Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.4 Thematic analysis
Keywords	Thematic analysis
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“21. The Register Committee learned from the report that AQUIB has a Thematic Analysis Protocol for a systematic approach to conducting thematic analyses, which was adopted in 2023 and is being implemented for the first time. However, the topic of the only thematic analysis conducted so far does not incorporate the results of its external quality assurance procedures.

22. Considering that the only thematic analysis conducted by AQUIB so far is outside the scope of ESG, the Register Committee was unable to concur with the panel’s conclusion of compliance and found that AQUIB only partially complies with the standard.

23. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	27/11/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	ESG Part 1
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision for renewal of registration (of 2020-03-16), the Register Committee found that VLUHR QA only partially fulfilled the requirements of the standard, as the ESG Part 1 was not sufficiently addressed in the main activities of VLUHR QA.

9. The Register Committee understood from the panel report that, since the last review, VLUHR QA has started employing a new framework for assessing programs in Flanders, which consists of eight quality features (QF). The new framework is stipulated by Flemish decree and must be implemented by the QA agencies evaluating programmes in Flanders.

10. The Register Committee learned from the panel analysis that the new quality framework still does not directly address certain elements of ESG 1.1, ESG 1.2 and ESG 1.4. There is no explicit mention that institutions must have a public quality policy (ESG 1.1) or processes for programme approval (ESG 1.2); nor it is addressed explicitly that “the internal processes of the university to ensure the monitoring of support processes for students at all stages of the lifecycle” (ESG 1.4).

11. The Register Committee also learned that VLUHR QA has addressed the missing elements only in the Guide for drawing up a self-evaluation report for higher education institutions. These elements are not covered in the Manual Programme Review, the main document followed by the external reviewers.

12. While the Register Committee understood that the new Flemish Framework addresses ESG to a higher extent than the previous one, the absence of ESG 1.1, ESG 1.2 and ESG 1.4 in the Framework and in the Manual raises concerns about the possibility of them being overlooked during the assessment. Therefore, the Register Committee found that VLUHR QA only partially complies to the standard and highlighted the panel’s recommendation on including the content of the Guide for drawing up a self-evaluation report in the Manual Programme Review.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	27/11/2024
Standard	3.4 Thematic analysis
Keywords	Thematic analysis
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its last decision for renewal of registration (of 2020-03-16), the Register Committee found that VLUHR QA only partially fulfilled the requirements of the standard, as the agency did not publish thematic analysis based on the findings of external quality assurance activities.

14. The Register Committee learned from the panel’s analysis that VLUHR QA has completed three thematic analysis reports since their last review and the number of reports aligns with the level of activity of the agency. Additionally, thematic analysis has been integrated into VLUHR QA’s daily work and in the current Policy Plan (2023-2027).

15. Furthermore, the Register Committee understood that VLUHR QA focusses on the thematic analyses being relevant to higher education stakeholders and ministry representatives, rather than solely concentrating on the outcomes of external review results.

16. The Register Committee was able to follow panel’s conclusion that VLUHR QA is now compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	26/11/2024
Standard	2.7 Complaints and appeals
Keywords	Separate and independent appeal body
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. In its last decision, the Register Committee noted that the Galician

Committee for Reports, Assessment, Certification and Accreditation (CGIACA) was

responsible for the evaluation, certification and accreditation and also for the

appeals following these reviews.

8. The Register Committee learned from the panel analysis that ACSUG has

set ap an appeal body (Review Committee). This body, however, has no decision-

making power as it can only provide a recommendation and return the case to the

original decision-making body, Galician Committee for Reports, Assessment,

Certification and Accreditation (CGIACA).

9. The Register Committee further noted from the analysis that the president

of CGIACA is a non-voting, member of the Review Committee. In panel’s view, due

to this organisational arrangement, the Review Committee and CGIACA are not

sufficiently separate and independent of each other as there is a possibility of a

CGIACA member also participating in the Review Committee meetings and

therefore potentially influence the discussions of the appeals’ body.

10. The Register Committee welcomed the steps taken by the agency regarding

establishing a separate body for appeals and reiterated that such a body needs to

be independent and separate, with full autonomy to make recommendations

regarding the appeal in question. However, it is sufficient that such a body makes

recommendations instead of final decisions on the result of external evaluation.

11. The Committee followed the panel’s view that there is lack of clear

separation between the accreditation (CGIACA) and appeal body (Review

Committee) of ACSUG and therefore concurred with the panel that ACSUG

complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	26/11/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Lack of strategic plan and deficiencies in strategic management, lack of yearly planning and monitoring, distinction between the agency's consultancy services and external QA processes
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The Register Committee learned from the review report that this standard

was not originally included in the targeted review, but the panel decided to include

it after considering all the evidence and input of the review as a whole.

13. From the review report, the Register Committee noted that since the last

strategy expired, ACSUG did not develop a new strategic plan. The Committee

further noted that ACSUG is lacking reliable yearly planning and monitoring that

would be linked to such a strategic plan. The panel found that this leads to

significant deficiencies in strategic management of the agency.

14. The Register Committee further understood from the analysis of the panel

that ACSUG lacks a clear communication and definitive distinction between the

agency's consultancy services and external QA processes.

15. Following the lack of strategic planning of ACSUG and absence of clear

distinction between its external quality assurance and consultancy activities, the

Register Committee concurred with the panel that ACSUG complies only partially

with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	26/11/2024
Standard	3.3 Independence
Keywords	Governmental influence, limited budget execution autonomy, limited human resources management autonomy
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. In its last decision, the Register Committee concluded that ACSUG complies

only partially with ESG 3.3 due to the strong influence of the regional government

over the process for appointment of the Director, the chair and members of the

Governing Board and the chairs of the CGIACA, leading to diminished organisational

independence of the agency.

17. The Register Committee learned from the analysis of the panel that no

change has taken place and that the Ministry still has a decisive role in the

appointment procedures of these ACSUG bodies.

18. The Register Committee further understood from the analysis of the panel

that ACSUG has limited autonomy in how to utilise its budget and manage its

human resources.

19. Following the strong influence of the regional government over the

agency, as well as ACSUG’s lack of autonomy in managing its resources, the

Register Committee concurred with the panel that ACSUG complies only partially

with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	26/11/2024
Standard	3.4 Thematic analysis
Keywords	Collaborative thematic analysis, lack of regularity
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. In its last decision, the Register Committee found that no thematic analysis)

was performed, and therefore concluded that ACSUG complies only partially with

ESG 3.4.

21. The Register Committee understood from the analysis of the panel that

ACSUG relies on collaboration with, and contributes to, the thematic analyses

coordinated by the Spanish Network of University Quality Agencies (REACU).

However, The Committee also understood that ACSUG does not have any stand-

alone thematic analyses that they conduct themselves and that thematic analysis is

still not included in the regular workflows and task distribution of the agency (see

also Register Committee remarks under ESG 3.1).

22. The Register Committee emphasised that conducting thematic analyses

under the partnership with REACU does not fulfil the requirements of the standard

because the regularity of such activities is sporadic, and ACSUG is dependent on the

thematic analysis coordinator (REACU).

23. Following the lack of thematic analysis conducted by ACSUG, the Register

Committee concurred with the panel that ACSUG complies only partially with ESG

3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	26/11/2024
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Addressing recommendations from the previous external review
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“24. In line with the EQAR Use and Interpretation of the ESG, the Register

Committee understands that ESG 3.6. implies that previous recommendations and

instances of partial compliance have been addressed properly.

25. The Register Committee noted that ACSUG has not responded

appropriately to most of the instances of partial compliance raised in a previous

external review, and had regressed in one standard (3.1), which has negative

implications for ACSUG’s level of compliance with ESG 3.6. The Register Committee

therefore once again emphasises the recommendations delivered by the 2019 and

2024 review panel and expects that these issues are addressed in the next (full)

review of ACSUG.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	Internal quality assurance
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“9. In its previous decision the Register Committee found the agency to be compliant with ESG 2.1. As per the

Policy on Targeted Reviews, ESG 2.1 shall always be part of the external review process. The Register Committee noted that all procedures share an underlying framework infrastructure for all of it external quality assurance activities that reflects well the standards of ESG Part 1.

10. The Committee therefore concurred with the panel’s conclusion that QQI continues to be compliant with ESG 2.1.

11. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.4 Peer-review experts
Keywords	Absence of student reviewers; Training of student reviewers
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“10. In its previous decision for renewal of registration on EQAR (of 2024-11-05), A3ES was found to be partially compliant with the standard due to the absence of student reviewers in panels in the New Study Programmes (NCE) procedures and overseas accreditations. The Register Committee noted from the panel analysis that the status quo has not changed.

11. Furthermore, the Committee understood that except for initial trainings, the agency does not organise systematic training for new or revised processes and that some reviewers, including students, have not received training in the past five years. Furthermore, the Committee understood that student reviewers receive only training for programme reviews, but not for institutional reviews.

12. Given the lack of students involvement in some procedures and the lack of systemic training for reviewers, the Register Committee concurred with the panel conclusion, and found that A3ES remains to be partially compliant with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.6 Reporting
Keywords	Publication of negative reports and decisions
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“13. The Register Committee learned from the analysis by the panel that A3ES does not publish negative reports and decisions on the assessment of new study programmes (NCE).

14. Given the lack of transparency by not publishing negative reports and decisions for all procedures the Register Committee concurred with the panel that A3ES only partially complies with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.4 Thematic analysis
Keywords	Inactivity in implementing thematic analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. The Register Committee understood from the analysis by the panel that the most recent thematic analysis published by the agency were done in 2017.Furthermore, the Committee, noted that “the agency confirmed to the panel that it does not currently have a systematic approach to conducting thematic analysis but confirmed its commitment to developing this.”

16. The Register Committee concurred with the panel that A3ES only partially complies with ESG 3.4. The Register Committee underlined the panel’s recommendation that the agency should resume conducting and publishing thematic analysis of the outcomes and findings of its external quality assurance activities.

17. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.1 Consideration of internal quality assurance
Keywords	Part 1 insufficiently covered, inconsistency in addressing Part 1 standards in different procedures.
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“10. ANVUR conducts wide variety of external quality assurance procedures in its national higher education system. The Committee understood that some of the activities are applied in conjunction to each other (e.g. initial programme accreditation combines in certain elements with periodic institutional assessment of universities).

11. From the review panel report, the Register Committee learned that ANVUR aims to cover all the ESG Part 1 standards holistically through different combinations of their EQA activities taken together (e.g. ESG 1.9 is not assessed each time an initial programme accreditation is conducted but is instead included in the periodic institutional assessment of the university).

12. The Register Committee took note of the different combinations of ANVUR’s external quality assurance activities. It, however, learned that even in this case, few of the standards (e.g. ESG 1.6, ESG 1.7, ESG 1.8 and ESG 1.9) are not fully covered yet. The Committee learned from the analysis that the procedures which do not address all standards of the ESG Part 1 on their own (i.e. complementary activities such as the initial accreditation and periodic assessment) do not do so even in combination with at least one other self-standing activity (see remark on the ESG 2.1 in the EQAR Use and Interpretations of the ESG ).

13. The Register Committee further learned that there is a level of inconsistency in integrating ESG Part 1 in different external QA activities of ANVUR, for example ESG 1.9 being considered only in the initial accreditation of PhD programmes, but not in other procedures.

14. The Register Committee found that the agency is yet to effectively translate standards 1.1 – 1.10 of the ESG into all of its activities and demonstrate that the complementary activities jointly address ESG Part 1 fully. The Register Committee therefore concurred with the panel that ANVUR complies only partially with ESG 2.1.”

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	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	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.6 Reporting
Keywords	Publication of all reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“20. The Register Committee learned from the panel analysis that the agency publishes full reports in only three out of its nine external quality assurance activities.

21. In its additional representation, ANVUR demonstrated that all reports are now published on ANVUR’s website. In addition, the agency explained that the accreditation protocols foresee a higher level of standardisation of reports which will in turn ensure that reports will continue to be published in full.

22. The Register Committee welcomed the steps taken by the agency and found that the agency now publishes all of its reports. Following this, the Register Committee could not follow panel’s conclusion and found ANVUR compliant with ESG 2.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Lack of stakeholder involvement in governance bodies
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“23. The Register Committee learned from the review report that the Governing Board of ANVUR consists exclusively of university professors, while no other stakeholders were involved in the governance of the agency.

24. In its additional representation, ANVUR explained that their regulations do not prevent any expert, regardless of which stakeholder group they belong to, from being a member of the Governing Board. In the Register Committee’s view, however, participation in the Governing Board is challenging, especially for students, due to the full-time character of the role, even though there are different governance arrangements and divisions of governance tasks which would enable broader stakeholder involvement. (e.g. by reducing the expected working hours for some stakeholder groups).

25. ANVUR further argued that stakeholders are involved in other bodies of the agency, such as the Advisory Board, leading to ANVUR’s governance being informed by stakeholders. While the Register Committee found the involvement of stakeholders in the work of the Advisory Board to be a positive practice, it noted that this does not fulfil the requirements of the standard which implies stakeholders’ involvement in strategic decision-making (governance), and not merely in the advisory processes of the agency.

26. Considering lack of stakeholder involvement, beyond the university academic staff, in ANVUR’s governance, the Register Committee was unable to concur with the panel’s conclusion and found that ANVUR only partially complies with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.3 Independence
Keywords	Lack of ability to independently design external QA procedures, lack of ability to autonomously determine organisational structure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“27. The Register Committee learned from the panel’s analysis that ANVUR’s ability to design its external QA procedures (i.e. operational independence) and to set up its internal organisational structure (i.e. organisational independence) is rather limited. In panel’s view, the Italian regulations stipulated very specific details on the agency’s external quality assurance procedures, methodologies and the evaluation standards, as well as the internal governance and organisational structure. This approach diminishes ANVUR’s ability to act autonomously regarding its internal regulations and structures.

28. In its additional representation, ANVUR argued that most of the issues outlined by the review panel stem from the Italian national context and legislation. In regard to the operational independence of the agency, ANVUR argued that it has sufficient autonomy in designing its external QA procedures because national legislation emphasises ANVUR’s responsibility to independently define the criteria, indicators, and requirements of its external QA, while in regard to organisational independence, ANVUR states that the national legislation prescribes collaborative relation between the Ministry and ANVUR, instead of a direct supervisory role of the Ministry.

29. The Register Committee took note of ANVUR's remarks. The Committee could still follow panel's view that ANVUR is facing obstacles regarding organisational and operational independence, as the review panel already considered these legislative acts and nonetheless outlined detailed reasons for their concerns about ANVUR’s independence.

30. Considering that the review panel presents convincing evidence and analysis that ANVUR faces obstacles in its organisational and operational independence, the Register Committee concurred with the panel that ANVUR complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.4 Thematic analysis
Keywords	Use of external QA results
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“31. The Register Committee noted that ANVUR’s main channel for publishing the thematic analysis is the Biennial Report on the State of the Italian Higher Education and Research System. In addition, ANVUR conducts several ad hoc research initiatives on topics relevant for the Italian higher education system.

32. The Register Committee followed the panel’s conclusion that the agency complies with the standard. The Committee, however, emphasised the panel’s recommendation that ANVUR could use the findings and analyses of its external quality assurance processes more systematically and critically in its thematic analyses.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Internal QA not sufficiently systematised and formalised
Panel conclusion	Compliance
Clarification request(s)	Panel (01/10/2024)
RC decision	Compliance

“33. The Register Committee noted that ANVUR is in the process of expanding and implementing a diverse set of internal quality assurance processes. For the Committee, it was not clear how far has the agency reached in this process of developing their IQA system and, therefore, it sought further clarification from the panel.

34. The review panel explained that even though ANVUR conducts its internal QA procedures regularly and effectively, including collection, analysis and reaction to the feedback of its stakeholders, it is yet to develop a structured and systematic framework for its internal QA processes.

35. The Register Committee could therefore follow the panel’s conclusion that the agency complies with the standard. The Committee, however, emphasised the panel’s recommendation to ensure that internal quality assurance of ANVUR should be systematised and formalised, leading to a more coherent and consistent approach.”

Full decision: see agency register entry