Portal for Registered Agencies
Reporting Substantive Changes
All registered agencies are expected to notify EQAR about changes to their legal form and status, amendments to their statutes and substantial changes in their process or methodology.”
It is the registered agency’s responsibility to inform EQAR of substantive changes that have occurred or are going to occur.
Changes should be reported as soon as the changes are sufficiently clearly defined to allow providing comprehensive information on their nature and impact. This may be before or after the changes actually take effect.
EQAR may also become aware of substantive changes in other ways. This may be either by third-party information received under the Complaints Policy, or on the basis of any information that is in the public domain.
Registered agencies are requested to inform EQAR of substantive changes so that EQAR will become aware of situations were an agency’s current practice differs substantially from the situation when it was reviewed against the ESG and admitted to the Register.
The requirement to report substantive changes is not intended to discourage change and innovation among registered agencies, and EQAR aims to minimise the burden on registered agencies.
EQAR therefore suggests that registered agencies keep their information on substantive changes as brief as possible, while giving a comprehensive picture of the nature and impact of the changes.
EQAR will normally merely take note of substantive change reports and update information on the Register, if necessary. Only in cases of serious concerns whether a registered agency continues to comply substantially with the European Standards and Guidelines (ESG) will the Register Committee consider further action.
There is a special online form through which registered agencies can make a Substantive Change Report.
While the form will help you to determine whether a Substantive Change Report is required and indicate how the changes should be described, please also refer to the EQAR Guide for Applicants and Registered Agencies (chapter 9) for further information on reporting changes.
Recent mergers of quality assurance agencies into one new agency required EQAR to develop a specific policy to address the registration status of agencies after a merger.
EQAR has developed a policy of “provisional registration”, which will enable agencies established as a merger of agencies already registered on EQAR to remain on the Register under certain conditions and requirements for a limited timeframe of maximum 2 years. During that period the new, merged agency will have to undergo an external review against the European Standards and Guidelines (ESG).
The conditions, requirements and process are set out in the Merger Policy[PDF].
If an application is approved, the agency is admitted to the Register for a period of five years, counted from the date of the external review report.
The ESG themselves specify that agencies have to undergo “an external review at least once every five years in order to demonstrate their compliance with the ESG” (see ESG 3.7).
The agency should normally apply for renewal at least 10-12 months before their registration expires, so as to ensure that the review is completed in time (see typical timeline).
In order to ensure an uninterrupted registration on EQAR, a registered agency has to plan its application for renewal so that the external review will be completed and submitted before expiry of its registration.
Extraordinary Review of Registration
There are two possible reasons for an extraordinary review of an agency’s registration before the 5-year period has elapsed:
- The initial decision to admit an agency was substantially flawed, either by a substantial procedural error or by being based on false information or evidence.
- Substantive changes (see chapter 6 ) in the agency’s status or operation have led to a situation in which the agency no longer substantially complies with the European Standards and Guidelines (ESG).
If the Register Committee initiates a review of registration, the agency
concerned will be notified and invited to make representation on the
matters of concern before any decision is taken.
The Register Committee may take one of the following decisions:
- If the criteria for inclusion were not fulfilled when the initial decision (to include the agency) was made, the inclusion may be declared “void ab initio”. That is, the agency is removed fromthe Register immediately and is deemed to have never been rightfully included.
- If the criteria for inclusion are evidently no longer fulfilled (for example, due to a substantial change of the agency’s methodology that is in obvious contradiction with the ESG’s principles) the agency may be removed from the Register.
- If there are substantial concerns about the agency’s compliance with the ESG, but it is not possible to judge clearly whether or not the agency still fulfils the criteria, the remaining period of inclusion on the Register may be reduced, thus triggering a need for an earlier external review.
- If the concerns reveal to be unsubstantiated or minor, the Register Committee may conclude the extraordinary review with no further action.