Database of Precedents

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

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

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

Full decision: see agency register entry

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

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

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

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

Full decision: see agency register entry

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

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

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

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

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

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

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.2 Designing methodologies fit for purpose
Keywords	Fitness for purpose difficult to fully assess due to dispersed methodologies
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. At the time of the review the methodologies were dispersed across different documents including ministerial decrees, other regulatory documents, and procedural guidelines, making it challenging to find information on each of the activities in a comprehensive manner. While the Register Committee could follow the panel’s conclusion that the agency complies with the standard it highlighted the panel’s recommendation that the agency should more explicitly define and consistently publish the purpose and aims of each of its external quality assurance activities.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.3 Implementing processes
Keywords	Difficulties in verifying that all procedures are pre-defined and published
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“16. The Register Committee understood that although ANVUR generally implements all stages of the review (self-assessment, site visit, report, follow-up), there are certain exceptions: site visits are not mandatory in the initial (ex ante) accreditation while the follow-up of the newly accredited institutions is only conducted via the periodic assessments.

17. The Register Committee learned from the analysis of the panel that ANVUR is lacking a comprehensive and published description for each external quality assurance procedure that would serve as an overarching guide (see also ESG 2.2). Due to this, the agency cannot ensure that its external QA processes are pre-defined and published, which could further endanger the consistent implementation of these processes and of their individual phases.

18. In its additional representation, ANVUR demonstrated that since the site visit, the agency published a Manual which comprehensively compiles, describes and explains all external QA activities of the agency in detail.

19. The Register Committee could verify that now ANVUR’s procedures are pre-defined and published, and was able to concur with the panel’s conclusion that ANVUR complies with ESG 2.3.”

Full decision: see agency register entry

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

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

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

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

Full decision: see agency register entry

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

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

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

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

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

Full decision: see agency register entry

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

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

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

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

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

Full decision: see agency register entry

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

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

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

Full decision: see agency register entry

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

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

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

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

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.5 Criteria for outcomes
Keywords	Lack of clear deliberation rules
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“7. In its last decision for renewal of registration (of 2019-11-05), the Register Committee found that CTI only partially fulfilled the requirements of the standard as the consistency in their decision making was not always assured - the Committee noted a lack of clear deliberation rules detailing the basis upon which specific decisions were made.

8. The Register Committee noted that CTI has introduced a new tool for ensuring consistency in its decision making – a deliberation table, used for synthesizing the panel assessments. Furthermore, the Committee understood from the analysis of the panel that the deliberation tables ensure consistency in the decision making process and make the review process more transparent.

9. Following the recent developments regarding the introduction of the new tool and its impact on consistency of the outcomes of CTI, the Register Committee was able to concur with the panel's conclusion, and found that now the agency complies with the standard.”

Full decision: see agency register entry

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

“10. In the previous decision for renewal of registration (of 2019-11-05), the Register Committee found CTI to be partially compliant with the standard as it only published summary of evaluation reports which lacked important details from the full reports.

11. From the external review report, the Register Committee learned that a new template, which includes the full report, was introduced. Furthermore the Committee understood from the analysis of the panel, since 2019, CTI started publishing in full all of its reports.

12. Having addressed the earlier concern regarding publication of full reports, the Register Committee concurred with the panel’s conclusion and found that the agency now complies with the standard. The Committee, however, underlined the panel’s recommendations that the agency ensures that the reports are more analytical, their clarity and soundness are improved as well as their visibility on the agency's website.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.3 Implementing processes
Keywords	Follow-up
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“11. The Register Committee, noted in the analysis by the panel that evalag’s review procedures include a self-assessment report and an external assessment followed by expert’s report, but no follow-up activities, unless related to conditions/requirements established by evalag when taking the corresponding decision.

12. Given the concerns on the lack of consistent follow-up in all of evalag's procedures the Register Committee concurred with the panel that evalag complies only partially with the standard.”

Full decision: see agency register entry

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

“13. The Register Committee understood that the panels involve students and other stakeholders on equal bases. Furthermore, the Committee learned that despite the regular (online) trainings offered by the agency, very few people have enrolled for this online trainings.

14. The Register Committee therefore followed the panel’s conclusion that the agency continues to comply with the standard. The Committee, however, shared the panel’s view that the agency should find ways into making training opportunities more attractive for the reviewers to attend.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.7 Complaints and appeals
Keywords	Definition of terms; Complaints; Appeals
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. The Register Committee noted that the Complaints and Appeals Policy is detailed, covering the potential causes for a complaint or an appeal and it is easily accessible on the agency’s website. However, the Committee noted the panel’s concerns on the need to clarify the terms ‘complaints’ and ‘appeals’.

16. The Committee, therefore, followed the panel’s conclusion that the agency continues to comply with the standard. The Committee, however, shared the panel’s view that the agency should clarify what is meant by the terms ‘complaints’ and ‘appeals’ in all its documents, including the name of the ‘Complaints Commission’.”

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	Student involvement in governance
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. In its last decision for renewal of registration on EQAR (of 2019-11-05), evalag was found to be partially compliant with the standard as it had no clear overarching strategy, bringing together planning, budgeting and risk assessment. Furthermore, the main decision-making body, the Foundation Board, did not included a student member.

18. From the review report and the panel’s analysis the Register Committee noted that the main shortcomings identified in the previous decision were only minimally improved i.e., the statutory changes in order to involve student member in the Foundation Board, limits their involvement only in specific cases ( “If international standards in the field of study and teaching are dealt with, a student member may be called upon as a permanent or temporary, non-voting guest.”)

19. Furthermore, the Committee understood that evalag, at the time of the review, worked on a new overarching strategy bringing together planning, budgeting and risk assessment, however this strategy was to be approved only in July 2024.

20. Considering the minimal improvements made since the last decision, the Register Committee could not follow the panel’s judgement of compliance and found that evalag complies only partially with the standard.”

Full decision: see agency register entry

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

“21. The Register Committee understood by the panel’s analysis that the agency, since the last review, produced two publication named “Thematic analysis 2018 to mid-2021” and “Thematic Analysis mid 2021 to mid 2023”. However, as noted by the panel “these significantly digressed from the previous approach and in the eyes of the panel could not be taken as reports that describe and analyse the general findings of evalag’s external quality assurance activities as established by the standard. These reports give merely an overview of the most important projects, publications and events in the period under study, more like an annual report.”

22. The Register Committee, could concur with the panel analysis and underlined the panel’s recommendation that the agency should resume the work on thematic analysis, which was abandoned after 2018, particularly in light of the severe changes in the ‘German system’.

23. The Register Committee therefore concurred with the panel that evalag complies only partially with the standard.

24. 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	11/10/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	ESG part 1, implementation in practice
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“10. The Register Committee understood from the analysis by the panel that only one external quality assurance activity, EQA Audit, covered all standards of the ESG Part 1 in full. Both provider accreditation and programme accreditation procedures did not cover ESG Part 1 in full.

11. The Committee learned that during the site-visit the panel was presented with the draft versions of the new Provider accreditation Manual and the new Programme Accreditation Manual and noted that further alignment with ESG Part 1 is expected to be ensured through these documents. In its statement on the report, MFHEA informed that the Provider Accreditation Manual has been published and in use as of January 2024 and the Programme Accreditation Manual will be in use as of January

2025.

12. The Register Committee took note and welcomed the actions taken by the agency. Nevertheless, the Committee could not confirm without a panel insight whether the new standards and procedures have been implemented in practice.

13. In its additional representation, MFHEA confirmed that its Provider Accreditation Manual came into force in January 2024 and that now all provider accreditation procedures follow the new methodology. MFHEA further informed that the Programme Accreditation Manual will be officially presented by the agency in November 2024 (see clarification of 2024-09-24) and the same will be in place for all programme accreditation procedures as of January 2025.

14. The Register Committee welcomed, once again, the actions taken by the agency in order to ensure that all MFHEA activities cover ESG Part 1 in full. Nevertheless, the Committee could not confirm how these changes have been implemented in practice without panel insight. Therefore, the Committee upheld its initial judgement that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.2 Designing methodologies fit for purpose
Keywords	methodology
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. The Register Committee learned that at the time of the site-visit the provider accreditation was a desk-based procedure conducted by the MFHEA’s staff. The Register Committee is concerned about the fitness for purpose of this procedure for regulating providers’ access to the higher education sector. As noted by the panel, the methodology differs for providers seeking university status and for other providers of higher education. The Committee noted that it was unclear for the panel which methodology is applied when.

16. In its statement on the report, MFHEA informed that these concerns have been further addressed in the revised manuals for programme and provider accreditation. Furthermore, MFHEA explained that all procedures now include a site-visit by a review panel (see more under ESG 2.3).

17. The Register Committee took note of the actions taken by the agency. The Committee could however not confirm whether and how the updated procedures are implemented in practice.

18. In its additional representation, the agency reaffirmed that it had addressed the panel’s concerns regarding the provider accreditation procedures in the new manual, which has been in use for all provider accreditation procedures as of January

2024. Furthermore, the agency reaffirmed this will also be addressed for all programme accreditation procedures when the new Programme Accreditation Manual will come into force as of January

2025.

19. The Register Committee welcomed the actions taken by the agency in order to address the concerns raised by the panel and the Register Committee. Nevertheless, the Committee could not confirm how these changes have been implemented in practice without a panel insight. Therefore, the Committee concurred with the panel’s conclusion that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.3 Implementing processes
Keywords	no site visits, inconsistency,
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. The Register Committee learned from the analysis of the panel that only the EQA Audit process is clearly outlined in the audit manual. For the rest of the activities, both the information provided to the panel as well as the publicly available documents, were not always consistent.

21. The Committee noted the panel’s concerns on a number of shortcomings related to the programme and provider accreditation

procedures, such as short application forms instead of self-evaluation reports for some procedures, no site-visits (see also ESG 2.2) and lack of consistent follow-up.

22. In its statement on the report (of 2024-05-20), MFHEA informed that the discrepancies between the documents and the shortcomings related to programme and provider accreditation procedures have been further addressed in the revised manuals for programme and provider accreditation procedures, which have been in use as of January 2024 for provider accreditation procedures and will be, respectively, as of January 2025, for programme accreditation procedures.

23. The Register Committee took note of the revised manuals but could not confirm whether and how these changes are implemented in practice.

24. In its additional representation, the agency reaffirmed that the concerns raised by the Committee for provider accreditation procedures have been addressed in the new Provider Accreditation Manual and the concerns for programme accreditation procedures will be addressed in the new Programme Accreditation Manual.

25. The Register Committee took in consideration the actions taken by the agency in order to address the concerns raised by the panel and the Register Committee. The Committee, however, could not confirm how these changes have been implemented in practice without a panel insight and found that some of them are yet to be implemented. Therefore, the Committee could concur with the panel that the agency complies only partially with the standard.”

Full decision: see agency register entry