Precedents database

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.3 Independence
Keywords	government involvement, organisational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“51. The Register Committee learned from the report that the members of the MFHEA Board are all nominated by the Minister responsible for

education and appointed by the Prime Minister of Malta. The Prime Minister also nominates the Chairperson and Deputy Chairperson of the Board, who undergo parliamentary scrutiny before being officially appointed. Furthermore, the dismissal and resignation of the Board members could be

only done by or via the Prime Minister.

52. Following the panel’s analysis, the Register Committee expressed its concerns that the organisational independence of the agency is constrained by its strong link and dependency on the government. This is reinforced by the small size of the higher education system.

53. The Quality Assurance Committee (QAC) of MFHEA is the body responsible for decision making on external quality assurance of further and

higher educational institutions. The MFHEA Board, on the other hand, is responsible for endorsement of the evaluation decisions taken by the QAC.

The panel noted inconsistencies regarding what accreditation procedures and which decisions are being endorsed by the Board. Further, as noted by the panel, the participation of the head of QAC, a body appointed by the Board, in the endorsement of QAC’s decisions as a Board member could create internal conflict of interest.

54. In its additional representation, the agency stated that “There are several layers to ensure the independence and suitability of the members of

the Board. These are nominated by the Minister for Education, however they are appointed by the Prime Minister and the Chairperson needs to be

approved by the Public Appointments Committee which is a Parliamentary committee made up of members from both sides of the House (Parliament) which conducts Parliamentary Scrutiny of the nominee. The law also lists the eligibility criteria for Board members, thus ensuring the objective suitability of person nominated by the Minister and appointed by the Prime Minister.”

55. Furthermore, the agency clarified that the current chairperson of the newly appointed QAC has not been appointed as a member of the Board and that the process for the required legislative changes to reflect this distinction are currently underway.

56. The Register Committee considered the additional representation and welcomed the distinction between the two bodies by excluding the

chairperson of the QAC in the Board. The Committee found that, however, this practice is yet to be codified as to ensure continuous prevention of

conflict of interest within the accreditation process. Furthermore, the committee maintains its concerns raised by the panel on the inconsistencies

regarding what accreditation procedures and which decisions are being endorsed by the Board.

57. Finally, the Committee maintains its concerns raised above about how the organisational independence of the agency is constrained by its strong link and dependency on the government.

58. Therefore, the Committee could not concur with the panel and found that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.3 Independence
Keywords	Lack of ability to independently design external QA procedures, lack of ability to autonomously determine organisational structure
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“27. The Register Committee learned from the panel’s analysis that ANVUR’s ability to design its external QA procedures (i.e. operational independence) and to set up its internal organisational structure (i.e. organisational independence) is rather limited. In panel’s view, the Italian regulations stipulated very specific details on the agency’s external quality assurance procedures, methodologies and the evaluation standards, as well as the internal governance and organisational structure. This approach diminishes ANVUR’s ability to act autonomously regarding its internal regulations and structures.

28. In its additional representation, ANVUR argued that most of the issues outlined by the review panel stem from the Italian national context and legislation. In regard to the operational independence of the agency, ANVUR argued that it has sufficient autonomy in designing its external QA procedures because national legislation emphasises ANVUR’s responsibility to independently define the criteria, indicators, and requirements of its external QA, while in regard to organisational independence, ANVUR states that the national legislation prescribes collaborative relation between the Ministry and ANVUR, instead of a direct supervisory role of the Ministry.

29. The Register Committee took note of ANVUR's remarks. The Committee could still follow panel's view that ANVUR is facing obstacles regarding organisational and operational independence, as the review panel already considered these legislative acts and nonetheless outlined detailed reasons for their concerns about ANVUR’s independence.

30. Considering that the review panel presents convincing evidence and analysis that ANVUR faces obstacles in its organisational and operational independence, the Register Committee concurred with the panel that ANVUR complies only partially with ESG 3.3.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	Independence, government representatives
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“18. The Register Committee understood from the analysis by the panel that the composition of the Board of Directors has dominant representation of the government and the UIB, and these two stakeholders appoint all six board members.

19. The Register Committee further learned that according to statutes, the Director of the agency is appointed by the Balearic minister responsible for university affairs. Since 2009, however, this position is vacant and the Technical Director, chosen with a public competition, manages the agency.

20. The Register Committee understood that to resolve the above mentioned issues new statutes of the Consortium of the Balearic Agency for Quality Assurance in Higher Education has been drafted. The statutes, however, are not yet in effect. Following this, the Committee concurred with the panel that AQUIB only partially complies with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	government,
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“16. The Register Committee learned from the panel analysis that the representation of stakeholders in the Governing Council has improved compared to the previous review and that the share of Government appointees in this body has been lowered.

17. The Committee, however, also noted that the regional minister, whose portfolio the agency is situated in, is acting as the President of the agency, chairs the Governing Council and has a casting vote.

18. Furthermore, the Register Committee noted, as underlined by the panel, that the agency is dependent on the Regional Government’s approval for hiring both temporary and permanent staff, which limits the agency’s operational autonomy.

19. Considering the significant level of involvement of the regional government in the governing of the agency and the potential constraints over the staff management and the operational independence of the agency, the Register Committee could not follow the panel’s judgement and concluded that ACCUA complies partially with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	14/03/2022
Standard	3.4 Thematic analysis
Keywords	Content of the thematic analysis
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“the content of the thematic publications mainly involved reflections on the agency’s own experiences in conducting EQA rather than analysis of the results of the EQA (an analysis which could be more appropriate to serve the internal quality assurance processes, ESG 3.6). The Committee agreed with the panel’s views that the agency could improve the content of the analyses so they are more meaningful for the wider academic and QA community”

Full decision: see agency register entry

Application	Initial
Review	Focused, coordinated by GAC
Decision of	12/12/2021
Standard	3.4 Thematic analysis
Keywords	Lack of development in preparing thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. The panel notes that AKAST reliably contributes the experience gained from its own quality assurance procedures to the regular evaluation of the Key Points and that the agency is documenting the results of its ongoing student survey on its website.

18. The Register Committee welcomes AKAST’s plan to further develop a thematic analysis after an appropriate number of programme accreditation procedures have been completed, but underlined that such an analysis has not been finalised.

19. Considering the limited development of thematic analysis, the Register Committee can follow the review panel conclusion that AKAST complies only partially with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	28/06/2022
Standard	3.4 Thematic analysis
Keywords	separate research or bilbiometric analyses do not qualify as thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“38. The panel considered that HCERES' recent activities have been focused on research and bibliometric analysis; analyses drawing on the results of evaluations within the scope of the ESG have not been produced regularly since the summary reports that HCERES/AERES used to produce following earlier evaluation campaigns.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	25/10/2022
Standard	3.4 Thematic analysis
Keywords	Consistent publication of thematic analyses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee learned that IQAA has published several thematic analyses since the last review. The panel, however, could not see

any formal plan for drafting and publishing these analyses.The Committee considered that despite the absence of a more formal planning the agency has developed a practice and demonstrated a clear vision for conducting analyses based on its EQA processes.”

Full decision: see agency register entry

Application	Renewal
Review	Focused, coordinated by ENQA
Decision of	19/06/2019
Standard	3.4 Thematic analysis
Keywords	Introduced policy for thematic analysis
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee learned that QANU approved a new policy for thematic analysis in October 2018, which defines explicit aims and objectives for various analysis. The panel stressed that QANU acknowledged its responsibility for producing thematic analysis as a way of contributing to the further development of the university research sector in the Netherlands. The panel further added that QANU has demonstrated capacity to use the experiences it gathered, to reflect on them, to share them and to publish outcomes through thematic analysis. Following the evidence and analysis provided by the panel, the Register Committee concurred with the panel’s conclusion that QANU now complies with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.4 Thematic analysis
Keywords	absence of regular analysis based on agency’s findings
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel specifically recommended that the agency “publishes reports of thematic analysis every year”. While the standard requires that such analyses be published "regularly”, it does not impose a specific cycle.

The Register Committee therefore underlined that this recommendation should rather be considered a suggestion.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	02/11/2020
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to thematic analysis; Quality of analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review panel found that BAC’s thematic review report provided a limited analysis, and was rather descriptive by simply summarising the content of inspection reports. Overall, the review panel felt there were still significant weaknesses in BAC’s approach to thematic analysis. In its additional representation, BAC agreed with the assessment of the panel and committed to prepare more meaningful thematic analysis that will serve to improve key areas related to the agency’s work by January 2021.While the Register Committee acknowledged the agency’s work towards improving its thematic analysis, the Committee remarked that such changes have not yet been implemented.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach to thematic analysis; Absence of regular analysis;
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that the agency has produced two analyses since its last review in 2014, both written in Russian but only published on the English version of AKKORK’s website. According to the panel, the last publication, however, does not meet the requirements of a thematic analysis. In particular, the panel noted the great qualitative difference between the publications, indicating a missing systematic approach to the publication of thematic analysis. The Register Committee underlines the panel’s recommendation that the agency should establish a clear process to address all of its activities in thematic analyses. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords	Producing effective thematic analysis reports
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“In its decision of 2015 to admit QQI to the Register, the Register Committee flagged for attention the production of thematic analyses by QQI.The Register Committee understood from the panel's report that QQI has been proactive and effective in producing a range of thematic analysis reports, which are considered useful in the sector for improving quality and quality assurance, even though not having completed full cycles in all external quality assurance activities.The Register Committee therefore considered that the flag has been addressed and concurred with the panel's conclusion that QQI complies withthe standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords	Producing effective thematic analysis reports
Panel conclusion	Full compliance
Clarification request(s)	–
RC decision	Compliance

“When evalag’s registration was last renewed, the Register Committee noted that the current review should address whether evalag produced analyses of the general findings of all reviews carried out by the agency. The review panel described clearly how evalag conducts thematic analyses based on the findings from its reviews. The Register Committee therefore concluded that the flag has been addressed.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“In the previous review the panel found that Unibasq had yet to produce a system-wide analysis and there was a lack of sufficient resources which is why this standard was flagged.The panel recognised that Unibasq has made clear progress in this area in recent years. The reports that agency produces show a clear shift from the evaluation of the procedures to a genuine thematic analysis (see page 24 of the report).The Committee concluded that the flag has been addressed and concurred with the review panel’s conclusion that Unibasq complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	05/11/2019
Standard	3.4 Thematic analysis
Keywords	Producing effective thematic analysis reports
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“At the time of its previous review in 2014, the Register Committee noted that AQ Austria was working on its first thematic analysis report on the development of quality assurance in Austria, and has not yet produced documentation to evidence substantial compliance. In its 2019 review report the panel’s findings show that the agency has since produced a number of reports focused on the results of QA processes and related issues in higher education. While the Register Committee underlined the recommendations of the panel for a further development of the thematic analysis, the Register Committee concluded that the flag has been satisfactorily addressed.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.4 Thematic analysis
Keywords	Implementation of thematic analysis
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee considered the panel's analysis as well as SQAA's statement on the panel report, referring to its recently published “methodology and procedure for drafting and disseminating system-wide and thematic analyses”. While the Committee welcomed the steps taken by SQAA to swiftly address the panel's recommendation, their actual implementation remains to be analysed within the next external review of SQAA.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	systematic approach to analyses and publishing
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“When AQAS last had its registration renewed, the publication of thematic analyses was flagged. Considering the review report, the Register Committee concluded that AQAS carried out a number of relevant internal analyses and produced relevant reports, e.g. the overarching report produced based on its accreditations in Moldova. These were, however, carried out on an ad-hoc basis, internal and not published as required by the standard. In its statement on the review report, AQAS explained that it had published a first set of thematic analyses on its website. While the Register Committee welcomed the efforts taken to date, it was not yet possible to conclude whether thematic analyses are produced regularly.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.4 Thematic analysis
Keywords	Lack of thematic analyeses
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“While a number of thematic analyses have been published since the last external review of the agency, the panel found that the analyses have been paused since the merger of FINHEEC into FINEEC. The panel also noted that FINEEC has not yet initiated thematic analyses of the accreditations of engineering degree programmes due to the small number of finished accreditations. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/12/2016
Standard	3.4 Thematic analysis
Keywords	Lack of systematic approach/lack of resources
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel stated that ACPUA has focused on thematic reports during its first year of existence, however the constraints on human and financial resources have hindered the agency’s activity in this area in recent years. Considering the increased number of external quality assurance activities carried out by ACPUA in recent years, the Register Committee underlined the panel’s recommendation to allocate sufficient resources to the activities supporting thematic analysis and ensure their implementation in a more systematic way”

Full decision: see agency register entry