Substantive Change Reports

Rationale

Registered agencies are required to report any substantive changes to EQAR:

6.1 A registered agency shall notify EQAR of its own accord about changes to its legal form and status, amendments to its statutes and substantial changes in its process or methodology.

6.2 The Register Committee shall consider whether these changes warrant an extraordinary revision of registration.

The objective of such reports is that EQAR becomes aware of situations were an agency's current practice differs substantially from the situation when it was reviewed against the ESG and admitted to the Register. Extensive information on reporting changes has been made available to registered agencies in the Guide for Applicants and Registered Agencies, so as to assist them in preparing a Substantive Change Report.

Process

EQAR staff: on Trello board, use template checklist Substantive Change Report

Substantive Change Reports are dealt with as follows:

  1. The Secretariat acknowledges receipt and screens the report.

  2. If the changes are minor and it is straight-forward that they only need to be taken note of, skip to step 5 directly.

    Otherwise, the Secretariat appoints two rapporteurs, with preference the same Committee members as for the agency's application.

  3. Rapporteurs review the report and request further clarification or information from the agency, if necessary.

  4. Rapporteurs make a recommendation to the Committee.

  5. The Register Committee considers the report, usually by email.

Templates for EQAR staff (all filled from Substantive Change Reports table):

  • EQAR_DOC/Official documents/Applications/Templates internal/TEMP_SubstantiveChanges_Analysis.odt
  • EQAR_DOC/Official documents/Applications/Templates external/TEMP_ChangeReport_RapporteurRequest.odt

Possible Outcomes

The Committee takes one of the following conclusions:

  • Take note without any action

    This is the default, unless another action is warranted.

  • Take note and request further report

    If there are specific issues that need to be resolved to ensure ESG compliance, but it would not be justified to ask for a new external review. In exceptional cases, also a focused review could be requested.

  • Initiate an Extraordinary Revision of Registration (see below), with a view to:

    • reducing the remaining validity of registration;
    • excluding the agency from the register; or
    • declaring its registration void ab initio.

The Committee normally simply takes note of the report, unless the change reported calls into question whether the agency continues to substantially comply with the ESG.

All Substantive Change Reports and any additional information obtained, where applicable, are published together with the Register Committee's decision.

Template for EQAR staff (filled from Substantive Change Reports table):

  • EQAR_DOC/Official documents/Applications/Templates external/TEMP_ChangeReport_Decision.odt

Mergers of Registered Agencies

Mergers of registered agencies are a specific case of a Substantive Change, and the Merger Policy (RC8/06.1, adopted 2012) addresses this case.

Provided that all agencies involved in a merger are already registered (or their registration expired not more than 6 months ago), the Committee may provisionally maintain registration of the new, merged agency. “Agencies” here refers to any entity or organisational unit that conducts external evaluation, accreditation or audit of higher education institutions or programmes, and thus could potentially be registered on EQAR.

Provisional Registration

Provisional registration is only granted if it can reasonably be established that the analysis and conclusions evidencing the predecessor agencies' compliance with the ESG (set out in the respective reports on the external reviews of the old agencies) remain by and large valid also for the new, merged agency. This is based on information provided by the agency.

The new, merged agency will have to undergo an external review against the ESG at its earliest convenience and within two years at the latest. If the earliest expiry date of the predecessor agencies' registrations is later, registration will usually be limited to 24 months counted from the date of the merger. If the earliest expiry date of the predecessor agencies' registrations is earlier, registration may exceptionally be prolonged to up to 24 months counted from the date of the merger.