Database of Precedents
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2.1 Consideration of internal quality assurance – ECTE – Non-compliance (2022) scope of the ESG, EQF level 5/short cycle, partial qualifications, alternative providers, QF-EHEA as decisive reference point
ECTE
Application Initial Review Full, coordinated by ASIIN Decision of 28/06/2022 Standard 2.1 Consideration of internal quality assurance Keywords scope of the ESG, EQF level 5/short cycle, partial qualifications, alternative providers, QF-EHEA as decisive reference point Panel conclusion Non-compliance Clarification request(s) Panel (03/05/2025)
RC decision Non-compliance “10. The external review panel noted that ECTE accredits institutions and programmes which belong to the “category of post-secondary courses/programmes” and which – in the panel's view – “are not covered by the ESG”. In particular, the panel refers to programmes such as Certificates1 in Theology, Diploma2 in Theology or the Postgraduate Certificate3 in Theology according to Appendix A of ECTE's Standards and Guidelines (see p. 15 of the review report).
11. In its response to EQAR's clarification request, the panel noted that it was “obvious for the panel that both the ESG and EQAR registration only cover formal tertiary education at bachelor and master level (levels 6 and 7 EQF)”4.
12. ECTE – in its standards – portrayed a “Certificate” as a partial qualification at/within EQF level 5 and a “Diploma” as a short-cycle, EQF level 5 qualification. In principle, short-cycle qualifications at EQF level 5 can be considered as part of the QF-EHEA. Moreover, the ESG generally cover higher education in its broadest sense and can also be applied to provision that is not part of a programme leading to a formal degree. [...]
14. Given that EQF level 5 and provision outside full formal degree programmes is not per se excluded from the scope of the ESG, the Register Committee confirmed this in the tripartite Terms of Reference.
15. The Register Committee considered that the distinction made by the panel between accreditation of higher education within the scope of the ESG and “post-secondary education” outside the scope of the ESG cannot be derived from the Terms of Reference, nor from ECTE's own presentation of its work. [...]
28. In the case of an alternative provider, the quality assurance procedure carried out by an EQAR-registered agency might be the only occasion to externally verify whether the education offered by the alternative provider is indeed at higher education level in terms of its learning outcomes. Therefore, the Committee found that attention to ESG Part 1 and in particular ESG 1.2 with its requirement that the qualification resulting from a programme should refer to the correct level of the Qualifications Framework for the European Higher Education Area (QF-EHEA) are of crucial importance in the domain of alternative providers.
29. Given that ECTE accredits a large number of alternative providers (see also under ESG 3.1) the Register Committee underlined that ESG 2.1 was a particularly crucial standard; it sought to ascertain that criteria are robust, fully aligned with the QF-EHEA and applied stringently in all cases, so as to protect the label and designation of what will be perceived as “higher education”.
30. With a view to the discussion on scope above, the Register Committee understood that the review panel clearly did not confirm whether ECTE's criteria for Certificate in Theology, Diploma in Theology and Postgraduate Certificate in Theology are correctly aligned with the QF-EHEA. As noted above, the quotes provided by ECTE from its Certification Framework cannot replace an external panel's analysis of the alignment in theory and practice.
31. As the Register Committee considers the accreditation of such programmes fully pertinent to the application (see above), this necessarily leads to a conclusion of non-compliance with ESG 2.1 as well.
32. The QF-EHEA further expects that students “have demonstrated knowledge and understanding in a field of study” upon completion of their studies. In general, ECTE's standards state that “theology” was the field of study they refer to. [...]
35. ECTE generally refers to the European Qualifications Framework for Lifelong Learning (EQF) in its framework and communication. While the Register Committee saw this as a legitimate choice, the Committee underlined that the analysis and formal assessment in respect of ESG 2.1 always need to refer to the QF-EHEA descriptors as a benchmark, given that the QF-EHEA is the framework adopted by the EHEA and referred to in ESG 1.2.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – ECTE – Partial compliance (2022) scope of the ESG, alternative providers, transparency of provider status, use of Bachelor and Master by alternative providers, need for clear distinction
ECTE
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 (03/05/2025)
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
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2.4 Peer-review experts – ACQUIN – Partial compliance (2021) Strength of the training for reviewers
ACQUIN
Application Renewal Review Full, coordinated by ENQA Decision of 13/12/2021 Standard 2.4 Peer-review experts Keywords Strength of the training for reviewers Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The training for experts relies mainly on sending materials to the experts and their self-
preparation and group briefings at the beginning of the review”
Full decision: see agency register entry
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2.6 Reporting – ACQUIN – Compliance (2021) Consistency in the content and publication of the reports
ACQUIN
Application Renewal Review Full, coordinated by ENQA Decision of 13/12/2021 Standard 2.6 Reporting Keywords Consistency in the content and publication of the reports Panel conclusion Partial compliance Clarification request(s) – RC decision Compliance “The agency publishes its reports on the website. The panel noted that, however, the structure of the reports and their publishing was not always consistent and that for some procedures the reports included summary information only. In their response to the review report, the agency explained that it now uses a template provided by GAC which enables a better structured and
standardised reporting. The agency is currently updating its database and
tackling the technical issues leading to an inconsistent report publishing. The Register Committee found that the agency has taken concrete
steps to address the issues related to the consistent drafting and publishing of its reports”
Full decision: see agency register entry
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3.6 Internal quality assurance and professional conduct – ACQUIN – Partial compliance (2021) Weak management of staff development and not addressing earlier flags
ACQUIN
Application Renewal Review Full, coordinated by ENQA Decision of 13/12/2021 Standard 3.6 Internal quality assurance and professional conduct Keywords Weak management of staff development and not addressing earlier flags Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “Partial compliance due the need for a more structured management of the professional development of the staff and the lack of a comprehensive response to the issues raised in the previous external reviews (i.e. instances of partial compliance from the previous renewals of the registration: the training of experts (ESG 2.4) is still weak (a concern raised in 2011) and the publication of thematic analyses (ESG 3.4) remains not systematic (a concern raised in 2016).)”
Full decision: see agency register entry
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2.4 Peer-review experts – ZEvA – Partial compliance (2022) monitoring expert training, experts trained by other agencies
ZEvA
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 2.4 Peer-review experts Keywords monitoring expert training, experts trained by other agencies Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “19. In addition,the review panel noted that the proportion of experts who take part in training had increased, but not sufficiently in the panel's view. The panel also considered that the process for recruitment and selection of experts was largely informal.
20. The Register Committee welcomed the newly introduced systematic monitoring of experts' training and prior experience, as explained in ZEvA's representation. The Committee agreed that ZEvA may of course rely on experts who were previously trained by other agencies operating in Germany.
21. At the same time, the Committee considered that 50% was not a very ambitious goal for the share of formally trained experts. Moreover, the Committee had some doubts whether prior experience should be considered entirely equal to a formal training.
22. While the Register Committee welcomed that the involvement of students was now ensured and that ZEvA is taking steps to enhance the formal training of experts, the Committee considered that the level of formal expert training remained weak to date. The Register Committee was therefore unable to concur with the panel, but considered that ZEvA only partially complies with the standard.”
Full decision: see agency register entry
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2.6 Reporting – ZEvA – Compliance (2022) responsibility to publish reports also when not submitted to GAC
ZEvA
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 2.6 Reporting Keywords responsibility to publish reports also when not submitted to GAC Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “23. The Register Committee concurred with the panel's conclusion that ZEvA complies with the standard; the Committee further underlined that ZEvA is responsible to ensure that all reports are ultimately published on its own website and on DEQAR, including those that are never submitted to GAC by the institution under review.”
Full decision: see agency register entry
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2.7 Complaints and appeals – ZEvA – Partial compliance (2022) requirement that appeals can be made against any report
ZEvA
Application Renewal Review Full, coordinated by ENQA Decision of 14/03/2022 Standard 2.7 Complaints and appeals Keywords requirement that appeals can be made against any report Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “25. The Committee underlined that any report is a formal outcome and thus needs to be open to appeal, even if it does not result in a yes/no decision.
26. In its additional representation, ZEvA clarified matters for evaluation reports. At the same time, it remained unclear whether and how institutions can appeal accreditation reports before submitting those to GAC. Even though GAC offers an appeals possibility, presumably GAC's process cannot fully investigate matters that are rooted in the report produced outside of GAC's direct control. Moreover, it would be unreasonable that institutions are forced to first submit to GAC a report against which they have strong objections before they can appeal against that report.”
Full decision: see agency register entry
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2.4 Peer-review experts – ACPUA – Partial compliance (2021) Involvement of students in panels
ACPUA
Application Renewal Review Full, coordinated by ENQA Decision of 15/10/2021 Standard 2.4 Peer-review experts Keywords Involvement of students in panels Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “The Register Committee learned that the absence of student
members in the panels in the two activities is due to the specificity of the
processes; the procedures focus on quantitative indicators on teaching
offering and the human, material and financial resources. The Committee, however, understood that the process goes beyond a
purely technical check of numbers, as it generally involves other experts also
making a qualitative assessment. The Committee could not agree with the
panel’s conclusion that the “student perspective could not add any value” in
those procedures and considered that the students’ views could offer an
important insight into the matters under observation in both activities”
Full decision: see agency register entry
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2.7 Complaints and appeals – FINEEC – Partial compliance (2022) Lack of formal complaints procedure; Appeals limited to negative decisions only
FINEEC
Application Renewal Review Full, coordinated by ENQA Decision of 27/06/2022 Standard 2.7 Complaints and appeals Keywords Lack of formal complaints procedure; Appeals limited to negative decisions only Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The institutions undergoing a review by FINEEC are limited to make an appeal only in a case of a negative
outcome.That the remarks on the review process are given in an informal manner.”
Full decision: see agency register entry
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2.7 Complaints and appeals – AI – Partial compliance (2021) Lack of formal complaints procedure and appeals' procedure
AI
Application Renewal Review Full, coordinated by ENQA Decision of 15/10/2021 Standard 2.7 Complaints and appeals Keywords Lack of formal complaints procedure and appeals' procedure Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The appeals process remains to be led by an external body. The agency is not handling any formal complains or appeals itself.”
Full decision: see agency register entry
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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
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3.6 Internal quality assurance and professional conduct – AI – Partial compliance (2021) Informal approach to IQA; Not addressing flags from previous review
AI
Application Renewal Review Full, coordinated by ENQA Decision of 15/10/2021 Standard 3.6 Internal quality assurance and professional conduct Keywords Informal approach to IQA; Not addressing flags from previous review Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “AI has adopted an overall framework for internal QA, which is publicly available. The panel, however, found that agency’s approach to internal QA is often informal and flexible. This was reflected in the self-evaluation report,
which the panel found to be lacking self-reflexivity and deeper analysis of agency’s internal needs. The Register Committee noted that the agency has not addressed the issues that led to a partially compliant conclusion in the
previous decision for renewal of registration (namely ESG 2.7 and ESG 3.1).”
Full decision: see agency register entry
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2.1 Consideration of internal quality assurance – AAQ – Partial compliance (2021) Incomplete coverage of Part 1 of the ESG
AAQ
Application Renewal Review Full, coordinated by ENQA Decision of 02/07/2021 Standard 2.1 Consideration of internal quality assurance Keywords Incomplete coverage of Part 1 of the ESG Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The panel noted that AAQ does not cover ESG 1.3 (Student-centred
learning, teaching and assessment) and covers ESG 1.2 (Design and
approval of programme) only partially in the criteria for institutional
accreditation. These standards are only fully covered in programme accreditation,
which is voluntary except for health professions. As institutional
accreditation is the core activity of the agency and the only mandatory
external quality assurance for all Swiss institutions, it should assure full
coverage of ESG Part 1 by itself.”
Full decision: see agency register entry
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2.2 Designing methodologies fit for purpose – AAQ – Partial compliance (2021) Using feedback for improving methodologies
AAQ
Application Renewal Review Full, coordinated by ENQA Decision of 02/07/2021 Standard 2.2 Designing methodologies fit for purpose Keywords Using feedback for improving methodologies Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee welcomed the diverse methods used by the agency
for gathering feedback from different stakeholders, but could
not confirm that the reflections are efficiently and systematically used in the
improvement of the activities. The findings indicate that the
feedback is only sporadically used in the improvement of the agency’s
external QA activities.”
Full decision: see agency register entry
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2.6 Reporting – AAQ – Partial compliance (2021) Publication of reports depends on the agreement with the HEIs; Lack of publication of negative reports
AAQ
Application Renewal Review Full, coordinated by ENQA Decision of 02/07/2021 Standard 2.6 Reporting Keywords Publication of reports depends on the agreement with the HEIs; Lack of publication of negative reports Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The panel pointed out that publication of AAQ’s reports is subjected to contract between the agency and the university. Such arrangements
primarily derive from the legal framework in Switzerland, which does not prescribe obligatory publication of reports. In practice, the agency has so far published all reports that led to a positive decision. The Register Committee learned that the agency has not published any
negative decisions on its website. In addition, the panel noted that on systemic level, there was no intention for discussing this matter further, and publishing of the reports with a negative outcome was not on the political agenda of the stakeholders.”
Full decision: see agency register entry
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2.1 Consideration of internal quality assurance – AKAST – Compliance (2020) Narrow focus in addressing Part 1 of the ESG
AKAST
Application Initial Review Full, coordinated by GAC Decision of 22/06/2020 Standard 2.1 Consideration of internal quality assurance Keywords Narrow focus in addressing Part 1 of the ESG Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The panel stated that requirements of ESG Part 1 are reflected in AKAST’s own guidelines for institutional evaluation and that the new review criteria to be applied by AKAST for accreditation of canonical study programmes in Germany follows the ESG. The Register Committee found the review panel’s analysis brief and lacking in analysis. However the Committee took note of the “equivalence” table” provided by the agency, mapping how ESG 1.1 to 1.10 are addressed in the agency’s programme accreditation procedures and found that standards are addressed implicitly, with a limited coverage, in particular with regards to ESG 1.1, ESG 1.3 and ESG 1.4.”
Full decision: see agency register entry
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2.2 Designing methodologies fit for purpose – AKAST – Compliance (2020) stakeholder involvement in the development of methodology
AKAST
Application Initial Review Full, coordinated by GAC Decision of 22/06/2020 Standard 2.2 Designing methodologies fit for purpose Keywords stakeholder involvement in the development of methodology Panel conclusion Full compliance Clarification request(s) Panel (03/05/2025)
RC decision Compliance “The Register Committee was unclear how the agency has developed its accreditation criteria and whether stakeholders were involved in the design of AKAST methodologies and has therefore asked the panel for further clarifications. The panel explained that Germany’s new legal framework defines the procedures for QA agencies carrying out their accreditations within Germany and that the German Accreditation Council (GAC) is entrusted with overseeing this process. The GAC has issued reporting templates and defined the structure of review reports as well as self-evaluation reports for higher education institutions, following the criteria established in the Specimen Degree, which follow the ESG.”
Full decision: see agency register entry
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2.6 Reporting – AKAST – Compliance (2020) publication of negative reports
AKAST
Application Initial Review Full, coordinated by GAC Decision of 22/06/2020 Standard 2.6 Reporting Keywords publication of negative reports Panel conclusion Full compliance Clarification request(s) Panel (03/05/2025)
RC decision Compliance “As not all reports were published on the agency’s website, the Register Committee was unclear whether the agency publishes all its review reports, including those with a negative result. The panel explained that while AKAST has not published reports right from the beginning of its activities, that the agency has been making available the review reports following the implementation of the new legal framework in Germany. As GAC has assumed the task of keeping a central register for all accreditation records, all the reports by AKAST will be made available in its register (including negative and older accreditations). The panel further added that at the time of the review, AKAST had not taken any negative accreditation decisions, and if it were to do so in the future, AKAST would have to publish it.”
Full decision: see agency register entry
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2.7 Complaints and appeals – AKAST – Partial compliance (2020) Impartiality in handling appeals (independence of the Appeals Committee). Coverage of all EQA activities by the appeals procedure
AKAST
Application Initial Review Full, coordinated by GAC Decision of 22/06/2020 Standard 2.7 Complaints and appeals Keywords Impartiality in handling appeals (independence of the Appeals Committee). Coverage of all EQA activities by the appeals procedure Panel conclusion Full compliance Clarification request(s) Agency (03/05/2025)
RC decision Partial compliance “The Register Committee underlined that the current arrangements does not ensure an impartial process in AKAST’s approach of handling appeals, since the appeals are considered by the same committee that also takes the accreditation decisions and nominates the review panel members for the review. The Register Committee further noted that the appeals and complaints procedure only cover issues concerning two of AKAST’s activities and it does not address the agency’s peer institutional evaluation procedures. While AKAST has not yet carried out any such evaluation, the Register Committee underlines that, since the activity is on offer, the agency is expected to ensure that all corresponding procedures will be adequately updated, including the agency’s appeals and complaints procedure.”
Full decision: see agency register entry