodologies fit for purpose
Keywords	fitness for purpose of doctoral schools EQA
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“Considering the fitness for purpose of external QA processes, the Register Committee noted the panel’s concerns with the effectiveness of the practice of evaluating doctoral schools every six months. In its additional representation HAC explained that the biannual checking of compliance with criteria for doctoral programmes has now been discontinued and that a new approach and criteria have been developed, which are expected to be finalised in autumn.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.2 Designing methodologies fit for purpose
Keywords	involvement of stakeholders (students)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel’s analysis showed that while IAAR involved a range of stakeholders in the ongoing review of the agency’s methodology, the panel found no evidence that student representative bodies had been consulted. The panel added that student involvement in IAAR’s relevant consultative and decision-making bodies was minimal.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.2 Designing methodologies fit for purpose
Keywords	stakeholder involvement
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The review report demonstrated that, based on the national legislation as the main framework, AEQES has developed its own methodological framework, procedures and criteria in consultation with the key stakeholders”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.2 Designing methodologies fit for purpose
Keywords	Fitness for purpose difficult to fully assess due to dispersed methodologies
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. At the time of the review the methodologies were dispersed across different documents including ministerial decrees, other regulatory documents, and procedural guidelines, making it challenging to find information on each of the activities in a comprehensive manner. While the Register Committee could follow the panel’s conclusion that the agency complies with the standard it highlighted the panel’s recommendation that the agency should more explicitly define and consistently publish the purpose and aims of each of its external quality assurance activities.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.2 Designing methodologies fit for purpose
Keywords	no ownership or full responsibility resting with a single actor, consequences for improvement
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Compliance

“9. The panel noted that no actor had ownership or full responsibility for the entire accreditation system and process, since the specimen decree appoints specific responsibilities to both GAC and the agencies.

10. The Register Committee sought further clarification from the panel as to how that impacted continuous improvement and development. The panel noted that opportunities for improvements were discussed actively; the ongoing review of the Specimen Decree was an example of that. The panel, however, saw a lack of GAC itself assuming a more proactive, coordinating role and taking responsibility for the system as a whole; this would be reasonable given its unique and pivotal position.

11. The Register Committee concluded that continuous improvement seems to be ensured despite the distributed responsibilities and thus concurred with the panel's conclusion that GAC complies with standard 2.2; the issues related to GAC's role and strategy are considered under standard 3.1 below.”

Full decision: see agency register entry