Database of Precedents
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3.1 Activities, policy and processes for quality assurance – CTI – Compliance (2019) Involvement of students in the governance
CTI
Application Renewal Review Full, coordinated by ENQA Decision of 05/11/2019 Standard 3.1 Activities, policy and processes for quality assurance Keywords Involvement of students in the governance Panel conclusion Full compliance Clarification request(s) Panel (14/07/2025)
RC decision Compliance “The Register Committee noted that the legal regulation over CTI’s governing structure limits the involvement of students in the agency’s formal bodies. The Committee has asked the panel to clarify whether the agency has taken any steps towards changing its legal framework and involving students in its governance. In its clarification response the panel emphasised the positive collaboration and involvement of students in the work of CTI but also admitted that students are not involved in the final decision making processes of CTI. The panel noted that students participated in the work of CTI as part of review panels, meetings and training activities along with CTI members and that the student union is consulted in the revision of CTI’s frameworks and guidelines. The panel argued that the involvement in CTI’s ‘committee’ would be very time consuming, as members fulfil the equivalent of one fourth to one half of a full time position and that in practice this would not lead to a significant increase in students participation. The panel concluded therefore that, given the reactions of all stakeholders, including the students, CTI was in (full) compliance with ESG 3.1. Given that CTI in practice ensures the regular consultation of students, considering that students did not request to be represented in the CTI’s Commission and due to their limited capacity to meet the expected workload, the Register Committee was therefore able to concur with the panel’s conclusion that CTI complies with the standard. The Committee further concurs with the panel’s remarks that students (and international experts) can add value to the governance of CTI, even though their expected overall workload for CTI could be more limited. The Register Committee also underlined the recommendation of the panel to recognise the official status of students in CTI’s governance. The Committee added, that in order to allow for the possibility of students’ involvement in the governance of CTI, a change in the legislative restrictions should be considered.”
Full decision: see agency register entry
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3.3 Independence – CTI – Compliance (2019) Operational independece
CTI
Application Renewal Review Full, coordinated by ENQA Decision of 05/11/2019 Standard 3.3 Independence Keywords Operational independece Panel conclusion Full compliance Clarification request(s) Panel (14/07/2025)
RC decision Compliance “Considering the organisational independence, the panel’s findings show that CTI outsources its accounting and management of human resources to the Conference of Deans of French Schools of Engineering (CDEFI), an organisation that represents the engineering schools that CTI accredits. CTI also shares its premises and one staff member with CDEFI. Considering the close interlinkage between CDEFI and CTI, the Register Committee asked the panel to elaborate how the agency ensures its operational and organisational independence. Regarding the operational independence the panel responded that procedures and methods are defined by CTI’s committees on the basis of preparatory work of working groups and that third parties are not involved in this processes. The panel was convinced on the basis of the self-assessment report and the meetings with representatives of CTI and its stakeholders, that independence was guaranteed. The panel commented that the financial administration of CTI is separate from the administration of CDEFI and while CDEFI administrates the contracts and selection of personnel, that the daily management of the staff are the responsibility of CTI alone. Considering the organisational independence, the panel argued that the independence of CTI from CDEFI remains guaranteed based on a signed agreement (as of June 2015) between the two organisation. The agreement defines the tasks expected from CDEFI and CTI, the annual fee in detail and stipulates how the independence of CTI and of CDEFI remains guaranteed. The panel added that the sharing of renting facilities in the same building is considered by all parties the panel spoke with as very positive. Having considered the clarifications from the panel, the Register Committee was therefore able to follow the panel’s conclusion that CTI complies with ESG 3.3.”
Full decision: see agency register entry
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2.4 Peer-review experts – A3ES – Partial compliance (2019) absence of student reviewers in panels for NCE procedures and overseas accreditations
A3ES
Application Renewal Review Full, coordinated by ENQA Decision of 05/11/2019 Standard 2.4 Peer-review experts Keywords absence of student reviewers in panels for NCE procedures and overseas accreditations Panel conclusion Substantial compliance Clarification request(s) Panel (21/10/2019)
RC decision Partial compliance “The involvement of students was flagged when A3ES was admitted to the Register. While the panel’s conclusion was that A3ES was substantially compliant withthe standard, the Register Committee noted that students were not involved in prior accreditation of study programmes (NCE) and international assessment teams. The Register Committee sought clarification from the panel in that regard. Inits response the panel explained that NCE was a compliance-check procedure based on juridic judgement and it involved only experts knowledgable in law. Furthermore, the panel considered A3ES arguments not to involve students in international assessment teams as reasonable andas exceptional cases that do not indicate that A3ES deviates significantly from the quality standards expected under 2.4.The clarification from the panel thus confirmed that students are not part of the panels for prior accreditation of study programmes (NCE) nor part of the panels for overseas compliance check. The Registered Committee considered that this arrangement did not meet the requirements of the standard and that students should be involved as expert panel members in all activities that involve an assessment by a panel of experts. Also for new study programme concepts and for existing programmes implemented in a new setting abroad, students may add a valuable additional and specific perspective to the process. Given the absence of student reviewers in panels for NCE procedures and overseas accreditations, the Register Committee concluded that the flag was not fully addressed and was unable to concur with the panel’s conclusion. The Register Committee concluded that A3ES only partially complies with the standard.”
Full decision: see agency register entry
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2.6 Reporting – A3ES – Compliance (2019) readability and accessibility of reports
A3ES
Application Renewal Review Full, coordinated by ENQA Decision of 05/11/2019 Standard 2.6 Reporting Keywords readability and accessibility of reports Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In the previous decision for inclusion, the Register Committee flagged for attention the readability and accessibility of reports. Based on the review report the Register Committee noted that the agency has made good efforts to address the issue.The Register Committee therefore considered that the flag has been addressed and concurred with the panel’s conclusion that A3ES complies with the standard.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – A3ES – Compliance (2019) Clear distinction between activities within and outside of the scope of the ESG
A3ES
Application Renewal Review Full, coordinated by ENQA Decision of 05/11/2019 Standard 3.1 Activities, policy and processes for quality assurance Keywords Clear distinction between activities within and outside of the scope of the ESG Panel conclusion Full compliance Clarification request(s) Panel (21/10/2019)
RC decision Compliance “When A3ES applied for renewal, the Register Committee stated in its Eligibility Confirmation that the external review report should address how the agency clearly separates activities outside the scope of the ESG from activities within the scope of the ESG. As the report did not address the issueof clear separation of these activities, the Register Committee sought clarification from the panel. The panel clarified that A3ES' consultancy activities are not provided to universities or colleges, but solely focused on advising the national authorities or organisations on the design of national quality assurance policies, criteria and processes. Having considered the panel’s clarification, the Register Committee concurred with the panel that these activities are clearly separated from activities within the scope of the ESG by their very nature, and do not bear the potential for unclarity or conflict of interest that services rendered to higher education institutions do. The Committee therefore concurred with the panel's conclusion that A3ES complies with the standard”
Full decision: see agency register entry
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2.3 Implementing processes – NCEQE – Compliance (2019) unclear monitoring processes
NCEQE
Application Initial Review Full, coordinated by ENQA Decision of 19/06/2019 Standard 2.3 Implementing processes Keywords unclear monitoring processes Panel conclusion Substantial compliance Clarification request(s) Agency (06/06/2019)
RC decision Compliance “The review panel found that the agency’s monitoring processes - the follow-up and case-based monitoring procedure - were not fully clear, and in particular on how these processes would be complementing each other. The Register Committee therefore asked the agency for further clarification.The agency explained (see letter of 06/06/2019) that higher education institutions complete a mandatory follow-up process which takes place onceevery three years, where HEIs provide a self-evaluation on the progress made following its previous institutional evaluation. In addition, the agency may carry out a site-visit to review progress at the requested of the Authorization or Accreditation Councils following a review of the institution’s compliance with the authorisation/accreditation standards.The agency further described its case based monitoring procedure that is initiated in case a substantiated complaint is received about an institution. If the concern remains unresolved, NCEQE assembles a group of experts to investigate the complaint, which may include a site visit at the institution. Having considered the agency’s clarifications, the Register Committee found the follow-up processes well defined and reasonable. The Committeetherefore could follow the panel’s conclusion that NCEQE complies with ESG 2.3.”
Full decision: see agency register entry
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2.4 Peer-review experts – NCEQE – Compliance (2019) Panels composition
NCEQE
Application Initial Review Full, coordinated by ENQA Decision of 19/06/2019 Standard 2.4 Peer-review experts Keywords Panels composition Panel conclusion Substantial compliance Clarification request(s) Agency (06/06/2019)
RC decision Compliance “The review panel learned that in cases where expert panels are employed for follow-up and case-based monitoring procedures their composition is not clearly defined. The Register Committee therefore asked the agency for further clarifications. The agency explained (see letter of 06/06/2019)) that its guidebook on follow-up procedures define the composition of panels for both follow-up and case-based monitoring procedures. The agency stated that it ensured that a student representative is included in the composition of the expert panel for both procedures.The Register Committee therefore concurred with the panel’s judgment that NCEQE is compliant with ESG 2.4.”
Full decision: see agency register entry
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2.7 Complaints and appeals – NCEQE – Partial compliance (2019) Unclear complaints processes. Inadequate composition of the Appeal Council.
NCEQE
Application Initial Review Full, coordinated by ENQA Decision of 19/06/2019 Standard 2.7 Complaints and appeals Keywords Unclear complaints processes. Inadequate composition of the Appeal Council. Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted that the agency’s Appeal Council is composed of 11 members nominated by the Minister. While the panel was satisfied with the process the panel also commented that the short term of their mandate might not be helpful for members to gain a broad overview of the decisions made. The Register Committee further noted that the nomination of the Appeal Council’s members is problematic in terms of agency’s independence from the Ministry (see also under ESG 3.3). According to the panel’s analysis NCEQE’s complaints process are rather vague, and the panel was not convinced that higher education institutions would be aware of the opportunity to complain about a procedural concern. In its letter to EQAR (of 6 June 2019) the agency stated that it has developed a user-friendly booklet on complaints procedure and that institutions may now issue complaints online, via its website. While the Register Committee welcomed the agency’s improvement to its complaints processes, the Committee could not verify the agency’s statements, as this would require a review by an expert panel. The Register Committee further underlined its concerns regarding the composition of the agency’s Appeals’ Council. Considering the above-mentioned concerns, the Committee was unable to concur with the review panel’s judgment of (substantial) compliance, and concluded that NCEQE complies only partially with ESG 2.7.”
Full decision: see agency register entry
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3.3 Independence – NCEQE – Partial compliance (2019) Organisational and operational independence
NCEQE
Application Initial Review Full, coordinated by ENQA Decision of 19/06/2019 Standard 3.3 Independence Keywords Organisational and operational independence Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee noted that the members of NCEQE’s Authorisation and Accreditation Council are appointed by the Prime Minister upon recommendations by the Minister of Education and Science. The panel commented that the ability of the Ministry to appoint and dismiss the Councilmembers does not support organisational independence and that the agencyshould take more ownership on how council members are nominated.In its letter to EQAR (of 6 June 2019) the agency stated that NCEQE is currently working on initiating legislative changes that will allow the agency to shift the mandate in the appointment and dismissal of the NCEQE’s Director and Council members to its main Coordinating Council. The agency added that discussions are also under way to increase the role of the Coordinating Council in the selection process of the Authorization and Accreditation Council members. While the Register Committee welcomed the agency’s initiative to increase its independence from the Ministry, the Committee underlined the panel’s concerns that the new rules for the selection of Council members do not fully alleviate the concern regarding the agency’s independence as the Council itself is set up at the recommendation of the Ministry.The Register Committee underlined the panel’s recommendation that the agency should be ensured that there is a structural independence from the government and that the agency should take ownership of how council members are appointed under the new rules. While considering that the failure to fully meet the requirement of the standard concern both the organisational and operational independence, the Register Committee nevertheless noted the agency has put forward legislative changes that would increase its independence, and therefore could follow the panel conclusion that NCEQE complies partially with ESG 3.3.”
Full decision: see agency register entry
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3.4 Thematic analysis – NCEQE – Partial compliance (2019) systematic approach
NCEQE
Application Initial Review Full, coordinated by ENQA Decision of 19/06/2019 Standard 3.4 Thematic analysis Keywords systematic approach Panel conclusion Substantial compliance Clarification request(s) Agency (06/06/2019)
RC decision Partial compliance “In its analysis the panel considered that while NCEQE produced a form of thematic analysis in its annual report, the panel commented that the activity was not yet systematically carried out. In its letter to EQAR, the agency reported that as part of its Twinning Project (starting in 2019) a methodology is developed for carrying out analytical and research activities in a more consistent and streamlined manner. The agency added it has also received support via other projects that will help the agency assess the results of implementation of the revised QA system and further improve its QA procedures. While the Register Committee welcomed the steps taken by NCEQE, it was not yet possible to conclude whether thematic analyses are produced regularly. The Committee therefore concluded that NCEQE complies only partially with ESG 3.4.”
Full decision: see agency register entry
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2.1 Consideration of internal quality assurance – AHPGS – Partial compliance (2020) Part 1 not clearly reflected in some processes
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.1 Consideration of internal quality assurance Keywords Part 1 not clearly reflected in some processes Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “10. The review panel concluded that “the quality assurance processes described in Part 1 of the ESG should be addressed with more detail in the assessments carried out outside Germany” (p. 30).
11. In its statement on the review report, AHPGS referred to additional explanations added to the corresponding handbooks in this regard. In the additional representation, AHPGS made these changes more visible in the text.
12. The Register Committee considered that this demonstrates in theory how ESG Part 1 will be addressed in more detail in future assessments, while the practical impact of those changes remains to be evaluated in detail within the next external review of AHPGS.”
Full decision: see agency register entry
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2.3 Implementing processes – AHPGS – Compliance (2020) Follow-up of conditions unclear
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.3 Implementing processes Keywords Follow-up of conditions unclear Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “16. For AHPGS' external quality assurance activities outside Germany, the review report concluded that AHPGS did not include follow-up as a mandatory step in the procedure. While the review report stated that “there are only recommendations, no conditions” in accreditation decisions outside Germany, the Register Committee noted that AHPGS had published (according to DEQAR as of 5/11/2019) at least 31 reports and decisions on programmes/institutions outside Germany that impose conditions in the decision. [...] it was not evident whether and how the fulfilment of these condition was verified, except for one case. […]
18. In its additional representation, AHPGS confirmed that also in accreditation/assessment procedures outside Germany conditions might be imposed (in cases with AHPGS final decision) or recommended (in cases where the decision is taken by a national authority). AHPGS further explained how these are followed up and noted that follow-up is now regulated formally in its contracts. AHPGS further explained that some mistakes were made when uploading the cases in question to DEQAR, which it had corrected.
19. The Register Committee could establish that the presentation of the reports in question was corrected in DEQAR. […]”
Full decision: see agency register entry
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2.4 Peer-review experts – AHPGS – Partial compliance (2020) training of experts, clarity of rules for expert pool
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.4 Peer-review experts Keywords training of experts, clarity of rules for expert pool Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “21. […] the review panel noted that the criteria for the recruitment of the experts were not formalised and published.
22. The review panel discussed that the training of experts consisted only of a phone briefing. The panel recommended that AHPGS intensify and further improve the training for both new and experienced experts.
23. The Register Committee took note of AHPGS' explanation that most of its new experts had prior experience from serving as accreditation experts for other agencies in Germany; given the common system there would be no need to re-train them. While the Committee could follow this argument for experts with prior experience, it considered that there will certainly be some – even if few – experts who participate in their first accreditation with AHPGS, and the Committee considered that a more in-depth training was warranted for those.
24. The additional representation underlined that AHPGS offers a regular training programme [...] it remained unclear whether it was ensured that all panel members have participated in a formal training session […]
25. The representation further clarified that there actually is an open invitation, […]
27. Given the panel’s analysis and the issues that remain unclear after clarification and additional representation, the Register Committee was unable to concur with the panel’s conclusion but considered that AHPGS only partially complies with the standard.”
Full decision: see agency register entry
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2.5 Criteria for outcomes – AHPGS – Compliance (2020) transparency of criteria
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.5 Criteria for outcomes Keywords transparency of criteria Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “29. The Register Committee took note of the panel's analysis that the criteria are well-documented in AHPGS' handbooks and are interpreted in a consistent manner.
30. Despite some room for improvement identified by the panel in that the Handbooks could be more detailed, the Register Committee considered that the flag was addressed and concurred with the panel's conclusion that AHPGS complies with the standard.”
Full decision: see agency register entry
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2.6 Reporting – AHPGS – Compliance (2020) not all reports published in the past
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.6 Reporting Keywords not all reports published in the past Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “31. When AHPGS' registration was last renewed, the Register Committee flagged for attention whether AHPGS’ policy of publishing full reports for all reviews has been implemented consistently.
32. The review report analysed and concluded that AHPGS has consistently published full reports from all of its activities. The Register Committee therefore considered that the flag has been addressed and concurred with the conclusion that AHPGS complies with the standard.”
Full decision: see agency register entry
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2.7 Complaints and appeals – AHPGS – Compliance (2020) brief procedure for complaints and appeals
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 2.7 Complaints and appeals Keywords brief procedure for complaints and appeals Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “33. […] there was only a brief procedure for complaints and appeals, and that the process was not fully known by the universities concerned; the Appeals Committee was not yet appointed, neither another body that deals with complaints and appeals.
34. [...] a statutory change, introducing the legal basis of the Appeals Committee, had entered into force and that the Appeals Committee had subsequently been appointed.
35. Having considered the additional information, the Register Committee concurred with the review panel's conclusion that AHPGS complies with the standard.”
Full decision: see agency register entry
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3.4 Thematic analysis – AHPGS – Partial compliance (2020) Lack of clarity about existing activities; lack of regular analyses as described by the standard
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 3.4 Thematic analysis Keywords Lack of clarity about existing activities; lack of regular analyses as described by the standard Panel conclusion Non-compliance Clarification request(s) – RC decision Partial compliance “36. [...] the publication of assessment reports, its yearly board meeting and the publication of books/journals by AHPGS staff – did not represent thematic analyses resulting from the review processes undertaken by AHPGS. […]
38. […] The statement by AHPGS did, however, not provide details as to whether and how these are clearly based on findings from AHPGS accreditation work.
39. In its additional representation, AHPGS reiterated the view that the various past publications would not have been possible without the experience from the agency’s review processes.
40. Moreover, AHPGS provided further details on its concept and work plan of publishing two thematic analyses per year. These were developed based on decisions by its governing bodies in
2019. 41. AHPGS also pointed out that it had already published its first two thematic analyses after the external review.
42. […] The Committee considered that through the combination of past publications and the two recently published thematic analyses AHPGS showed its capacity to implement that concept.”
Full decision: see agency register entry
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3.6 Internal quality assurance and professional conduct – AHPGS – Compliance (2020) formalisation of QA processes
AHPGS
Application Renewal Review Full, coordinated by ENQA Decision of 16/03/2020 Standard 3.6 Internal quality assurance and professional conduct Keywords formalisation of QA processes Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “44. The panel analysed that AHPGS has a system describing the internal QA processes, but given the agency's small size some processes were not formalised and relied on “informal procedures and tacit knowledge”.
45. The Register Committee noted the publication of AHPGS’ comprehensive internal quality assurance reports for the years 2009-2013 and 2013-2017 on its website.”
Full decision: see agency register entry
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2.1 Consideration of internal quality assurance – IEP – Compliance (2019) Part 1 reflected in the agency’s external QA
IEP
Application Renewal Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 2.1 Consideration of internal quality assurance Keywords Part 1 reflected in the agency’s external QA Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In the previous decision of renewal of IEP’s registration, the Register Committee flagged for attention the extent to which the different elements of Part 1 of the ESG were reflected in the agency’s institutional evaluation reports. The Register Committee noted the review panel findings that show that IEP amended the guidelines for institutions as well as the guidelines for evaluation teams to directly reference 2015 ESG Part 1. The panel commended IEP’s efforts to analyse reports and to provide clear guidance on implementing the ESG standard 2.1. Having considered the mapping of ESG part I and the analysis of the panel, the Register Committee concluded that the flag was addressed.”
Full decision: see agency register entry
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2.3 Implementing processes – IEP – Partial compliance (2019) Consistent follow-up
IEP
Application Renewal Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 2.3 Implementing processes Keywords Consistent follow-up Panel conclusion Substantial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee acknowledged the steps taken by IEP to enhance the participation in follow-up processes, but noted that the current follow-up model does not ensure for a consistent follow-up for all evaluated higher education institutions. The Committee considered that a progress report, which is a relatively light requirement, could possibly be a feasible follow-up for all evaluated institutions. The Committee took note of the panel's concern that making the requirement more stringent would pose a risk of turning progress reports into a purely formal requirement, but considered that such a risk had not necessarily to become true. Moreover, the same argument could be used against any obligatory element in quality assurance, or obligatory quality assurance as such.”
Full decision: see agency register entry