Database of Precedents

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.6 Reporting
Keywords	publication of reports, negative
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“7. In its previous decision, the Register Committee found the agency to be partially compliant due to the lack of publication of reports with negative results of its ex-ante verification of study programmes.

8. The Register Committee learned that ACCUA now publishes reports with negative and positive results of all evaluations processes except for reviews of universities for recognition on its website. From the report, the Committee learned that these reviews only occur by a request from the regional ministry and are sporadic. The Committee further understood that the agency is not authorised to publish the reports as this is in the remit of the regional parliament.

9. Given the improvements made in publication of the negative reports, the Register Committee could concur with the panel that the agency now complies with the standard. The Register Committee, nevertheless, highlighted the panel’s recommendation that the agency should raise the issue with the publication of the results of the reviews of universities for recognition with the regional authorities to ensure that these reports are made available to the public.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.7 Complaints and appeals
Keywords	internal appeals system
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“10. In its last decision, the Register Committee raised concerns regarding the lack of an internal appeals system within the agency and as a result found the agency to be partially compliant with the standard.

11. The Register Committee noted that since the last review of ACCUA the agency has established a separate body within the agency responsible for appeals. Furthermore, the panel noted that the appeals procedure is clear, publicly available and ensures impartiality in decision-making by the Appeals Committee.

12. The Register Committee thus found that the agency has addressed the issues raised in the previous report and therefore can follow the panel’s conclusion of compliance.”

Full decision: see agency register entry

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

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	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.4 Thematic analysis
Keywords	thematic report
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“20. The Register Committee learned that ACCUA has created a statistical analysis unit and produced five thematic reports since the last external review. However, as noted by the panel, out of the five reports only one can be considered as a thematic analysis in the sense of the standard, since the other four reports provided useful inputs for policy debates with regional stakeholders and for improvements in quality assurance at universities.

21. The Register Committee finds, in line with its interpretation of the standard, that the thematic analysis report in question is sufficient for achieving compliance with the standard and therefore could not follow the panel’s judgement of partial compliance and concluded that ACCUA complies with ESG 3.4.

22. The Register Committee nevertheless underlined the panel’s recommendation that the agency should devise a clear plan for thematic studies and use its evaluation reports to produce these studies.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality asssurnace system
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“23. In its last decision, the Register Committee found the agency to be partially compliant due to the lack of development and proper implementation of its internal quality assurance system.

24. The Register Committee understood, from the panel analysis, that the agency has made a significant progress, by introducing a number of internal mechanisms, reviewing policies, procedures and guides. The panel noted that, however, the agency does not yet have a full internal quality assurance system in place, but intends to work on this in the coming period.

25. While the Register Committee welcomed the progress made by the agency. The Committee noted that, however, a well-rounded internal quality assurance system that synchronises the newly introduced tools is yet to be set. Therefore, the Register Committee could not follow the panel’s judgement and found the agency to be partially compliant with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.3 Implementing processes
Keywords	Informing stakeholders
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“9. The Register Committee understood from the panel’s analysis, that while external quality assurance processes are in line with the standard, there are discrepancies in understanding the processes of drafting and finalising review reports, as well as the role of the QA expert in the Commission of Study Programmes Evaluation (CET).

10. The Register Committee could follow the panel's view that the agency is compliant with standard, but emphasized the panel's recommendation that the agency should ensure that all stakeholders are effectively informed about the entire external evaluation process.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.4 Peer-review experts
Keywords	Peer-review experts
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“11. The Register Committee learned from the panel’s analysis that, in the ex-post accreditation reviews are collaborative effort between the panel and the Commission of Study Programmes Evaluation (CET). In particular, the Criterion 3 of the methodology is pre-evaluated by a member of the CET. Even though it is not currently the practice, these members can also participate in the external site visit.

12. The Register Committee shared the panel’s concerns that the current set up in which the CET members are participating both in the external evaluation and the decision making on the final outcomes of the review may lead to a potential conflict of interest. Further, the Register Committee noted that this arrangement is contrary to the requirement that external quality assurance is conducted by a group of external experts.

13. The Register Committee also learned that follow-up activities are not conducted by panels, but directly by CET sub-commissions. CET sub-commission includes a chairperson, two academic members, one student member and one quality spokesperson.

14. Given the above mentioned issues, 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

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

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	Initial
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.4 Thematic analysis
Keywords	Thematic analysis
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“21. The Register Committee learned from the report that AQUIB has a Thematic Analysis Protocol for a systematic approach to conducting thematic analyses, which was adopted in 2023 and is being implemented for the first time. However, the topic of the only thematic analysis conducted so far does not incorporate the results of its external quality assurance procedures.

22. Considering that the only thematic analysis conducted by AQUIB so far is outside the scope of ESG, the Register Committee was unable to concur with the panel’s conclusion of compliance and found that AQUIB only partially complies with the standard.

23. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	27/11/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	ESG Part 1
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision for renewal of registration (of 2020-03-16), the Register Committee found that VLUHR QA only partially fulfilled the requirements of the standard, as the ESG Part 1 was not sufficiently addressed in the main activities of VLUHR QA.

9. The Register Committee understood from the panel report that, since the last review, VLUHR QA has started employing a new framework for assessing programs in Flanders, which consists of eight quality features (QF). The new framework is stipulated by Flemish decree and must be implemented by the QA agencies evaluating programmes in Flanders.

10. The Register Committee learned from the panel analysis that the new quality framework still does not directly address certain elements of ESG 1.1, ESG 1.2 and ESG 1.4. There is no explicit mention that institutions must have a public quality policy (ESG 1.1) or processes for programme approval (ESG 1.2); nor it is addressed explicitly that “the internal processes of the university to ensure the monitoring of support processes for students at all stages of the lifecycle” (ESG 1.4).

11. The Register Committee also learned that VLUHR QA has addressed the missing elements only in the Guide for drawing up a self-evaluation report for higher education institutions. These elements are not covered in the Manual Programme Review, the main document followed by the external reviewers.

12. While the Register Committee understood that the new Flemish Framework addresses ESG to a higher extent than the previous one, the absence of ESG 1.1, ESG 1.2 and ESG 1.4 in the Framework and in the Manual raises concerns about the possibility of them being overlooked during the assessment. Therefore, the Register Committee found that VLUHR QA only partially complies to the standard and highlighted the panel’s recommendation on including the content of the Guide for drawing up a self-evaluation report in the Manual Programme Review.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	27/11/2024
Standard	3.4 Thematic analysis
Keywords	Thematic analysis
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its last decision for renewal of registration (of 2020-03-16), the Register Committee found that VLUHR QA only partially fulfilled the requirements of the standard, as the agency did not publish thematic analysis based on the findings of external quality assurance activities.

14. The Register Committee learned from the panel’s analysis that VLUHR QA has completed three thematic analysis reports since their last review and the number of reports aligns with the level of activity of the agency. Additionally, thematic analysis has been integrated into VLUHR QA’s daily work and in the current Policy Plan (2023-2027).

15. Furthermore, the Register Committee understood that VLUHR QA focusses on the thematic analyses being relevant to higher education stakeholders and ministry representatives, rather than solely concentrating on the outcomes of external review results.

16. The Register Committee was able to follow panel’s conclusion that VLUHR QA is now compliant with the standard.”

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	26/11/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Lack of strategic plan and deficiencies in strategic management, lack of yearly planning and monitoring, distinction between the agency's consultancy services and external QA processes
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The Register Committee learned from the review report that this standard

was not originally included in the targeted review, but the panel decided to include

it after considering all the evidence and input of the review as a whole.

13. From the review report, the Register Committee noted that since the last

strategy expired, ACSUG did not develop a new strategic plan. The Committee

further noted that ACSUG is lacking reliable yearly planning and monitoring that

would be linked to such a strategic plan. The panel found that this leads to

significant deficiencies in strategic management of the agency.

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

that ACSUG lacks a clear communication and definitive distinction between the

agency's consultancy services and external QA processes.

15. Following the lack of strategic planning of ACSUG and absence of clear

distinction between its external quality assurance and consultancy activities, the

Register Committee concurred with the panel that ACSUG complies only partially

with ESG 3.1.”

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	26/11/2024
Standard	3.4 Thematic analysis
Keywords	Collaborative thematic analysis, lack of regularity
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. In its last decision, the Register Committee found that no thematic analysis)

was performed, and therefore concluded that ACSUG complies only partially with

ESG 3.4.

21. The Register Committee understood from the analysis of the panel that

ACSUG relies on collaboration with, and contributes to, the thematic analyses

coordinated by the Spanish Network of University Quality Agencies (REACU).

However, The Committee also understood that ACSUG does not have any stand-

alone thematic analyses that they conduct themselves and that thematic analysis is

still not included in the regular workflows and task distribution of the agency (see

also Register Committee remarks under ESG 3.1).

22. The Register Committee emphasised that conducting thematic analyses

under the partnership with REACU does not fulfil the requirements of the standard

because the regularity of such activities is sporadic, and ACSUG is dependent on the

thematic analysis coordinator (REACU).

23. Following the lack of thematic analysis conducted by ACSUG, the Register

Committee concurred with the panel that ACSUG complies only partially with ESG

3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	26/11/2024
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Addressing recommendations from the previous external review
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“24. In line with the EQAR Use and Interpretation of the ESG, the Register

Committee understands that ESG 3.6. implies that previous recommendations and

instances of partial compliance have been addressed properly.

25. The Register Committee noted that ACSUG has not responded

appropriately to most of the instances of partial compliance raised in a previous

external review, and had regressed in one standard (3.1), which has negative

implications for ACSUG’s level of compliance with ESG 3.6. The Register Committee

therefore once again emphasises the recommendations delivered by the 2019 and

2024 review panel and expects that these issues are addressed in the next (full)

review of ACSUG.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	Internal quality assurance
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“9. In its previous decision the Register Committee found the agency to be compliant with ESG 2.1. As per the

Policy on Targeted Reviews, ESG 2.1 shall always be part of the external review process. The Register Committee noted that all procedures share an underlying framework infrastructure for all of it external quality assurance activities that reflects well the standards of ESG Part 1.

10. The Committee therefore concurred with the panel’s conclusion that QQI continues to be compliant with ESG 2.1.

11. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.4 Peer-review experts
Keywords	Absence of student reviewers; Training of student reviewers
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“10. In its previous decision for renewal of registration on EQAR (of 2024-11-05), A3ES was found to be partially compliant with the standard due to the absence of student reviewers in panels in the New Study Programmes (NCE) procedures and overseas accreditations. The Register Committee noted from the panel analysis that the status quo has not changed.

11. Furthermore, the Committee understood that except for initial trainings, the agency does not organise systematic training for new or revised processes and that some reviewers, including students, have not received training in the past five years. Furthermore, the Committee understood that student reviewers receive only training for programme reviews, but not for institutional reviews.

12. Given the lack of students involvement in some procedures and the lack of systemic training for reviewers, the Register Committee concurred with the panel conclusion, and found that A3ES remains to be partially compliant with ESG 2.4.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.6 Reporting
Keywords	Publication of negative reports and decisions
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“13. The Register Committee learned from the analysis by the panel that A3ES does not publish negative reports and decisions on the assessment of new study programmes (NCE).

14. Given the lack of transparency by not publishing negative reports and decisions for all procedures the Register Committee concurred with the panel that A3ES only partially complies with ESG 2.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.4 Thematic analysis
Keywords	Inactivity in implementing thematic analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. The Register Committee understood from the analysis by the panel that the most recent thematic analysis published by the agency were done in 2017.Furthermore, the Committee, noted that “the agency confirmed to the panel that it does not currently have a systematic approach to conducting thematic analysis but confirmed its commitment to developing this.”

16. The Register Committee concurred with the panel that A3ES only partially complies with ESG 3.4. The Register Committee underlined the panel’s recommendation that the agency should resume conducting and publishing thematic analysis of the outcomes and findings of its external quality assurance activities.

17. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.1 Consideration of internal quality assurance
Keywords	Part 1 insufficiently covered, inconsistency in addressing Part 1 standards in different procedures.
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“10. ANVUR conducts wide variety of external quality assurance procedures in its national higher education system. The Committee understood that some of the activities are applied in conjunction to each other (e.g. initial programme accreditation combines in certain elements with periodic institutional assessment of universities).

11. From the review panel report, the Register Committee learned that ANVUR aims to cover all the ESG Part 1 standards holistically through different combinations of their EQA activities taken together (e.g. ESG 1.9 is not assessed each time an initial programme accreditation is conducted but is instead included in the periodic institutional assessment of the university).

12. The Register Committee took note of the different combinations of ANVUR’s external quality assurance activities. It, however, learned that even in this case, few of the standards (e.g. ESG 1.6, ESG 1.7, ESG 1.8 and ESG 1.9) are not fully covered yet. The Committee learned from the analysis that the procedures which do not address all standards of the ESG Part 1 on their own (i.e. complementary activities such as the initial accreditation and periodic assessment) do not do so even in combination with at least one other self-standing activity (see remark on the ESG 2.1 in the EQAR Use and Interpretations of the ESG ).

13. The Register Committee further learned that there is a level of inconsistency in integrating ESG Part 1 in different external QA activities of ANVUR, for example ESG 1.9 being considered only in the initial accreditation of PhD programmes, but not in other procedures.

14. The Register Committee found that the agency is yet to effectively translate standards 1.1 – 1.10 of the ESG into all of its activities and demonstrate that the complementary activities jointly address ESG Part 1 fully. The Register Committee therefore concurred with the panel that ANVUR complies only partially with ESG 2.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.2 Designing methodologies fit for purpose
Keywords	Fitness for purpose difficult to fully assess due to dispersed methodologies
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. At the time of the review the methodologies were dispersed across different documents including ministerial decrees, other regulatory documents, and procedural guidelines, making it challenging to find information on each of the activities in a comprehensive manner. While the Register Committee could follow the panel’s conclusion that the agency complies with the standard it highlighted the panel’s recommendation that the agency should more explicitly define and consistently publish the purpose and aims of each of its external quality assurance activities.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.3 Implementing processes
Keywords	Difficulties in verifying that all procedures are pre-defined and published
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“16. The Register Committee understood that although ANVUR generally implements all stages of the review (self-assessment, site visit, report, follow-up), there are certain exceptions: site visits are not mandatory in the initial (ex ante) accreditation while the follow-up of the newly accredited institutions is only conducted via the periodic assessments.

17. The Register Committee learned from the analysis of the panel that ANVUR is lacking a comprehensive and published description for each external quality assurance procedure that would serve as an overarching guide (see also ESG 2.2). Due to this, the agency cannot ensure that its external QA processes are pre-defined and published, which could further endanger the consistent implementation of these processes and of their individual phases.

18. In its additional representation, ANVUR demonstrated that since the site visit, the agency published a Manual which comprehensively compiles, describes and explains all external QA activities of the agency in detail.

19. The Register Committee could verify that now ANVUR’s procedures are pre-defined and published, and was able to concur with the panel’s conclusion that ANVUR complies with ESG 2.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	2.6 Reporting
Keywords	Publication of all reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“20. The Register Committee learned from the panel analysis that the agency publishes full reports in only three out of its nine external quality assurance activities.

21. In its additional representation, ANVUR demonstrated that all reports are now published on ANVUR’s website. In addition, the agency explained that the accreditation protocols foresee a higher level of standardisation of reports which will in turn ensure that reports will continue to be published in full.

22. The Register Committee welcomed the steps taken by the agency and found that the agency now publishes all of its reports. Following this, the Register Committee could not follow panel’s conclusion and found ANVUR compliant with ESG 2.6.”

Full decision: see agency register entry

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

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	14/03/2025
Standard	3.4 Thematic analysis
Keywords	Use of external QA results
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“31. The Register Committee noted that ANVUR’s main channel for publishing the thematic analysis is the Biennial Report on the State of the Italian Higher Education and Research System. In addition, ANVUR conducts several ad hoc research initiatives on topics relevant for the Italian higher education system.

32. The Register Committee followed the panel’s conclusion that the agency complies with the standard. The Committee, however, emphasised the panel’s recommendation that ANVUR could use the findings and analyses of its external quality assurance processes more systematically and critically in its thematic analyses.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Internal QA not sufficiently systematised and formalised
Panel conclusion	Compliance
Clarification request(s)	Panel (01/10/2024)
RC decision	Compliance

“33. The Register Committee noted that ANVUR is in the process of expanding and implementing a diverse set of internal quality assurance processes. For the Committee, it was not clear how far has the agency reached in this process of developing their IQA system and, therefore, it sought further clarification from the panel.

34. The review panel explained that even though ANVUR conducts its internal QA procedures regularly and effectively, including collection, analysis and reaction to the feedback of its stakeholders, it is yet to develop a structured and systematic framework for its internal QA processes.

35. The Register Committee could therefore follow the panel’s conclusion that the agency complies with the standard. The Committee, however, emphasised the panel’s recommendation to ensure that internal quality assurance of ANVUR should be systematised and formalised, leading to a more coherent and consistent approach.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.5 Criteria for outcomes
Keywords	Lack of clear deliberation rules
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“7. In its last decision for renewal of registration (of 2019-11-05), the Register Committee found that CTI only partially fulfilled the requirements of the standard as the consistency in their decision making was not always assured - the Committee noted a lack of clear deliberation rules detailing the basis upon which specific decisions were made.

8. The Register Committee noted that CTI has introduced a new tool for ensuring consistency in its decision making – a deliberation table, used for synthesizing the panel assessments. Furthermore, the Committee understood from the analysis of the panel that the deliberation tables ensure consistency in the decision making process and make the review process more transparent.

9. Following the recent developments regarding the introduction of the new tool and its impact on consistency of the outcomes of CTI, the Register Committee was able to concur with the panel's conclusion, and found that now the agency complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.6 Reporting
Keywords	Publication of full reports
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“10. In the previous decision for renewal of registration (of 2019-11-05), the Register Committee found CTI to be partially compliant with the standard as it only published summary of evaluation reports which lacked important details from the full reports.

11. From the external review report, the Register Committee learned that a new template, which includes the full report, was introduced. Furthermore the Committee understood from the analysis of the panel, since 2019, CTI started publishing in full all of its reports.

12. Having addressed the earlier concern regarding publication of full reports, the Register Committee concurred with the panel’s conclusion and found that the agency now complies with the standard. The Committee, however, underlined the panel’s recommendations that the agency ensures that the reports are more analytical, their clarity and soundness are improved as well as their visibility on the agency's website.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.3 Implementing processes
Keywords	Follow-up
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“11. The Register Committee, noted in the analysis by the panel that evalag’s review procedures include a self-assessment report and an external assessment followed by expert’s report, but no follow-up activities, unless related to conditions/requirements established by evalag when taking the corresponding decision.

12. Given the concerns on the lack of consistent follow-up in all of evalag's procedures the Register Committee concurred with the panel that evalag complies only partially with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.4 Peer-review experts
Keywords	Training of experts
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. The Register Committee understood that the panels involve students and other stakeholders on equal bases. Furthermore, the Committee learned that despite the regular (online) trainings offered by the agency, very few people have enrolled for this online trainings.

14. The Register Committee therefore followed the panel’s conclusion that the agency continues to comply with the standard. The Committee, however, shared the panel’s view that the agency should find ways into making training opportunities more attractive for the reviewers to attend.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.7 Complaints and appeals
Keywords	Definition of terms; Complaints; Appeals
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. The Register Committee noted that the Complaints and Appeals Policy is detailed, covering the potential causes for a complaint or an appeal and it is easily accessible on the agency’s website. However, the Committee noted the panel’s concerns on the need to clarify the terms ‘complaints’ and ‘appeals’.

16. The Committee, therefore, followed the panel’s conclusion that the agency continues to comply with the standard. The Committee, however, shared the panel’s view that the agency should clarify what is meant by the terms ‘complaints’ and ‘appeals’ in all its documents, including the name of the ‘Complaints Commission’.”

Full decision: see agency register entry

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

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.4 Thematic analysis
Keywords	Inactivity in thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“21. The Register Committee understood by the panel’s analysis that the agency, since the last review, produced two publication named “Thematic analysis 2018 to mid-2021” and “Thematic Analysis mid 2021 to mid 2023”. However, as noted by the panel “these significantly digressed from the previous approach and in the eyes of the panel could not be taken as reports that describe and analyse the general findings of evalag’s external quality assurance activities as established by the standard. These reports give merely an overview of the most important projects, publications and events in the period under study, more like an annual report.”

22. The Register Committee, could concur with the panel analysis and underlined the panel’s recommendation that the agency should resume the work on thematic analysis, which was abandoned after 2018, particularly in light of the severe changes in the ‘German system’.

23. The Register Committee therefore concurred with the panel that evalag complies only partially with the standard.

24. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	ESG part 1, implementation in practice
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“10. The Register Committee understood from the analysis by the panel that only one external quality assurance activity, EQA Audit, covered all standards of the ESG Part 1 in full. Both provider accreditation and programme accreditation procedures did not cover ESG Part 1 in full.

11. The Committee learned that during the site-visit the panel was presented with the draft versions of the new Provider accreditation Manual and the new Programme Accreditation Manual and noted that further alignment with ESG Part 1 is expected to be ensured through these documents. In its statement on the report, MFHEA informed that the Provider Accreditation Manual has been published and in use as of January 2024 and the Programme Accreditation Manual will be in use as of January

2025.

12. The Register Committee took note and welcomed the actions taken by the agency. Nevertheless, the Committee could not confirm without a panel insight whether the new standards and procedures have been implemented in practice.

13. In its additional representation, MFHEA confirmed that its Provider Accreditation Manual came into force in January 2024 and that now all provider accreditation procedures follow the new methodology. MFHEA further informed that the Programme Accreditation Manual will be officially presented by the agency in November 2024 (see clarification of 2024-09-24) and the same will be in place for all programme accreditation procedures as of January 2025.

14. The Register Committee welcomed, once again, the actions taken by the agency in order to ensure that all MFHEA activities cover ESG Part 1 in full. Nevertheless, the Committee could not confirm how these changes have been implemented in practice without panel insight. Therefore, the Committee upheld its initial judgement that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.2 Designing methodologies fit for purpose
Keywords	methodology
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. The Register Committee learned that at the time of the site-visit the provider accreditation was a desk-based procedure conducted by the MFHEA’s staff. The Register Committee is concerned about the fitness for purpose of this procedure for regulating providers’ access to the higher education sector. As noted by the panel, the methodology differs for providers seeking university status and for other providers of higher education. The Committee noted that it was unclear for the panel which methodology is applied when.

16. In its statement on the report, MFHEA informed that these concerns have been further addressed in the revised manuals for programme and provider accreditation. Furthermore, MFHEA explained that all procedures now include a site-visit by a review panel (see more under ESG 2.3).

17. The Register Committee took note of the actions taken by the agency. The Committee could however not confirm whether and how the updated procedures are implemented in practice.

18. In its additional representation, the agency reaffirmed that it had addressed the panel’s concerns regarding the provider accreditation procedures in the new manual, which has been in use for all provider accreditation procedures as of January

2024. Furthermore, the agency reaffirmed this will also be addressed for all programme accreditation procedures when the new Programme Accreditation Manual will come into force as of January

2025.

19. The Register Committee welcomed the actions taken by the agency in order to address the concerns raised by the panel and the Register Committee. Nevertheless, the Committee could not confirm how these changes have been implemented in practice without a panel insight. Therefore, the Committee concurred with the panel’s conclusion that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.3 Implementing processes
Keywords	no site visits, inconsistency,
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“20. The Register Committee learned from the analysis of the panel that only the EQA Audit process is clearly outlined in the audit manual. For the rest of the activities, both the information provided to the panel as well as the publicly available documents, were not always consistent.

21. The Committee noted the panel’s concerns on a number of shortcomings related to the programme and provider accreditation

procedures, such as short application forms instead of self-evaluation reports for some procedures, no site-visits (see also ESG 2.2) and lack of consistent follow-up.

22. In its statement on the report (of 2024-05-20), MFHEA informed that the discrepancies between the documents and the shortcomings related to programme and provider accreditation procedures have been further addressed in the revised manuals for programme and provider accreditation procedures, which have been in use as of January 2024 for provider accreditation procedures and will be, respectively, as of January 2025, for programme accreditation procedures.

23. The Register Committee took note of the revised manuals but could not confirm whether and how these changes are implemented in practice.

24. In its additional representation, the agency reaffirmed that the concerns raised by the Committee for provider accreditation procedures have been addressed in the new Provider Accreditation Manual and the concerns for programme accreditation procedures will be addressed in the new Programme Accreditation Manual.

25. The Register Committee took in consideration the actions taken by the agency in order to address the concerns raised by the panel and the Register Committee. The Committee, however, could not confirm how these changes have been implemented in practice without a panel insight and found that some of them are yet to be implemented. Therefore, the Committee could concur with the panel that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.4 Peer-review experts
Keywords	students
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“26. The Register Committee learned from the analysis of the panel that at the time of the review, some provider and programme accreditation procedures did not involve experts and that these procedures were conducted by MFHEA’s staff. The Committee understood that the only reviews that involved panels were the accreditation procedures for provider seeking university status and EQA Audit (see also ESG 2.3).

27. In its statement to the report, MFHEA informed that the revised manuals, referenced earlier in this decision, require that now every procedure is conducted by an external review panel of a minimum of three experts out of whom one is a student.

28. The Register Committee took note of the actions taken by the agency. Nevertheless, the Committee could not confirm whether these changes have been implemented in practice.

29. In its additional representation, MFHEA referred to the new manuals for provider and programme accreditation where the involvement of students in every external review panel will be guaranteed. Furthermore, MFHEA informed that despite that, the new Programme Accreditation Manual would be in place as of January 2025, the agency already includes students in the review panels for programme accreditation procedures.

30. From the additional representation, the Committee has learned that at the given time only a very small portion of programme accreditation reports are available on MFHEA’s website and further publication of reports is planned in January 2025 (see ESG 2.6). From the limited number of reports available online, the Committee could see that the agency started including a student reviewer in the expert panel.

31. The Register Committee welcomed the changes made by the agency in order to involve students in all external review procedures and encouraged MFHEA to continue this practice. The Committee, however, found that it remains to be evaluated by an external panel whether the planned changes have been consistently implemented and students are included in all programme review panels once the new programme accreditation manual is adopted. Therefore, the Committee concurred with the panel that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.5 Criteria for outcomes
Keywords	inconsistency in outcomes
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“32. MFHEA has established a National Quality Assurance Framework (NQAF), which sets the parameters for external quality assurance in Malta. The Register Committee learned that at the time of the review, only the standards for the EQA Audit procedures mirrored the NQAF standards and that only for that procedure the criteria were clearly defined and ensure a consistent judgement of each standard.

33. The panel noted several inconsistencies regarding the rest of the MFHEA’s activities. For example, the NQAF standards for programme accreditation were not clearly referred to in the internal application form. Similar challenges were noted in the report for awarding university status to a provider; the report did not follow the application form where the NQAF standards were referred to.

34. Furthermore, the panel could not find further evidence that the agency had a clear approach which standards and procedure manuals are applied in its activities. The panel could not find consistency in the agency’s guidelines, standards and manuals. The panel was also unable to find guiding criteria for outcomes in order to ensure a consistent judgement for all types of providers and programme accreditation.

35. In its statement to the report, MFHEA informed that it addressed some of the panel’s recommendations in its revision of the Accreditation Manual for Higher Education Institutions; for the Committee, though, it was unclear what particular changes took place to address the shortcomings. The agency also explained that they will further address the shortcomings in the new

Programme Accreditation Manual in January 2025.

36. The Committee could follow the panel’s view and found that the agency did not have clear criteria for outcomes and that there is lack of consistency in their implementation for most of its procedures, as well as the lack of systemic approach to ensuring consistency in its decision making.

37. In its additional representation, MFHEA informed that the concerns raised by the Register Committee have been or will be addressed with the respective manuals for provider and programme accreditation procedures. Furthermore, MFHEA informed that at the given time, they are designing the guidelines for the Quality Assurance Committee and its peer reviewers to refine its criteria for outcomes.

38. The Register Committee noted the steps taken by MFHEA to formulate its criteria for outcomes for programme and provider accreditation procedures in a clear manner in its new manuals. The Register Committee, however, found it challenging to assess the practical implementation without a panel insight. The Committee also found that the new programme evaluation manual is yet to be adopted and implemented in practice. Following this, the Committee thus concurred with the panel’s conclusion that MFHEA complies partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.6 Reporting
Keywords	publication of reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“39. The Register Committee learned from the analysis of the panel, that the agency did not publish all of its reports from its programme and provider

accreditation procedures.

40. In its statement on the report, the agency informed that with the publication of the new manuals, as of January 2024 and January 2025 respectively, all accreditation reports and decisions will be published on its website. The Register Committee, however, could not find any recently

published reports when performing an additional check on the MFHEA’s website.

41. In its additional representation, MFHEA informed that as of January 2024, all accreditation decisions are to be published on the MFHEA website

together with the expert panel reports. MFHEA further explained that “the reason no Provider Accreditation Reports have been found on MFHEA

website is that since this is a recent development, to date no provider accreditation have been finalised and therefore there were no provider

accreditation reports to publish” and that “with regards to programme accreditations there is a small number of reports which are ready. It is expected that actual publication will happen in January 2025…”.

42. The Register Committee took note and welcomed the planned actions by MFHEA to ensure that all reports and decisions are publicly available. The Committee found that, however, the presented actions are yet to be implemented in practice and once implemented, remain to be reviewed by

an external review panel.

43. Therefore, the Committee concurred with the panel that the agency complies only partially with the standard.”

Full decision: see agency register entry

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

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.3 Independence
Keywords	government involvement, organisational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“51. The Register Committee learned from the report that the members of the MFHEA Board are all nominated by the Minister responsible for

education and appointed by the Prime Minister of Malta. The Prime Minister also nominates the Chairperson and Deputy Chairperson of the Board, who undergo parliamentary scrutiny before being officially appointed. Furthermore, the dismissal and resignation of the Board members could be

only done by or via the Prime Minister.

52. Following the panel’s analysis, the Register Committee expressed its concerns that the organisational independence of the agency is constrained by its strong link and dependency on the government. This is reinforced by the small size of the higher education system.

53. The Quality Assurance Committee (QAC) of MFHEA is the body responsible for decision making on external quality assurance of further and

higher educational institutions. The MFHEA Board, on the other hand, is responsible for endorsement of the evaluation decisions taken by the QAC.

The panel noted inconsistencies regarding what accreditation procedures and which decisions are being endorsed by the Board. Further, as noted by the panel, the participation of the head of QAC, a body appointed by the Board, in the endorsement of QAC’s decisions as a Board member could create internal conflict of interest.

54. In its additional representation, the agency stated that “There are several layers to ensure the independence and suitability of the members of

the Board. These are nominated by the Minister for Education, however they are appointed by the Prime Minister and the Chairperson needs to be

approved by the Public Appointments Committee which is a Parliamentary committee made up of members from both sides of the House (Parliament) which conducts Parliamentary Scrutiny of the nominee. The law also lists the eligibility criteria for Board members, thus ensuring the objective suitability of person nominated by the Minister and appointed by the Prime Minister.”

55. Furthermore, the agency clarified that the current chairperson of the newly appointed QAC has not been appointed as a member of the Board and that the process for the required legislative changes to reflect this distinction are currently underway.

56. The Register Committee considered the additional representation and welcomed the distinction between the two bodies by excluding the

chairperson of the QAC in the Board. The Committee found that, however, this practice is yet to be codified as to ensure continuous prevention of

conflict of interest within the accreditation process. Furthermore, the committee maintains its concerns raised by the panel on the inconsistencies

regarding what accreditation procedures and which decisions are being endorsed by the Board.

57. Finally, the Committee maintains its concerns raised above about how the organisational independence of the agency is constrained by its strong link and dependency on the government.

58. 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

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.4 Thematic analysis
Keywords	thematic analysis
Panel conclusion	Compliance
Clarification request(s)	Agency (24/09/2024)
RC decision	Compliance

“59. The Register Committee learned from the report that the agency has conducted only one thematic analysis, focussing on only one standard from

its EQA Audit procedures carried out by the agency as of

2016.

60. The Committee learned that the agency is considering conducting a thematic analysis for the remaining ten standards. The panel, however, was

not provided with further information on the status of the development of this analysis or, in general, MFHEA’s policy on thematic analysis.

61. The Register Committee noted the agency's plans to revisit its policy and enhance its work on the thematic analysis. The Register Committee

found that these plans have yet to materialise in practice.

62. In its additional representation, the agency informed that it was in a process of conducting its latest thematic analysis and the same should be

finalised by the end of

2024.

63. The Register Committee further asked for clarification whether the work on the thematic analysis is ongoing and whether there is a clear

timeframe when the thematic analysis will be published. The agency clarified that the thematic analysis is currently being finalised and will be

published and presented to the public in December 2024 (see minuted clarification of 2024-09-24).

64. The Committee welcomed the work and progress done by the agency in producing thematic analysis and expects that MFHEA will continue

conducting thematic analysis on regular basis. Given the provided information in the additional representation and the further clarification,

the Register Committee could concur with the panel that the agency is in fact compliant with ESG 3.4.”

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	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategic plan, stakeholder, stakeholders involvement
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The Register Committee noted the concerns raised by the panel that CYQAA’s Strategic Plan (2020-2025) is rather generic, with no specific

activities and clear timeframes. Furthermore, the Committee noted that the panel did not see any evidence of public, annual corporate or activity plan than operationalise the Strategic Plan.

13. The Register Committee understood by the panels analysis, that the agency involves representatives from both public and private universities, students and regulated professions. However, as underlined by the panel, the involvement of private higher education institutions and many public and private colleges and their students is very limited and CYQAA should further widen their engagement in its governance and evaluation processes.

14. Considering the lack of comprehensive and rather generic Strategic Plan and the shortcomings in the involvement of stakeholders from all

higher education institutions, public and private colleges, the Register Committee concurred with the panel and found that CYQAA only partially

complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	operational independence, methodologies
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. In the decision for inclusion of CYQAA on EQAR (of 2019-11-05), the Committee raised concerns regarding the shortcomings related to the operational independence of CYQAA and the close interlinkage between the agency and the responsible ministry.

16. Despite some progress being made by consultation with key stakeholders on the appointment of Council members and the Minister, the Register Committee noted that the Council members are still appointed by the Council of Ministers, upon recommendation by the Minister responsible for higher education.

17. The Register Committee took note of the panel’s concerns regarding the operational independence of the agency, The Committee understood that CYQAA cannot hire its own staff and is fully relying on secondments from the central Government and the Ministry of Education, Sport and Youth.

18. The Register Committee further noted, as underlined by the panel, that despite being fully independent in defining its evaluation methodologies, CYQAA is still challenged by the limits set in the provisions of the national legislation regarding engaging stakeholders in the development of methodologies (see issue raised under ESG 2.2 in the external review report).

19. Following the panel’s analysis, the Register Committee expressed its concerns that the operational independence of CYQAA remains constrained by the close link and dependence on the Ministry of Education, Sport and Youth regarding the appointment of the Council members, hiring of staff and engaging stakeholders in the development of methodologies. Therefore, the Register Committee concurred with the panel conclusion, and found that CYQAA remains to be partially compliant with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.5 Criteria for outcomes
Keywords	Inconsistent use of tools for decision making; Consistency in the interpretation of the agency’s criteria
Panel conclusion	Partial compliance
Clarification request(s)	Panel (28/05/2024)
RC decision	Partial compliance

“The Register Committee learned that, out of 24 applications concluded between

2022 and 2024, the final conclusions on the standards differed from those

proposed by the panels in four cases – three of which occurred in

2024. This

trend resulted in either more or less favourable outcomes for the concerned

higher education institutions.The Committee could not understand, without a panel insight, whether

the increased discrepancy between the panels’ and the Authorisation

Council’s conclusions occurring after the site visit (2023-11-05) steams from

the (im)proper use of the tools for consistent application of agency’s criteria

or other external factors (see more in ESG 3.3)”

Full decision: see agency register entry