Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of QA and consultancy activities
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that AQU carried out one training activity in

2011. The review panel found that such activities should be considered as consultancy /support activities and that they should be differentiated more cautiously from the quality assurance activities which are provided by AQU Catalunya. (Review report, pg. 18).The Register Committee concurred with the panel that such consultancy activities should be clearly separated from external QA activities, in particular when those activities are carried out for the same higher education institution. The Committee drew AQU's attention to the guiding principles set out in Annex 5 to the Policy on the Use and Interpretation of the ESG and underlined that AQU is expected to make a substantive change report should it resume the same or similar consultancy-type activities offered to higher education institution.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.3 Independence
Keywords	organisational independence (overlap in the composition of the agency’s different bodies)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged for attention the independence of AQU from both government and higher education institutions. The panel found that the new legal framework (AQU Catalunya Bill adopted in 2015) has increased the agency's independence, whereby the government is no longer directly involved in the appointment of senior staff members in the agency.In its statement to the review report, the agency explained that the representation of higher education institutions was in line with existing legislation and that the role of the Governing Board is separated from the committees dealing with evaluation results. The agency further emphasised that the current composition does not allow for a partisan decision to be made by any stakeholder group and argued that the panel's concerns were based on conjecture and not evidence.The Register Committee noted the review panel’s concerns with regard to the lack of a clear separation between the composition of subject-specific committees and review panels that implement and monitor the procedures, which might create unwanted and unintended interference between the different roles. AQU stressed in its statement to the review report that this practice in fact ensures greater consistency in the application of the review criteria and since the decisions are made collectively the agency considers there is no undue influence.The Register Committee noted the agency’s clarifications. While it found that the flag on the independence of the Governing Board was largely addressed, the Committee underlined the concerns of the panel with regard to the overlap in the composition of the agency’s different bodies.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	lack of transparency in criteria for awarding the premium seal
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the decision of renewal of FIBAA’s registration, the Register Committee flagged for attention the lack of transparency in the agency’s criteria for awarding the “FIBAA Premium” seal to accredited programmes.The panel noted that FIBAA has made improvements to the transparency of its procedure, including to the criteria for awarding the premium seal. The panel, however, underlined that the weighing of the criteria is not sufficiently transparent as this information it is not made accessible for external parties (in particular to higher education institutions).

In its statement to the review report the agency stated that weighing for the criteria for awarding the premium seal (along with the other criteria) are published on the homepage of FIBAA. The Register Committee was able to verify this information and therefore concluded that the agency has addressed the flag. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Inconsistency in preparation of reports; publication of programme accreditation reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that the practice of sending review reports to higher education institutions for approval after decisions have been made should be reconsidered as this is not standard practice. To ensure consistency in the preparation of reports, the panel underlined the need for clearer manuals. The panel also referred to the results of an analysis carried out by the Accreditation Council, which showed that a number of programme accreditation reports have not been published by FIBAA. The Register Committee noted the intention of FIBAA to improve its practice of publishing reports and considered that improvements have not yet been externally reviewed.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Lack of impartiality in the appeals process; lack of clear complaints procedures.
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel learned from its discussion with the agency that higher education institutions can point out faults in the procedure of the review in their statement to the review report. While higher education institutions are given the possibility to make a statement on the review report the panel underlined that there was not a clear indication on whether higher education institutions can issue a complaint regarding the course of the procedure. In its statement on the review report the agency stated the appeal procedure has been published on its website and also included in its quality management handbook. According to the procedure, once the appeal is lodged by a higher education institution it will be passed on – after consultation with the review panel – to the responsible Committee who can decide on whether to allow the appeal to go forth. In case this is granted the appeal will be submitted to the FIBAA Appeal’s Committee for examination. The Register Committee considered that the current procedure, whereby the Committee that issued the initial decision decides on whether the appeal of that institution will be passed to the Appeals Committee, might affect the impartiality of the process. The Register Committee further found the procedure to be documented only rudimentarily, with little or no explanation on the issues that could be raised under the appeal, no provision on the expected timeline to process a complaint, publication policy etc.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	Systematic approach to analyses
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“When FIBAA ‘s registration was last renewed, the Register Committee flagged for attention the establishment of a systematic analyses of FIBAA's overarching reflections and observations from its accreditation, evaluation and audit activities. The panel showed in its analysis that FIBAA initiated a regular collection of information on the outcomes of the agency’s processes, such as conditions formulated, feedback from workshops and from staff. The findings are presented in FIBAA’s newsletters, workshop articles and academic articles. While the review panel noted an increase in the analytical publications prepared by the agency, the panel also recommended that such publications are extended so as to also cover fields of activity beyond programme and system accreditation. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.1 Consideration of internal quality assurance
Keywords	Part 1 reflected in ANQA’s criteria
Panel conclusion	Full compliance
Clarification request(s)	Panel (09/07/2025)
RC decision	Compliance

“The review panel provided a mapping table between ANQA's criteria (for institutional accreditation and for programme accreditation) and Part 1 of the ESG. The Register Committee requested the panel to elaborate on its analysis and findings as to how the different standards of ESG Part 1 are reflected in ANQA's criteria. The Committee appreciated the explanations provided, noted that the panel had reviewed ANQA's institutional accreditation reports and came to the conclusion that all standards were reflected in the same measure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	follow up (ineffective and not reviewed by the panel); implementation of programme accreditation was not analysed by the panel
Panel conclusion	Full compliance
Clarification request(s)	Panel (09/07/2025)
RC decision	Partial compliance

“The panel noted that it did not analyse the effectiveness of the monitoring process, normally taking place two years after accreditation, since it had not yet been implemented. The Register Committee sought and received clarification from the panel on the 6-monthly follow-up processes after conditional accreditations. The Committee understood that the panel did not consider the 6-monthly follow-up effective and, hence, recommended revisiting the 6-month period. The Register Committee further sought clarification from the panel concerning the programme accreditation process, since only pilot accreditations had been carried out so far. While the panel clarified that it had analysed how ANQA took into account the lessons learned from the pilots, it had not analysed the implementation of the pilots. While the Committee considered that the review report demonstrates that ANQA's process for programme accreditation includes the features required by the standard in theory, no statement could be made on actual practice at this point. One of the two follow-up processes appears to be considered ineffective by the panel, the other follow-up process was not reviewed by the panel and the implementation of programme accreditation was not analysed by the panel.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.5 Criteria for outcomes
Keywords	criteria not published fully
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel noted that ANQA's evaluation protocols, containing additional details about its standards, and the decision rules, used by the Accreditation Committee to differentiate their different possible accreditation decisions, are not published; the panel recommended that they be published.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.6 Reporting
Keywords	Publication of the reports of the pilot programme accreditations
Panel conclusion	Full compliance
Clarification request(s)	Panel (09/07/2025)
RC decision	Partial compliance

“The Register Committee noted that the reports of the pilot programme accreditations were not published on ANQA's website. The Committee sought clarification from the panel as to how it viewed the non-publication of those reports. The review panel noted that these pilots “were organised under supervision of other EQAR registered QA agencies and therefore the responsibility of these other QA agencies”, without, however, mentioning the agencies and addressing whether or not the reports were published by them. The Register Committee, however, noted that both ANQA's self-evaluation report and the external review report repeatedly state that ANQA had implemented the pilot accreditations. The Committee was therefore not persuaded by the panel's point of view that ANQA had no responsibility for the publication of these reports.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Inadequate appeals process
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel noted that – while being clearly defined and published – “the process of appeals established by ANQA cannot be considered an appeal, but a second opportunity giving the institution time to improve its situation and then undergo one more evaluation and receive a new decision in a short period of time”. The Register Committee concurred with the panel that the ANQA process differs substantially from the common understanding of an “appeal” and considered that it was doubtful whether the process was fit to address the type of issues it is expected to address, i.e. “adversely assessed criteria and/or alleged procedural violations against the institution”. The Register Committee considered that the standard does not prescribe a specific appeals procedure and that the review report identified serious shortcomings in the appeals procedure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	cosultancy/training to HEIs
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In connection with ANQA's budget, the panel noted that ANQA is carrying out consultancy activities on a minor scale. As it was not specifically analysed in the report, the Register Committee sought clarification from the panel on potential conflicts of interest arising from consultancy work. The Register Committee understood from the panel's response that ANQA provides collective training opportunities to Armenian higher education institutions, but does not render services to individual institutions, and that, therefore, there is no specific potential for conflicts of interest.The Register Committee, however, underlined that in case ANQA provides consultancy to individual institutions in the future it would have to implement appropriate policies to prevent that ANQA accredits the same institution to which it rendered consultancy services.”

Full decision: see agency register entry

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 (09/07/2025)
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

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/11/2017
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to system-wide analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ In its decision for inclusion, the Register Committee flagged QANU’s systematic approach to system-wide analyses. While QANU has not produced thematic analysis in its strict sense, the panel noted that the agency published reports at the request of research universities and state of the art reports for programmes that are assessed in clusters. The panel noted that QANU did not have a systematic approach towards producing thematic analysis and that the agency views this activity to remain mainly in the responsibility of NVAO. In its additional representation, QANU's underlined that its core activity is to conduct assessments, and due to its limited size, financial resources and scope QANU’s ability to conduct thematic analyses in a systematic way was limited. The Board of QANU had nevertheless considered the recommendations of the panel and stated that it would adapt its approach to thematic analysis.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	follow up procedure for programmes accredited without condition
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In the review report (p. 28) the panel stated that if a programme is accredited with conditions, the programme is expected to submit an interim report on how it has fulfilled these conditions. The Register Committee was unclear if a follow-up is also implemented for programmes accredited without conditions and have therefore requested the panel to clarify this matter.The panel (response letter of 28/05/2017) stated that higher education institutions are expected to inform FINEEC of significant changes related to their programme organisation, implementation and development. The panel found no other evidence of a follow-procedure that would apply to programmes accredited without conditions. The Register Committee considered the design of the follow-up of programmes accredited without conditions to be minimal but nevertheless appropriate.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.7 Complaints and appeals
Keywords	Limited scope of the appeals system
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of initial inclusion (of 18/11/2010) the Register Committee flagged for attention FIN(H)EEC’s appeals procedure. The Committee noted that considerations should be given to this matter even though FIN(H)EEC’s decisions do not have a formal consequence (in terms of an institution’s license or financing), its audits result in a formal result, i.e. the report. The panel stated that audit results are considered expert opinions and according to Finnish law, appeals can be filed against administrative decisions only. The Register Committee underlined that a system for complaints and appeals should be in place irrespective of the formal status, while the status of the appeal system may be different from the common system of appeals that might be applicable to public administration. The panel explained that FINEEC has nevertheless made it possible for higher education institutions under review to request an assessment of the results of an audit or a re-audit on the grounds that the audit has not been carried out in compliance with the audit manual. Higher education institutions cannot, however, appeal the actual conclusion of the audit or accreditation team nor the decisions of the decision-making committees, a situation the panel described as “less optimal”. The panel further established that until now there was only one request to review the result of an audit, but the case was not yet decided upon by the time of the site visit. While an appeals system is established and publicly described, due to the lack of actual practice the Register Committee was so far unable to conclude whether the current system, limited in scope, was sufficient to safeguard the interest of institutions under review. The Committee noted that practical experiences with the appeals system should be addressed in the next review of FINEEC.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Scope of the thematic analysis (evaluations)
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the eligibility verification (see letter to FINEEC of 12/02/2016) the Register Committee considered FINEEC’s thematic evaluations to be activities within the scope of the ESG, as far as they concern individual institutions or programmes of higher education. The Register Committee noted from the panel’s analysis that thematic evaluations have been paused after the merger of FINHEEC, and that the agency intends, according to its National Plan for Education Evaluations to reintroduce these evaluations between 2016-2019. […] the panel stated that thematic evaluations were found to be outside the scope of the ESG. The panel noted that thematic evaluations did not evaluate individual higher education institutions (or parts of them) or programmes, nor did they address the effectiveness of internal quality assurance as defined in Part 1 of the ESG. The panel, however, added that – although these evaluations are outside the scope of the ESG – the procedures and practices applied by FINEEC largely comply with the ESG. While the Register Committee concurred with the panel in that thematic evaluations in general fall outside of the scope of the ESG. The Register Committee, however, noted that at least in one particular case, i.e. the thematic evaluation of education in the maritime sector (2015-2017), FINEEC (also) addressed the quality management of individual education units and that the results of the FINEEC evaluation will serve as a basis for the International Maritime Organization (IMO) to decide on the right of the educational establishments in the maritime field to issue certificates of competency. The Register Committee concluded that thematic evaluations are within the scope of the ESG only if they apply to the three cycles described in the QF-EHEA and include formal results, statements or judgements on individual higher education institutions. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.3 Independence
Keywords	organisational independence
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its analysis, the panel discussed that the processes for the appointment of the Director and members of the Evaluation Council may be seen as political and as a potential risk in terms of FINEEC’s organisational independence. The panel thus emphasised the need for transparent procedures with clear and predetermined criteria. The Register Committee sought clarification from the panel as to how it satisfied itself that there was no undue influence in the nomination process given the current absence of a formal procedure and criteria. In its response letter, the panel stated that the need for the procedure to be transparent was brought up to underline the need to guarantee the independence of the agency and not to indicate that there was not a formal procedure in place or that it was not transparent. The panel clarified that in case of the Director, the appointment follows the procedure for the recruitment of civil servants in Finland, while in case of appointing the members of the Evaluation Council, the members are chosen from the proposals made by different stakeholder groups (from the educational sector, teacher education, research, working life and students). The Register Committee was able to verify that the documentation related to both procedure is published.In the review report the panel stated that FINEEC might in the future merge with the National Board of Education and the Centre for International Mobility (CIMO). The panel noted that this merger might affect the independence of evaluation activities as the tasks of the Board of Education are closely related to the political work of the Ministry of Education and Culture.

The Register Committee underlined that FINEEC is expected to submit a Substantive Change Report should its organisational status change in the future.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	Lack of thematic analyeses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While a number of thematic analyses have been published since the last external review of the agency, the panel found that the analyses have been paused since the merger of FINHEEC into FINEEC. The panel also noted that FINEEC has not yet initiated thematic analyses of the accreditations of engineering degree programmes due to the small number of finished accreditations. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	2.3 Implementing processes
Keywords	Lack of consistent follow-up procedures
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its decision of initial inclusion (18/05/2011) the Register Committee flagged the introduction of site visits as well as follow-up procedures undertaken by HCERES. The panel noted that since its last review HCERES did not ensure a consistent follow-up in its EQA activities due to a prolonged process of succeeding evaluations (that included the introduction of site evaluations). The agency replaced the follow-up with a progress report that higher education institutions would prepare as part of their self-evaluation so as to facilitate and speed up the process. Moreover, the panel noted that evaluations of programmes are carried out without site visits.”

Full decision: see agency register entry