Precedents database
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3.1 Activities, policy and processes for quality assurance – ANVUR – Partial compliance (2025) Lack of stakeholder involvement in governance bodies
ANVUR
Application Initial Review Full, coordinated by ENQA Decision of 14/03/2025 Standard 3.1 Activities, policy and processes for quality assurance Keywords Lack of stakeholder involvement in governance bodies Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “23. The Register Committee learned from the review report that the Governing Board of ANVUR consists exclusively of university professors, while no other stakeholders were involved in the governance of the agency.
24. In its additional representation, ANVUR explained that their regulations do not prevent any expert, regardless of which stakeholder group they belong to, from being a member of the Governing Board. In the Register Committee’s view, however, participation in the Governing Board is challenging, especially for students, due to the full-time character of the role, even though there are different governance arrangements and divisions of governance tasks which would enable broader stakeholder involvement. (e.g. by reducing the expected working hours for some stakeholder groups).
25. ANVUR further argued that stakeholders are involved in other bodies of the agency, such as the Advisory Board, leading to ANVUR’s governance being informed by stakeholders. While the Register Committee found the involvement of stakeholders in the work of the Advisory Board to be a positive practice, it noted that this does not fulfil the requirements of the standard which implies stakeholders’ involvement in strategic decision-making (governance), and not merely in the advisory processes of the agency.
26. Considering lack of stakeholder involvement, beyond the university academic staff, in ANVUR’s governance, the Register Committee was unable to concur with the panel’s conclusion and found that ANVUR only partially complies with ESG 3.1.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – AQUIB – Partial compliance (2024) Stakeholder involvement in governance
AQUIB
Application Initial Review Full, coordinated by ENQA Decision of 27/11/2024 Standard 3.1 Activities, policy and processes for quality assurance Keywords Stakeholder involvement in governance Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “15. The Register Committee learned that the governing body of AQUIB (i.e., the Board of Directors), is composed exclusively of representatives of the University of the Balearic Islands (UIB) and the regional government. The Board does not include student members nor other stakeholders.
16. The Register Committee learned that AQUIB has prepared a draft of the new Statutes which, in the review panel’s view, would ensure a more representative composition of the Board of Directors. However, these Statutes are not yet in force at the time of the review.
17. Considering lack of stakeholder involvement in AQUIB’s governance, the Register Committee was unable to concur with the panel’s conclusion of compliance and found that AQUIB only partially complies with the standard.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – ACCUA – Compliance (2024) stakeholders invovlement
ACCUA
Application Renewal Review Full, coordinated by ENQA Decision of 27/11/2024 Standard 3.1 Activities, policy and processes for quality assurance Keywords stakeholders invovlement Panel conclusion Compliance Clarification request(s) – RC decision Compliance “13. In its last decision, the Register Committee found the agency to be partially compliant due to the lack of stakeholders involvement on governance level and its lack of strategic planning.
14. The Register Committee learned from the panel’s analysis that the agency has addressed the issues raised in the previous review. The Committee noted that ACCUA has involved students and other stakeholder as members of the Governing Council of the agency. Furthermore, the Committee noted that ACCUA adopted an Initial Action Plan which is well-conceived to carry forwards the agency's mission and vision.
15. Following the improvements towards ESG compliance undertaken by the agency, the Register Committee was able to follow the panel’s conclusion that the agency complies with the standard.”
Full decision: see agency register entry
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3.1 Activities, policy and processes for quality assurance – ACSUCYL – Partial compliance (2025) Student involvement
ACSUCYL
Application Renewal Review Targeted, coordinated by ENQA Decision of 27/06/2025 Standard 3.1 Activities, policy and processes for quality assurance Keywords Student involvement Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “28. In the last decision of renewal of registration, the Register Committee found the agency to be partially compliant due to the lack of student involvement in the agency’s governance and work. To offer students the opportunity to contribute to governance and operations, the agency at that time established a Student Board, however, only as an advisory board without further involvement in the agency’s decision-making. The Register Committee found that students have not been included as members of the Board of Directors (the governance body of the agency). While ACSUCYL made attendance of students at the meetings of the Board of Directors possible since October 2021, the agency has not yet utilised it in practice.
29. The Register Committee noted from the panel analysis that since the last review, the agency included a student in the Degree Assessment Commission.
30. In its statement to the report, ACSUCYL explained that they have not employed this in practice because, since the change, the Board of Directors' meetings have only addressed management, administrative, and financial issues.
31. While the Register Committee welcomed the action taken for better student involvement in the work of the agency, it found that the involvement of students in the governance of the agency (as per the requirement of the standard) remains insufficient, given that students are not involved in the Board of Directors.
32. In its additional representation, ACSUCYL noted that while student participation had not been utilised in the Board of Directors due to the nature of issues discussed in its meetings, this practice was now initiated in their recent meeting. The agency has updated the rules governing the functioning of the Student Board to include them in the decision-making process and approved the proposal to initiate legislative changes to include student members in the Board of Directors (see more under ESG 3.3).
33. The Register Committee welcomed the actions taken by the agency in order to address the concerns on student involvement. Nevertheless, the Committee could not confirm how these changes have been implemented in practice. Furthermore, the announced changes in legislation are yet to be enacted and systematically implemented. The Register Committee therefore concurred with the panel that the agency complies only partially with the standard.”
Full decision: see agency register entry
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3.2 Official status – IEP – Compliance (2019) agency’s formal recognition
IEP
Application Renewal Review Full, coordinated by ENQA Decision of 03/04/2019 Standard 3.2 Official status Keywords agency’s formal recognition Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that IEP itself does not have separate legal personality and therefore it is represented by EUA in all legal and contractual matters. The Committee acknowledged that the recognition of IEP as a quality assurance agency by public authorities is demonstrated by the numerous contracts that IEP (represented by EUA) signed with national authorities for conducting evaluations, or by the selection of IEP as an evaluating body through a public procurement procedure. [...] The Register Committee interprets the requirement of formal recognition in a broad sense and therefore concurred with the panel's conclusion that IEP complies with the standard.”
Full decision: see agency register entry
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3.3 Independence – ECAQA – Partial compliance (2023) Infringement of the organizational independence
ECAQA
Application Initial Review Full, coordinated by ENQA Decision of 03/03/2023 Standard 3.3 Independence Keywords Infringement of the organizational independence Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “The Committee could not verify how the agency ensures its independence from its founder and found the distribution of power among stakeholders in the governing of the agency unequal. The Committee noted that the current arrangements include the possibility of
the founder or the Director General exercising their controlling stake in several regards, causing a substantial risk of an infringement on the
independence of the agency (see also interpretation 18).”
Full decision: see agency register entry
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3.3 Independence – UKÄ – Partial compliance (2021) Organizational independence; Lack of formal mechanisms for tackling conflict of interest
UKÄ
Application Initial Review Full, coordinated by ENQA Decision of 18/03/2021 Standard 3.3 Independence Keywords Organizational independence; Lack of formal mechanisms for tackling conflict of interest Panel conclusion Substantial compliance Clarification request(s) Panel (15/03/2021)
RC decision Partial compliance “Concerns about the Government's control of all major appointments remain. In particular, the way in which the Director General is selected has not been made fully transparent and it remained unclear whether the involvement of stakeholders in appointing the Advisory Board is secured in official documents. Moreover, the potential conflict of interest that the Director General could come across in their daily operations does not seem to be fully addressed through formal means by the agency.”
Full decision: see agency register entry
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3.3 Independence – ACSUCYL – Partial compliance (2020) Organisational independence; Appointment of the members by minister
ACSUCYL
Application Renewal Review Full, coordinated by ENQA Decision of 22/06/2020 Standard 3.3 Independence Keywords Organisational independence; Appointment of the members by minister Panel conclusion Full compliance Clarification request(s) – RC decision Partial compliance “In terms of organisational independence, the evidence presented by the panel shows that members of the Governing Board are appointed by the regional minister responsible for universities and that the Governing Board has a strong representation of its regional Government, including the Chairperson. The agency is largely dependent on the regional Government also for the approvals and hiring of new staff and the annual approval of its budget. ”
Full decision: see agency register entry
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3.3 Independence – ANECA – Compliance (2018) Organisational independence
ANECA
Application Renewal Review Full, coordinated by ENQA Decision of 11/09/2018 Standard 3.3 Independence Keywords Organisational independence Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that since its last evaluation, ANECA has strengthened its independence i.e. becoming an autonomous public body, ensuring a more balanced representations in its Governing Council, appointing of its own director and operating with full fiscal autonomy. The Register Committee further noted that “the operation of ANECA’s policies and procedures surrounding the design, implementation and reporting on all the evaluation processes takes place in a fully independent and autonomous manner” (Review report, p. 26).”
Full decision: see agency register entry
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3.3 Independence – ANQA – Compliance (2017) operational independence
ANQA
Application Initial Review Full, coordinated by ENQA Decision of 20/06/2017 Standard 3.3 Independence Keywords operational independence Panel conclusion Full compliance Clarification request(s) Panel (17/08/2025)
RC decision Compliance “The Register Committee sought and received clarification from the panel as regards ANQA's independence in defining its own procedures and methods. The Committee appreciated the panel's explanation as to how ANQA developed its Manual independently.”
Full decision: see agency register entry
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3.3 Independence – AEQES – Compliance (2017) organisational and operational independence
AEQES
Application Renewal Review Full, coordinated by ENQA Decision of 20/06/2017 Standard 3.3 Independence Keywords organisational and operational independence Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “The review panel was satisfied that the 2014 decree on AEQES and the current organisational status and structure sufficiently demonstrate and safeguard AEQES independence. In particular, AEQES gained the ability to hire staff from its own budget, independently of the Ministry”
Full decision: see agency register entry
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3.3 Independence – THEQC – Partial compliance (2023) Infringement of the operational independence
THEQC
Application Initial Review Focused, coordinated by ENQA Decision of 03/03/2023 Standard 3.3 Independence Keywords Infringement of the operational independence Panel conclusion Compliance Clarification request(s) – RC decision Partial compliance “Dependency of the agency on staff paid by higher education institutions”
Full decision: see agency register entry
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3.3 Independence – ECCE – Partial compliance (2023) Overlapping responsibilities between different bodies/ Lack of diversity
ECCE
Application Initial Review Full, coordinated by ENQA Decision of 30/06/2023 Standard 3.3 Independence Keywords Overlapping responsibilities between different bodies/ Lack of diversity Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “34. The panel raised issues related to the high involvement of representatives of accredited institutions, amplified by the small size of the chiropractic community, as well as the overlapping responsibilities between different agency bodies. In particular, the panel regarded critically the ex-officio mutual memberships of the Executive Committee and QAAC chairperson in the respective other committee, the involvement of both bodies in the QA process and the close involvement of the QAAC in pre-screening self-evaluation reports.
35. In light of these concerns, the Register Committee concurred with the panel’s conclusion that ECCE only partially complies with the standard.”
Full decision: see agency register entry
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3.3 Independence – CAAAE – Partial compliance (2023) Operational independence; Independence of formal outcomes
CAAAE
Application Initial Review Full, coordinated by ENQA Decision of 13/10/2023 Standard 3.3 Independence Keywords Operational independence; Independence of formal outcomes Panel conclusion Partial compliance Clarification request(s) – RC decision Partial compliance “The Committee learned that both the president and the vice president
of KAZSEE have voting rights in the two bodies in which they are members
of, i.e. the Accreditation Council and the Supervisory Board. In panel’s view
the “mixture of roles [of the President and the vice President] could make
the [decision making] system vulnerable”. The Committee could follow panel’s reasoning that the current
arrangements could pose threat for the operational independence and the
independence of formal outcomes.”
Full decision: see agency register entry
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3.3 Independence – NCEQE – Non-compliance (2024) High level of involvement of the Government of Georgia in the selection of candidates for several leadership and managerial positions in the agency
NCEQE
Application Renewal Review Full, coordinated by ENQA Decision of 27/11/2024 Standard 3.3 Independence Keywords High level of involvement of the Government of Georgia in the selection of candidates for several leadership and managerial positions in the agency Panel conclusion Partial compliance Clarification request(s) Panel (28/05/2024)
RC decision Non-compliance “The Register Committee found that the agency remains having weak
organisational independence as the government persists having strong involvement in the appointment of several NCEQE’s bodies. The Committee found that further panel insight should asses whether the Government’s significant involvement in the agency’s operations affects the notable staff overturn (i.e. the operational independence) and the final conclusions of the accreditation decisions (i.e. the independence of formal outcomes).”
Full decision: see agency register entry
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3.3 Independence – SKVC – Compliance (2022) involvement of ministry in accreditation of HEIs in exile
SKVC
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 3.3 Independence Keywords involvement of ministry in accreditation of HEIs in exile Panel conclusion Compliance Clarification request(s) – RC decision Compliance “15. The review panel noted some concerns about the process of ex-post accreditation of higher education institutions in exile, especially given the direct involvement of the Ministry of Foreign Affairs in the evaluation, i.e. certain standards being assessed by the Ministry instead of the panel of experts.
16. The Register Committee considered that the rationale might lie in the obvious political and diplomatic dimensions involved and that this might justify distributed responsibilities in principle. The Committee, however, considered that it must be transparent to the public what is an assessment made by SKVC and its independent expert panels, and what part of the assessment is made by the Ministry, potentially taking into account political considerations. The Committee recommends that SKVC and the Ministry explore how to disentangle political/diplomatic considerations and quality assessments fully, e.g. by having the Ministry make a separate assessment and decision either preceding SKVC's quality assessment, or following a decision by SKVC.
17. Given the rare occurrence of these procedures and the brief analysis by the panel on the matter, the Register Committee was unable to draw a definitive conclusion; the independence and transparency in these procedures should thus receive close attention in SKVC's next review.”
Full decision: see agency register entry
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3.3 Independence – AQU – Compliance (2022) composition of governing bodies; independence of the appeals process; financial independence
AQU
Application Renewal Review Targeted, coordinated by ENQA Decision of 25/10/2022 Standard 3.3 Independence Keywords composition of governing bodies; independence of the appeals process; financial independence Panel conclusion Full compliance Clarification request(s) – RC decision Compliance “In its previous decision the Register Committee underlined the concerns of the panel with regard to the overlap in the composition of the agency’s different bodies. The review panel found that AQU has separated the membership of its strategic and oversight bodies from its specific commissions and review panels. The Register Committee welcomed these changes, including the appointment of two non-local members to the Appeals Committee, but noted that the Chair of the Appeals Committee is a member of the Governing Board. While the role of the members in the Governing Board is limited to the strategic decision-making and management of the organisation, the Register Committee found that the involvement of a representative of the Board (in particular as a Chair) in the Appeals Committee might put undue pressure in the discussion and decision-making of the Appeals Committee. The Register Committee nevertheless agreed that the Appeals Committee was sufficiently independent given that the AQU’s Governing Board does not adopt the reports or decisions that are being appealed. The Register Committee further noted that AQU’s funding comes primarily from the Government of Catalonia (about 90% of the agency’s budget) and is allocated on an annual basis. The Committee welcomed AQU’s plans to move to a four-year contract with the Government of Catalonia, which could further improve its operational independence. Considered the steps taken to separate the membership of the agency’s strategic and oversight bodies, the Register Committee could follow the panel’s conclusion that AQU now complies with the standard ESG 3.3.”
Full decision: see agency register entry
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3.3 Independence – AKAST – Compliance (2021) Independence of formal outcomes
AKAST
Application Initial Review Focused, coordinated by GAC Decision of 12/12/2021 Standard 3.3 Independence Keywords Independence of formal outcomes Panel conclusion Substantial compliance Clarification request(s) Agency (07/12/2021)
RC decision Compliance “In its past review the Register Committee noted that AKAST was subject to the vigilance of the German Bishops’ Conference and that its influence extended to giving consent for the admission of members of the association and the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and the Board, and the approval of each of the accreditation decision by the member of the Commission for Science and Arts (Commission VIII) of the German Bishops’ Conference. Due to these interlinkages, the Register Committee concluded (see decision of 30/11/2019) that AKAST did not comply with ESG 3.3. The Register Committee in particular found the requirement that each accreditation decision requires the consent of the representative of the German Bishops’ Conference (member of the Accreditation Committee) to be in contrast with the requirement of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation While the German Bishops’ Conference continues to play a strong role in the governance of the agency, i.e. confirming the person who chairs the Executive Board, the Accreditation Committee and the Advisory Board, the Register Committee welcomes the steps taken by AKAST to strengthen the independence of formal outcomes and of its operation”
Full decision: see agency register entry
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3.3 Independence – ASIIN – Compliance (2021) Integrity/conflict of interest
ASIIN
Application Renewal Review Full, coordinated by ASHE Decision of 15/10/2021 Standard 3.3 Independence Keywords Integrity/conflict of interest Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “The Register Committee noted that the members of ASIIN’s technical committees can simultaneously hold the position of an external reviewer for ASIIN’s review panels, which would put them in a conflict of interest when discussing the reports prepared by the same panel they were members of.
23. Considering the panel’s concern of a potential conflict of interest resulting from this arrangement, the Committee concluded in its initial decision that ASIIN complied only partially with ESG 3.3.
24. In its Appeal of 20/01/2022, ASIIN challenged the Committee’s conclusion and judgment arguing that the independent decision making of its Technical Committee was not compromised. The agency made the case that the involvement of active experts as members within ASIIN’s 14 Technical Committees ensured a consistent application of procedures and criteria in the preparation of accreditation reports. ASIIN further explained that ASIIN’s Technical Committees did not have any decision-making power as regards the accreditation decision. Moreover, the experts involved in the procedure would regularly abstain.
25. The Committee welcomed the abstention of the Technical Committee members, but could not determine if the practice of abstention was institutionalised in ASIIN’s procedure.
26. The Register Committee further underlined that the integrity of the review process could be better safeguarded by ensuring that members of the Technical Committees would not partake at all (i.e. by leaving the room) when their report is considered by the Technical Committee.
27. Having weighed the limited role of the Technical Committee in ASIIN’s decision making process and the fact that its members abstain from decision-making in such cases where they were involved as reviewers, the Register Committee concluded that ASIIN’s independent decision-making is not compromised and thus found that the requirement of the standard is met. The Committee therefore concurred that the agency complies with ESG 3.3”
Full decision: see agency register entry
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3.3 Independence – EQ-Arts – Compliance (2021) nomination of the Board members
EQ-Arts
Application Initial Review Focused, coordinated by ECA Decision of 18/03/2021 Standard 3.3 Independence Keywords nomination of the Board members Panel conclusion Substantial compliance Clarification request(s) – RC decision Compliance “21. The review panel noted that EQ-Arts' statutes were reviewed in order to reorganise its Board and allow for the inclusion of students. Moreover, the Board and Executive Group were merged. The Governance Framework defined the composition and responsibilities of the Board, as well as the criteria for Board membership (p.34).
22. The panel reported that a call for Board members was issued in May 2020 and addressed to relevant subject-specific stakeholder organisations; on that basis, the Board members were selected.
23. The Register Committee considered that the new arrangements improved transparency and therefore concurred with the panel's conclusion that EQ-Arts complies with the standard.
24. The Committee was unable to verify whether the nomination arrangements apply only to initial nominations or also to re-appointments. In the interest of assuring a regular link with the sector, the Committee encouraged EQ-Arts to ask for nominations also for re-appointments.”
Full decision: see agency register entry