Database of Precedents
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3.1 Activities, policy and processes for quality assurance – MFHEA – Partial compliance (2024) student in governance, distintion between activities
MFHEA
Application Initial Review Full, coordinated by ENQA Decision of 11/10/2024 Standard 3.1 Activities, policy and processes for quality assurance Keywords student in governance, distintion between activities Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “44. MFHEA has a mission statement which is publicly available and included in the strategic plan. As outlined by the panel, however, the strategic plan lacks a detailed outline of clear and explicit goals.
45. The Committee learned from the panel’s analysis that MFHEA did not ensure a clear distinction between its external quality assurance activities in the field of higher education and its other fields of work. In its statement on the report, the agency explained in order to enable a clear distinction
between its activities, it plans to initiate legislative changes. These changes, however, were either planned to happen later in 2024 or in 2025.
46. The Register Committee also learned from the report that MFHEA involves external stakeholders from different sectors in its governance and
work, e.g., members of the Board have different backgrounds in higher education. The Committee, however, noted that students are not involved in
the work of the governance body (or governance), i.e., the Board nor in its accreditation body, i.e., the Quality Assurance Committee (QAC). The Register Committee understood that in order to ensure better involvement of stakeholders, including students, in its governance structures, MFHEA
has foreseen legislative changes.
47. For the Committee it was unclear which particular changes will take place in order to address the lack of clear distinction between higher education and non-higher education activities and the lack of student involvement in the governance and work of the agency (in the Board and the
QAC), and whether the planned legislative changes have been adopted yet
48. In its additional representation, the agency informed that the clear distinction between MFHEA’s external quality assurance activities in higher
education and its other fields of work, will be ensured through structural changes in its organisational structure; the agency plans to set two units
tackling further and higher education separately.as of January
2025. Furthermore, the agency informed that legal provisions were amended to
include student representatives in the Quality Assurance Committee and the MFHEA Board and that students are now represented in both of them.
49. The Register Committee noted and welcomed the planned changes aiming to ensure clear distinction between its external quality assurance
activities in the field of higher education and its other fields of work and the involvement of students in the Board and the Quality Assurance Committee.
50. However, given the concerns raised above and that relevant parts of the presented actions are yet to be fully translated into the daily work of the
agency, they remain to be reviewed by an external review panel. Therefore, the Committee could not concur with the panel and found that the agency complies only partially with the standard.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – EVALAG – Partial compliance (2024) Student involvement in governance
EVALAG
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
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3.1 Activities, policy and processes for quality assurance – ANVUR – Partial compliance (2025) Lack of stakeholder involvement in governance bodies
ANVUR
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
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3.1 Activities, policy and processes for quality assurance – AQUIB – Partial compliance (2024) Stakeholder involvement in governance
AQUIB
Application Initial Review Full, coordinated by ENQA Decision of 27/11/2024 Standard 3.1 Activities, policy and processes for quality assurance Keywords Stakeholder involvement in governance Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “15. The Register Committee learned that the governing body of AQUIB (i.e., the Board of Directors), is composed exclusively of representatives of the University of the Balearic Islands (UIB) and the regional government. The Board does not include student members nor other stakeholders.
16. The Register Committee learned that AQUIB has prepared a draft of the new Statutes which, in the review panel’s view, would ensure a more representative composition of the Board of Directors. However, these Statutes are not yet in force at the time of the review.
17. Considering lack of stakeholder involvement in AQUIB’s governance, the Register Committee was unable to concur with the panel’s conclusion of compliance and found that AQUIB only partially complies with the standard.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – ACCUA – Compliance (2024) stakeholders invovlement
ACCUA
Application Renewal Review Full, coordinated by ENQA Decision of 27/11/2024 Standard 3.1 Activities, policy and processes for quality assurance Keywords stakeholders invovlement Panel conclusion Compliance Clarification request(s) – RC decision Compliance “13. In its last decision, the Register Committee found the agency to be partially compliant due to the lack of stakeholders involvement on governance level and its lack of strategic planning.
14. The Register Committee learned from the panel’s analysis that the agency has addressed the issues raised in the previous review. The Committee noted that ACCUA has involved students and other stakeholder as members of the Governing Council of the agency. Furthermore, the Committee noted that ACCUA adopted an Initial Action Plan which is well-conceived to carry forwards the agency's mission and vision.
15. Following the improvements towards ESG compliance undertaken by the agency, the Register Committee was able to follow the panel’s conclusion that the agency complies with the standard.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – ACSUCYL – Partial compliance (2025) Student involvement
ACSUCYL
Application Renewal Review Targeted, coordinated by ENQA Decision of 27/06/2025 Standard 3.1 Activities, policy and processes for quality assurance Keywords Student involvement Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “28. In the last decision of renewal of registration, the Register Committee found the agency to be partially compliant due to the lack of student involvement in the agency’s governance and work. To offer students the opportunity to contribute to governance and operations, the agency at that time established a Student Board, however, only as an advisory board without further involvement in the agency’s decision-making. The Register Committee found that students have not been included as members of the Board of Directors (the governance body of the agency). While ACSUCYL made attendance of students at the meetings of the Board of Directors possible since October 2021, the agency has not yet utilised it in practice.
29. The Register Committee noted from the panel analysis that since the last review, the agency included a student in the Degree Assessment Commission.
30. In its statement to the report, ACSUCYL explained that they have not employed this in practice because, since the change, the Board of Directors' meetings have only addressed management, administrative, and financial issues.
31. While the Register Committee welcomed the action taken for better student involvement in the work of the agency, it found that the involvement of students in the governance of the agency (as per the requirement of the standard) remains insufficient, given that students are not involved in the Board of Directors.
32. In its additional representation, ACSUCYL noted that while student participation had not been utilised in the Board of Directors due to the nature of issues discussed in its meetings, this practice was now initiated in their recent meeting. The agency has updated the rules governing the functioning of the Student Board to include them in the decision-making process and approved the proposal to initiate legislative changes to include student members in the Board of Directors (see more under ESG 3.3).
33. The Register Committee welcomed the actions taken by the agency in order to address the concerns on student involvement. Nevertheless, the Committee could not confirm how these changes have been implemented in practice. Furthermore, the announced changes in legislation are yet to be enacted and systematically implemented. The Register Committee therefore concurred with the panel that the agency complies only partially with the standard.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – MusiQuE – Partial compliance (2025) Distinction between the external quality assurance and consultancy
MusiQuE
Application Renewal Review Targeted, coordinated by ENQA Decision of 18/11/2025 Standard 3.1 Activities, policy and processes for quality assurance Keywords Distinction between the external quality assurance and consultancy Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “17. The Register Committee found from the panel analysis that the status and the role of the Critical Friend Review are unclear to MusiQuE's stakeholders. Guiding documents and practice show minor inconsistencies, and interviews revealed diverging stakeholder views on how the procedure is perceived.
18. The panel found that MusiQuE conducts consultative Critical Friend visits using the same procedure as those within the Critical Friend Review, even though the former is a consultative, advisory version, while the latter is part of a formal quality assurance activity aligned with the ESG.
19. According to the panel's analysis, the two activities are conceptually distinct. However, stakeholders often perceive them as conflated, and in practice they may become indistinct. Additionally, although rules for conflicts of interest exist on paper, they are not always clear to involved parties.
20. Taking into account the lack of a clear distinction between the external quality assurance activity and the consultancy nature of the Critical Friend visits for the public and stakeholders, the Register Committee concurred with the panel that MusiQuE complies with the standard only partially.”
Full decision: see agency register entry
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3.2 Official status – IEP – Compliance (2019) agency’s formal recognition
IEP
Application Renewal Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 3.2 Official status Keywords agency’s formal recognition Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that IEP itself does not have separate legal personality and therefore it is represented by EUA in all legal and contractual matters. The Committee acknowledged that the recognition of IEP as a quality assurance agency by public authorities is demonstrated by the numerous contracts that IEP (represented by EUA) signed with national authorities for conducting evaluations, or by the selection of IEP as an evaluating body through a public procurement procedure. [...] The Register Committee interprets the requirement of formal recognition in a broad sense and therefore concurred with the panel's conclusion that IEP complies with the standard.”
Full decision: see agency register entry
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3.3 Independence – AVAP – Partial compliance (2023) strong involvement of the regional government
AVAP
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 3.3 Independence Keywords strong involvement of the regional government Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Register Committee notes that the overall setup of the agency
provides the Regional Government with a large influence in the governance
and operation of AVAP, i.e. the operative decisions are mainly taken by the
Executive Committee which consists of six members, three of them being
the representatives of the Regional Government, the proposal for Director
comes from the Regional Government. The agency has initiated a legal
process for reducing the number of local Governmental representatives
in its steering bodies - a change hat was yet to take place.”
Full decision: see agency register entry
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3.3 Independence – IQAA – Partial compliance (2022) Strong role of a single actor
IQAA
Application Renewal Review Full, coordinated by ENQA Decision of 25/10/2022 Standard 3.3 Independence Keywords Strong role of a single actor Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “The founder of the agency, acting as a President, has a strong executive role - they nominate and appoint members of the Supervisory Board (and is a board member), the Appeals Commission, the Complaints Commission and the experts councils, recruits the staff
members and attends the meetings of the Accreditation Council. The Committee found that the current arrangements, in which one
single actor could use their controlling stake over the agency in several regards, represents a substantial risk of an infringement on the independence of the agency.”
Full decision: see agency register entry
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3.3 Independence – ECAQA – Partial compliance (2023) Infringement of the organizational independence
ECAQA
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 3.3 Independence Keywords Infringement of the organizational independence Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “The Committee could not verify how the agency ensures its independence from its founder and found the distribution of power among stakeholders in the governing of the agency unequal. The Committee noted that the current arrangements include the possibility of
the founder or the Director General exercising their controlling stake in several regards, causing a substantial risk of an infringement on the
independence of the agency (see also interpretation 18).”
Full decision: see agency register entry
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3.3 Independence – UKÄ – Partial compliance (2021) Organizational independence; Lack of formal mechanisms for tackling conflict of interest
UKÄ
Application Initial Review Full, coordinated by ENQA Decision of 18/03/2021 Standard 3.3 Independence Keywords Organizational independence; Lack of formal mechanisms for tackling conflict of interest Panel conclusion Substantial compliance Clarification request(s) Panel (15/03/2021)
RC decision Partial compliance “Concerns about the Government's control of all major appointments remain. In particular, the way in which the Director General is selected has not been made fully transparent and it remained unclear whether the involvement of stakeholders in appointing the Advisory Board is secured in official documents. Moreover, the potential conflict of interest that the Director General could come across in their daily operations does not seem to be fully addressed through formal means by the agency.”
Full decision: see agency register entry
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3.3 Independence – ACSUCYL – Partial compliance (2020) Organisational independence; Appointment of the members by minister
ACSUCYL
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
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3.3 Independence – ANECA – Compliance (2018) Organisational independence
ANECA
Application Renewal Review Full, coordinated by ENQA Decision of 11/09/2018 Standard 3.3 Independence Keywords Organisational independence Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that since its last evaluation, ANECA has strengthened its independence i.e. becoming an autonomous public body, ensuring a more balanced representations in its Governing Council, appointing of its own director and operating with full fiscal autonomy. The Register Committee further noted that “the operation of ANECA’s policies and procedures surrounding the design, implementation and reporting on all the evaluation processes takes place in a fully independent and autonomous manner” (Review report, p. 26).”
Full decision: see agency register entry
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3.3 Independence – ANQA – Compliance (2017) operational independence
ANQA
Application Initial Review Full, coordinated by ENQA Decision of 20/06/2017 Standard 3.3 Independence Keywords operational independence Panel conclusion Full compliance Clarification request(s) Panel (21/04/2026)
RC decision Compliance “The Register Committee sought and received clarification from the panel as regards ANQA's independence in defining its own procedures and methods. The Committee appreciated the panel's explanation as to how ANQA developed its Manual independently.”
Full decision: see agency register entry
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3.3 Independence – AEQES – Compliance (2017) organisational and operational independence
AEQES
Application Renewal Review Full, coordinated by ENQA Decision of 20/06/2017 Standard 3.3 Independence Keywords organisational and operational independence Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The review panel was satisfied that the 2014 decree on AEQES and the current organisational status and structure sufficiently demonstrate and safeguard AEQES independence. In particular, AEQES gained the ability to hire staff from its own budget, independently of the Ministry”
Full decision: see agency register entry
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3.3 Independence – THEQC – Partial compliance (2023) Infringement of the operational independence
THEQC
Application Initial Review Focused, coordinated by ENQA Decision of 03/03/2023 Standard 3.3 Independence Keywords Infringement of the operational independence Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “Dependency of the agency on staff paid by higher education institutions”
Full decision: see agency register entry
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3.3 Independence – ECCE – Partial compliance (2023) Overlapping responsibilities between different bodies/ Lack of diversity
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 3.3 Independence Keywords Overlapping responsibilities between different bodies/ Lack of diversity Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “34. The panel raised issues related to the high involvement of representatives of accredited institutions, amplified by the small size of the chiropractic community, as well as the overlapping responsibilities between different agency bodies. In particular, the panel regarded critically the ex-officio mutual memberships of the Executive Committee and QAAC chairperson in the respective other committee, the involvement of both bodies in the QA process and the close involvement of the QAAC in pre-screening self-evaluation reports.
35. In light of these concerns, the Register Committee concurred with the panel’s conclusion that ECCE only partially complies with the standard.”
Full decision: see agency register entry
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3.3 Independence – IKCA – Partial compliance (2023) dominant role of the Director, lack of independent stakeholder consisted governing body
IKCA
Application Initial Review Full, coordinated by ENQA Decision of 12/12/2023 Standard 3.3 Independence Keywords dominant role of the Director, lack of independent stakeholder consisted governing body Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Committee found that in the present arrangements the founder has a dominant figure in the work of the agency. His/her
position could endanger the organisational and the operational independence of IKCA, especially in the absence of an independent
stakeholder governing body. The Committee found also that further clarity is needed in the selection processes of its different bodies.”
Full decision: see agency register entry
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3.3 Independence – CAAAE – Partial compliance (2023) Operational independence; Independence of formal outcomes
CAAAE
Application Initial Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 3.3 Independence Keywords Operational independence; Independence of formal outcomes Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Committee learned that both the president and the vice president
of KAZSEE have voting rights in the two bodies in which they are members
of, i.e. the Accreditation Council and the Supervisory Board. In panel’s view
the “mixture of roles [of the President and the vice President] could make
the [decision making] system vulnerable”. The Committee could follow panel’s reasoning that the current
arrangements could pose threat for the operational independence and the
independence of formal outcomes.”
Full decision: see agency register entry