Precedents database

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

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

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 (24/04/2025)
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

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

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

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

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

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

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

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

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

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

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

Application	Initial
Review	Full, coordinated by GAC
Decision of	22/06/2020
Standard	3.3 Independence
Keywords	Organisational (of the accreditation committee and executive board from the founding organisation) and operational independence
Panel conclusion	Substantial compliance
Clarification request(s)	Agency (24/04/2025)
RC decision	Non-compliance

“The panel’s findings show that, under canon law, AKAST is subject to the vigilance of the German Bishops’ Conference. The Bishops' Conference influence extends to giving consent for the admission of members of the association, the consent for the nomination of members of the Accreditation Committee, the confirmation of the Chairperson of the Accreditation Committee and 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. AKAST is also financed by an annual grant from the Association of German Dioceses (VDD), the legal entity for the German Bishops’ Conference. The panel explained that the German Bishop Conference member serves within the Accreditation Committee “in more moderatorial and advisory capacity” (review report p. 19) and that the elected Accreditation Committee members, permanent guests and experts involved in reviews are all requested to sign a declaration of no-conflict-of interest. The agency also added that the involvement of the German Bishops’ Conference in the decision-making process “helps ensure that there is no conflict between accreditation decisions and the subsequent ecclesiastical approval required under canon law” (self evaluation report p. 15). While the Register Committee considered it usual and acceptable for the Bishops' Conference, as the main founder and hence key stakeholder of the agency, to be involved, the Register Committee underlined that the requirement of independence should be understood to the effect that the new organisation, once it has been founded, should be able to function independently as required by the standard. 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), in contrast with the understanding of the ESG that the responsibility for the final outcomes of the quality assurance processes remain the responsibility of the quality assurance agency. The Register Committee added that the accreditation decision by AKAST and the ecclesiastical approval required under cannon law are the purview of two different entities, and could be therefore considered independently from each other. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	18/03/2021
Standard	3.3 Independence
Keywords	Organisational and operational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel noted that THEQC’s operational independence is affected by the key role played by experts and consultants, who serve as the agency's professional staff but remain employed and on the payroll of higher education institutions. The analysis of the panel showed that the current organisational structure of the agency affects the independence of its operations and formal outcomes since there is a potential for conflicts of interest to arise regarding the different roles played by the Councils’ members. The agency responded in its statement to the review report that THEQC had increased the number of permanent employees (4 new full-time employees started working for the Council in 2020). The agency also stated that its organisation structure was defined by law, but it had nevertheless conveyed the recommendation related to THEQC’s organizational structure to the relevant authorities. In its additional representation the agency added that as of January 2021, the number of THEQC employees had further increased and that the duties and responsibilities of the Council members had been reframed. While the Register Committee noticed the increase in the number of permanent staff, the Committee considered that the agency is still relying to a large extent (14 of 35 staff members) on experts and consultants that are at the same time on the payroll of higher education institutions. This could constitute a conflict of interest for obvious reasons. The Committee thus concluded that the panel’s concerns related to THEQC's operational independence have not been fully addressed”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by NASM
Decision of	02/11/2020
Standard	3.3 Independence
Keywords	nomination and dismissal of the Board members of the organisation
Panel conclusion	Full compliance
Clarification request(s)	Panel (24/10/2020)
RC decision	Compliance

“The panel noted that since its last review the MusiQuE Board now makes the final decision on its own composition. Considering the changed arrangements, the Register Committee was unclear how the members of the MusiQuE Board could be dismissed and if so on what ground. The Committee has therefore sought further clarifications from the pane. In its response, the panel explained that the absence of an external body to appoint or dismiss Board members was something specific to the legal form of a Foundation in Belgium. The panel further referred to the agency’s statutes, which provide the possible reasons/circumstances for the ending of the mandate of one board membe. The Committee noted that the panel found the current organisational arrangement to be adequate in guaranteeing the independence of the Board and its members in the context of an international quality assurance agency.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	16/03/2020
Standard	3.3 Independence
Keywords	Organisational independence: appointments in the majority of the agency’s made by the Galician government
Panel conclusion	Full compliance
Clarification request(s)	Panel (14/02/2020)
RC decision	Partial compliance

“The Register Committee noted that the president of the Governing Board of ACSUG, the director of ACSUG and the president of the CGIACA (following the nomination by the Governing Board) are all members appointed by the Galician Government. In view of the panel’s recommendation to ACSUG i.e. to set procedures in the selection of the director of the agency, president of the Governing Board and president of the CGIACA the Register Committee asked the panel to clarify whether the appointments of these bodies follow a set of criteria and if the panel has reviewed these criteria. The panel responded that it has only considered the criteria and tasks set in the Statutes of 2018, based on professional competence and prior experience, and that these criteria are intended to be used in the future appointment processes. While the Register Committee welcomed the appointment criteria based on professional competence and prior experience, the Committee underlined that the regional Galician Government nevertheless remains directly involved in the appointment of the majority of members in the agency’s governing body, in the appointment of president of the Governing Body, the president of the agency’s decision making body (CGIACA), the director of the agency and the president of the Advisory Council. The Register Committee welcomed ACSUG’s intention of appointing a representative from outside Galicia in the Governing Board and as part of CGIACA’s but noted that the current addition does not change the agencies reliance on the regional Spanish government. While the involvement of the government (as one of its stakeholders) is encouraged, the current organisational arrangements does not guarantee clear and sufficient safeguards to prevent the possible interference of the regional Galician government in ACSUG’s governance. Considering the close interlinkage between ACSUG and the Galician government, the Committee could not follow the panel’s judgment of (full) compliance, and concluded that ACSUG complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.3 Independence
Keywords	CYQAA’s link to the ministry of education
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its analysis the panel noted that the agency’s Council members are appointed by the Council of Ministers upon recommendation from the Minister of Education and Culture (MOEC) who consults the Rectors’ Conference and relevant professional bodies (except the student member, who is appointed by POFEN).In terms of organisational arrangements, the Ministry is further involved in the recruitment process of the agency’s staff and in CYQAA’s financial services. The panel noted that “MOEC provides what the agency needs, as evidenced by a big budget increase and new staff, and the agency itself is proposing amendments on fees to the law which would further increase its income. While the panel noted that the provision of the quality assurance law and the strict rules for Council members reduces the risk of the Ministry’s interference with the agency's independence, the panel also stated that the current arrangements could be further revised, especially in reconsidering CYQAA’s organisational ties with the Ministry of Education and Culture. The Register Committee underlined the recommendations of the panel to ensure a clear separation of CYQAA from MOEC in its staff recruitment process, infrastructure and management of its own finances. In its additional representation the agency presented its proposed legislation changes and argued that this would safeguard the agency’s independence and the Council’s autonomy. Considering the proposed changes the Register Committee was not convinced that the changes in the appointment of CYQAA’s Council members would result in an increase of independence from the Ministry as, according to the proposed changes most of the Council members (eight out of eleven), are proposed (following stakeholder consultation in some cases) by the Minister. The Register Committee took note of the provision regarding the operational independence of the agency and welcomed the steps taken to increase its financial independence i.e. including a budget provisions that will allow the agency to hire additional staff, if the agency intends to do so. While the Committee noted some progress towards safeguarding the independence and autonomy of the agency, the Committee underlined the existing close interlinkage between CYQAA and MOEC and therefore concluded that the agency complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.3 Independence
Keywords	Operational independece
Panel conclusion	Full compliance
Clarification request(s)	Panel (24/04/2025)
RC decision	Compliance

“Considering the organisational independence, the panel’s findings show that CTI outsources its accounting and management of human resources to the Conference of Deans of French Schools of Engineering (CDEFI), an organisation that represents the engineering schools that CTI accredits. CTI also shares its premises and one staff member with CDEFI. Considering the close interlinkage between CDEFI and CTI, the Register Committee asked the panel to elaborate how the agency ensures its operational and organisational independence. Regarding the operational independence the panel responded that procedures and methods are defined by CTI’s committees on the basis of preparatory work of working groups and that third parties are not involved in this processes. The panel was convinced on the basis of the self-assessment report and the meetings with representatives of CTI and its stakeholders, that independence was guaranteed. The panel commented that the financial administration of CTI is separate from the administration of CDEFI and while CDEFI administrates the contracts and selection of personnel, that the daily management of the staff are the responsibility of CTI alone. Considering the organisational independence, the panel argued that the independence of CTI from CDEFI remains guaranteed based on a signed agreement (as of June 2015) between the two organisation. The agreement defines the tasks expected from CDEFI and CTI, the annual fee in detail and stipulates how the independence of CTI and of CDEFI remains guaranteed. The panel added that the sharing of renting facilities in the same building is considered by all parties the panel spoke with as very positive. Having considered the clarifications from the panel, the Register Committee was therefore able to follow the panel’s conclusion that CTI complies with ESG 3.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	19/06/2019
Standard	3.3 Independence
Keywords	Organisational and operational independence
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that the members of NCEQE’s Authorisation and Accreditation Council are appointed by the Prime Minister upon recommendations by the Minister of Education and Science. The panel commented that the ability of the Ministry to appoint and dismiss the Councilmembers does not support organisational independence and that the agencyshould take more ownership on how council members are nominated.In its letter to EQAR (of 6 June 2019) the agency stated that NCEQE is currently working on initiating legislative changes that will allow the agency to shift the mandate in the appointment and dismissal of the NCEQE’s Director and Council members to its main Coordinating Council. The agency added that discussions are also under way to increase the role of the Coordinating Council in the selection process of the Authorization and Accreditation Council members. While the Register Committee welcomed the agency’s initiative to increase its independence from the Ministry, the Committee underlined the panel’s concerns that the new rules for the selection of Council members do not fully alleviate the concern regarding the agency’s independence as the Council itself is set up at the recommendation of the Ministry.The Register Committee underlined the panel’s recommendation that the agency should be ensured that there is a structural independence from the government and that the agency should take ownership of how council members are appointed under the new rules. While considering that the failure to fully meet the requirement of the standard concern both the organisational and operational independence, the Register Committee nevertheless noted the agency has put forward legislative changes that would increase its independence, and therefore could follow the panel conclusion that NCEQE complies partially with ESG 3.3.”

Full decision: see agency register entry