Precedents database

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.7 Complaints and appeals
Keywords	allegations, appeals, complaints
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. The Register Committee noted that the agency defines three different processes for allegations, appeals and complaints.

17. The allegations (considered as a form of feedback opportunity for the institutions) are dealt with by the Technical Committees, who is also responsible for drafting the reports (see also under ESG 2.6).

18. The appeals and complaints procedures are defined by law and are under the legal competency of the Canary government.

19. The Committee noted, that ACCUEE’s appeals and complaints policies are limited as the agency does not have its own appeals and complaints processes or a separate body in considering complaints or appeals.

20. The Committee considered that external quality assurance processes should always include an internal possibility to appeal and complain with the responsible body that carried out the review itself.

21. The Register Committee noted that ACCUEE intends to appoint an independent and permanent body, Guarantee Commission that will consider all appeals and complaints related to all procedures that are in the scope of the ESG.

22. The Register Committee welcomed ACCUE’s intention to set up a separate body to handle appeals and complaints, but the Committee underlined that such changes are yet to be implemented and to be reviewed. The Register Committee therefore concurred with the panel that ACCUEE only partially complies with ESG 2.7.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	30/06/2023
Standard	2.7 Complaints and appeals
Keywords	no possibility to appeal the formal decisions
Panel conclusion	Partial compliance
Clarification request(s)	Panel (15/02/2023)
RC decision	Partial compliance

“23. The panel raised concerns about the slight unclarity and overlap between the “appeals and complaints procedure” and the separate “complaints procedure”. Even though the wording is unusual, the Register Committee considered that both appeals and complaints, as understood in the ESG, are generally possible.

24. The Committee obtained clarification by the panel on the composition of the Appeals Committee. Even though the members are different from the QAAC, the Committee shares the panel’s concern that all but one come from the rather small chiropractic community.

25. The Register Committee’s further noted that there is no possibility to appeal the formal decision by the QAAC, only the expert report. The Committee regarded this as problematic given that the QAAC alone decides on the accreditation term.

26. In its additional representation the agency explained that the judgement itself of the QAAC cannot be appealed solely on the basis of disagreement with the decision, but can be made based on incorrect procedures, or if it was executed in an unfair and discriminatory manner. The Committee thus understood that while ECCE makes possible appeals based on procedural error, errors of fact, mitigating circumstances where material was not available at the time and for situation where members of QAAC or ECCE behaved in a discriminatory or unprofessional manner, the agency does not allow for an appeal of QAAC’s judgement itself. The Committee thus finds that the appeals process is limited, given that the reviewed higher education institution may not challenge based on e.g., criteria that may have not been correctly applied or disagreements in how standards were interpreted by QAAC.

27. The Committee noted that the agency considered and upheld an appeal against a QAAC formal decision, but also noted that there is no public documentation on this appeal and that the agency does not have any information on its website on the composition of its Appeal’s Committee.

28. The Register Committee therefore concurred with the panel’s conclusion that ECCE only partially complies with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/03/2023
Standard	2.7 Complaints and appeals
Keywords	Independence of the appeal's body
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The panel argued that there was “no avenue available to have an

external review of a decision” and noted the “absence of external

adjudication in the mechanism used”. The Register Committee expects that

an appeal is considered by another body than the one whose

decision/report is appealed (see interpretation 13 of the ESG); this will

nevertheless normally be a body of the agency, as the standard requires an

internal appeals process (see also interpretation 12 of the ESG). As the

HAHE appeals committee consists of different persons than the (current)

EAC, this requirement is formally fulfilled, even if HAHE may reconsider the

practice of appointing only retired EAC members when it reviews its

appeals procedures as recommended by the panel, Further, the fact that the appeals' committee makes a recommendation to the

EAC is compatible with EQAR's expectations (see interpretation 14 of the

ESG).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	2.7 Complaints and appeals
Keywords	appeals and complaints, committee
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its initial application for inclusion the Register Committee raised concerns regarding the lack of an internal appeals system within the agency.

14. The Register Committee noted that since the last external review of NEAA, nothing has changed in relation to the possibilities for higher education institutions to make an appeals with the agency.

15. The Register Committee further noted, that NEAA does not have its own appeals process nor a separate body in considering appeals and that the only existing appeals procedures are outside of NEAA’s remit, defined by law and under the legal competency of the Bulgarian courts.

16. The Committee considered that external quality assurance processes should always include an internal possibility to appeal within the responsible body that carried out the review itself.

17. In its representation the agency provided full documentation on its new internal provisions for complaints and appeals and for the functioning of its body the Complaints and Appeals Committee. The Committee noted that the new body is a standing committee within the agency, fully operative with permanent members and clear provisions outlined in the Statutes of the Complaints and Appeals Committee.

18. Having been able to verify that the agency provides both internal processes for complaints and appeals, the Register Committee finds that the initial concerns have been addressed. The Register Committee therefore concluded that NEAA now complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	2.7 Complaints and appeals
Keywords	appeals procedure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“27. The Register Committee noted in its past decision that the chairperson of the agency’s board takes the final decision on the appeal and reviews the conclusions of the Appeals Committee. The Register Committee found this may affect the integrity of the appeals process. Additionally, the Register Committee found that higher education institutions do not have the possibility in case of institutional accreditation to appeal the report with AIC (only with ministry).

28. In the Substantive Change Report (of 2022-03-15), AIC elaborated further on the modalities for potential appeals against accreditation decisions regarding the Accreditation of foreign study programmes. The explanations, however, left open how such appeals would be considered.

29. In the review report the panel explained the possibility to appeal accreditation decisions made by the agency. The panel considers that the appeals procedure which has been developed, and the Appeals Committee which has been compiled in January 2022, brought the agency’s review procedures for Latvian higher education institutions in line with the standard.

30. The Register Committee considered the statement of the agency regarding the appeals and complaints procedures and noted that the amendments to the legislation were approved and an appeal procedure including independent appeals commission, has been set and is functioning. The Register Committee welcomes the progress made, but follows the panel’s concern on the lack of the transparency of external quality assurance system, due to a lack of written procedure for hearing complaints.

31. The Register Committee underscores the panel recommendations on the publication of the procedures to follow-up complaints concerning activities of the agency in Latvia and on the development of an appeals and complaints procedure for its accreditation procedure for foreign degrees.

32. Having considered the improvements by the agency, the Register Committee noted the need to further elaborate on the procedure for complaints. The Register Committee agrees on compliance for this standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	2.7 Complaints and appeals
Keywords	Lack of transparency in the agency’s appeals processes, accessibility of Appeals Procedure
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“11. In its past decision, the Register Committee raised a concern regarding the lack of transparency in the agency’s processes concerning the members nominated to act in the Appeals Committee. The Committee also noted at that time that the appeals procedure was not easily accessible on ARACIS’s website.

12. The Register Committee noted from the analysis of the panel that ARACIS has appointed a Permanent Appeals Commission for a four-year term and published the composition of the commission. The Committee also learned that as of October 2022, ARACIS has a new, integrated and simplified Appeals and Complaints procedure that can be easily retrieved from the website1.

13. The Committee welcomed the newly updated procedure, and while noting that the procedure is rather generic in what concerns handling of complains, that it satisfies the requirements of the standard.”

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	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	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Student involvement in decision making bodies
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Partial compliance

“ANQA involves students in the review panels, but not in the body

responsible for making decisions on accreditation (i.e. the Accreditation

Council). The Committee highlighted the panel’s recommendation and

found it necessary that the agency improves the involvement of students in

the decision-making process.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	14/03/2022
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of stakeholders in governing bodies; Lack of clear policy for separation of EQA and consultancy activities and preventing conflict of interest
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The governing body (i.e. the Managing Board) of the agency does not involve other stakeholders than academics. The agency has not published any policy or statements in regards to the separation of its consultancy activities and preventing conflicts of interest.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	15/10/2021
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Weak involvement of stakeholders in the governance of the agency
Panel conclusion	Substantial compliance
Clarification request(s)	Panel (28/09/2021)
RC decision	Partial compliance

“AI has no advisory or governing board, nor any other strategical decision making body (hence lacks stakeholder involvement in the governance of the agency).”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	clarification of external QA carried abroad
Panel conclusion	Full compliance
Clarification request(s)	Agency (21/05/2019)
RC decision	Compliance

“In its confirmation of eligibility, the Register Committee noted that PKA is expected to also address activities carried out by the agency abroad i.e. in Lithuania. As it was unclear on whether such activities were addressed in the external review of PKA, the Committee asked PKA for further clarifications. PKA explained that the external QA activities carried out in Lithuania only extended to one foreign branch of a Polish higher education institution and that the procedures and criteria used were identical with those applied in the case of national HE providers.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/06/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholder involvement in the governance and work of the agency
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While the panel noted that a broader stakeholder involvement would require a change of the law on higher education and might have further implications for the overall functioning of the agency, the Register Committee underlined that the unbalanced composition of NEAA's governing bodies was already flagged as a matter requiring attention when NEAA was first admitted to the Register in 2009”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	06/12/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Agency lacks explicit goals and objectives; limited stakeholder involvement i.e. consultations only where specific topics are addressed
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that while NEAQA’s strategy could provide a comprehensive framework for the agency's daily operations, the agency does not have in place mechanisms for effective forward planning and reviewing progress towards its objectives. Considering the involvement of stakeholders, the panel’s findings show that, since its last review, NEAQA has improved the engagement with employer representatives in its quality assurance activities. However, stakeholder involvement is still limited in agency's work given that neither students nor employers are involved in NEAQA’s governance.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	13/06/2018
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Involvement of students in agency’s decision making
Panel conclusion	Full compliance
Clarification request(s)	Panel (02/06/2018)
RC decision	Compliance

“The Register Committee understood that the reference to “consultative services” in the report in fact referred to so-called “consultative visitations”. These are, however, not consultancy activities, but a step in EAEVE's external quality assurance scheme. […] The Register Committee underlined the panel’s suggestion that EAEVE should involve students in the ECOVE and the appeals panels, even though students do not request membership at the moment.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Stakeholder involvement
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee flagged in its decision of inclusion the effectiveness of the Accreditation Institution’s activities to engage with its stakeholders.The Committee noted that the involvement of stakeholders is generally ensured trough consultations by the Ministry and the Accreditation Council (Review Report, p. 29), while AI’s only formalised form of stakeholder involvement is related to the thematic analysis of reports. The Committee concurred with the panel’s conclusion that AI should further develop stakeholder involvement in its governance and work in order to meet the agency’s objectives of enhancement and further development of quality assurance.”

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	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