Database of Precedents

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	2.4 Peer-review experts
Keywords	Student involvement in panels
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that QANU has, since its last review, taken steps towards the inclusion of students in the assessment of research units/PhD programmes. QANU agreed with VSNU, KNAW and KWO (the organisations who developed the Standard Evaluation Protocol for these assessments) to include students on the experts panels in the form of a pilotscheme, starting in

2019. The Register Committee found that QANU has so far finalised one assessment of a research unit/PhD programme in 2019 (report published as of 15 March 2019), but that the expert panel for that review did not include a student.While the Register Committee recognised and welcomed the clear stepstaken by QANU so far, it considered that the involvement of students on research unit/PhD assessment panels is so far at the stage of a pilot and notyet implemented in practice. The Committee was therefore unable to concur with panel’s conclusion of (substantially) compliant but found that QANU stillcomplies only partially with ESG 2.4. The Register Committee further underlined the review panel’s recommendation to ensure that students become a constituent element of the research units/PhD programme assessments panels. The Committee further added that students involvement should not be limited to the assessment of specific aspects, but that they are to be fully involved along all expert panel members.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	2.7 Complaints and appeals
Keywords	Absence of the body responsible for handling complaints (established in renewal)
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that QANU has revised its complaints and appeals procedure and established an independent committee to consider its appeals.The panel noted that institutions can now submit an appeal against all external quality assurance activities of QANU and the decisions are taken by an Appeals Committee, instead of QANU’s director.The panel’s analysis further show that QANU offers the possibility to institutions to express their dissatisfaction about the conduct of the external quality assurance activity carried out by QANU or misbehaviour of people acting on behalf of the agency. The agency has also established different processes in the handling of complaints i.e. if a complaint refers to the behaviour of a staff member of QANU this is processed by the director; if a complaint is about the director of the agency, the complaint is processed by the chair of the Board etc.Having considered the changes put in place by QANU since its last external review, the Register Committee was able to follow the panel’s judgement that QANU now complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of QA and consultancy activities
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that the agency put in place a policy regarding the separation of the agency’s consultancy and assessment activities which dictates that if a project coordinator is involved in providing consultancy services to a higher education institution, he/she is not allowed to act as a secretary in an assessment procedure for a period of at least five years. The panel further commented that QANU’s management have shown high awareness of of the need to avoid conflicts of interest and to ensure QANU’s independence in its activities. With regards to the stakeholder involvement in the governance and work of the agency, the panel found that QANU has formalised the involvement of students in the Board of the agency following its change in Statutes. While the Register Committee welcomed the involvement of students, the Committee further underlined the panel’s recommendation of ensuring a broader stakeholder involvement in the agency’s governing structure. In view of the changes introduced by the agency the Register Committee was able to follow the panel’s conclusion that QANU complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.4 Thematic analysis
Keywords	Introduced policy for thematic analysis
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee learned that QANU approved a new policy for thematic analysis in October 2018, which defines explicit aims and objectives for various analysis. The panel stressed that QANU acknowledged its responsibility for producing thematic analysis as a way of contributing to the further development of the university research sector in the Netherlands. The panel further added that QANU has demonstrated capacity to use the experiences it gathered, to reflect on them, to share them and to publish outcomes through thematic analysis. Following the evidence and analysis provided by the panel, the Register Committee concurred with the panel’s conclusion that QANU now complies with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Internal quality policy
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“ The panel confirmed that the agency had some procedures and processes in place aiming to support, reflect and improve its own day-to-day operations (i.e. Quick Reference Guide, annual reports, bi-weekly staff briefings, evaluation of assessments). The panel found that QANU did not have an internal quality assurance policy or an integrated quality management system (related to i.e. human resources, briefing of panels, collegial feedback on draft reports). In its additional representation the agency argued that the necessary components of a quality policy are in place and described briefly in QANU’s Quick Reference Guide. In terms of a cohesive and integrated quality plan the agency stated that it had started developing such a plan that will be an integration of the processes and procedures QANU has in place. Given the commendations by the panel on the internal quality assurance processes, e.g. good procedure for monitoring and improving the quality of the staff, good quality of assessment reports, QANU stated it did not understand the Committee’s conclusion of partial compliance.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.6 Reporting
Keywords	Lack of public reports for evaluations of new institutions (authorisation)
Panel conclusion	Full compliance
Clarification request(s)	Agency (16/07/2025)
RC decision	Partial compliance

“The panel noted that the assessment of institutions' programmes development plans is “a procedure to authorise their operation” (under ESG 2.3) and that the resulting reports "'are all issued on demand from universities and are not published' because programmes have not started yet” (under ESG 2.6).

The standard requires that all reports be published for all external quality assurance activities. Based on the information in the report the Register Committee understood that the assessment of institutions' programmes development plans is part of an authorisation process in which institutions are assessed against preset criteria, and thus should be considered a quality assurance process. Unlike for consultancy services or similar, which would be outside the scope of the ESG, the Register Committee therefore considered that the standard applies here.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.4 Thematic analysis
Keywords	absence of regular analysis based on agency’s findings
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel specifically recommended that the agency “publishes reports of thematic analysis every year”. While the standard requires that such analyses be published "regularly”, it does not impose a specific cycle.

The Register Committee therefore underlined that this recommendation should rather be considered a suggestion.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.6 Internal quality assurance and professional conduct
Keywords	not clear how agency ensures ESG compliance when using non-registered QAAs’ results
Panel conclusion	Full compliance
Clarification request(s)	Panel (16/07/2025)
RC decision	Partial compliance

“The panel pointed out that it was “assured by the agency that the same criteria and guidelines were applied”. The panel noted it had discussed the issue with the madri+d Accreditation Commission, which “confirmed its focus on being assured that meeting the ESG standards are a key focus of such accreditations”.

The external review report and the panel’s clarification did not refer to any evidence or further details to support this assurance. The Register Committee noted that at least two actual cases (accreditation based on ABET accreditation, https://data.deqar.eu/report/8971/ and https://data.deqar.eu/report/9129/) raised concerns insofar as the ABET reports, forming the basis for these decisions, are not published as required in ESG 2.6.

The rather generic statements, combined with these two examples, did not demonstrate sufficiently how ESG compliance is assured for reports by other, non-registered agencies. The Register Committee was therefore unable to concur with the panel's conclusion, but considered that madri+d only partially complied with standard 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.3 Implementing processes
Keywords	Lack follow-up procedures
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“ In its previous decision of inclusion (05/06/2015) the Register Committee flagged for attention whether follow-up procedures were introduced for degree assessments between the first ex-post accreditation and consecutive periodic re-accreditations. ACSUCYL has since its last review introduced a new system of annual follow-up procedures. The panel also confirmed that it was convinced that the follow-up procedures are well and consistently implemented. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.4 Peer-review experts
Keywords	student involvement
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (16/07/2025)
RC decision	Compliance

“The review panel noted that “when the nature of the assessment in question so requires, every effort is made to include non-academic experts [...] as well as students who are experienced in quality assessment in higher education“ (ERR, p. 39). As the Register Committee found the analysis unclear as to whether students are consistently involved in all ACSUCYL’s review panels, the Committee asked the panel for further clarifications. The panel explained that all evaluation procedures within the scope of the ESG include one student member. The panel further added that students are regarded as equal members of peer review expert panels.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.6 Reporting
Keywords	publication of negative reports
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (16/07/2025)
RC decision	Compliance

“While ACSUCYL publishes the results of its external evaluations, the Register Committee was unclear on whether the agency also makes public the assessment reports with a negative result. The Register Committee therefore sought further clarification from the panel. In its clarification response, the panel stated that according to ACSUCYL’s handbook, the assessment reports are published once the University Council, the body responsible for taking the formal decision concerning verification and modification of curricula takes its decision. The panel added that it does not have any indication to show that negative reports of this activity are not published (in case a decision is taken).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee; Clarification of appeals’ procedure
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous decision for renewal, the Register Committee flagged for attention the appeals system, as the panel recommended that ACSUCYL should revise its appeals system so that a separate committee handles appeals. The external review panel confirmed in its external evaluation report that ACSUCYL established an independent body, the Guarantees Commission, that is responsible for examining appeals or complaints in areas where the agency is competent. For procedures where the final decision belongs to the University Council or Regional Ministry (i.e. verification/modification, accreditation renewal, evaluation to create, recognize, modify or withdraw university centres), the appeal is considered by the corresponding decision making body. ACSUCYL provides input into the consideration of these cases, but it does not decide. Within ACSUCYL, the request will be sent to the Guarantees Commission, which consults the relevant Assessment Commission, before preparing an answer. If the appeal is granted, ACSUCYL will be requested to review its earlier conclusion. The Register Committee underlined that ACSUCYL’s complaints policy should communicate better that higher education institutions have the possibility to raise matters about the conduct of the process or those carrying it out (i.e. complaints in the understanding of the ESG), even in such procedures where the final decision is taken by other bodies.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of students in agency’s decision making
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (16/07/2025)
RC decision	Partial compliance

“There is a lack of student representation. Students are neither involved in the governing body nor in the bodies that review and design the agency’s procedures or take decisions on the adoption of such procedures (Governing and Advisory Board). The agency stated (in its Statement to the Review Report) that the Student Board is an Advisory Body and that students can contribute in that capacity to the governance and work of the agency. The Committee underlined the limited involvement of students in the agency’s governance and work. While the legislation does not prescribe their involvement in the agency’s Board of Directors, ACSUCYL may nevertheless improve its consultation process and also request a change of its current legal framework.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.3 Independence
Keywords	Organisational independence; Appointment of the members by minister
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“In terms of organisational independence, the evidence presented by the panel shows that members of the Governing Board are appointed by the regional minister responsible for universities and that the Governing Board has a strong representation of its regional Government, including the Chairperson. The agency is largely dependent on the regional Government also for the approvals and hiring of new staff and the annual approval of its budget. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/11/2020
Standard	2.6 Reporting
Keywords	Quality of reporting
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Considering the quality of reports, the Committee considered the panel’s assessments that BAC’s reports “still fail to completely meet the expectations of this standard as they are not yet ‘full’ reports” (Review report p. 40)

24. The panel further pointed out that the reports provide limited qualitative insight and there was no evidence of how the Accreditation Committee was able to consider the effectiveness of a higher education institution’s internal quality assurance process. In its additional representation BAC stated that it is in the process of addressing the shortcomings of its reporting format and that it is committed to publishing the negative outcomes of its reviews While the Register Committee acknowledged agency’s progress towards more qualitative reportin,, the Committee noted that a full redraft of BAC’s reporting template is only expected to be completed in the following years”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/11/2020
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to thematic analysis; Quality of analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel found that BAC’s thematic review report provided a limited analysis, and was rather descriptive by simply summarising the content of inspection reports. Overall, the review panel felt there were still significant weaknesses in BAC’s approach to thematic analysis. In its additional representation, BAC agreed with the assessment of the panel and committed to prepare more meaningful thematic analysis that will serve to improve key areas related to the agency’s work by January 2021.While the Register Committee acknowledged the agency’s work towards improving its thematic analysis, the Committee remarked that such changes have not yet been implemented.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.1 Consideration of internal quality assurance
Keywords	Part 1 insufficiently covered; Lack of clear guidance what should be evaluated by experts
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Reviewing each of the agency’s procedures individually the review panel showed that the independent evaluation procedure (international accreditation of educational programmes) does not sufficiently cover aspects related to ESG Part 1, concerning student- centred learning and teaching, the system for consideration of students’ appeals and complaints.In its additional representation the agency stated that new indicators have been added covering these matters and provided a full self-assessment with the mapping of its criteria to the ESG. In case of professional-public accreditations the panel was not able to gather conclusive evidence about what criteria are checked by the expert panel in these reviews. Following the analysis of AKKORK’s own standards and their correlation with ESG (according to the agency’s additional information) the Register Committee took note of the mapping and revisions, but could not conclude whether all concerns of the panel have been addressed. The Committee further underlined that the revised criteria still had to be officially approved, tested and implemented by AKKORK in its professional-public accreditation procedures. The Register Committee noted that experts do not have clear guidelines on what they are expected to evaluate and how to refer back to the agency’s own criteria. In its additional representation AKKORK provided its revised guidelines (as of 30/01/2020) describing its procedures and the assessment criteria that experts are expected to follow. The Register Committee welcomed the revised version of the guidelines, but noted that its use and implementation has yet to be reviewed by an external review panel. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.2 Designing methodologies fit for purpose
Keywords	Clarity of activities; lack of stakeholder involvement in the development of methodologies and criteria;
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“Considering the design of AKKORK’s methodology of external QA procedures, the panel noted that the aims of the different activities were not clearly differentiated and that there were inconsistencies between the different language versions of the AKKORK ‘s website (English and Russian). In its additional representation the agency responded that it has made revisions to the information on its website. While the Register Committee could verify the publication of the procedures, the Committee further noted that the agency also has ‘on offer’ the activity quality assurance of educational programmes on the level of higher education and remains to demonstrate that the activity has been defined and designed to achieve the objectives set for it, as required by the standard. The panel further commented on the lack of involvement of external stakeholders, apart from the representatives from its own bodies, in the design and continuous improvement of the offered procedures. The agency commented in its additional representation that it has developed a Regulation on collaboration with partners designed to be implemented in AKKORK’s daily routine. The Register Committee welcomed the thorough work in the development of a cooperation regulation with stakeholders, but could not confirm that the Regulation is already in effect as no evidence of the stakeholders' engagement was provided for in the recent substantive changes introduced by the agency. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.3 Implementing processes
Keywords	Lack follow-up procedures
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“In its decision of inclusion, the Register Committee noted that AKKORK’s follow-up procedures were not consistently implemented for all off the agency’s external quality assurance activities and therefore flagged this matter for future attention. In its 2019 review report, the panel showed that AKKORK had taken steps to address its flag by including follow-up processes as part of its contracts with higher education institutions. The panel found that - while follow-ups are not part of all contracts signed with the reviewed institutions, that they are nevertheless carried out after a conditional accreditation. The panel further underlined a number of shortcomings related to AKKORK’s independent accreditation reviews at institutional level and AKKORK’s IQAS procedures. Since these procedures are no longer on offer by AKKORK, the Register Committee found that the panel’s concerns were therefore addressed”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.4 Peer-review experts
Keywords	student involvement; Mismatch between number of experts enlisted in the reports and number of experts required according to agency’s review methodology; Unavailability of some reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged AKKORK’s involvement of students in its previous decision of inclusion. The panel received confirmations during its multiple interviews that all of AKKORK’s peer review expert groups now included a student member.

The panel’s findings nevertheless show inconsistencies in the number of experts, listed by AKKORK in its published reports and the number of experts expected to be involved according to AKKORK’s own methodology. In particular, the review panel expressed concerns about the use of single experts for professional-public accreditations, although it was told that not all panel members were in fact listed in the prepared reports. The panel therefore concluded that while the formal procedure in the composition of review panel was met on paper, the practice differed. The Register Committee noted from AKKORK’s additional representation that its procedures are published, but noted that the above raised concerns were not addressed and remain unresolved. The Register Committee noted from the statement by the agency - in its further information on the report and additional representation - that the links have been checked and all review panel members are now listed in the published reports. Following a check of the agency’s website, the Register Committee found that a number of reports still have broken links (see the agency’s Register of programmes, under the Russian version of its website). ”

Full decision: see agency register entry