Precedents database

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	procedure for handling complaints
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“12. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard due to the unclear procedure for handling complaints. From the report, the Committee learned that Unibasq now has a well established complaints procedure noted in the agency’s regulations of the Ethics and Guarantees Committee and the Code of Ethics.

13. Following the changes made by the agency, the 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	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	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee and limited coverage of appeals
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (07/12/2021)
RC decision	Compliance

“In its decision of rejection (of June 2020), the Register Committee noted that AKAST’s appeals and complaints procedure did not cover the peer institutional evaluation procedures and that the appeals were only considered by the same committee that also took the appealed decision. While AKAST agreed to revise its procedure and to establish a complaints committee consisting of independent members, the Register Committee remained unable to follow the panel’s judgment of compliance since the procedure was not yet in operation and the committee handling appeals has not been elected. 8. The panel notes that AKAST has now a revised complaints and appeals regulation and has elected a Complaints Committee at the AKAST General Meeting on 28/01/2021. In the description of the provisions for complaints (AKAST Complaints and Appeals Regulations as amended on 28/01/2021), the agency noted that the Complaints Committee’s statement is to be taken into account in the final decision of the Executive Board or the Accreditation Committee and that further details shall be regulated in the rules of procedure issued by the Complaints Committee and approved by the Executive Board.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	2.7 Complaints and appeals
Keywords	Board member in appeals committee, independence of decisions on appeals
Panel conclusion	Full compliance
Clarification request(s)	Panel (14/06/2022)
RC decision	Compliance

“28. In the last renewal of registration, HCERES was found to be only partially compliant with the standard since its appeals and complaints processes were only just set up and not yet reviewed by an external panel; a specific concern was whether the decision-making on appeals was fully independent from those in charge of the appealed report/decision.

29. The panel considered that HCERES' appeals and complaints processes were clearly defined and communicated. The panel noted that HCERES had not received appeals or complaints since 2016.

30. The panel clarified that it considered the appeals committee's composition suitable. While HCERES Board members indeed serve on the appeals committee, the Board does adopt neither evaluation reports nor accreditation decisions. In addition, one external expert is part of the committee.

31. The Register Committee agreed that the appeals committee was sufficiently independent given that the HCERES Board does not adopt the reports or decisions that are being appealed. The Committee therefore concurred with the panel's conclusion that HCERES complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	2.7 Complaints and appeals
Keywords	handling of appeals and complaints
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee considered the panel’s findings that show that ASIIN’s appeals and complaints processes are not well differentiated and as a result not consistently used, i.e. the institutional accreditation handbook discuss complaints procedure although what is described is the means to appeal a decision, whereas the handbooks for the programme accreditation and certification processes mention appeals procedure, the name of the Appeals/Complaints Committee appear to have four different permutation. The panel further comments on the agency’s lack of understanding of the two different concepts. In its response to the review report (19/07/2021) ASIIN’s stated that it has revised its documents and website, employing the right terminology. While the Register Committee welcomed ASIIN’s corrections, the Committee found the panel’s concerns have not been fully address, as the lack of understanding of the two concepts may affect the agency’s ability to effectively handle both appeals and complains for all its activities.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	2.7 Complaints and appeals
Keywords	Rudimentary nature of appeals procedure
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. In its last decision, the Register Committee underlined the panel’s observation that there is no clear indication on whether higher education institutions can issue a complaint regarding the course of the procedure. The Committee also remarked at that the appeals procedure is documented only rudimentarily, with little or no explanation on the issues that could be raised under the appeal, no provision on the expected timeline to process a complaint, publication policy etc.

17. In its review report, the panel stated that higher education institutions may submit complaints about the conduct of the process writing an email to FIBAA and that FIBAA has established a procedure for appeals.

18. The Register Committee learned that FIBAA’s appeals procedure only applies to the procedures where the agency is awarding its seal and it does not cover the reviews where GAC is the decision-making body. Since higher education institutions may have concerns related to the application of the criteria and the judgments also in the reports prepared for the GAC, these should equally be subject to appeal in line with the standard.

19. The Register Committee further noted that FIBAA’s appeals procedure date back to December 2016, and has not been updated since the agency’s last review. The Committee found it surprising that the review panel has not addressed any of the issues the Committee raised in its last decision regarding the rudimentary nature of FIBAA’s appeals procedure and only commented on the wording of the process for complaints and appeals (that should be clarified).

20. In light of the above observations the Register Committee cannot follow the panel’s judgement of (substantially) compliant, but find that FIBAA complies only partially with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	14/03/2022
Standard	2.7 Complaints and appeals
Keywords	requirement that appeals can be made against any report
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“25. The Committee underlined that any report is a formal outcome and thus needs to be open to appeal, even if it does not result in a yes/no decision.

26. In its additional representation, ZEvA clarified matters for evaluation reports. At the same time, it remained unclear whether and how institutions can appeal accreditation reports before submitting those to GAC. Even though GAC offers an appeals possibility, presumably GAC's process cannot fully investigate matters that are rooted in the report produced outside of GAC's direct control. Moreover, it would be unreasonable that institutions are forced to first submit to GAC a report against which they have strong objections before they can appeal against that report.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Impartiality in handling appeals (independence of the Appeals Committee). Coverage of all EQA activities by the appeals procedure
Panel conclusion	Full compliance
Clarification request(s)	Agency (16/03/2025)
RC decision	Partial compliance

“The Register Committee underlined that the current arrangements does not ensure an impartial process in AKAST’s approach of handling appeals, since the appeals are considered by the same committee that also takes the accreditation decisions and nominates the review panel members for the review. The Register Committee further noted that the appeals and complaints procedure only cover issues concerning two of AKAST’s activities and it does not address the agency’s peer institutional evaluation procedures. While AKAST has not yet carried out any such evaluation, the Register Committee underlines that, since the activity is on offer, the agency is expected to ensure that all corresponding procedures will be adequately updated, including the agency’s appeals and complaints procedure.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	2.7 Complaints and appeals
Keywords	Implementation of an appeals process and information about the appeals committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“ The Register Committee noted from the panel’s analysis that the agency’s appeals and complaints processes were not clearly defined. The panel stressed that as the agency moves towards an institutional accreditation process, it will need to reevaluate its current processes for both complaints and appeals.

The Committee further noted that the agency does not have a designated body to handle appeals, but that they are considered by the Council in consultation with the IEE Commission. In its additional representation, THEQC explained that it has developed and integrated the complaints process into its Feedback Management System. The Register Committee was able to verify that the new complaints process and form is easily accessible on THEQC’s website. With a view to appeals, the Register Committee welcomed the decision to establish a distinct Appeals Committee to handle appeals and took note of THEQC’s newly developed Directive of Complaints and Appeals. The Committee, however, noted that the Appeals Committee is not part of THEQC’s organisational chart and that no information is provided on the members of the Appeals Committee. The Register Committee asked the agency to elaborate on whether any other provisions have been added to its Complaints and Appeals regulation. The agency clarified in its response letter that the latest version of the Rules of Procedure of the Appeals Committee dated 19/05/2021was now in use and published on the agency’s website (only available in German) which include minor updates. The Register Committee noted that the additions to the updated procedure are in line with the expectation of the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	2.7 Complaints and appeals
Keywords	Scope of the appeals system, clarity, independent decision making body
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that MusiQuE’s appeals procedure only applies to the reviews that result in an accreditation decision, but does not cover the agency’s enhancement type of reviews. Since higher education institutions may have concerns related to the application of the criteria and the judgments also in the enhancement reports, these should equally be subject to appeal in line with the standard. During its site-visit the panel further learned that it is not always clear to stakeholders involved how a complaint will be approached and how exactly are responsibilities defined. The Register Committee noted that MusiQuE has an Appeals’ Committee, formed of one standing member and one individual appointed in response to each specific appeal. The panel remarked that the Board of MusiQuE is the decision-making body responsible for endorsing the judgement of the review team and also the body nominating the members of the Appeals’ Committee, which may raise a concern of potential conflict of interest. The Register Committee therefore underlined the panel’s recommendation of reviewing the procedure for appeals in order to guarantee a fair decision making and avoid such potential conflicts of interest. Considering the several above-mentioned issues the Register Committee could not follow the panel’s conclusion of (substantial) compliance but considered that MusiQuE complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	2.7 Complaints and appeals
Keywords	Absence of the body responsible for handling complaints (established in renewal)
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that QANU has revised its complaints and appeals procedure and established an independent committee to consider its appeals.The panel noted that institutions can now submit an appeal against all external quality assurance activities of QANU and the decisions are taken by an Appeals Committee, instead of QANU’s director.The panel’s analysis further show that QANU offers the possibility to institutions to express their dissatisfaction about the conduct of the external quality assurance activity carried out by QANU or misbehaviour of people acting on behalf of the agency. The agency has also established different processes in the handling of complaints i.e. if a complaint refers to the behaviour of a staff member of QANU this is processed by the director; if a complaint is about the director of the agency, the complaint is processed by the chair of the Board etc.Having considered the changes put in place by QANU since its last external review, the Register Committee was able to follow the panel’s judgement that QANU now complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee; Clarification of appeals’ procedure
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its previous decision for renewal, the Register Committee flagged for attention the appeals system, as the panel recommended that ACSUCYL should revise its appeals system so that a separate committee handles appeals. The external review panel confirmed in its external evaluation report that ACSUCYL established an independent body, the Guarantees Commission, that is responsible for examining appeals or complaints in areas where the agency is competent. For procedures where the final decision belongs to the University Council or Regional Ministry (i.e. verification/modification, accreditation renewal, evaluation to create, recognize, modify or withdraw university centres), the appeal is considered by the corresponding decision making body. ACSUCYL provides input into the consideration of these cases, but it does not decide. Within ACSUCYL, the request will be sent to the Guarantees Commission, which consults the relevant Assessment Commission, before preparing an answer. If the appeal is granted, ACSUCYL will be requested to review its earlier conclusion. The Register Committee underlined that ACSUCYL’s complaints policy should communicate better that higher education institutions have the possibility to raise matters about the conduct of the process or those carrying it out (i.e. complaints in the understanding of the ESG), even in such procedures where the final decision is taken by other bodies.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that appeals procedures are published together with every procedure on the agency’s website, except the independent accreditation at the institutional level. To date AKKORK has only received a complaint, but no appeals. The panel’s analysis show that AKKORK’s Appeals Committee involves members of the International Accreditation Council, the same body that is involved in the accreditation decision-making process in addition to the members of its Supervisory Board. The Register Committee underlined that in such cases the impartiality of the decision making in considering appeals is not ensured. In its further information to the review report, AKKORK stated that its regulation on appeals have been updated and that its new appeals body, appointed by AKKORK’s Supervisory Board, includes members from the agency’s partner organisations. In its additional representation the agency has further provided a link to its revised regulation on appeals. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	2.7 Complaints and appeals
Keywords	Lack of an impartial decision making → lack of an independent appeals committee
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that higher education institutions reviewed by AAC-DEVA may file an appeal before the Universities Council in case of verification/modification, accreditation renewal and institutional accreditation. If the claim is accepted, the appeal is sent to AAC-DEVA where a group of experts who have not intervened in the evaluation that led to the unfavourable decision will revise the report. The Committee underlined that AAC-DEVA’s current appeals process does not fully ensure the impartiality of decision making, as the Universities Council is both the body responsible for the accreditation decisions and the resolution of appeals after such procedures. In case of DOCENTIA, IMPLANTA and the accreditation of foreign language skills, the resolution of the appeal is with the same body who issued the initial decision. Thus the impartiality of the decision making is not fully ensured in any of the external QA activities carried out by the agency. In its additional representation the agency explained that according to the Spanish legal framework the agency cannot exclude the University Council in the consideration of the appeals procedure – in the case of verification/modification, accreditation renewal and institutional accreditation. The appeal is assessed by a commission which includes experts that have not intervened in the evaluation, and following their examination, if the appeal is ratified it will be further submitted to the corresponding evaluation body for reevaluation. The Register Committee noted that AAC-DEVA intends to establish an Appeals Committee to consider all appeals related to the evaluation of programmes. The decision of the Appeals Committee will be binding for the DEVA Director. Furthermore, while higher education institutions have been able to state their dissatisfaction with the review process i.e. by filling in an online ‘suggestions form’, AAC-DEVA lacks a formal procedure that explains what form of complaints may be submitted and considered by the agency. In its additional representation the agency stated that it has designed a specific procedure for complaints as part of its quality management system and that it has updated its online form for the submission of such complaints. The Register Committee could verify that a complaints protocol has been developed and that the modified online form allows the submission of various forms of complaints. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.7 Complaints and appeals
Keywords	Lack of an independent appeals committee
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that Galician Committee for Reports, Assessment, Certification and Accreditation (CGIACA) is both the body responsible for evaluation, certification and accreditation and also the body responsible for the appeals following these reviews. In order to ensure a fair decision-making, the panel recommends the establishment of an independent committee to review appeals. In its Additional information to the external review report (p. 4) the agency stated that following the CGIACA’s meeting in late autumn, the agency will consider the possible nomination of candidates for an independent appeals board. The Register Committee welcomed the ACSUG’s intention to set up a separate board to handle appeals, but the Committee underlined that such changes are yet implemented and that the nomination of its members and the revised appeal process is yet to be reviewed. The Register Committee was therefore unable to concur with the review panel’s judgment of (substantial) compliance, and concluded that ACSUG complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.7 Complaints and appeals
Keywords	Limited scope of complaints procedure and implementation of appeals and complaints procedures still to be assessed
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While the panel confirmed that CYQAA has in place formal and clearly defined processes for higher education institutions to appeal against its accreditation decision, the panel also pointed out that the process of considering appeals is not independent as it is being handled by the Council of CYQAA. The Register Committee understood that following the amendments to the law, CYQAA would appoint a three-member ad-hoc committee to handle appeals on a case by case basis. In addressing complaints, the analysis of the panel shows that while CYQAA has an established practice for handling complaints there is a ‘tendency to rely mainly on informal communication, and that the arrangements in place do not add up yet to a clearly defined and formal’ procedure. In its additional representation CYQAA stated that its revised appeals’procedure sets out the appointment of a three member Advisory Committee of Experts (ACE) to examine the appeals that have been approved by the Council of CYQAA. Additionally CYQAA has written a formal regulation concerning the withdrawal of the accreditation of an institution, department or program of study offered by the institution. The appeal in these cases is being handled by an Independent ad hoc Advisory Committees. In addressing complaints CYQAA stated that the agency has published its complaints policy on its website and explained that individuals and organisations may issue complains about an accredited institution, department or programme. The Register Committee however noted that the concept of complaints is limited to general issues concerning higher education institutions and that it does not allow the possibility to address complaints related to the conduct of a review or complaints concerning the agency’s own processes. While the Register Committee welcomed the steps taken by the agency to address its shortcomings related to the functioning of the Appeals Committee and the implementation of the Complaints Procedure, the Committee underlined the limited scope of the complaints procedure and that the implementation and functioning of these procedures are yet to be considered by a review panel. Considering these limitations, the Register Committee could not follow the panels judgment and therefore concluded that CYQAA complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	2.7 Complaints and appeals
Keywords	Unclear complaints processes. Inadequate composition of the Appeal Council.
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that the agency’s Appeal Council is composed of 11 members nominated by the Minister. While the panel was satisfied with the process the panel also commented that the short term of their mandate might not be helpful for members to gain a broad overview of the decisions made. The Register Committee further noted that the nomination of the Appeal Council’s members is problematic in terms of agency’s independence from the Ministry (see also under ESG 3.3). According to the panel’s analysis NCEQE’s complaints process are rather vague, and the panel was not convinced that higher education institutions would be aware of the opportunity to complain about a procedural concern. In its letter to EQAR (of 6 June 2019) the agency stated that it has developed a user-friendly booklet on complaints procedure and that institutions may now issue complaints online, via its website. While the Register Committee welcomed the agency’s improvement to its complaints processes, the Committee could not verify the agency’s statements, as this would require a review by an expert panel. The Register Committee further underlined its concerns regarding the composition of the agency’s Appeals’ Council. Considering the above-mentioned concerns, the Committee was unable to concur with the review panel’s judgment of (substantial) compliance, and concluded that NCEQE complies only partially with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	2.7 Complaints and appeals
Keywords	Clarification whether the agency addressed complaints and appeals within the same procedure
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted the agency's argument that there was no requirement for an appeals procedure in its case “as IEP evaluations do not result in decisions”. Based on the analysis of the panel, the Register Committee, however, understood and concurs with the panel that IEP's ‘substantive’ complaints are, in fact, appeals in the ESG terminology: they enable the institution to “questions the formal outcomes of the process” (in this case, the evaluation report), where it can “demonstrate that the outcome is not based on sound evidence” (see guidelines to standard 2.7), which IEP’s complaints policy translates to erroneous judgments, erroneous assumption of non-existent factors as facts, failure in exploring relevant facts, and ignoring or misjudging factual base.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	2.7 Complaints and appeals
Keywords	Implementation of an appeals process and independent appeals body.
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (16/03/2025) Panel (20/02/2020)
RC decision	Partial compliance

“The panel noted in the review report that a clear and transparent formal complaints procedure within ANVUR was not yet fully developed. The panel also noted that there was no specific appeals committee, but that the Governing Board fulfilled both the role of the accreditation body and that of the re-examination body. The Register Committee further noted that the agency has no clear processes in handling complaints (EER, p. 51-52). In light of these concerns and the panel’s conclusion of compliance, the Register Committee sought further clarifications. The panel responded that the spirit of the standard was followed in practice, although the clarity and transparency of appeals processes could be further improved. In its response letter, ANVUR explained that its Governing Board had now approved the establishment of a separate Appeals’ Committee, which will include a member from ANVUR’s Governing Board, one member appointed by the Board of Rectors of Italian Universities and one member from the National Authority for anti-corruption, transparency and public procurement (ANAC).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	2.7 Complaints and appeals
Keywords	unclear process for handling complaints
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In order to improve the appeals procedure, the former Ethics Committee became the Ethics and Guarantees Committee, which was composed of members who play an active role within the agency. The review panel noted that the composition of the Committee was limiting its independence. The Register Committee underlined the recommendation of the panel that the Ethics and Guarantees Committee be composed of members who are independent from the agency and the Basque higher education system. In its additional representation, Unibasq stated that the composition of the Committee had been changed. The new Ethics and Guarantees Code, which was approved by Unibasq’s Governing Council, established that the Committee is now composed of experts from outside the Basque University System, who moreover cannot be part of any other Unibasq body or committee. The Register Committee was able to see the new composition on Unibasq’s website. Furthermore, while the panel confirmed that Unibasq has developed a clear appeals processes, it referred to “a more general procedure for the reception and handling of complaints and suggestion”, but did not analyse that in detail. In its additional representation, Unibasq did not comment further on the complaints procedure. Given the unclear process for handling complaints, the Register Committee remained unable to concur with the review panel’s conclusion of compliance, but concluded that Unibasq complies only partially with ESG 2.7.”

Full decision: see agency register entry