Precedents database

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clarity in activities and services; Conflicts of interest
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“10. While the Register Committee was able to follow panel’s conclusion that AQ Austria is compliant with the standard, it highlighted the panel’s recommendation that the agency should enhance the clarity on its ESG aligned activities and consultancy services for the public and add explanation on avoiding conflicts of interest on their website.

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	Initial
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategy not reflecting agency's central role, lack of broad discussions with stakeholders
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (05/10/2022)
RC decision	Partial compliance

“16. The panel considered that the lack of involvement of stakeholders beyond those individuals who are members of the agency bodies themselves might lead to a lack of critical distance. The panel thus saw a need for more and broader stakeholder feedback, and recommended more regular dialogues with stakeholder organisations on strategic and policy matters.

17. The panel further considered that GAC's strategic planning did not sufficiently reflect its central, pivotal role in the accreditation system (see also the comments under ESG 2.2 above). The panel saw a strong need for a broader discussion with agencies and all stakeholders on GAC’s role in the system and its strategy. In particular in view of the upcoming revision of the

Specimen Decree, the panel found such a discussion was urgent to define a strategy that describes clearly the role GAC plans to assume in the system and its mid-term priorities.

18. While the Register Committee appreciates that GAC has begun to plan a strategy process (see statement on the report), it considered that the panel's analysis under this standard points to important issues in GAC's governance and engagement with stakeholders; these are particularly important in light of GAC's pivotal role in the German system.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ASHE
Decision of	15/10/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	stakeholder representation within the governance and separation of EQA within and outside the scope of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In its last decision, the Register Committee noted that ASIIN continued to use the term evaluation for type 2 evaluations against the panel’s recommendation, and thus the separation between activities within the scope of the ESG and those that are carried out as type-2 evaluations remained unclear. In its review report the panel considered that the difference made by ASIIN in various documents between type 1 evaluation and type 2 evaluation sufficiently differentiated between accreditation and consultancy. The panel further noted that ASIIN had a policy not to conduct accreditation for those institutions/ programmes at which consultancy activities were carried out, and that this was adhered to in practice (p.31). The Committee therefore concluded that this shortcoming has been addressed. The Register Committee noted that ASIIN’s Board of Directors consists exclusively of representatives of member organisations/institutions of ASIIN. The involvement of a diverse set of stakeholders (including students) in the governance of the agency is, however, ensured within the technical committees, Accreditation Commission and Certification Commission. Considering ASIIN’s expansion of its external QA activities to other areas the panel underlined that ASIIN should rethink its current structure and broaden its competences (p.16). The panel recommended a stronger involvement of the Board of Directors in the strategic direction of the agency and the monitoring of its strategic goals, while at the same time expanding its membership to also include external stakeholders (including a student member). The Committee underlined that recommendation of the panel.”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by ECA
Decision of	18/03/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of external QA and consultancy activities; possible conflicts between different types of reviews
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“16. [...] The report noted that it would be against EQ-Arts' principles to engage in paid consultancy work (p. 31), this was now explicitly ruled out in the Governance Framework.

17. The Register Committee considered that the issue has been addressed for consultancy in the classical meaning, i.e. paid services provided to institutions. The Committee therefore now concurred with the panel's conclusion that EQ-Arts complies with the standard.

18. The Register Committee nevertheless underlined that EQ-Arts needs to be mindful for all other current or future activities with individual higher education institutions – whether paid or unpaid – if they could be regarded as compromising its ability to make an independent assessment of that institution later on and, if so, to make adequate provisions to rule out carrying out a review of that institution.

19. In addition, the next external review of EQ-Arts should analyse whether any risk lies in the fact that the same higher education institutions might undergo an enhancement review first and request a formal assessment later, depending on whether such patterns occur in practice.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	07/02/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student involvement in governance, lack of periodic and multi-annual Strategic Plan, a clear distinction between external quality assurance and its other fields of work
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (24/11/2024)
RC decision	Partial compliance

“21. The panel found that in general stakeholders are involved in the work of the agency, but commented that there is no student representative on the Foundation Council and that FIBAA should consider broadening its stakeholders to include, for example, members of committees from outside of FIBAA’s circle of ‘customers’.

22. The panel also remarked that FIBAA does not have a periodic and multi-annual Strategic Plan but that the strategic goals are considered during the Council’s last meeting in the year. The review panel noted that the consideration of strategic matters takes place as and when necessary, but still in a highly informal process. The Committee concurs with the view of the panel that the current strategic planning process, should be further developed to ensure that it also considers the medium to long term future of the agency.

23. While the review panel confirmed that FIBAA has in place a strict separation between its consultancy services and external QA activities within the scope of the ESG, the Register Committee noted that this separation was not clear in the case of FIBAA’s Evaluation Procedures According to Individual Objectives (see also point 5 above).

24. The Committee underlined that agencies are expected to take appropriate precautions to prevent any conflicts of interest arising from the consultancy activities they carry out, as indicated in Annex 2 to the EQAR Policy on the Use and Interpretation of the ESG.

25. Considering the shortcomings of involving students in FIBAA’s governance and the lack of a comprehensive Strategic Plan and the separation of consultancy and external QA procedures, the Committee cannot follow the panel’s conclusion of (substantial) compliance but finds that FIBAA complies only partially with standard 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	mentorship programme, participation of students, stakeholder consultation in the design of methodologies
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (09/10/2020)
RC decision	Partial compliance

“ Considering the mentorship programme run by the agency, the Register Committee noted the panel's concerns related to the possible conflict of interest of such experts providing support to institutions.

Considering THEQC’ shifts towards institutional accreditation and the panels’ recommendation to ensure that any conflict of interest is avoided in this new activity, the Committee asked the agency whether it has kept or discontinued its mentorship programme.

The agency explained that the mentorship programme was a feature of the Institutional External Evaluation Programme (IEEP) and that THEQC continues to carry out evaluations for higher education institutions that have been newly established or have no graduate students. The agency added that it has launched a new call for mentors in 2020, and that those mentors are requested to declare possible interest when assigned to an institution, and to sign a Code of Ethics as well. The Committee further noted the panel’s concerns regarding the design of methodologies and other related documents, which are only discussed by the Council with no further consultation being carried out with THEQC’s stakeholders. The agency did not comment on this issue in its additional representation. The panel's analysis further shows that the participation of students is limited compared to that of other Council members, as no student was included in any of the Council’s commissions. In its additional representation, THEQC stated that students now actively participate in two additional committees.The Register Committee welcomed the clarification and steps taken to prevent conflict of interest in its mentorship programme and nomination of students in the agency’s governance. The Committee, however, underlined that the effectiveness of stakeholder involvement in the agency’s governance and work has yet to be fully reviewed in practice, in particular with regards to stakeholder consultation in the design of methodologies. The Committee therefore considered that THEQC complies only partially with ESG 3.1.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ASIIN
Decision of	28/06/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	scope of the ESG, alternative providers, transparency of provider status, use of Bachelor and Master by alternative providers, need for clear distinction
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (24/11/2024)
RC decision	Partial compliance

“39. The ESG cover “higher education in its broadest sense, including that which is not part of a programme leading to a formal degree”. The ESG do not specifically limit what "higher education" means and explicitly include education that does not lead to a "formal degree".

40. The Register Committee therefore considers that the scope of the ESG needs to be determined by the quality and level of the education provided, not the legal status of the provider. That is, if an alternative provider offers learning opportunities with learning outcomes at higher education level, as defined by the QF-EHEA descriptors (see discussion under 2.1 above), the ESG can be considered applicable as a framework for the provider's quality assurance. [...]

42. In general, the ESG are underpinned by an expectation of utmost transparency; in turn, information that could be misleading, in particular for (potential) students, should be avoided. EQAR's Policy on the Use and Interpretation further specifies that the Register Committee should be guided by EQAR’s overall mission of ensuring transparency and trust when applying the standards.

43. Under ESG 3.1 it is expected that quality assurance agencies distinguish clearly and transparently between their external QA within the scope of the ESG and other activities. In line with the overall goal of transparency, the Register Committee applies the same principle to different types of accredited providers with a clearly different status and formal recognition; a lack of transparency about the status of different providers would bear the risk of confusing potential students as well as others, and might raise false expectations as to the status and recognition of credentials earned from those providers.

44. The guidelines to ESG 3.6 further reflect the expectation that an agency “establish the status and recognition of the institutions with which it conducts external quality assurance”. In view of the overarching goal of transparency, the Register Committee expects that agencies not only establish, but also make clear publicly the status of the different types of providers they work with.

45. In the interest of avoiding confusion and upholding the credibility of the education system, the Register Committee thus expects that the difference between formally recognised higher education institutions, awarding formally (nationally) recognised qualifications, and alternative providers must be absolutely clear for stakeholders and the general public.

46. The possible “dichotomy of national versus international, professional accreditation”, referred to by the panel in its clarification, cannot be a reason to accept unclarity or confusion about a provider's formal status. The Committee would consider it incompatible with the principles of the ESG if international, professional accreditation were to contribute to such unclarity or confusion. [...]

48. The Register Committee noted that a number of alternative providers accredited by ECTE used the terms “Bachelor” or “Master” for their education offer. The QF-EHEA employs these terms for officially recognised degrees. In the vast majority of EHEA jurisdictions, these terms are legally protected, similar to terms such as "university", "university college" or "higher education institution". Equally, in the public eye these terms are understood as implying formal recognition as a higher education institution.

49. The Register Committee therefore considers that the use of these terms by alternative providers is not acceptable unless it can be explicitly demonstrated that an alternative provider may legally use those terms.

50. ECTE's standards specified that “Programmes that are not recognized by national authorities should ensure that the qualification nomenclature that is used is appropriate and not in breach of protected terminology” (B.2.1, p. 27) and further that “If the qualification is not recognised by competent national authorities, this should be specified.” (B.5.1, p. 39)

51. It remained unclear to the Committee how stringently these provisions were verified or enforced in practice. In its response to the clarification request, the panel did not provide any further details. Given that the terms “Bachelor” and “Master” are typically legally protected, neither the fact that “ECTE's international experts from the field [...] are checking compliance with professional standards” (clarification by the panel) nor the fact that some of “ECTE’s members cannot or do not want to obtain a national recognition” (idem) give clear reassurance that the institutions in question use those terms legally.

52. The Register Committee considered that the unrestricted use by ECTE of the terms “Bachelor” and “Master” for alternative providers significantly reduced transparency and blurred, rather than clarified these providers' status. [...]

55. The fact that the majority of ECTE-accredited providers are alternative providers underpins the importance of ensuring that not only ECTE's own communication is clear, but also that ECTE ensures – through its respective standards and their stringent application – that the accredited providers themselves live up to the same level of clarity about their status.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	conflict of interest in review processes
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (24/10/2020)
RC decision	Compliance

“The Register Committee noted that MusiQuE has since its last review created a permanent student seat on its Board (as of November 2017). While the Register Committee welcomed this change, the Committee further underlined the review panel's recommendation on the need for a more diverse range of stakeholders to be involved in the governance and work of the agenc. The Register Committee sought clarification from the panel whether it had considered the risk that the critical friend reviews could have a supporting or consulting role, which could lead to the quality enhancement review issuing judgments on matters that MusiQuE's critical friends have assisted to develop or implement. The panel was asked how it satisfied itself that MusiQuE prevents such potential conflicts of interest.The panel explained that it considered the critical friend review as a first phase of the Quality Enhancement review. The panel argued that this process did not result in conflicts of interest as the MusiQuE processes were similar to other processes where institutions are required to follow-up on previous peer reviews and consider inputs from stakeholders”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of QA and consultancy activities
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted that the agency put in place a policy regarding the separation of the agency’s consultancy and assessment activities which dictates that if a project coordinator is involved in providing consultancy services to a higher education institution, he/she is not allowed to act as a secretary in an assessment procedure for a period of at least five years. The panel further commented that QANU’s management have shown high awareness of of the need to avoid conflicts of interest and to ensure QANU’s independence in its activities. With regards to the stakeholder involvement in the governance and work of the agency, the panel found that QANU has formalised the involvement of students in the Board of the agency following its change in Statutes. While the Register Committee welcomed the involvement of students, the Committee further underlined the panel’s recommendation of ensuring a broader stakeholder involvement in the agency’s governing structure. In view of the changes introduced by the agency the Register Committee was able to follow the panel’s conclusion that QANU complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of students in agency’s decision making
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (24/11/2024)
RC decision	Partial compliance

“There is a lack of student representation. Students are neither involved in the governing body nor in the bodies that review and design the agency’s procedures or take decisions on the adoption of such procedures (Governing and Advisory Board). The agency stated (in its Statement to the Review Report) that the Student Board is an Advisory Body and that students can contribute in that capacity to the governance and work of the agency. The Committee underlined the limited involvement of students in the agency’s governance and work. While the legislation does not prescribe their involvement in the agency’s Board of Directors, ACSUCYL may nevertheless improve its consultation process and also request a change of its current legal framework.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Mission implementation in daily work; Clear distinction between activities; Stakeholders’ involvement; Involvement of students
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its analysis the panel commented that it was unclear which is the body in the agency responsible for developing a strategy, how AKKORK’s procedures are developed and what types of activities and services the agency is offering. Furthermore the panel could not find any clear evidence on how the agency’s mission is translated into the daily work of the agency. The panel also noted that AKKORK’s actual structure and relations between its governing bodies were different to the ones presented in the last version of the statutes, adopted in

2013. While stakeholders are part of AKKORK’s multiple bodies, the panel noted that their involvement could be broadened. In particular, the panel recommended that students be involved also in other bodies than the Advisory Council, where only representatives from professional organisations and higher education institutions are present. The Register Committee noted from the additional information that AKKORK has updated its mission statement and detailed its objectives and main activities on its website. The agency further stated that a new Strategic plan 2020-2024 has been approved by the Supervisory Board and that its Financial Plan also have been updated. The Register Committee could also verify that the new Strategic Plan has been adopted by the Supervisory Board at its meeting on December

2019. While the Committee welcomed the steps taken by the agency to address the panel’s concerns, the Committee further considers that these changes still have to be fully implemented and externally reviewed by a panel, i.e. showing evidence of a robust yearly work planning, implementation of the strategic plan. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholders’ involvement; Involvement of students; Lack of strategical planning
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted the panel’s concerns in terms of the agency’s engagement with stakeholders. While the agency has strong connections with universities, the relationship with student representatives, and other civic and social groups is very weak. This lack of engagement is reflected in both the composition, working arrangements and internal interaction of the agency’s committees. The Register Committee considered the agency’s explanation that the current regulation of its statutes limit the involvement of students, but the Register Committee underlined that stakeholder involvement such as students is a key requirement of the standard. the agency lacked a strategic focus and that there was no evidence of governance level oversight of strategic planning or review by AAC-DEVA. In its additional representation the agency reported that steps have been already made to ensure the presence of students and professionals in all evaluation committees for ex-ante verification, modification and accreditation renewal. The agency stated that it intends to further strengthen the role of the Technical Committee for Evaluation and Accreditation (CTEyA) by incorporating professionals and by increasing the number of students. Considering the lack of a strategic focus and governance oversight, the agency added that its new Strategic Plan for 2021-2026 is in preparation and that it will reflect the engagement of stakeholders and the different levels of strategic governance. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of student in evalag’s governing structure, and overarching strategy
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel found that evalag had no clear overarching strategy, bringing together planning, budgeting and risk assessment. The review panel noted stakeholders are formally involved in evalag’s governance through the Foundation Board, while the Board does not include a student member. Stakeholders are further involved in evalag’s work through participation in workshops and similar activities. The panel recommended that a student be appointed to the Foundation Board.Considering the concerns re. the lack of an overarching strategy and that one important stakeholder group is not represented in evalag’s governing structure, the Register Committee was unable to concur with the panel’s conclusion of substantial compliance, but considered that evalag only partially complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of students in the governance
Panel conclusion	Full compliance
Clarification request(s)	Panel (24/11/2024)
RC decision	Compliance

“The Register Committee noted that the legal regulation over CTI’s governing structure limits the involvement of students in the agency’s formal bodies. The Committee has asked the panel to clarify whether the agency has taken any steps towards changing its legal framework and involving students in its governance. In its clarification response the panel emphasised the positive collaboration and involvement of students in the work of CTI but also admitted that students are not involved in the final decision making processes of CTI. The panel noted that students participated in the work of CTI as part of review panels, meetings and training activities along with CTI members and that the student union is consulted in the revision of CTI’s frameworks and guidelines. The panel argued that the involvement in CTI’s ‘committee’ would be very time consuming, as members fulfil the equivalent of one fourth to one half of a full time position and that in practice this would not lead to a significant increase in students participation. The panel concluded therefore that, given the reactions of all stakeholders, including the students, CTI was in (full) compliance with ESG 3.1. Given that CTI in practice ensures the regular consultation of students, considering that students did not request to be represented in the CTI’s Commission and due to their limited capacity to meet the expected workload, the Register Committee was therefore able to concur with the panel’s conclusion that CTI complies with the standard. The Committee further concurs with the panel’s remarks that students (and international experts) can add value to the governance of CTI, even though their expected overall workload for CTI could be more limited. The Register Committee also underlined the recommendation of the panel to recognise the official status of students in CTI’s governance. The Committee added, that in order to allow for the possibility of students’ involvement in the governance of CTI, a change in the legislative restrictions should be considered.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clear distinction between activities within and outside of the scope of the ESG
Panel conclusion	Full compliance
Clarification request(s)	Panel (21/10/2019)
RC decision	Compliance

“When A3ES applied for renewal, the Register Committee stated in its Eligibility Confirmation that the external review report should address how the agency clearly separates activities outside the scope of the ESG from activities within the scope of the ESG. As the report did not address the issueof clear separation of these activities, the Register Committee sought clarification from the panel. The panel clarified that A3ES' consultancy activities are not provided to universities or colleges, but solely focused on advising the national authorities or organisations on the design of national quality assurance policies, criteria and processes. Having considered the panel’s clarification, the Register Committee concurred with the panel that these activities are clearly separated from activities within the scope of the ESG by their very nature, and do not bear the potential for unclarity or conflict of interest that services rendered to higher education institutions do. The Committee therefore concurred with the panel's conclusion that A3ES complies with the standard”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of activities within and outside the scope of the ESG
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (20/02/2020)
RC decision	Compliance

“The Register Committee found the presentation of the accreditation of post-graduate programmes in medicine and healthcare inconsistent with the presentation of the activity on ANVUR’s website, where the activity was described together with ANVUR’s accreditation of PhDs programmes, as an accreditation activity under the responsibility of ANVUR. The Committee therefore underlined the panel’s remarks (letter of 22/10/2019) that in order to avoid misunderstandings, ANVUR should make a clearer description of its different activities on its website. In its additional representation ANVUR presented the clear distinction of its activities, which was published on its website. ANVUR created separate pages which clarifies transparently the activities within and outside the scope of the ESG. As the issue of a clear separation of external QA activities within and outside the scope of the ESG was addressed, the Register Committee was able to conclude that ANVUR now complies with the ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clasification of Titulos propios
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (20/05/2019)
RC decision	Partial compliance

“The Register Committee sought and received clarification regarding the evaluation of “títulos propios”. Unibasq clarified that these activities were not listed in its application for renewal of registration because Unibasq “realized that it was more a consultancy activity as Unibasq just provides an external expert report” and thus did not consider them as activities within the scope of ESG.In support of its classification, Unibasq stated that it acted only as a subcontractor to the UPV/EHU and had no own responsibility for the review process or the outcomes. The Register Committee also noted that Unibasq does not provide “accreditation” of ‘títulos propios”, contrary to what was published by UPV/EHU. Unibasq, however, stated on its website that it “will evaluate and certificate” those degrees.Unibasq further noted that the misunderstandings were caused by a discrepancy between the internal regulations of the UPV/EHU and the public information on their website, stating that some programmes are accredited by Unibasq.Having considered Unibasq's response, the Register Committee accepted that the evaluation of “títulos propios” may be classified as consultancy service performed by Unibasq to UPV/EHU. The Register Committee further considered how Unibasq ensured a clear distinction from its external quality assurance activities within the scope of the ESG (see EQAR Policy on the Use and Interpretation of the ESG, standard 3.1 and Annex 5). The Committee noted that such a clear distinction was particularly crucial in this case, given that the terminology and the characteristic of the activity caused an actual risk of confusion with ESG activities.The Register Committee concluded that the presentation on Unibasq's website was misleading and did not ensure clarity as to the different nature of these evaluations; it thus considered that Unibasq did not comply with the standard.In its additional representation, Unibasq stated that it held specific meetings with the UPV/EHU, sent a formal letter regarding this issue and elaborated a new agreement with the UPV/EHU, which was approved by Unibasq’s Governing Council. As stated in the agreement, the evaluations of “Títulos propios” are consultancy activities which cannot be represented as ”Accredited, validated or reviewed by Unibasq”. In addition, Unibasq removed from its website the information that could have been misleading about “títulos propios” previously. The Committee, however, noted that UPV/EHU continues to refer to an “external report” by Unibasq in its advertisement of “títulos propios”.The Register Committee welcomed Unibasq's steps that were taken to clarifythe status of this activity and to avoid further misinterpretations. At the sametime, the Register Committee considered that it cannot be fully determined at this stage whether the new communication is fully clear to all stakeholders and avoids any misrepresentation; this should thus be analysedin the next external review of Unibasq.The Register Committee remained unable to concur with the panel's conclusion of compliance but concluded that Unibasq now complies partially with standard 3.1”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ECA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Separation of external QA and consultancy activities
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (19/11/2018)
RC decision	Partial compliance

“33. The panel considered that it was “clear from EQ-Arts procedures and documentation, and confirmed during the site-visit – and, importantly, ‘ethos’ - [...] that those involved in any consultation activities cannot be involved in any assessment/ reviews nor in the making of any accreditation decisions nor involved in any related appeals procedures” (letter by the panel).

34. In its additional representation, EQ-Arts elaborated on the nature of its enhancement-oriented reviews and formal assessments, respectively. The Register Committee, however, underlined that the question related to the clear separation between consultancy activities, i.e. activities outside the scope of the ESG, and either of the two types of reviews (enhancement- oriented and formal assessment) offered by EQ-Arts. While it might be regarded more crucial for formal assessments, the Register Committee underlined that safeguards should be in place to avoid conflicts of interest in both types of reviews.

35. Having considered the panel's clarification and EQ-Arts' additional representation, the Committee remained unable to identify a specific provision in EQ-Arts’ suite of documents that rules out the possibility of reviewing an institution or programme that was previously consulted by EQ- Arts.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/03/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clear separation of reviews and consultancy carried out for higher education institutions.
Panel conclusion	Full compliance
Clarification request(s)	Agency (31/01/2019) Panel (05/11/2018)
RC decision	Partial compliance

“The Register Committee sought clarification from the panel regarding the separation of reviews and consultancy to higher education institutions, including both services rendered by QAA itself (internationally) or through its subsidiary QAAE (domestically). The Committee took note of the various measures and policies the panel referred to. The Committee also noted the clarification that “no evidence was found which would bring any doubt about the proper separation between [of] consulting units and undertaking reviews”. The Register Committee considered QAA's activities in Albania, which QAA described as a capacity-building activity that involved the support of the Albanian Ministry of Education Sport and the Albanian national QA agency (initially PAAHE, later APAAL, now ASCAL) in (1) developing review materials, (2) training reviewers and (3) conducting the reviews of all Albanian higher education institutions. […] The Register Committee thus considered how QAA ensured a clear distinction of such work from its external quality assurance activities (see EQAR Policy on the Use and Interpretation of the ESG, standard 3.1 and Annex 5). In doing so, the Committee considered that also an uninformed reader needs to be able to distinguish the reviews in Albania from review reports (co-)owned by QAA, and thus not falling within the scope of QAA's registration on EQAR and not officially certified as in line with the ESG. While the final paragraph of the section “About this review” indeed states that QAA “provided expert support” in producing the report, the initial paragraph states that “Institutional Review is a peer-review process with each review team composed of a mix of UK reviewers appointed by QAA and Albanian reviewers appointed by the Albanian Public Accreditation Agency for Higher Education (APAAL)”. Considering the entire text, the Register Committee remained in doubt whether readers (at least lay readers) are able to clearly recognise the substantially different roles of QAA and ASCAL in the process, with QAA being “just” a consultant and ASCAL having full and sole ownership of and responsibility for the report.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategic plan, stakeholder involvement in the governance of the agency
Panel conclusion	Partial compliance
Clarification request(s)	Panel (26/02/2021)
RC decision	Compliance

“With regards to the agency’s vision mission and strategy, the panel stated that ARACIS “does not have a strategic plan that spans several years and does not appear to set targets for itself against which its Council and others can measure the Agency’s performance” (Review report p. 17).

Considering the involvement of stakeholders, the Register Committee noted that this is limited to representatives of students and employers sitting in ARACIS Council and Permanent Speciality Commissions. In the view of the panel, ARACIS tended to define the term ‘stakeholder’ narrowly, confining it to students, employers and trades union representatives and the panel was not confident that ARACIS understands the need to involve stakeholders more fully in the work of the Council and the work of ARACIS.

In its additional representation, ARACIS noted that it has followed up on the recommendations of the panel and it has developed a Strategic plan for the period 2018-2021 and the operational plans for 2018 and 2019, which were approved by the ARACIS Council. The Register Committee could verify the published plans.

The agency further provided a detailed overview on how representatives of stakeholders i.e. academics, representatives of students, representatives of employers and employers’ federation, representative of trade-unions, including one representative of ESU and ENQA.- participate in the council and different commissions of ARACIS.

ARACIS further explained that it has recently approved the inclusion of representatives of employers in the permanent Speciality Commissions, with priority the Commission of Engineering Sciences that awards the EUR-ACE label, and that the selection process for new members will be soon initiated.

The agency added that it has put forward a project application for “Stakeholder Engagement in QA” under a call of the Erasmus+ programme. The project aims to promote the diversification of stakeholders' involvement in quality assurance activities across EHEA and to provide the means for making the involvement of stakeholders effective.

The Register Committee welcomed the agency’s newly adopted strategic and operational work plans and was satisfied with the level of stakeholder involvement in the work and governance of the agency.”

Full decision: see agency register entry