Decision on Registration

After completion of the external review process, the applicant agency submits the external review report to EQAR. The EQAR Register Committee will now analyse the review report and take a decision on the agency’s compliance with the ESG.

Submission of Review Documents

The following documents must be submitted via email to applications[at]eqar.eu:

  • Self-evaluation report (PDF document)
  • External review report (PDF document)
  • Declaration of Honour completed and signed by the review coordinator (PDFDOCODT).

Optionally, the applicant may submit a statement on the external review report.

Additional documentation might be useful where changes have been introduced after the completion of the external review on which the application is based, or where recommended improvements have already been implemented. Applicants should, however, bear in mind that, as a rule, the external review report serves as the main basis for EQAR’s decision making. Therefore, supplementary documentation should be as extensive as necessary, but as concise as possible. Supplementary documentation should add to the analysis in the external review report, and should not replace it.

Language: if documents are in another language than English, the applicant is expected to arrange for their translation.

Clarification Requests

In some cases, EQAR might request additional information or clarification from the applicant or the external review panel before the Register Committee considers the application at its meeting.

This happens if a request can be plausibly answered in a 2 – 3 week period. If a request is referred to the review panel or coordinator, the applicant will always receive a copy for information.

Additional clarification is requested in order to supplement the aspects considered by the external review report or to clarify aspects that are unclear but pertinent to the application. Externally reviewed evidence will nevertheless remain the main basis of EQAR’s decisions.

Decision-Making

In reviewing the application the Register Committee makes an assessment of each standard and concludes on compliance (which may be full or substantial), partial compliance or no compliance.

If the panel’s conclusion on the compliance with a standard are not found persuasive, the Register Committee will explain its reasoning in the decision. If a specific standard is not addressed in the decision it is implied that the Committee largely concurred with the review panel’s analysis and conclusion without further comments.

The Register Committee’s final judgement on the agency’s compliance with the ESG as a whole can either be substantially compliant or not substantially compliant.

Considerations in making the final judgment on an agency’s application:

  • there is no distinction between substantial compliance and full compliance, since for inclusion on the Register it is sufficient to substantially comply with the ESG;
  • if the conclusion is not substantially compliant, no difference is made between partial or no compliance;
  • a conclusion of compliance for all standards leads to a final judgement of substantially compliant;
  • a conclusion of partial compliance for one or more standard(s) will be considered in a holistic judgement, which can be positive or negative;
  • a conclusion of non-compliance for any one standard would lead to a final judgement of not substantially compliant.
Register Committee decision making process on ESG

Consequences

The Register Committee’s initial consideration might result in:

  1. approval of the application, or
  2. considering rejection of the application.

In the former case, the applicant is admitted to the Register for five years, or registration is renewed for a further five years, respectively. The applicant may make additional representation to the Register Committee within 40 days if it considers that specific conclusions are unreasonable or disproportionate in the light of the available evidence.

In the latter case, the applicant receives a detailed account of the grounds for which rejection is considered and is invited to make additional representation before the Register Committee takes a final decision. Applicants will normally have 2- 3 months to make additional representation and the application is deferred to the next meeting of the Register Committee.

The applicant can also withdraw the application instead of making additional representation. Should EQAR not receive any notice by the deadline this will be deemed a withdrawal of the application.

If an application is rejected, the applicant receives a reasoned rejection decision in writing. The rejection decision will only be published once it is final, i.e. after the deadline for appeal has passed and a potential appeal has been dealt with.

Rejected applicants may reapply within 18 months from the date of the rejection decision by undergoing a focused external review addressing those issues that led to rejection. If the re-application is successful the agency shall be included for five years from the date of the first, full external review report. If no focused review is submitted within the 18 month period, a new full external review is required.

The Register Committee may also invite the rejected applicant to reapply without an additional external review, if it can be verified on the basis of documentation submitted that the issues that led to rejection have been satisfactorily addressed.

There is no possibility for an applicant’s “conditional inclusion”. The Register Committee thus has to have full confidence in an agency’s substantial compliance with the ESG when accepting it on the Register.

Appeal

Applicants may appeal decisions of the Register Committee on procedural grounds or in case of perversity of judgement. The Appeals Committee has the responsibility to consider appeals. The Appeals Committee consists of a chair, two further members, a deputy chair and two deputy members. They are elected by the General Assembly.

Appeals need to be submitted to EQAR in writing within 40 days of the Register Committee’s final decision. The appeal has to clearly specify on which grounds it is lodged.

Agencies may also (optional) submit an additional representation (also on positive decisions) in writing within 40 days; appeals can only be made after this opportunity was used (within the following 40 days).  The Register Committee will review its decision based on the representations; the agency will be notified of the Register Committee’s final decision.

The Appeals Committee will decide on the appeal within 90 days following receipt.

Analysis of Register Committee Decision

A full analysis reflecting on the Register Committee’s decisions on application since the adoption of the ESG 2015 can be consulted below. The study also documents changes within the registered agency’s activities, organisational structure, their mergers and complaints.

More information about the Register Committee’s process in considering applications is provided in EQAR’s Internal Handbook.