Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.3 Independence
Keywords	Lack of ability to independently design external QA procedures, lack of ability to autonomously determine organisational structure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“27. The Register Committee learned from the panel’s analysis that ANVUR’s ability to design its external QA procedures (i.e. operational independence) and to set up its internal organisational structure (i.e. organisational independence) is rather limited. In panel’s view, the Italian regulations stipulated very specific details on the agency’s external quality assurance procedures, methodologies and the evaluation standards, as well as the internal governance and organisational structure. This approach diminishes ANVUR’s ability to act autonomously regarding its internal regulations and structures.

28. In its additional representation, ANVUR argued that most of the issues outlined by the review panel stem from the Italian national context and legislation. In regard to the operational independence of the agency, ANVUR argued that it has sufficient autonomy in designing its external QA procedures because national legislation emphasises ANVUR’s responsibility to independently define the criteria, indicators, and requirements of its external QA, while in regard to organisational independence, ANVUR states that the national legislation prescribes collaborative relation between the Ministry and ANVUR, instead of a direct supervisory role of the Ministry.

29. The Register Committee took note of ANVUR's remarks. The Committee could still follow panel's view that ANVUR is facing obstacles regarding organisational and operational independence, as the review panel already considered these legislative acts and nonetheless outlined detailed reasons for their concerns about ANVUR’s independence.

30. Considering that the review panel presents convincing evidence and analysis that ANVUR faces obstacles in its organisational and operational independence, the Register Committee concurred with the panel that ANVUR complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	Independence, government representatives
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“18. The Register Committee understood from the analysis by the panel that the composition of the Board of Directors has dominant representation of the government and the UIB, and these two stakeholders appoint all six board members.

19. The Register Committee further learned that according to statutes, the Director of the agency is appointed by the Balearic minister responsible for university affairs. Since 2009, however, this position is vacant and the Technical Director, chosen with a public competition, manages the agency.

20. The Register Committee understood that to resolve the above mentioned issues new statutes of the Consortium of the Balearic Agency for Quality Assurance in Higher Education has been drafted. The statutes, however, are not yet in effect. Following this, the Committee concurred with the panel that AQUIB only partially complies with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	government,
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. The Register Committee learned from the panel analysis that the representation of stakeholders in the Governing Council has improved compared to the previous review and that the share of Government appointees in this body has been lowered.

17. The Committee, however, also noted that the regional minister, whose portfolio the agency is situated in, is acting as the President of the agency, chairs the Governing Council and has a casting vote.

18. Furthermore, the Register Committee noted, as underlined by the panel, that the agency is dependent on the Regional Government’s approval for hiring both temporary and permanent staff, which limits the agency’s operational autonomy.

19. Considering the significant level of involvement of the regional government in the governing of the agency and the potential constraints over the staff management and the operational independence of the agency, the Register Committee could not follow the panel’s judgement and concluded that ACCUA complies partially with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	26/11/2024
Standard	3.3 Independence
Keywords	Governmental influence, limited budget execution autonomy, limited human resources management autonomy
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. In its last decision, the Register Committee concluded that ACSUG complies

only partially with ESG 3.3 due to the strong influence of the regional government

over the process for appointment of the Director, the chair and members of the

Governing Board and the chairs of the CGIACA, leading to diminished organisational

independence of the agency.

17. The Register Committee learned from the analysis of the panel that no

change has taken place and that the Ministry still has a decisive role in the

appointment procedures of these ACSUG bodies.

18. The Register Committee further understood from the analysis of the panel

that ACSUG has limited autonomy in how to utilise its budget and manage its

human resources.

19. Following the strong influence of the regional government over the

agency, as well as ACSUG’s lack of autonomy in managing its resources, the

Register Committee concurred with the panel that ACSUG complies only partially

with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	27/06/2025
Standard	3.3 Independence
Keywords	Independence; Dual role of Interim Director
Panel conclusion	Non-compliance
Clarification request(s)	Agency (05/06/2025)
RC decision	Partial compliance

“34. In the last decision of renewal of registration, the Register Committee found the agency to be partially compliant with the standard due to issues related to the organisational independence of the agency. Namely, the Governing Board was predominantly composed of the representatives of the regional government, including the Chairperson, while the members were appointed by the regional Minister responsible for universities and research. Furthermore, the agency was largely dependent on the regional government for approval and hiring of new staff and the annual approval of the budget.

35. The Register Committee noted from the panel analysis that the concerns raised during the last review remain pertinent. The majority of Board members are either appointed by the regional Minister of Education or take on their roles by virtue of holding specific positions within state administration, and the Board is chaired by the Head of the Regional Ministry for Universities.

36. Furthermore, the Register Committee learned from the panel analysis that the Acting Director of the agency during the site visit was simultaneously the head of the General Directorate responsible for universities and research, who also serves as a vice-chair of the Board.

37. The Register Committee concurred with the panel that the dual role of the Acting Director endangers the independence of the agency, especially given that the agency's organisational structure is centred around the director's position, which grants this position significant influence.

38. The Register Committee further learned from the panel analysis that the agency does not have sufficient autonomy in the recruitment process, and the budgetary constraints remain under the authority of the regional government, hindering the agency's operational flexibility and autonomy.

39. In its additional representation, ACSUCYL informed EQAR that in order to reduce the representation of regional government members on the Board of Directors, the agency approved a proposal to replace two governmental officials with two students. To that end, it has submitted a proposal to the regional government for legislative amendment. The Register Committee further asked for clarification on the timeframe when the legislative amendments would be approved. The agency clarified there was no precise timeline for amending the legislation, but they expect it to be approved by January 2026.

40. The Register Committee welcomed the actions taken by the agency, but it acknowledged that the proposed legislative changes have yet to be adopted. Additionally, once adopted, it remains to be considered and reviewed by an external review panel.

41. To address the dual role of the Interim Director, the agency has taken accelerated steps to appoint a new Director and has published an open call with expedited deadlines to resolve this issue. Following a clarification request, the agency clarified that as of yet it had no formal mechanism to avoid the dual role of the director, but they have accelerated the process to select the new director by 9 June 2025.

42. Following the clarification call with ACSUCYL (of 2025-06-05), the agency informed the Committee that a new Director has been selected on 9 June 2025 (see Annex 4). The Register Committee welcomed the steps taken by the agency to appoint a new Director with expedited deadlines and emphasised the importance of introducing measures to avoid dual/multiple roles for the Director of the agency in the future, which could compromise the agency’s independence.

43. In its additional representation, the agency further explained that budget control mechanisms from the regional government are mandatory, as the agency receives public funding. The agency clarified that while being accountable to the regional government, the agency has autonomy to plan and execute the budget and manage its staffing process.

44. The Register Committee welcomed the clarification, however, noted that concerns about the dependency on the regional government for the approval of the budget and staffing are still pertinent.

45. While concerns on the agency’s independence are yet to be fully resolved, considering the agency has already selected a new Director following an open call, the Register Committee concurred that ACSUCYL now partially complies with the ESG 3.3. Furthermore, the Register Committee noted that ACSUCYL should inform EQAR once the new Director starts its term and the legislative changes are approved.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	27/06/2025
Standard	3.3 Independence
Keywords	organisational independence, operational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“19. The Register Committee learned from the report that the Director is appointed by the Parliament upon the recommendation by the Minister responsible for higher education, without a public call nor specific selection criteria.

20. The Committee found this problematic given the Director’s extensive power within the organisation and responsibilities in ensuring the independent operations of the agency: besides being the member of the Steering Committee (governing body), the Director also appoints the evaluation panels, chairs the Evaluation Committee and recommends the two other members of the Evaluation Committee, the body responsible for taking the accreditation decisions and issuing the final evaluation reports.

21. The Register Committee further noted that the organisational independence from the Ministry is undermined by fact that a senior Ministry official is sitting on and chairing the Appeals Committee, body of three members who are all simultaneously members of the Steering Committee as well.

22. In its statement to the report, AQUA informed that following the changes in the national legislation of January 2025, the process for selection of Director of AQUA will be based on a public call and an objective merit-based selection process, which will be lead by a commission responsible higher education in the Parliament instead of the Minister.

23. Furthermore, the agency informed that with the legal changes of January 2025, the composition of the agency’s Appeals Committee has changed from three to six members, and no longer includes a representative from the Ministry. In addition, the number of Steering Committee members in the Appeals Committee is decreased to one.

24. The Register Committee took note of these updates and welcomed the legal changes made in order to ensure organisational independence of AQUA. While noting the changes made in the composition of the Appeals Committee, the Register Committee underlined that the presented changes on the procedure for appointment of AQUA Director are yet to be implemented and reviewed by an external review panel to verify whether they have been properly implement in practice.

25. The Register Committee therefore concurred with the panel that AQUA complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/06/2025
Standard	3.3 Independence
Keywords	operational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. In its last decision, the Register Committee found the agency to be partially compliant due to THEQC’s workforce that was heavily consisting of (academic) experts working at the agency but being paid by their higher education institutions.

21. The Register Committee, learned that while the number of permanent staff has increased since the last focused review, the number of seconded experts working at the agency while being paid by their higher education institutions remains ‘significant’ (10 out of 44 permanent staff members).

22. Considering that the concerns from the last decision regarding the dependency of the agency on staff being paid by higher education institutions remained, the Register Committee concurred with the panel that the agency remains to be partially compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	14/03/2022
Standard	3.4 Thematic analysis
Keywords	Content of the thematic analysis
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“the content of the thematic publications mainly involved reflections on the agency’s own experiences in conducting EQA rather than analysis of the results of the EQA (an analysis which could be more appropriate to serve the internal quality assurance processes, ESG 3.6). The Committee agreed with the panel’s views that the agency could improve the content of the analyses so they are more meaningful for the wider academic and QA community”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	3.4 Thematic analysis
Keywords	Lack of independent thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	Agency (20/04/2026)
RC decision	Partial compliance

“AVAP had conducted meta-analyses of their review activities before the pandemic but discontinued this practice. As

part of REACU, AVAP also carried out structured analyses of the situation of the university system. The agency, however, is not developing any thematic analysis independently.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	3.4 Thematic analysis
Keywords	Lack of development in preparing thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. The panel notes that AKAST reliably contributes the experience gained from its own quality assurance procedures to the regular evaluation of the Key Points and that the agency is documenting the results of its ongoing student survey on its website.

18. The Register Committee welcomes AKAST’s plan to further develop a thematic analysis after an appropriate number of programme accreditation procedures have been completed, but underlined that such an analysis has not been finalised.

19. Considering the limited development of thematic analysis, the Register Committee can follow the review panel conclusion that AKAST complies only partially with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	3.4 Thematic analysis
Keywords	separate research or bilbiometric analyses do not qualify as thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“38. The panel considered that HCERES' recent activities have been focused on research and bibliometric analysis; analyses drawing on the results of evaluations within the scope of the ESG have not been produced regularly since the summary reports that HCERES/AERES used to produce following earlier evaluation campaigns.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.4 Thematic analysis
Keywords	Consistent publication of thematic analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee learned that IQAA has published several thematic analyses since the last review. The panel, however, could not see

any formal plan for drafting and publishing these analyses.The Committee considered that despite the absence of a more formal planning the agency has developed a practice and demonstrated a clear vision for conducting analyses based on its EQA processes.”

Full decision: see agency register entry

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

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

Full decision: see agency register entry

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

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

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

Full decision: see agency register entry

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

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

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to thematic analysis; Absence of regular analysis;
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that the agency has produced two analyses since its last review in 2014, both written in Russian but only published on the English version of AKKORK’s website. According to the panel, the last publication, however, does not meet the requirements of a thematic analysis. In particular, the panel noted the great qualitative difference between the publications, indicating a missing systematic approach to the publication of thematic analysis. The Register Committee underlines the panel’s recommendation that the agency should establish a clear process to address all of its activities in thematic analyses. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords	Producing effective thematic analysis reports
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its decision of 2015 to admit QQI to the Register, the Register Committee flagged for attention the production of thematic analyses by QQI.The Register Committee understood from the panel's report that QQI has been proactive and effective in producing a range of thematic analysis reports, which are considered useful in the sector for improving quality and quality assurance, even though not having completed full cycles in all external quality assurance activities.The Register Committee therefore considered that the flag has been addressed and concurred with the panel's conclusion that QQI complies withthe standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords	Producing effective thematic analysis reports
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“When evalag’s registration was last renewed, the Register Committee noted that the current review should address whether evalag produced analyses of the general findings of all reviews carried out by the agency. The review panel described clearly how evalag conducts thematic analyses based on the findings from its reviews. 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	3.4 Thematic analysis
Keywords
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the previous review the panel found that Unibasq had yet to produce a system-wide analysis and there was a lack of sufficient resources which is why this standard was flagged.The panel recognised that Unibasq has made clear progress in this area in recent years. The reports that agency produces show a clear shift from the evaluation of the procedures to a genuine thematic analysis (see page 24 of the report).The Committee concluded that the flag has been addressed and concurred with the review panel’s conclusion that Unibasq complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords	Producing effective thematic analysis reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“At the time of its previous review in 2014, the Register Committee noted that AQ Austria was working on its first thematic analysis report on the development of quality assurance in Austria, and has not yet produced documentation to evidence substantial compliance. In its 2019 review report the panel’s findings show that the agency has since produced a number of reports focused on the results of QA processes and related issues in higher education. While the Register Committee underlined the recommendations of the panel for a further development of the thematic analysis, the Register Committee concluded that the flag has been satisfactorily addressed.”

Full decision: see agency register entry