Reporting Substantive Changes
All registered agencies are expected to notify EQAR about changes to their legal form and status, amendments to their statutes and substantial changes in their process or methodology. It is the registered agency’s responsibility to inform EQAR of substantive changes that have occurred or are going to occur.
Changes should be reported as soon as the changes are sufficiently clearly defined to allow providing comprehensive information on their nature and impact. In case of new external QA activities, the substantive change report should be submitted between the design and implementation phase, namely once the methodology has been adopted/approved and before the external QA activity has been carried out.
Registered agencies are requested to inform EQAR of substantive changes so that EQAR will become aware of situations where an agency’s current practice differs substantially from the situation when it was reviewed against the ESG and admitted to the Register.
The requirement to report substantive changes is not intended to discourage change and innovation among registered agencies, and EQAR aims to minimise the burden on registered agencies.
EQAR therefore suggests that registered agencies keep their information on substantive changes as brief as possible, while giving a comprehensive picture of the nature and impact of the changes.
EQAR will normally merely take note of substantive change reports and update information on the Register, if necessary. Only in cases of serious concerns whether a registered agency continues to comply substantially with the European Standards and Guidelines (ESG) will the Register Committee consider further action.
Whether or Not to Report Changes
Substantive changes include any type of change that may affect the registered agency’s substantial compliance with the ESG. This may include, for example:
- changes to the legal form or status of the organisation;
- mergers with or absorption of other agencies or organisations;
- changes in the agency’s organisational structure (e.g. new statutory bodies/committees, or changes to their roles or composition);
- start of new external quality assurance of activities (e.g. launching a new type of accreditation or certification);
- changes to existing quality assurance activities (e.g. changes to their processes, criteria or methodologies);
- activities being discontinued.
If unsure whether or not a change should be reported, please refer to the questions in the Online Substantive Change Report Form for guidance. As a rule, if the answer is “yes” to either of the three main questions, a substantive change report should me made. If you are unsure whether the answer is “yes”, please refer to the examples for types of changes under each of the questions.
If you remain unsure whether a substantive change report is warranted or not, please seek advice from the EQAR Secretariat.
When to Report Changes
Changes should be reported as soon as the changes are sufficiently clearly defined to allow providing comprehensive information on their nature and impact. This may be before or after the changes actually take effect.
EQAR may also become aware of substantive changes in other ways. This may be either by third-party information received under the Complaints Policy, or on the basis of any information that is in the public domain. EQAR will then contact the agency for additional information or, if applicable, a change report.
Registered agencies are requested to submit Substantive Change Reports through the online form linked below.
Agencies might include appendices related to the changes. These should be limited to what is absolutely necessary to provide comprehensive information. Appendices can be attached in PDF format when filling the form (please avoid Word documents or any other formats) or provided as a hyperlink.
Please do not send any documents by regular mail, fax or otherwise.
Documents in another language than English will not be reviewed.
The timeframe in which substantive change reports are considered by the Register Committee depends on the complexity of the substantive changes.
Should EQAR require clarification to fully understand the nature and impact of the substantive changes it may contact the registered agency.
There are no fees or other costs related to substantive change reports.
How to Describe Changes
Please use the questions contained the on-line form to guide your submission (see also section above, on When to Report Changes).
The main headings are formulated as yes/no questions. Under each main heading, there are examples of what type of changes might occur and what type of information is typically relevant for EQAR.
The nature of the changes should be described concisely. The key question for EQAR is how the current situation differs from the situation when the external review of the agency was carried out or when substantive changes were last reported regarding that aspect, respectively. The key consideration relates to the ways in which the changes impact on the agency’s substantial compliance with the ESG.
For changed or new external quality assurance activities, please comment briefly on all aspects (i. to viii.) listed in the form and provide references (as a hyperlink or as an attachment) to the formal documentation governing these activities (preferably in English).
Mergers of Registered Agencies
Recent mergers of quality assurance agencies into one new agency required EQAR to develop a specific policy to address the registration status of agencies after a merger.
EQAR has developed a policy of “provisional registration“, which will enable agencies established as a merger of agencies already registered on EQAR to remain on the Register under certain conditions and requirements for a limited timeframe of maximum 2 years. During that period the new, merged agency will have to undergo an external review against the European Standards and Guidelines (ESG).
The conditions, requirements and process are set out in the Merger Policy (see link below).
Online Reporting Form
Please use the following online form to make a Substantive Change Report: