Database of Precedents

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

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	Initial
Review	Full, coordinated by ENQA
Decision of	27/06/2025
Standard	3.3 Independence
Keywords	organisational independence, operational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“19. The Register Committee learned from the report that the Director is appointed by the Parliament upon the recommendation by the Minister responsible for higher education, without a public call nor specific selection criteria.

20. The Committee found this problematic given the Director’s extensive power within the organisation and responsibilities in ensuring the independent operations of the agency: besides being the member of the Steering Committee (governing body), the Director also appoints the evaluation panels, chairs the Evaluation Committee and recommends the two other members of the Evaluation Committee, the body responsible for taking the accreditation decisions and issuing the final evaluation reports.

21. The Register Committee further noted that the organisational independence from the Ministry is undermined by fact that a senior Ministry official is sitting on and chairing the Appeals Committee, body of three members who are all simultaneously members of the Steering Committee as well.

22. In its statement to the report, AQUA informed that following the changes in the national legislation of January 2025, the process for selection of Director of AQUA will be based on a public call and an objective merit-based selection process, which will be lead by a commission responsible higher education in the Parliament instead of the Minister.

23. Furthermore, the agency informed that with the legal changes of January 2025, the composition of the agency’s Appeals Committee has changed from three to six members, and no longer includes a representative from the Ministry. In addition, the number of Steering Committee members in the Appeals Committee is decreased to one.

24. The Register Committee took note of these updates and welcomed the legal changes made in order to ensure organisational independence of AQUA. While noting the changes made in the composition of the Appeals Committee, the Register Committee underlined that the presented changes on the procedure for appointment of AQUA Director are yet to be implemented and reviewed by an external review panel to verify whether they have been properly implement in practice.

25. The Register Committee therefore concurred with the panel that AQUA complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	27/06/2025
Standard	3.3 Independence
Keywords	Independence; Dual role of Interim Director
Panel conclusion	Non-compliance
Clarification request(s)	–
RC decision	Partial compliance

“34. In the last decision of renewal of registration, the Register Committee found the agency to be partially compliant with the standard due to issues related to the organisational independence of the agency. Namely, the Governing Board was predominantly composed of the representatives of the regional government, including the Chairperson, while the members were appointed by the regional Minister responsible for universities and research. Furthermore, the agency was largely dependent on the regional government for approval and hiring of new staff and the annual approval of the budget.

35. The Register Committee noted from the panel analysis that the concerns raised during the last review remain pertinent. The majority of Board members are either appointed by the regional Minister of Education or take on their roles by virtue of holding specific positions within state administration, and the Board is chaired by the Head of the Regional Ministry for Universities.

36. Furthermore, the Register Committee learned from the panel analysis that the Acting Director of the agency during the site visit was simultaneously the head of the General Directorate responsible for universities and research, who also serves as a vice-chair of the Board.

37. The Register Committee concurred with the panel that the dual role of the Acting Director endangers the independence of the agency, especially given that the agency's organisational structure is centred around the director's position, which grants this position significant influence.

38. The Register Committee further learned from the panel analysis that the agency does not have sufficient autonomy in the recruitment process, and the budgetary constraints remain under the authority of the regional government, hindering the agency's operational flexibility and autonomy.

39. In its additional representation, ACSUCYL informed EQAR that in order to reduce the representation of regional government members on the Board of Directors, the agency approved a proposal to replace two governmental officials with two students. To that end, it has submitted a proposal to the regional government for legislative amendment. The Register Committee further asked for clarification on the timeframe when the legislative amendments would be approved. The agency clarified there was no precise timeline for amending the legislation, but they expect it to be approved by January 2026.

40. The Register Committee welcomed the actions taken by the agency, but it acknowledged that the proposed legislative changes have yet to be adopted. Additionally, once adopted, it remains to be considered and reviewed by an external review panel.

41. To address the dual role of the Interim Director, the agency has taken accelerated steps to appoint a new Director and has published an open call with expedited deadlines to resolve this issue. Following a clarification request, the agency clarified that as of yet it had no formal mechanism to avoid the dual role of the director, but they have accelerated the process to select the new director by 9 June 2025.

42. Following the clarification call with ACSUCYL (of 2025-06-05), the agency informed the Committee that a new Director has been selected on 9 June 2025 (see Annex 4). The Register Committee welcomed the steps taken by the agency to appoint a new Director with expedited deadlines and emphasised the importance of introducing measures to avoid dual/multiple roles for the Director of the agency in the future, which could compromise the agency’s independence.

43. In its additional representation, the agency further explained that budget control mechanisms from the regional government are mandatory, as the agency receives public funding. The agency clarified that while being accountable to the regional government, the agency has autonomy to plan and execute the budget and manage its staffing process.

44. The Register Committee welcomed the clarification, however, noted that concerns about the dependency on the regional government for the approval of the budget and staffing are still pertinent.

45. While concerns on the agency’s independence are yet to be fully resolved, considering the agency has already selected a new Director following an open call, the Register Committee concurred that ACSUCYL now partially complies with the ESG 3.3. Furthermore, the Register Committee noted that ACSUCYL should inform EQAR once the new Director starts its term and the legislative changes are approved.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/06/2025
Standard	3.3 Independence
Keywords	operational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. In its last decision, the Register Committee found the agency to be partially compliant due to THEQC’s workforce that was heavily consisting of (academic) experts working at the agency but being paid by their higher education institutions.

21. The Register Committee, learned that while the number of permanent staff has increased since the last focused review, the number of seconded experts working at the agency while being paid by their higher education institutions remains ‘significant’ (10 out of 44 permanent staff members).

22. Considering that the concerns from the last decision regarding the dependency of the agency on staff being paid by higher education institutions remained, the Register Committee concurred with the panel that the agency remains to be partially compliant with the standard.”

Full decision: see agency register entry

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

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

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

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

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

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

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

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

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

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

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

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	stakeholder representation within the governance and separation of EQA within and outside the scope of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last decision, the Register Committee noted that ASIIN continued to use the term evaluation for type 2 evaluations against the panel’s recommendation, and thus the separation between activities within the scope of the ESG and those that are carried out as type-2 evaluations remained unclear. In its review report the panel considered that the difference made by ASIIN in various documents between type 1 evaluation and type 2 evaluation sufficiently differentiated between accreditation and consultancy. The panel further noted that ASIIN had a policy not to conduct accreditation for those institutions/ programmes at which consultancy activities were carried out, and that this was adhered to in practice (p.31). The Committee therefore concluded that this shortcoming has been addressed. The Register Committee noted that ASIIN’s Board of Directors consists exclusively of representatives of member organisations/institutions of ASIIN. The involvement of a diverse set of stakeholders (including students) in the governance of the agency is, however, ensured within the technical committees, Accreditation Commission and Certification Commission. Considering ASIIN’s expansion of its external QA activities to other areas the panel underlined that ASIIN should rethink its current structure and broaden its competences (p.16). The panel recommended a stronger involvement of the Board of Directors in the strategic direction of the agency and the monitoring of its strategic goals, while at the same time expanding its membership to also include external stakeholders (including a student member). The Committee underlined that recommendation of the panel.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of external QA and consultancy activities; possible conflicts between different types of reviews
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“16. [...] The report noted that it would be against EQ-Arts' principles to engage in paid consultancy work (p. 31), this was now explicitly ruled out in the Governance Framework.

17. The Register Committee considered that the issue has been addressed for consultancy in the classical meaning, i.e. paid services provided to institutions. The Committee therefore now concurred with the panel's conclusion that EQ-Arts complies with the standard.

18. The Register Committee nevertheless underlined that EQ-Arts needs to be mindful for all other current or future activities with individual higher education institutions – whether paid or unpaid – if they could be regarded as compromising its ability to make an independent assessment of that institution later on and, if so, to make adequate provisions to rule out carrying out a review of that institution.

19. In addition, the next external review of EQ-Arts should analyse whether any risk lies in the fact that the same higher education institutions might undergo an enhancement review first and request a formal assessment later, depending on whether such patterns occur in practice.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student involvement in governance, lack of periodic and multi-annual Strategic Plan, a clear distinction between external quality assurance and its other fields of work
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (24/10/2025)
RC decision	Partial compliance

“21. The panel found that in general stakeholders are involved in the work of the agency, but commented that there is no student representative on the Foundation Council and that FIBAA should consider broadening its stakeholders to include, for example, members of committees from outside of FIBAA’s circle of ‘customers’.

22. The panel also remarked that FIBAA does not have a periodic and multi-annual Strategic Plan but that the strategic goals are considered during the Council’s last meeting in the year. The review panel noted that the consideration of strategic matters takes place as and when necessary, but still in a highly informal process. The Committee concurs with the view of the panel that the current strategic planning process, should be further developed to ensure that it also considers the medium to long term future of the agency.

23. While the review panel confirmed that FIBAA has in place a strict separation between its consultancy services and external QA activities within the scope of the ESG, the Register Committee noted that this separation was not clear in the case of FIBAA’s Evaluation Procedures According to Individual Objectives (see also point 5 above).

24. The Committee underlined that agencies are expected to take appropriate precautions to prevent any conflicts of interest arising from the consultancy activities they carry out, as indicated in Annex 2 to the EQAR Policy on the Use and Interpretation of the ESG.

25. Considering the shortcomings of involving students in FIBAA’s governance and the lack of a comprehensive Strategic Plan and the separation of consultancy and external QA procedures, the Committee cannot follow the panel’s conclusion of (substantial) compliance but finds that FIBAA complies only partially with standard 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ASIIN
Decision of	28/06/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	scope of the ESG, alternative providers, transparency of provider status, use of Bachelor and Master by alternative providers, need for clear distinction
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (24/10/2025)
RC decision	Partial compliance

“39. The ESG cover “higher education in its broadest sense, including that which is not part of a programme leading to a formal degree”. The ESG do not specifically limit what "higher education" means and explicitly include education that does not lead to a "formal degree".

40. The Register Committee therefore considers that the scope of the ESG needs to be determined by the quality and level of the education provided, not the legal status of the provider. That is, if an alternative provider offers learning opportunities with learning outcomes at higher education level, as defined by the QF-EHEA descriptors (see discussion under 2.1 above), the ESG can be considered applicable as a framework for the provider's quality assurance. [...]

42. In general, the ESG are underpinned by an expectation of utmost transparency; in turn, information that could be misleading, in particular for (potential) students, should be avoided. EQAR's Policy on the Use and Interpretation further specifies that the Register Committee should be guided by EQAR’s overall mission of ensuring transparency and trust when applying the standards.

43. Under ESG 3.1 it is expected that quality assurance agencies distinguish clearly and transparently between their external QA within the scope of the ESG and other activities. In line with the overall goal of transparency, the Register Committee applies the same principle to different types of accredited providers with a clearly different status and formal recognition; a lack of transparency about the status of different providers would bear the risk of confusing potential students as well as others, and might raise false expectations as to the status and recognition of credentials earned from those providers.

44. The guidelines to ESG 3.6 further reflect the expectation that an agency “establish the status and recognition of the institutions with which it conducts external quality assurance”. In view of the overarching goal of transparency, the Register Committee expects that agencies not only establish, but also make clear publicly the status of the different types of providers they work with.

45. In the interest of avoiding confusion and upholding the credibility of the education system, the Register Committee thus expects that the difference between formally recognised higher education institutions, awarding formally (nationally) recognised qualifications, and alternative providers must be absolutely clear for stakeholders and the general public.

46. The possible “dichotomy of national versus international, professional accreditation”, referred to by the panel in its clarification, cannot be a reason to accept unclarity or confusion about a provider's formal status. The Committee would consider it incompatible with the principles of the ESG if international, professional accreditation were to contribute to such unclarity or confusion. [...]

48. The Register Committee noted that a number of alternative providers accredited by ECTE used the terms “Bachelor” or “Master” for their education offer. The QF-EHEA employs these terms for officially recognised degrees. In the vast majority of EHEA jurisdictions, these terms are legally protected, similar to terms such as "university", "university college" or "higher education institution". Equally, in the public eye these terms are understood as implying formal recognition as a higher education institution.

49. The Register Committee therefore considers that the use of these terms by alternative providers is not acceptable unless it can be explicitly demonstrated that an alternative provider may legally use those terms.

50. ECTE's standards specified that “Programmes that are not recognized by national authorities should ensure that the qualification nomenclature that is used is appropriate and not in breach of protected terminology” (B.2.1, p. 27) and further that “If the qualification is not recognised by competent national authorities, this should be specified.” (B.5.1, p. 39)

51. It remained unclear to the Committee how stringently these provisions were verified or enforced in practice. In its response to the clarification request, the panel did not provide any further details. Given that the terms “Bachelor” and “Master” are typically legally protected, neither the fact that “ECTE's international experts from the field [...] are checking compliance with professional standards” (clarification by the panel) nor the fact that some of “ECTE’s members cannot or do not want to obtain a national recognition” (idem) give clear reassurance that the institutions in question use those terms legally.

52. The Register Committee considered that the unrestricted use by ECTE of the terms “Bachelor” and “Master” for alternative providers significantly reduced transparency and blurred, rather than clarified these providers' status. [...]

55. The fact that the majority of ECTE-accredited providers are alternative providers underpins the importance of ensuring that not only ECTE's own communication is clear, but also that ECTE ensures – through its respective standards and their stringent application – that the accredited providers themselves live up to the same level of clarity about their status.”

Full decision: see agency register entry