Database of Precedents

Application	Renewal
Review	Full, coordinated by GAC
Decision of	03/12/2016
Standard	2.7 Complaints and appeals
Keywords	Absence of clear complaints and appeals procedures
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that higher education institutions whose procedures are decided on by the Commission for International Affairs (KIA) do not seem to have an option to lodge complaints or appeals. The Register Committee further considered the panel’s analysis showing that institutions do not have the possibility to launch a complaint to settle conflicts related to ZEvA’s procedures. The panel review also noted that the complaints procedure employed by ZEvA is not visibly communicated on the agency’s website. In its letter to the review panel (of 31/5/2016) ZEvA stated that it has reviewed its rules of procedure to allow handling of all complaints and appeals’ procedures. Additional information on appeals and complaints have been added to the website page of the agency. While the Register Committee took note of ZevA’s response to the review report it could not fully satisfy itself that the updated procedure for complaints and appeals address all concerns raised by the panel”

Full decision: see agency register entry

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

“16. The Register Committee noted that the agency defines three different processes for allegations, appeals and complaints.

17. The allegations (considered as a form of feedback opportunity for the institutions) are dealt with by the Technical Committees, who is also responsible for drafting the reports (see also under ESG 2.6).

18. The appeals and complaints procedures are defined by law and are under the legal competency of the Canary government.

19. The Committee noted, that ACCUEE’s appeals and complaints policies are limited as the agency does not have its own appeals and complaints processes or a separate body in considering complaints or appeals.

20. The Committee considered that external quality assurance processes should always include an internal possibility to appeal and complain with the responsible body that carried out the review itself.

21. The Register Committee noted that ACCUEE intends to appoint an independent and permanent body, Guarantee Commission that will consider all appeals and complaints related to all procedures that are in the scope of the ESG.

22. The Register Committee welcomed ACCUE’s intention to set up a separate body to handle appeals and complaints, but the Committee underlined that such changes are yet to be implemented and to be reviewed. The Register Committee therefore concurred with the panel that ACCUEE only partially complies with ESG 2.7.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	2.7 Complaints and appeals
Keywords	no possibility to appeal the formal decisions
Panel conclusion	Partial compliance
Clarification request(s)	Panel (15/02/2023)
RC decision	Partial compliance

“23. The panel raised concerns about the slight unclarity and overlap between the “appeals and complaints procedure” and the separate “complaints procedure”. Even though the wording is unusual, the Register Committee considered that both appeals and complaints, as understood in the ESG, are generally possible.

24. The Committee obtained clarification by the panel on the composition of the Appeals Committee. Even though the members are different from the QAAC, the Committee shares the panel’s concern that all but one come from the rather small chiropractic community.

25. The Register Committee’s further noted that there is no possibility to appeal the formal decision by the QAAC, only the expert report. The Committee regarded this as problematic given that the QAAC alone decides on the accreditation term.

26. In its additional representation the agency explained that the judgement itself of the QAAC cannot be appealed solely on the basis of disagreement with the decision, but can be made based on incorrect procedures, or if it was executed in an unfair and discriminatory manner. The Committee thus understood that while ECCE makes possible appeals based on procedural error, errors of fact, mitigating circumstances where material was not available at the time and for situation where members of QAAC or ECCE behaved in a discriminatory or unprofessional manner, the agency does not allow for an appeal of QAAC’s judgement itself. The Committee thus finds that the appeals process is limited, given that the reviewed higher education institution may not challenge based on e.g., criteria that may have not been correctly applied or disagreements in how standards were interpreted by QAAC.

27. The Committee noted that the agency considered and upheld an appeal against a QAAC formal decision, but also noted that there is no public documentation on this appeal and that the agency does not have any information on its website on the composition of its Appeal’s Committee.

28. The Register Committee therefore concurred with the panel’s conclusion that ECCE only partially complies with the standard.”

Full decision: see agency register entry

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

“The panel argued that there was “no avenue available to have an

external review of a decision” and noted the “absence of external

adjudication in the mechanism used”. The Register Committee expects that

an appeal is considered by another body than the one whose

decision/report is appealed (see interpretation 13 of the ESG); this will

nevertheless normally be a body of the agency, as the standard requires an

internal appeals process (see also interpretation 12 of the ESG). As the

HAHE appeals committee consists of different persons than the (current)

EAC, this requirement is formally fulfilled, even if HAHE may reconsider the

practice of appointing only retired EAC members when it reviews its

appeals procedures as recommended by the panel, Further, the fact that the appeals' committee makes a recommendation to the

EAC is compatible with EQAR's expectations (see interpretation 14 of the

ESG).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.7 Complaints and appeals
Keywords	appeals and complaints, committee
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its initial application for inclusion the Register Committee raised concerns regarding the lack of an internal appeals system within the agency.

14. The Register Committee noted that since the last external review of NEAA, nothing has changed in relation to the possibilities for higher education institutions to make an appeals with the agency.

15. The Register Committee further noted, that NEAA does not have its own appeals process nor a separate body in considering appeals and that the only existing appeals procedures are outside of NEAA’s remit, defined by law and under the legal competency of the Bulgarian courts.

16. The Committee considered that external quality assurance processes should always include an internal possibility to appeal within the responsible body that carried out the review itself.

17. In its representation the agency provided full documentation on its new internal provisions for complaints and appeals and for the functioning of its body the Complaints and Appeals Committee. The Committee noted that the new body is a standing committee within the agency, fully operative with permanent members and clear provisions outlined in the Statutes of the Complaints and Appeals Committee.

18. Having been able to verify that the agency provides both internal processes for complaints and appeals, the Register Committee finds that the initial concerns have been addressed. The Register Committee therefore concluded that NEAA now complies with ESG 2.7.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	2.7 Complaints and appeals
Keywords	independence and impartiality of the Appeals Committee
Panel conclusion	Partial compliance
Clarification request(s)	Panel (21/06/2023)
RC decision	Partial compliance

“23. In considering the panel’s analysis the Committee was unclear on whether the main concerns related to the agency’s functioning or set up of the Appeals Commission. The Register Committee therefore sought further clarification from the panel.

24. The panel underlined that the process of appointing the members which is solely done by the Director, who is also founder of ARQA (see ESG 3.3) is problematic. The panel further underlined that the process where the recommendations from the Appeals Commission would go back to the Accreditation Council who can either take them into account or disregard them completely does not function properly. In the panels’ view, the Appeals Commission has not enough authority to be taken seriously by the Accreditation Council.

25. The Register Committee noted the concerns raised by the panel and underlined that the independence and impartiality of the Appeals Commission is of importance and should be further addressed by ARQA.

26. The Register Committee therefore followed the panel’s conclusion that ARQA only partially complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.7 Complaints and appeals
Keywords	appeals procedure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“27. The Register Committee noted in its past decision that the chairperson of the agency’s board takes the final decision on the appeal and reviews the conclusions of the Appeals Committee. The Register Committee found this may affect the integrity of the appeals process. Additionally, the Register Committee found that higher education institutions do not have the possibility in case of institutional accreditation to appeal the report with AIC (only with ministry).

28. In the Substantive Change Report (of 2022-03-15), AIC elaborated further on the modalities for potential appeals against accreditation decisions regarding the Accreditation of foreign study programmes. The explanations, however, left open how such appeals would be considered.

29. In the review report the panel explained the possibility to appeal accreditation decisions made by the agency. The panel considers that the appeals procedure which has been developed, and the Appeals Committee which has been compiled in January 2022, brought the agency’s review procedures for Latvian higher education institutions in line with the standard.

30. The Register Committee considered the statement of the agency regarding the appeals and complaints procedures and noted that the amendments to the legislation were approved and an appeal procedure including independent appeals commission, has been set and is functioning. The Register Committee welcomes the progress made, but follows the panel’s concern on the lack of the transparency of external quality assurance system, due to a lack of written procedure for hearing complaints.

31. The Register Committee underscores the panel recommendations on the publication of the procedures to follow-up complaints concerning activities of the agency in Latvia and on the development of an appeals and complaints procedure for its accreditation procedure for foreign degrees.

32. Having considered the improvements by the agency, the Register Committee noted the need to further elaborate on the procedure for complaints. The Register Committee agrees on compliance for this standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	2.7 Complaints and appeals
Keywords	Lack of transparency in the agency’s appeals processes, accessibility of Appeals Procedure
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“11. In its past decision, the Register Committee raised a concern regarding the lack of transparency in the agency’s processes concerning the members nominated to act in the Appeals Committee. The Committee also noted at that time that the appeals procedure was not easily accessible on ARACIS’s website.

12. The Register Committee noted from the analysis of the panel that ARACIS has appointed a Permanent Appeals Commission for a four-year term and published the composition of the commission. The Committee also learned that as of October 2022, ARACIS has a new, integrated and simplified Appeals and Complaints procedure that can be easily retrieved from the website1.

13. The Committee welcomed the newly updated procedure, and while noting that the procedure is rather generic in what concerns handling of complains, that it satisfies the requirements of the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/03/2024
Standard	2.7 Complaints and appeals
Keywords	lack of indepence in decision of appeals committee,
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“14. The Register Committee noted that the provisions for complaints and appeals are distributed in two documents, the Methodology of External Evaluation and the Regulations on the settlement of petitions submitted to ANACEC. The panel remarked that when comparing these two documents there are contradictions and inconsistencies that should be addressed.

15. Furthermore, the Register Committee noted that the President of ANACEC appoints the Appeals Committees and validates the decision of the Appeals Committees, while at the same time chairs the Governing Board which is the decision making body, which may raise concern of potential conflict of interest.

16. The Register Committee therefore underlined the panels’s recommendation of revising the applicable regulations in order to avoid contradictions as well as the division of responsibilities in terms of appointing and approval of appeals in order to guarantee a fair decision making and avoid potential conflict of interest.

17. Considering the several above-mentioned issues the Register Committee could not follow the panel’s conclusion of compliance, but considered that ANACEC complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	appeals procedure, appeals committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. In the decision on the for inclusion of CYQAA on the register (of 2019-11- 05), the Register Committee raised concerns regarding the shortcomings of the appeal procedure regarding the independence of the processes and the lack of clearly defined and formal complaints procedure.

8. From the external review report, the Register Committee learned that the Complains Policy is well established and higher education institutions have already used the possibility to submit a complaint (18 until the time of the external review).

9. The Register Committee further learned that CYQAA has revised its Appeals Procedure and now sets Advisory Committee of Experts (ACE) - groups of experts that examine and give opinion on the grounds for appeals to CYQAA’s Council. Despite the updated policy, the Council still holds the powers to make the final decision whether there are grounds for an appeal and can dismiss or uphold the appeal.

10. Furthermore, the Committee noted that the current Appeal Procedure is not entirely clear as it may suggest that an ACE is appointed for each appeal that is allowed for consideration by the Council, whereas in practice it is set only when the Council proposes to reject an appeal and needs advice from external experts.

11. The Register Committee welcomed (changes made related to the complaints procedure) and found the earlier concerns related to the complaints procedure addressed. The Committee, however, found that CYQAA is yet to demonstrate an independent functioning of the Appeals Procedure, where the final decision is not with CYQAA’s Council. Having in mind the shortcomings related to the Appeals Procedure, the Register Committee concurred with the panel conclusion that CYQAA only partially complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	26/11/2024
Standard	2.7 Complaints and appeals
Keywords	Separate and independent appeal body
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. In its last decision, the Register Committee noted that the Galician

Committee for Reports, Assessment, Certification and Accreditation (CGIACA) was

responsible for the evaluation, certification and accreditation and also for the

appeals following these reviews.

8. The Register Committee learned from the panel analysis that ACSUG has

set ap an appeal body (Review Committee). This body, however, has no decision-

making power as it can only provide a recommendation and return the case to the

original decision-making body, Galician Committee for Reports, Assessment,

Certification and Accreditation (CGIACA).

9. The Register Committee further noted from the analysis that the president

of CGIACA is a non-voting, member of the Review Committee. In panel’s view, due

to this organisational arrangement, the Review Committee and CGIACA are not

sufficiently separate and independent of each other as there is a possibility of a

CGIACA member also participating in the Review Committee meetings and

therefore potentially influence the discussions of the appeals’ body.

10. The Register Committee welcomed the steps taken by the agency regarding

establishing a separate body for appeals and reiterated that such a body needs to

be independent and separate, with full autonomy to make recommendations

regarding the appeal in question. However, it is sufficient that such a body makes

recommendations instead of final decisions on the result of external evaluation.

11. The Committee followed the panel’s view that there is lack of clear

separation between the accreditation (CGIACA) and appeal body (Review

Committee) of ACSUG and therefore concurred with the panel that ACSUG

complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	18/11/2025
Standard	2.7 Complaints and appeals
Keywords	Complaints and Appeals Committee
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its last decision for renewal of registration (of 2020-11-02), the Register Committee found the agency to be partially compliant with the standard, as the appeals procedures were not applied to the enhancement-type reviews. Additionally, the Committee noted that the Board of MusiQuE, the agency's decision-making body responsible for endorsing the review team's judgments, also nominated members of the Appeals Committee, raising concerns about potential conflicts of interest.

14. The Register Committee learned from the review report that MusiQuE has revised its procedures for complaints and appeals to address this concern, including outlining detailed steps for submitting complaints and appeals on its website. The revised procedures now also apply to the outcomes of the agency's quality enhancement activities as well.

15. The Register Committee noted that the agency has established a Complaints and Appeals Committee. The nomination procedure has been revised: three voting members are nominated by the MusiQuE office and appointed by the MusiQuE Board for a fixed three-year term, renewable once. To address concerns about conflicts of interest, committee members must not have served on MusiQuE's decision-making or executive bodies during the previous five years.

16. The Register Committee welcomed the steps taken by MusiQuE and found that the concerns raised in the last renewal of registration had been addressed. Therefore, the Committee concurred with the panel that MusiQuE is compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee learned that IQAA now publishes in full the decisions from institutional and programme accreditations, including the

negative ones. Even though the bulk of reports is public, this is not the case for all of them - the reports from the initial accreditation and the post-accreditation monitoring are still not published.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	2.6 Reporting
Keywords	publication of all reports
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“14. In its last decision, the Register Committee noted that a number of programme accreditation reports have not been published by FIBAA and concluded that the agency at that time complied only partially with ESG 2.6. In response to the recommendation made in the previous review, the Register Committee learned that FIBAA is now publishing both the positive and negative reports on accreditation and certification processes from national as well as international activities, on its website.

15. The Register Committee therefore agreed with the panel’s conclusion, that FIBAA complies with standard 2.6.”

Full decision: see agency register entry

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

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

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 (21/04/2026)
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	2.6 Reporting
Keywords	Publication of all reports
Panel conclusion	Non-compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its previous decision of inclusion, the Register Committee flagged AKKORK’s practice of ensuring the consistent publication of all external evaluation reports. In its additional information and additional representation to the review report the agency claimed that all its review reports and decisions were now published on its website, including the reports from its professional-public accreditation activity. The Register Committee could verify that with a few exceptions all of these reports are now published by the agency on its website i.e. links included under the Russian version of its agency’s website under Register of programmes. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.6 Reporting
Keywords	Publication of negative reports
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“When evalag’s registration was last renewed it was flagged for attention whether evalag has moved to publish reports where the accreditation decision was negative. The review panel observed that evalag has had no negative decisions so far. The panel nevertheless confirmed that evalag’s clear policy is to publish all reports regardless of the outcome; the panel had no doubts that a negative report will be published. The Register Committee therefore concluded that the flag has been addressed.”

Full decision: see agency register entry

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