Database of Precedents

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	2.7 Complaints and appeals
Keywords	lack of internal appeals process for HEIs in exile
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. The Register Committee shared the panel's reservations that the inability for higher education institutions in exile to use SKVC's internal appeals process is a shortcoming.

14. Given that this only concerns one single institution at the moment and no accreditation has taken place so far, the Committee, however, did not consider this shortcoming material enough to influence the conclusion per this standard and concurred with the panel's conclusion that SKVC complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	3.3 Independence
Keywords	involvement of ministry in accreditation of HEIs in exile
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. The review panel noted some concerns about the process of ex-post accreditation of higher education institutions in exile, especially given the direct involvement of the Ministry of Foreign Affairs in the evaluation, i.e. certain standards being assessed by the Ministry instead of the panel of experts.

16. The Register Committee considered that the rationale might lie in the obvious political and diplomatic dimensions involved and that this might justify distributed responsibilities in principle. The Committee, however, considered that it must be transparent to the public what is an assessment made by SKVC and its independent expert panels, and what part of the assessment is made by the Ministry, potentially taking into account political considerations. The Committee recommends that SKVC and the Ministry explore how to disentangle political/diplomatic considerations and quality assessments fully, e.g. by having the Ministry make a separate assessment and decision either preceding SKVC's quality assessment, or following a decision by SKVC.

17. Given the rare occurrence of these procedures and the brief analysis by the panel on the matter, the Register Committee was unable to draw a definitive conclusion; the independence and transparency in these procedures should thus receive close attention in SKVC's next review.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	3.5 Resources
Keywords	reliance on temporary funding sources, state budget allocations insufficient
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. The panel discussed SKVC funding, relying on sources from several channels. In particular, SKVC's activities still partly depended on EU structural funds, which are temporary by nature. The panel further noted that the funding from Lithuania's state budget seemed to be insufficient to support the agency's activities sustainably.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	2.4 Peer-review experts
Keywords	students, panel members
Panel conclusion	Compliance
Clarification request(s)	Panel (17/02/2023)
RC decision	Partial compliance

“10. The panel noted that the internal system of the agency generally aimed to have students in every expert panel, in each of ANECA’s procedure. The panel, however, found out that the majority of AUDIT INTERNATIONAL experts panels did not include students (see clarification of 2023-02-17).

11. According to the panel, ANECA found it challenging to ensure student participation in these experts panel due to the limited availability of the students. The Committee acknowledged that recruiting student experts might be more difficult for some reviews than for others, but underlined that this challenge has to be addressed by any agency and cannot serve as a reason to carry out reviews without student panel members.

12. Given the absence of students from most expert panels for AUDIT INTERNATIONAL, the Register Committee was unable to concur with the panel’s conclusion, but concluded that ANECA only partially complies with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	03/03/2023
Standard	2.6 Reporting
Keywords	reports, publication
Panel conclusion	Compliance
Clarification request(s)	Panel (17/02/2023)
RC decision	Partial compliance

“14. The panel reported that all reports from programme evaluations were now published on ANECA’s website in a more extensive format; for SIC, AUDIT and AUDIT INTERNATIONAL the agency published the full expert reports.

17. The panel further explained (see clarification) that in programme evaluations the external review reports are prepared by ANECA’s Committees, based on the initial experts’ reports and following the multiple-stage process that is described in the review report. For SIC, AUDIT and AUDIT international procedures the panel noted that ANECA did not have the same practice and specific committees preparing external review reports, but instead considered the full experts’ reports as final report.

18. Having thus considered the report and the clarification, the Committee concluded that the two step approach, where the external review reports are prepared by internal specialised committees, might mean that the full content of the reports prepared by the panel would not be publicly known. Further, the Committee could not, based on the evidence provided by the panel, identify "before" and "after" examples of programme evaluation reports, and hence understand what "more extensive" might mean in practice, and was therefore unable to concur with the panel assessment of compliance.

19. The Committee therefore concluded that ANECA is not living up to the intentions of standard 2.6 which states that "full reports by the experts should be published”. Therefore, the Register Committee concluded that ANECA only partially complies with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	2.1 Consideration of internal quality assurance
Keywords	how ESG 1.9 is addressed in AQU’s activities
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that in the implementation of ESG 1.9 the review panel considered how AQU’s different activities address the cyclicity of external reviews. The Committee, however, underlined that the focus of the standard is on the monitoring and periodical review of programmes as part of the institutions internal QA, ensuring that objectives set for the programmes are achieved and that monitoring processes lead to the continuous improvement of the programme.

Given that the Register Committee was unable to draw a definitive conclusion on how ESG 1.9 is addressed in AQU’s activities, the issue should thus receive close attention in AQU’s next review.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	2.6 Reporting
Keywords	publication of reports from ex-ante accreditation
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous renewal decision, the Register Committee noted that AQU publishes all reports except those from ex-ante evaluations that result in a negative accreditation decision. The review panel reports that AQU now publishes all review reports, independent of their outcome. The Committee also noted that reports with a negative ex-ante accreditation outcome are released with an initial page warning that the degree will not be taught. While the practice of publishing ex-ante reports with a negative outcome was originally met with unease by the institutions whose study programme was rejected, there now is an agreement within AQU on the value of ensuring accountability and trust in the whole system. In relation to the AQU reports for the ex-ante accreditation of short learning programmes (SLP) and micro-credentials, the Committee noted that the agency struggles in scaling the demands of accrediting such programmes, in particular ensuring the proportionate length and detail in its reporting. The Committee underlined the panel’s suggestion on expanding the level of detail and analysis in reports for SLPs to facilitate the usability by various stakeholders and to reflect the detailed evaluation work of the experts. Having considered the change in practice in the publication of negative ex-ante reports, the Register Committee concurred with the panel’s conclusion that AQU now complies with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	25/10/2022
Standard	3.3 Independence
Keywords	composition of governing bodies; independence of the appeals process; financial independence
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous decision the Register Committee underlined the concerns of the panel with regard to the overlap in the composition of the agency’s different bodies. The review panel found that AQU has separated the membership of its strategic and oversight bodies from its specific commissions and review panels. The Register Committee welcomed these changes, including the appointment of two non-local members to the Appeals Committee, but noted that the Chair of the Appeals Committee is a member of the Governing Board. While the role of the members in the Governing Board is limited to the strategic decision-making and management of the organisation, the Register Committee found that the involvement of a representative of the Board (in particular as a Chair) in the Appeals Committee might put undue pressure in the discussion and decision-making of the Appeals Committee. The Register Committee nevertheless agreed that the Appeals Committee was sufficiently independent given that the AQU’s Governing Board does not adopt the reports or decisions that are being appealed. The Register Committee further noted that AQU’s funding comes primarily from the Government of Catalonia (about 90% of the agency’s budget) and is allocated on an annual basis. The Committee welcomed AQU’s plans to move to a four-year contract with the Government of Catalonia, which could further improve its operational independence. Considered the steps taken to separate the membership of the agency’s strategic and oversight bodies, the Register Committee could follow the panel’s conclusion that AQU now complies with the standard ESG 3.3.”

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	14/03/2022
Standard	3.4 Thematic analysis
Keywords	Content of the thematic analysis
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“the content of the thematic publications mainly involved reflections on the agency’s own experiences in conducting EQA rather than analysis of the results of the EQA (an analysis which could be more appropriate to serve the internal quality assurance processes, ESG 3.6). The Committee agreed with the panel’s views that the agency could improve the content of the analyses so they are more meaningful for the wider academic and QA community”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.4 Peer-review experts
Keywords	involvement of students, regular expert trainings
Panel conclusion	Partial compliance
Clarification request(s)	Agency (28/03/2026)
RC decision	Compliance

“The Committee could further verify that all AVAP commissions now

include a student representative in the review for all types of procedures, including the authorisation of new programmes. The role of the student member has been redefined and that the administrative role of student in the Panel (including the different assignment for each panel member) is now removed. The Committee noted that the protocols clearly set out that students are

equal panel members in the review and reporting process. AVAP also set out a regular training of

experts and that one such session was carried out in early February.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.5 Criteria for outcomes
Keywords	Undocumented mechanisms for ensuring consistency
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (28/03/2026)
RC decision	Partial compliance

“The Committee noted the informal nature of the internal mechanisms for ensuring consistency and agreed with the panel on

the risk posed in ensuring the consistency of outcomes in the assessment procedures.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.7 Complaints and appeals
Keywords	weak complaints' and appeals' procedures
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“After the external review report has been published, the agency provided the full documentation on its

new internal provision for complaints and appeals and the functioning of its new appeals’ body. The Committee noted that the Protocols and Appeals Commission is now operative and that the accreditation process has been

with AVAP’s evaluation commissions. The Committee further noted that AVAP’s QA protocol clearly defines

the process for complaints (dissatisfaction with the conduct of the process

or those conducting it) and the process for appeals (to challenge the formal

outcome), and that the process to receiving complaints has been improved.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	3.3 Independence
Keywords	strong involvement of the regional government
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee notes that the overall setup of the agency

provides the Regional Government with a large influence in the governance

and operation of AVAP, i.e. the operative decisions are mainly taken by the

Executive Committee which consists of six members, three of them being

the representatives of the Regional Government, the proposal for Director

comes from the Regional Government. The agency has initiated a legal

process for reducing the number of local Governmental representatives

in its steering bodies - a change hat was yet to take place.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	3.4 Thematic analysis
Keywords	Lack of independent thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	Agency (28/03/2026)
RC decision	Partial compliance

“AVAP had conducted meta-analyses of their review activities before the pandemic but discontinued this practice. As

part of REACU, AVAP also carried out structured analyses of the situation of the university system. The agency, however, is not developing any thematic analysis independently.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee and limited coverage of appeals
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (07/12/2021)
RC decision	Compliance

“In its decision of rejection (of June 2020), the Register Committee noted that AKAST’s appeals and complaints procedure did not cover the peer institutional evaluation procedures and that the appeals were only considered by the same committee that also took the appealed decision. While AKAST agreed to revise its procedure and to establish a complaints committee consisting of independent members, the Register Committee remained unable to follow the panel’s judgment of compliance since the procedure was not yet in operation and the committee handling appeals has not been elected. 8. The panel notes that AKAST has now a revised complaints and appeals regulation and has elected a Complaints Committee at the AKAST General Meeting on 28/01/2021. In the description of the provisions for complaints (AKAST Complaints and Appeals Regulations as amended on 28/01/2021), the agency noted that the Complaints Committee’s statement is to be taken into account in the final decision of the Executive Board or the Accreditation Committee and that further details shall be regulated in the rules of procedure issued by the Complaints Committee and approved by the Executive Board.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	3.3 Independence
Keywords	Independence of formal outcomes
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (07/12/2021)
RC decision	Compliance

“In its past review the Register Committee noted that AKAST was subject to the vigilance of the German Bishops’ Conference and that its influence extended to giving consent for the admission of members of the association and the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and the Board, and the approval of each of the accreditation decision by the member of the Commission for Science and Arts (Commission VIII) of the German Bishops’ Conference. Due to these interlinkages, the Register Committee concluded (see decision of 30/11/2019) that AKAST did not comply with ESG 3.3. The Register Committee in particular found the requirement that each accreditation decision requires the consent of the representative of the German Bishops’ Conference (member of the Accreditation Committee) to be in contrast with the requirement of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	3.4 Thematic analysis
Keywords	Lack of development in preparing thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. The panel notes that AKAST reliably contributes the experience gained from its own quality assurance procedures to the regular evaluation of the Key Points and that the agency is documenting the results of its ongoing student survey on its website.

18. The Register Committee welcomes AKAST’s plan to further develop a thematic analysis after an appropriate number of programme accreditation procedures have been completed, but underlined that such an analysis has not been finalised.

19. Considering the limited development of thematic analysis, the Register Committee can follow the review panel conclusion that AKAST complies only partially with ESG 3.4.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.2 Designing methodologies fit for purpose
Keywords	no ownership or full responsibility resting with a single actor, consequences for improvement
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Compliance

“9. The panel noted that no actor had ownership or full responsibility for the entire accreditation system and process, since the specimen decree appoints specific responsibilities to both GAC and the agencies.

10. The Register Committee sought further clarification from the panel as to how that impacted continuous improvement and development. The panel noted that opportunities for improvements were discussed actively; the ongoing review of the Specimen Decree was an example of that. The panel, however, saw a lack of GAC itself assuming a more proactive, coordinating role and taking responsibility for the system as a whole; this would be reasonable given its unique and pivotal position.

11. The Register Committee concluded that continuous improvement seems to be ensured despite the distributed responsibilities and thus concurred with the panel's conclusion that GAC complies with standard 2.2; the issues related to GAC's role and strategy are considered under standard 3.1 below.”

Full decision: see agency register entry