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  • 3.3 Independence – PKA – Partial compliance (2024) organisational independence, minstry,

    PKA

    Application Renewal
    Review Targeted, coordinated by ENQA
    Decision of 04/04/2024
    Standard 3.3 Independence
    Keywords organisational independence, minstry,
    Panel conclusion Partial compliance
    Clarification request(s) Panel (04/10/2023)
    RC decision Partial compliance

    “27. In its decision of the Substantive change report decision (of 28-06-2022) the Register Committee concluded that the dismissal of the President casts serious doubts on whether PKA remains able to “act autonomously” and to assume “full responsibility for [its] operations”, as required by ESG standard 3.3.

    28. The Register Committee considered that the law and regulations on PKA provided insufficient safeguards against an infringement on the agency's independence by allowing for such a decision to be taken discretionary by the Minister. The Committee found that its earlier conclusion that PKA complies with ESG 3.3 might have been flawed, and based on a positive external review report that did not allay such concerns.

    29. In its current review the panel confirmed the concerns of the Register Committee i.e., the panel “could not gauge the extent to which the looming possibility of dismissal without reason may affect the behaviour and performance of the President…”. The panel also noted that there are no clear rules and procedures for the dismissal of PKA’s President, thus the Minister can continue to use discretionary power to dismiss the President of PKA.

    30. Following the review panel’s recommendation, the President of PKA submitted a letter, dated August 2, 2023, to the Minister of Education and Science, articulating the recommendations delineated in the ENQA’s review report. In its response letter (Annex 1 of Statement), the Minister showed readiness for a discussion that would determine the criteria for dismissing the PKA President.

    31. The Register Committee considered that the Minister was willing to recommend a change in the Law and that would remove the question mark over the independence of PKA (as noted in the Review Report and PKA’s Statement to the Review Report). The Committee nevertheless found that since its Change Report (of 2022-06-28) and the review panel’s review report of June 2023, no change or new evidence in the form of a policy, protocol, procedure or similar, specifying reasons/rationale for the dismissal of the President regulating the Minister’s discretionary power was developed and adopted.

    32. The Committee further noted existing possible conflict of interest in PKA’s decision making bodies (see further under ESG 3.6), which raises concerns related to the integrity and independence of the agency’s formal outcomes.

    33. The Register Committee finds the above issues of significance given the powers conferred in the position of the PKA’s President (expressed mainly in article 7, 8, 9 & 11a of PKA Statutes) and the controlling stake laid in the hands of the Minister, who has already employed its discretionary power to dismiss the President of PKA at any point (see Change Report Decision of 2022-10-25).

    34. In its additional representation, the agency provided a declaration from the new Minister of Science of Poland, where he shows willingness to initiate an amendment on the provisions of the Act of Higher Education and Science in order to limit the Minister’s powers and remove their right to dismiss the President of PKA. Furthermore, the declaration states that the proposed amendment it would empower PKA to be responsible for the dismissal of the President.

    35. The declaration of the Minister also informed the Register Committee, that until the legislative framework is changed, he shall introduce an internal procedure in case the President needs to be dismissed, in order to eliminate any further doubts of the Register Committee.

    36. The Register Committee welcomed the proposed changes by PKA and the Polish Ministry of Science. Nevertheless, the presented changes have not been implemented in practice yet and at the moment are promises that have yet to be implemented. Therefore, once adopted it remains to be considered and reviewed by an external review panel to determine whether the changes have been properly implemented.

    37. The Register Committee therefore concurs with the panel that PKA complies only partially with ESG 3.3. The agency is expected to submit a Substantive Change Report informing the Register Committee once the changes have been made.”

    Full decision: see agency register entry

  • 3.3 Independence – AKAST – Partial compliance (2023) operational independence, decision-making

    AKAST

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 12/12/2023
    Standard 3.3 Independence
    Keywords operational independence, decision-making
    Panel conclusion Partial compliance
    Clarification request(s) –
    RC decision Partial compliance

    “8. In its last decision, the Register Committee noted the strong role the German Bishops’ Conference (DBK) plays in the governance of the agency.

    9. Despite the changes made by the agency to further its operational independence, the Register Committee noted that DBK maintains a significant role in the organisational structure of AKAST.

    10. The Committee underlined the possible influence that may be exerted by the DBK Episcopal Commissioner in the decision making of the Accreditation Committee. Although the Episcopal Commissioner is present in the Accreditation Committee (AC) of the agency in an advisory capacity, there is still the possibility of undue influence considering the fact that the Episcopal Commissioner still issues a separate consent impacting the programme.

    11. Furthermore as noted by the panel, it also seems possible for the episcopal commissioner to express, even unintentionally, a preliminary opinion on particular study programmes, not necessarily based on the findings of the expert panel during the AC meeting.

    12. The Committee noted the concentration of power in one place, i.e., the current Chairperson of the Executive Board of AKAST holds the position of Chair of the Accreditation Committee and Chair of the Advisory Board of AKAST. Furthermore, the DBK nominates the Chairperson of the Executive Board.

    13. Considering the strong influence of one main stakeholder in the running of the agency, the Register Committee underlined the risk to the agency’s operational independence, as well as to its independent decision-making. The Register Committee therefore concurred with the panel’s view that AKAST complies only partially with ESG 3.3.”

    Full decision: see agency register entry

  • 3.3 Independence – IEP – Compliance (2024) Organisational independence

    IEP

    Application Renewal
    Review Targeted, coordinated by ENQA
    Decision of 04/04/2024
    Standard 3.3 Independence
    Keywords Organisational independence
    Panel conclusion Compliance
    Clarification request(s) –
    RC decision Compliance

    “12. In the previous renewal decision of IEP’s registration, the Register Committee noted that the agency’s organisational independence still continued to be compelled by the close link with the EUA.

    13. The Register Committee understood that IEP has taken further steps to address the flagged issues raised in the previous decision. The Committee notes the panel’s analysis and the conclusion that while the EUA is providing resources to IEP, it does not have any role in the decision making processes within the IEP. Furthermore, the Committee notes that in order to better distinguish between EUA and the separate activities undertaken by the IEP, the agency has developed a new website and a distinguishable new corporate identity.

    14. Furthermore, the Register Committee took note of the agency’s revised Terms of Reference in order to show the Steering Committee’s full ownership of the development and operation of the IEP.

    15. The Register Committee therefore concurred with the panel's conclusion that IEP complies with the standard. The Committee, however, shared the panel’s view that the agency should make publicly visible the IEP Terms of Reference and other official documents that state the organisational independence of IEP from EUA.”

    Full decision: see agency register entry

  • 3.3 Independence – CYQAA – Partial compliance (2024) operational independence, methodologies

    CYQAA

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 04/04/2024
    Standard 3.3 Independence
    Keywords operational independence, methodologies
    Panel conclusion Partial compliance
    Clarification request(s) –
    RC decision Partial compliance

    “15. In the decision for inclusion of CYQAA on EQAR (of 2019-11-05), the Committee raised concerns regarding the shortcomings related to the operational independence of CYQAA and the close interlinkage between the agency and the responsible ministry.

    16. Despite some progress being made by consultation with key stakeholders on the appointment of Council members and the Minister, the Register Committee noted that the Council members are still appointed by the Council of Ministers, upon recommendation by the Minister responsible for higher education.

    17. The Register Committee took note of the panel’s concerns regarding the operational independence of the agency, The Committee understood that CYQAA cannot hire its own staff and is fully relying on secondments from the central Government and the Ministry of Education, Sport and Youth.

    18. The Register Committee further noted, as underlined by the panel, that despite being fully independent in defining its evaluation methodologies, CYQAA is still challenged by the limits set in the provisions of the national legislation regarding engaging stakeholders in the development of methodologies (see issue raised under ESG 2.2 in the external review report).

    19. Following the panel’s analysis, the Register Committee expressed its concerns that the operational independence of CYQAA remains constrained by the close link and dependence on the Ministry of Education, Sport and Youth regarding the appointment of the Council members, hiring of staff and engaging stakeholders in the development of methodologies. Therefore, the Register Committee concurred with the panel conclusion, and found that CYQAA remains to be partially compliant with ESG 3.3.”

    Full decision: see agency register entry

  • 3.3 Independence – MFHEA – Partial compliance (2024) government involvement, organisational independence

    MFHEA

    Application Initial
    Review Full, coordinated by ENQA
    Decision of 11/10/2024
    Standard 3.3 Independence
    Keywords government involvement, organisational independence
    Panel conclusion Compliance
    Clarification request(s) –
    RC decision Partial compliance

    “51. The Register Committee learned from the report that the members of the MFHEA Board are all nominated by the Minister responsible for

    education and appointed by the Prime Minister of Malta. The Prime Minister also nominates the Chairperson and Deputy Chairperson of the Board, who undergo parliamentary scrutiny before being officially appointed. Furthermore, the dismissal and resignation of the Board members could be

    only done by or via the Prime Minister.

    52. Following the panel’s analysis, the Register Committee expressed its concerns that the organisational independence of the agency is constrained by its strong link and dependency on the government. This is reinforced by the small size of the higher education system.

    53. The Quality Assurance Committee (QAC) of MFHEA is the body responsible for decision making on external quality assurance of further and

    higher educational institutions. The MFHEA Board, on the other hand, is responsible for endorsement of the evaluation decisions taken by the QAC.

    The panel noted inconsistencies regarding what accreditation procedures and which decisions are being endorsed by the Board. Further, as noted by the panel, the participation of the head of QAC, a body appointed by the Board, in the endorsement of QAC’s decisions as a Board member could create internal conflict of interest.

    54. In its additional representation, the agency stated that “There are several layers to ensure the independence and suitability of the members of

    the Board. These are nominated by the Minister for Education, however they are appointed by the Prime Minister and the Chairperson needs to be

    approved by the Public Appointments Committee which is a Parliamentary committee made up of members from both sides of the House (Parliament) which conducts Parliamentary Scrutiny of the nominee. The law also lists the eligibility criteria for Board members, thus ensuring the objective suitability of person nominated by the Minister and appointed by the Prime Minister.”

    55. Furthermore, the agency clarified that the current chairperson of the newly appointed QAC has not been appointed as a member of the Board and that the process for the required legislative changes to reflect this distinction are currently underway.

    56. The Register Committee considered the additional representation and welcomed the distinction between the two bodies by excluding the

    chairperson of the QAC in the Board. The Committee found that, however, this practice is yet to be codified as to ensure continuous prevention of

    conflict of interest within the accreditation process. Furthermore, the committee maintains its concerns raised by the panel on the inconsistencies

    regarding what accreditation procedures and which decisions are being endorsed by the Board.

    57. Finally, the Committee maintains its concerns raised above about how the organisational independence of the agency is constrained by its strong link and dependency on the government.

    58. Therefore, the Committee could not concur with the panel and found that the agency complies only partially with the standard.”

    Full decision: see agency register entry

  • 3.3 Independence – ANVUR – Partial compliance (2025) Lack of ability to independently design external QA procedures, lack of ability to autonomously determine organisational structure

    ANVUR

    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

  • 3.3 Independence – AQUIB – Partial compliance (2024) Independence, government representatives

    AQUIB

    Application Initial
    Review Full, coordinated by ENQA
    Decision of 27/11/2024
    Standard 3.3 Independence
    Keywords Independence, government representatives
    Panel conclusion Partial compliance
    Clarification request(s) –
    RC decision Partial compliance

    “18. The Register Committee understood from the analysis by the panel that the composition of the Board of Directors has dominant representation of the government and the UIB, and these two stakeholders appoint all six board members.

    19. The Register Committee further learned that according to statutes, the Director of the agency is appointed by the Balearic minister responsible for university affairs. Since 2009, however, this position is vacant and the Technical Director, chosen with a public competition, manages the agency.

    20. The Register Committee understood that to resolve the above mentioned issues new statutes of the Consortium of the Balearic Agency for Quality Assurance in Higher Education has been drafted. The statutes, however, are not yet in effect. Following this, the Committee concurred with the panel that AQUIB only partially complies with ESG 3.3.”

    Full decision: see agency register entry

  • 3.3 Independence – ACCUA – Partial compliance (2024) government,

    ACCUA

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 27/11/2024
    Standard 3.3 Independence
    Keywords government,
    Panel conclusion Compliance
    Clarification request(s) –
    RC decision Partial compliance

    “16. The Register Committee learned from the panel analysis that the representation of stakeholders in the Governing Council has improved compared to the previous review and that the share of Government appointees in this body has been lowered.

    17. The Committee, however, also noted that the regional minister, whose portfolio the agency is situated in, is acting as the President of the agency, chairs the Governing Council and has a casting vote.

    18. Furthermore, the Register Committee noted, as underlined by the panel, that the agency is dependent on the Regional Government’s approval for hiring both temporary and permanent staff, which limits the agency’s operational autonomy.

    19. Considering the significant level of involvement of the regional government in the governing of the agency and the potential constraints over the staff management and the operational independence of the agency, the Register Committee could not follow the panel’s judgement and concluded that ACCUA complies partially with the standard.”

    Full decision: see agency register entry

  • 3.3 Independence – ACSUG – Partial compliance (2024) Governmental influence, limited budget execution autonomy, limited human resources management autonomy

    ACSUG

    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

  • 3.2 Official status – IEP – Compliance (2019) agency’s formal recognition

    IEP

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 03/04/2019
    Standard 3.2 Official status
    Keywords agency’s formal recognition
    Panel conclusion Full compliance
    Clarification request(s) –
    RC decision Compliance

    “The Register Committee noted that IEP itself does not have separate legal personality and therefore it is represented by EUA in all legal and contractual matters. The Committee acknowledged that the recognition of IEP as a quality assurance agency by public authorities is demonstrated by the numerous contracts that IEP (represented by EUA) signed with national authorities for conducting evaluations, or by the selection of IEP as an evaluating body through a public procurement procedure. [...] The Register Committee interprets the requirement of formal recognition in a broad sense and therefore concurred with the panel's conclusion that IEP complies with the standard.”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – ANQA – Partial compliance (2022) Student involvement in decision making bodies

    ANQA

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 25/10/2022
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords Student involvement in decision making bodies
    Panel conclusion Full compliance
    Clarification request(s) –
    RC decision Partial compliance

    “ANQA involves students in the review panels, but not in the body

    responsible for making decisions on accreditation (i.e. the Accreditation

    Council). The Committee highlighted the panel’s recommendation and

    found it necessary that the agency improves the involvement of students in

    the decision-making process.”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – AQAS – Partial compliance (2022) Involvement of stakeholders in governing bodies; Lack of clear policy for separation of EQA and consultancy activities and preventing conflict of interest

    AQAS

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 14/03/2022
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords Involvement of stakeholders in governing bodies; Lack of clear policy for separation of EQA and consultancy activities and preventing conflict of interest
    Panel conclusion Substantial compliance
    Clarification request(s) –
    RC decision Partial compliance

    “The governing body (i.e. the Managing Board) of the agency does not involve other stakeholders than academics. The agency has not published any policy or statements in regards to the separation of its consultancy activities and preventing conflicts of interest.”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – AI – Partial compliance (2021) Weak involvement of stakeholders in the governance of the agency

    AI

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 15/10/2021
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords Weak involvement of stakeholders in the governance of the agency
    Panel conclusion Substantial compliance
    Clarification request(s) Panel (28/09/2021)
    RC decision Partial compliance

    “AI has no advisory or governing board, nor any other strategical decision making body (hence lacks stakeholder involvement in the governance of the agency).”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – PKA – Compliance (2019) clarification of external QA carried abroad

    PKA

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 19/06/2019
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords clarification of external QA carried abroad
    Panel conclusion Full compliance
    Clarification request(s) Agency (21/05/2019)
    RC decision Compliance

    “In its confirmation of eligibility, the Register Committee noted that PKA is expected to also address activities carried out by the agency abroad i.e. in Lithuania. As it was unclear on whether such activities were addressed in the external review of PKA, the Committee asked PKA for further clarifications. PKA explained that the external QA activities carried out in Lithuania only extended to one foreign branch of a Polish higher education institution and that the procedures and criteria used were identical with those applied in the case of national HE providers.”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – NEAA – Partial compliance (2018) Stakeholder involvement in the governance and work of the agency

    NEAA

    Application Initial
    Review Full, coordinated by ENQA
    Decision of 13/06/2018
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords Stakeholder involvement in the governance and work of the agency
    Panel conclusion Substantial compliance
    Clarification request(s) –
    RC decision Partial compliance

    “While the panel noted that a broader stakeholder involvement would require a change of the law on higher education and might have further implications for the overall functioning of the agency, the Register Committee underlined that the unbalanced composition of NEAA's governing bodies was already flagged as a matter requiring attention when NEAA was first admitted to the Register in 2009”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – NEAQA – Partial compliance (2018) Agency lacks explicit goals and objectives; limited stakeholder involvement i.e. consultations only where specific topics are addressed

    NEAQA

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 06/12/2018
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords Agency lacks explicit goals and objectives; limited stakeholder involvement i.e. consultations only where specific topics are addressed
    Panel conclusion Partial compliance
    Clarification request(s) –
    RC decision Partial compliance

    “The Register Committee noted that while NEAQA’s strategy could provide a comprehensive framework for the agency's daily operations, the agency does not have in place mechanisms for effective forward planning and reviewing progress towards its objectives. Considering the involvement of stakeholders, the panel’s findings show that, since its last review, NEAQA has improved the engagement with employer representatives in its quality assurance activities. However, stakeholder involvement is still limited in agency's work given that neither students nor employers are involved in NEAQA’s governance.”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – EAEVE – Compliance (2018) Involvement of students in agency’s decision making

    EAEVE

    Application Initial
    Review Full, coordinated by ENQA
    Decision of 13/06/2018
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords Involvement of students in agency’s decision making
    Panel conclusion Full compliance
    Clarification request(s) Panel (02/06/2018)
    RC decision Compliance

    “The Register Committee understood that the reference to “consultative services” in the report in fact referred to so-called “consultative visitations”. These are, however, not consultancy activities, but a step in EAEVE's external quality assurance scheme. […] The Register Committee underlined the panel’s suggestion that EAEVE should involve students in the ECOVE and the appeals panels, even though students do not request membership at the moment.”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – AI – Partial compliance (2016) Stakeholder involvement

    AI

    Application Renewal
    Review Full, coordinated by ENQA
    Decision of 03/12/2016
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords Stakeholder involvement
    Panel conclusion Partial compliance
    Clarification request(s) –
    RC decision Partial compliance

    “The Register Committee flagged in its decision of inclusion the effectiveness of the Accreditation Institution’s activities to engage with its stakeholders.The Committee noted that the involvement of stakeholders is generally ensured trough consultations by the Ministry and the Accreditation Council (Review Report, p. 29), while AI’s only formalised form of stakeholder involvement is related to the thematic analysis of reports. The Committee concurred with the panel’s conclusion that AI should further develop stakeholder involvement in its governance and work in order to meet the agency’s objectives of enhancement and further development of quality assurance.”

    Full decision: see agency register entry

  • 3.1 Activities, policy and processes for quality assurance – AQ Austria – Compliance (2024) Clarity in activities and services; Conflicts of interest

    AQ Austria

    Application Renewal
    Review Targeted, coordinated by ENQA
    Decision of 02/07/2024
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords Clarity in activities and services; Conflicts of interest
    Panel conclusion Compliance
    Clarification request(s) –
    RC decision Compliance

    “10. While the Register Committee was able to follow panel’s conclusion that AQ Austria is compliant with the standard, it highlighted the panel’s recommendation that the agency should enhance the clarity on its ESG aligned activities and consultancy services for the public and add explanation on avoiding conflicts of interest on their website.

    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

  • 3.1 Activities, policy and processes for quality assurance – GAC – Partial compliance (2022) strategy not reflecting agency's central role, lack of broad discussions with stakeholders

    GAC

    Application Initial
    Review Full, coordinated by ENQA
    Decision of 25/10/2022
    Standard 3.1 Activities, policy and processes for quality assurance
    Keywords strategy not reflecting agency's central role, lack of broad discussions with stakeholders
    Panel conclusion Substantial compliance
    Clarification request(s) Panel (05/10/2022)
    RC decision Partial compliance

    “16. The panel considered that the lack of involvement of stakeholders beyond those individuals who are members of the agency bodies themselves might lead to a lack of critical distance. The panel thus saw a need for more and broader stakeholder feedback, and recommended more regular dialogues with stakeholder organisations on strategic and policy matters.

    17. The panel further considered that GAC's strategic planning did not sufficiently reflect its central, pivotal role in the accreditation system (see also the comments under ESG 2.2 above). The panel saw a strong need for a broader discussion with agencies and all stakeholders on GAC’s role in the system and its strategy. In particular in view of the upcoming revision of the

    Specimen Decree, the panel found such a discussion was urgent to define a strategy that describes clearly the role GAC plans to assume in the system and its mid-term priorities.

    18. While the Register Committee appreciates that GAC has begun to plan a strategy process (see statement on the report), it considered that the panel's analysis under this standard points to important issues in GAC's governance and engagement with stakeholders; these are particularly important in light of GAC's pivotal role in the German system.”

    Full decision: see agency register entry