Precedents database

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.6 Internal quality assurance and professional conduct
Keywords	not clear how agency ensures ESG compliance when using non-registered QAAs’ results
Panel conclusion	Full compliance
Clarification request(s)	Panel (24/04/2025)
RC decision	Partial compliance

“The panel pointed out that it was “assured by the agency that the same criteria and guidelines were applied”. The panel noted it had discussed the issue with the madri+d Accreditation Commission, which “confirmed its focus on being assured that meeting the ESG standards are a key focus of such accreditations”.

The external review report and the panel’s clarification did not refer to any evidence or further details to support this assurance. The Register Committee noted that at least two actual cases (accreditation based on ABET accreditation, https://data.deqar.eu/report/8971/ and https://data.deqar.eu/report/9129/) raised concerns insofar as the ABET reports, forming the basis for these decisions, are not published as required in ESG 2.6.

The rather generic statements, combined with these two examples, did not demonstrate sufficiently how ESG compliance is assured for reports by other, non-registered agencies. The Register Committee was therefore unable to concur with the panel's conclusion, but considered that madri+d only partially complied with standard 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Lack of sufficient and fit for purpose IQA processes; Inconsistency of presentation of internal structures;
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that while the responsibilities in internal quality assurance are defined in the ‘AKKORK Internal Regulations’, the main tool of the agency for internal quality assurance of its activities are the regular staff meetings. The panel’s analysis showed a number of concerns related to the agency’s internal workings, i.e. inconsistencies in the information presented on the agency’s website, the information regarding the publication of the reports or information available on external QA activities on the Russian and English parts of the website; inconsistency in the presentation of the agency’s organizational chart in ‘AKKORK Internal Regulations’ and the structure outlined in the review report, etc.. Considering the above examples, the panel considered that not all outcomes of the agency’s work, especially not the production of documentation, are covered by the existing QA cycles. ”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	22/06/2020
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Lack of sufficient and consistent IQA processes
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“In its previous decision of inclusion, the Register Committee flagged the effectiveness of AAC-DEVA’s internal quality assurance arrangements. In May 2018, AAC-DEVA established an Internal Quality Assurance Commission to review its own internal quality assurance methodology, but at the time of the site-visit the agency was still reviewing its internal documentation. The panel saw insufficient evidence of a pattern of continuous improvement in the internal quality assurance of AAC-DEVA. While there has been a spur of activity in preparation for the external review the panel did not consider this was sufficient to achieve meaningful results. In its additional representation the agency reasserted its commitment for improving its internal QA system and that it was in the process of reviewing its Services Charter and setting up a web application designed to support continuous improvement and facilitate the management of the agency’s activities. ”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	03/04/2019
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Implementation of the processes for external feedback mechanism
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Compliance

“The Register Committee noted from the review panel’s analysis that [...] internal and external feedback mechanisms are not entirely in place within the agency and the processes for examining data and collecting feedback are not systematic and formalised (Review Report p. 30). In its additional representation, HAC explained that internal quality assurance practices that are in place i.e. internal regulations for professional conduct and integrity, code of ethics, by-laws laying down the responsibilities for all activities of external members and staff, handbook for programme officers etc. The agency added that the surveys carried out with evaluated institutions were discussed in staff meetings and by the HAC Board and actions have been taken to improve procedures. The Register Committee further took note that HAC’s Quality Assurance and Development Committee has scheduled further activities to revise and develop surveys on accreditation procedures.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2019
Standard	3.6 Internal quality assurance and professional conduct
Keywords	IQA processes are not fit for purpose
Panel conclusion	Substantial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The review report noted an improvement in the agency’s internal quality assurance process [...] but stressed the need for ARACIS’s internal QA to be improved so as to support the work of its speciality commissions, responsible for the consistency check of evaluation reports and for preparing the Council’s decisions. The panel found that the members of Permanent Speciality Commissions do not have access to the searchable digital copies of evaluation reports, and that they are provided with a pile of reports the day before the meeting, thus being prevented in making their own judgements on the findings of individual reports.

While the panel stated that ARACIS newly introduced comprehensive IQA procedures and new staff member will provide the agency with a sound basis for reviewing and improving the effectiveness with which it works, the Register Committee found this has not been implemented at the time of the review, in particular in supporting the internal activity of its speciality commissions.

ARACIS explained in its additional representation that the procedure to fill in the positions for the Internal public audit department has been delayed due to a temporary staff hiring interdiction in the public sector. As the interdiction has been lifted the agency started to fill in these positions.

The agency further stated that the Permanent Speciality Commissions are supported in their work by the experts and speciality inspectors for accreditation and quality assurance (permanent staff of the agency) providing all the logistics and necessary material. After the site visit each member of the Permanent Speciality Commission receives by e-mail, for analysis, the documents drafted by the visit panel. The panel coordinator of the site visit also presents the results in front of the Permanent Specialty Commission who takes the final decision.[…]. The Committee also noted that the agency has made little progress in making its reports machine-readable (p. 5) since its last review..”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	20/06/2017
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Effectiveness of agency’s IQA
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The panel recommended that ECCE develop a single consolidated internal quality assurance document that includes internal and external feedback mechanisms for continuous improvement. In its additional representation the agency stated that while the internal QA and professional conduct was an issue at the time of the external review ECCE had since put in place a number of measures to address these issues, i.e. a Complaints and Appeals procedures (document expected to be finalised in May 2017), questionnaires to collect feedback from ECCE committee members and is planning a study to compare its standards. Given that most of these steps are plans and their effectiveness has not yet been reviewed by an external panel, the Register Committee could not conclude that, as it stands, the agency’s internal quality assurance processes are fully sufficient to assure and enhance the quality and integrity of its activities. The Committee underlined the need for an external review of the changes to its internal quality assurance related to defining, assuring and enhancing the quality and integrity of the agency’s activities.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by GAC
Decision of	03/12/2016
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Efectiveness and clarity of agency’s IQA
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“The Register Committee noted that ZEvA has a formalised and binding system for internal quality management that is addressed by the “Guidelines for Internal Quality Assurance”. In its analysis the panel identified a number of gaps in the agency’s quality assurance system in particular out-dated aspects within the Guidelines for Internal Quality Assurance as well as insufficient presentation of the (newer) internationally oriented procedures. For instance the agency’s new external quality assurance activities (i.e. audit and certification procedures) are not fully integrated into the quality handbook; or the newly developed rules for system accreditation are not represented in the Guidelines for Internal Quality Assurance.the Register Committee noted that quality assurance processes primarily focus on the programme accreditation activities and that there is little mention of how the outcomes of the processes are used for improvement of the agency’s work and communicated to the users.In its response to the review report analysis the agency (of 30/5/2016) stated that it has provided the panel with a non-revised version of the Guidelines, which in fact have been updated and has incorporated all procedure offered by the agency.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	13/10/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal, internal QA system,
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“32. The panel noted that NEAA started developing its internal quality assurance system introducing, some new mechanisms and procedures. However, the panel underlined that the elements of the procedures are fragmented and not fully structured, integrated and connected in a systematic way. The panel also noted the lack of transparency of the mechanisms and their results.

33. Despite NEAA’s efforts to develop its own internal quality assurance system, the Register Committee found that the process is still in a developmental phase. The Committee underlines the panel’s recommendation that all the elements of the internal QA system needs to be better connected, regularly implemented with the involvement of all internal and external stakeholders.

34. In its representation, NEAA informed that in 2023, the agency undertook an internal audit to identify the weaknesses and bottlenecks in its own internal processes and review procedures. The agency also provided details of the internal audit process and the series of recommendations that were outlined to correct the issues. NEAA further stated that necessary measures are being implemented to improve the functioning of the agency.

35. While the Register Committee welcomed the steps taken by NEAA, the Committee underlined that the issues outlined before remain to be considered and reviewed by an external review panel to determine the improvement in the functioning of NEAA’s internal QA system.

36. The Register Committee therefore concurred with the panel’s conclusion that NEAA only partially complies with ESG 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal management system, feedback mechanisms
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“33. The Register Committee understood from the panel’s analysis that AIC has set up an internal management system to support the daily work of the agency and the collection of feedback from different sources to inform improvements.

34. The Committee however noted AIC’s internal quality assurance system faces a number of issues and limitations: no major changes/ improvements can take place without government regulation or legal change; the informal nature of the feedback limits the ability of the agency to measure objectively “the outputs of the system”; no sufficient evidence that experts are getting acquainted with additional requirements or obligations set by Study Quality Commission after the accreditation procedure.

35. The Register Committee therefore finds that AIC has yet to consolidate its internal quality assurance system, including internal and external feedback mechanisms for continuous improvement.

36. The Register Committee could not conclude that, as it stands, the agency’s internal quality assurance processes are fully sufficient to assure and enhance the quality and integrity of its activities and therefore could not follow the panel’s conclusion, but found that AIC complies only partially with the standard 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality assurance, mechanisms
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“17. The Register Committee, noted in the analysis by the panel the gaps and shortcomings in the implementation of the agency’s Internal Quality Assurance (IQA) Regulations.

18. Furthermore, the Committee underlined that the mechanisms for fostering continuous improvement within the agency are weak and unsustainable on the long-term, i.e., the heavy responsibility of AKAST administrator for all of the IQA processes, the lack of systematic approach in gathering feedback and lack of evidence and example of enhancement based IQA.

19. The Register Committee further noted the lack of commitment in timely addressing the issues previously noted under ESG 3.3 and ESG 3.4 which impacts the overall effectiveness of the agency’s internal quality assurance arrangements.

20. In light of these concerns, the Register Committee could not follow the panel’s judgement of compliance and found that AKAST complies only partially with ESG 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal QA,
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“41. In its Change Report Decision (of 2022-11-25), the Register Committee considered the reported change on the newly established body, the Quality Council, and expressed concern with the current proposal of an open-ended regulation that would affect the operability and independence of the Quality Council.

42. While the panel was unable to address concerns with the current proposal of an open-ended regulation that would affect the operability and independence of the Quality Council, it noted that the PKA’s President maintains a supervisory role in the internal quality management system of the agency (by being responsible for supervision of the internal quality management system (IQMS) and in appointing a Quality Management System.

43. The Register Committee found that the current proposal for Quality Council (based on Statutes articles 11a & 15a) could have far reaching consequences, while also noting the organisational issues highlighted under ESG 3.3.

44. The Committee was also made aware of possible conflict of interest scenarios (1) where the Chairs of Section may participate in the discussion of the Presidium, even if they have been part of assessments they have previously prepared and (2) where the Chair of the Appeals Body may vote on resolutions adopted by the Presidium which may be later considered by the Appeals Body. The Register Committee found that this setup lacks the appropriate checks and balances and may affect the integrity of PKA’s activities. The Committee could not understand why PKA has not set up a system that would allow the recusal from the discussion or the possibility for restricting the participation (to no voting rights) of those that could be in a conflict of interest scenario.

45. In its additional representation, PKA informed that the responsibility for establishing the Quality Council will be with the Presidium and no longer solely with the President.

46. Furthermore, PKA committed to introduce provisions stipulating that members of the Presidium participating in programme evaluation procedures or preparing a review in the opinion-giving processes, shall be excluded from voting on those procedures.

47. In its additional representation, PKA clarified that the participation and voting rights of the Chair of the Appeals Body in the Presidium is based on the provisions of the Higher Education Act and PKA’s Statutes. PKA clarified that the Chair of the Appeals Body participates only in the part of the meetings where motions for reconsideration of assessment of opinions are discussed and votes only on this matter.

48. Furthermore, PKA clarified that the Chair of the Appeals Body does not take part in the proceeding assessments of opinions that may become object of applications for reconsideration, nor do they vote on such matters.

49. In the additional documentation (of 2024-03-28), PKA reported that the following statutory changes have been made: (a) The responsibility for establishing the Quality Council will be with the Presidium rather than solely with the President; (b) The members of the Presidium participating in the programme evaluation procedures or preparing a review in the opinion-giving processes, shall be excluded from voting on the decisions resulting from those procedures.

50. While the Register Committee welcomed the changes taken by PKA, it underlined that the issues outlined before remain to be addressed and subsequently to be considered and review by an external review panel in order to determine their implementation in practice.

51. The Register Committee therefore could not follow the review panel’s judgment of compliance and found that PKA complies only partially with ESG 3.6.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	12/12/2023
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality assurance (IQA) system not implemented
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“15. In its past decision the Register Committee found that the internal quality assurance (IQA) system had not been implemented at that time. In particular it found that the IQA had yet to prove its role in supporting the internal activity of its speciality commissions and in providing the agency with a sound basis for reviewing and improving the effectiveness with which it works.

16. The Register Committee noted from the detailed analysis of the review repot that ARACIS has set up a functional internal QA system including relevant documentation, structures and personnel. Having considered the evidence presented, the Committee can follow the panel’s conclusion that ARACIS now complies with the requirements of standard 3.6.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	14/03/2025
Standard	3.6 Internal quality assurance and professional conduct
Keywords	Internal QA not sufficiently systematised and formalised
Panel conclusion	Compliance
Clarification request(s)	Panel (01/10/2024)
RC decision	Compliance

“33. The Register Committee noted that ANVUR is in the process of expanding and implementing a diverse set of internal quality assurance processes. For the Committee, it was not clear how far has the agency reached in this process of developing their IQA system and, therefore, it sought further clarification from the panel.

34. The review panel explained that even though ANVUR conducts its internal QA procedures regularly and effectively, including collection, analysis and reaction to the feedback of its stakeholders, it is yet to develop a structured and systematic framework for its internal QA processes.

35. The Register Committee could therefore follow the panel’s conclusion that the agency complies with the standard. The Committee, however, emphasised the panel’s recommendation to ensure that internal quality assurance of ANVUR should be systematised and formalised, leading to a more coherent and consistent approach.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.6 Internal quality assurance and professional conduct
Keywords	internal quality asssurnace system
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“23. In its last decision, the Register Committee found the agency to be partially compliant due to the lack of development and proper implementation of its internal quality assurance system.

24. The Register Committee understood, from the panel analysis, that the agency has made a significant progress, by introducing a number of internal mechanisms, reviewing policies, procedures and guides. The panel noted that, however, the agency does not yet have a full internal quality assurance system in place, but intends to work on this in the coming period.

25. While the Register Committee welcomed the progress made by the agency. The Committee noted that, however, a well-rounded internal quality assurance system that synchronises the newly introduced tools is yet to be set. Therefore, the Register Committee could not follow the panel’s judgement and found the agency to be partially compliant with the standard.”

Full decision: see agency register entry