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Students in quality assurance – representatives, partners, or even experts?

by Jens Jungblut & Bjørn Stensaker

Throughout Europe, students are often regular members of external quality assurance mandated to perform evaluations and accreditations in higher education. While this role has been secured through the Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG), we have little knowledge about how students participate in such panels and which roles they take up. In a paper presented at the SRHE conference in Nottingham in December 2025, we addressed this issue – both conceptually and empirically.

One could imagine that there are several roles that students could play as part in an external quality assurance panel. Students are most often seen as representatives of their fellow students. This has implications as to how students are appointed to such panels, as various student interest organizations usually have the power to nominate specific students to the task. More recently, the idea of students being partners has also gained interest, where a key assumption is that students should be involved and participate in all aspect and processes related to their own education – including quality assurance. The initiative “student partnerships in quality Scotland (sparqs)” is a well-known example of this inclusive approach (Varwell, 2021). However, one could argue that students may even take on an expertise-based role in quality assurance. This type of role is not based on experience per se but rather the ability to reflect upon the knowledge possessed and the ability to engage in systematic efforts to learn more – based on these reflections (Ericsson, 2017).

In our paper presented at the SRHE conference we argue that the role of students participating in quality assurance panels (or any other related processes in higher education) may not be static, restricting students to merely one role at a time (see also Stensaker & Matear, 2024). We rather argue – in line with Holen et al (2021) – that the roles students may take on are highly dynamic. A consequence of this would be that students may shift rapidly from one role to another, depending on, for example, the evaluation context, committee setting, or the issue that is being discussed.

To test our assumptions, we conducted a survey targeting students taking part in European quality assurance processes; to be more specific, we targeted the `Quality Assurance Student Experts Pool` within the European Students’ Union. This group was established in 2009 with the aim to improve the contribution of students in quality assurance in Europe. When included in the pool, students undergo training sessions providing them with relevant background knowledge about quality assurance processes and the ESG. The members of the pool are then called upon by quality assurance agencies throughout Europe to act as student representatives on their quality assurance panels at program, institutional, or national level, performing evaluations, accreditations and other forms of assessments. The `Quality Assurance Student Experts Pool` therefore represents a unique entity in Europe, as it is the only European structure that collects and trains students for these roles. 35 students (of a total of 90) responded to our survey.

The students responding have on average been involved in quality assurance for more than four years, and over 60 percent have participated in four or more evaluation or accreditation processes. In line with our expectations, the students indeed report that they are taking on several roles during the evaluation processes, they are representatives of students, they feel they are equal partners within the evaluation panel they are part of, and they also see themselves as experts. In our data, we could not identify a clear hierarchy between the different roles. However, our data suggest that students are often perceived as a partner, while less often as experts. A possible interpretation here is that temporality and experience matter: students may be initially viewed as a representative and as a partner when starting their work within the panel, and through the process of participating in multiple panels over time they might demonstrate expertise which is in turn recognized by their peers in the panels. An interesting feature coming out of the data is also that the students in the `Quality Assurance Student Experts Pool` regularly share knowledge among the members of the pool, and in that way contribute to continuously build the expertise of all members. Expertise is in this way not taken for granted or expected as a prerequisite for being a member, but rather nurtured, systematised and made available to newer and future members.

We want to thank all the students that bothered to respond to our small questionnaire. While our study is exploratory, we do think it provides new insights regarding student involvement and influence in a setting characterized by a high level of expertise and professionalism, and we hope that the findings can help future research to further unpack the dynamic nature of students’ roles in quality assurance panels.

Jens Jungblut is a Professor at the Department of Political Science at the University of Oslo. His main research interests include party politics, policy-making, and public governance in the knowledge policy domain (education & research), organizational change in higher education, agenda-setting research, and the role of (academic) expertise in policy advice.

Bjørn Stensaker is a Professor at the Department of Education at the University of Oslo. He has a special research interest in governance, leadership, and organizational change in higher education – including quality assurance. He has published widely on these topics in a range of journals and book series.


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Risk-based quality regulation – drivers and dynamics in Australian higher education

by Joseph David Blacklock, Jeanette Baird and Bjørn Stensaker

Risk-based’ models for higher education quality regulation have been increasingly popular in higher education globally. At the same time there is limited knowledge of how risk-based regulation can be implemented effectively.

Australia’s Tertiary Education Quality and Standards Agency (TEQSA) started to implement risk-based regulation in 2011, aiming at an approach balancing regulatory necessity, risk and proportionate regulation. Our recent published study analyses TEQSA’s evolution between 2011 and 2024 to contribute to an emerging body of research on the practice of risk-based regulation in higher education.

The challenges of risk-based regulation

Risk-based approaches are seen as a way to create more effective and efficient regulation, targeting resources to the areas or institutions of greatest risk. However, it is widely acknowledged that sector-specificities, political economy and social context exert a significant influence on the practice of risk-based regulation (Black and Baldwin, 2010). Choices made by the regulator also affect its stakeholders and its perceived effectiveness – consider, for example, whose ideas about risk are privileged. Balancing the expectations of these stakeholders, along with their federal mandate, has required much in the way of compromise.

The evolution of TEQSA’s approaches

Our study uses a conceptual framework suggested by Hood et al (2001) for comparative analyses of regimes of risk regulation that charts aspects respectively of context and content. With this as a starting point we end up with two theoretical constructs of ‘hyper-regulation’ and ‘dynamic regulation’ as a way to analyse the development of TEQSA over time. These opposing concepts of regulatory approach represent both theoretical and empirical executions of the risk-based model within higher education.

From extensive document analysis, independent third-party analysis, and Delphi interviews, we identify three phases to TEQSA’s approach:

  • 2011-2013, marked by practices similar to ‘hyper-regulation’, including suspicion of institutions, burdensome requests for information and a perception that there was little ‘risk-based’ discrimination in use
  • 2014-2018, marked by the use of more indicators of ‘dynamic regulation’, including reduced evidence requirements for low-risk providers, sensitivity to the motivational postures of providers (Braithwaite et al. 1994), and more provider self-assurance
  • 2019-2024, marked by a broader approach to the identification of risks, greater attention to systemic risks, and more visible engagement with Federal Government policy, as well as the disruption of the pandemic.

Across these three periods, we map a series of contextual and content factors to chart those that have remained more constant and those that have varied more widely over time.

Of course, we do not suggest that TEQSA’s actions fit precisely into these timeframes, nor do we suggest that its actions have been guided by a wholly consistent regulatory philosophy in each phase. After the early and very visible adjustment of TEQSA’s approach, there has been an ongoing series of smaller changes, influenced also by the available resources, the views of successive TEQSA commissioners and the wider higher education landscape as a whole.

Lessons learned

Our analysis, building on ideas and perspectives from Hood, Rothstein and Baldwin offers a comparatively simple yet informative taxonomy for future empirical research.

TEQSA’s start-up phase, in which a hyper-regulatory approach was used, can be linked to a contextual need of the Federal Government at the time to support Australia’s international education industry, leading to the rather dominant judicial framing of its role. However, TEQSA’s initial regulatory stance failed to take account of the largely compliant regulatory posture of the universities that enrol around 90% of higher education students in Australia, and of the strength of this interest group. The new agency was understandably nervous about Government perceptions of its performance, however, a broader initial charting of stakeholder risk perspectives could have provided better guardrails. Similarly, a wider questioning of the sources of risk in TEQSA’s first and second phases could have highlighted more systemic risks.

A further lesson for new risk-based regulators is to ensure that the regulator itself has a strong understanding of risks in the sector, to guide its analyses, and can readily obtain the data to generate robust risk assessments.

Our study illustrates that risk-based regulation in practice is as negotiable as any other regulatory instrument. The ebb and flow of TEQSA’s engagement with the Federal Government and other stakeholders provides the context. As predicted by various authors, constant vigilance and regular recalibration are needed by the regulator as the external risk landscape changes and the wider interests of government and stakeholders dictate. The extent to which there is political tolerance for any ‘failure’ of a risk-based regulator is often unstated and always variable.

Joseph David Blacklock is a graduate of the University of Oslo’s Master’s of Higher Education degree, with a special interest in risk-based regulation and government instruments for managing quality within higher education.

Jeanette Baird consults on tertiary education quality assurance and strategy in Australia and internationally. She is Adjunct Professor of Higher Education at Divine Word University in Papua New Guinea and an Honorary Senior Fellow of the Centre for the Study of Higher Education at the University of Melbourne.

Bjørn Stensaker is a professor of higher education at University of Oslo, specializing in studies of policy, reform and change in higher education. He has published widely on these issues in a range of academic journals and other outlets.

This blog is based on our article in Policy Reviews in Higher Education (online 29 April 2025):

Blacklock, JD, Baird, J & Stensaker, B (2025) ‘Evolutionary stages in risk-based quality regulation in Australian higher education 2011–2024’ Policy Reviews in Higher Education, 1–23.


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Mind the policy gaps: regulating quality and ethics in digitalised and privatised crossborder education

by Hans de Wit, Tessa DeLaquil, Ellen Hazelkorn and Hamish Coates

Hans de Wit, Ellen Hazelkorn and Hamish Coates are editors and Tessa DeLaquil is associate editor of Policy Reviews in Higher Education. This blog is based on their editorial for issue 1, 2025.

Transnational education (TNE), also referred to as crossborder education, is growing and morphing in all kinds of interesting ways which, while exciting for innovators, surface important policy, regulatory, quality and ethical concerns. It is therefore vital that these developments do not slip around or through policy gaps. This is especially true for on-line TNE which is less visible than traditional campus-based higher education. Thus, it is vital that governments take the necessary actions to regulate and quality assure such education and training expansion and to inform the sector and broader public. Correspondingly, there is a pressing need for more policy research into the massive transformations shaking global higher education.

TNE and its online variants have been part of international higher education for a few decades. As Coates, Xie, and Hong (2020) foreshadowed, it has seen a rapid increase after the Covid-19 pandemic. In recent years, TNE operations have grown and diversified substantially. Wilkins and Huisman (2025) identify eleven types of TNE providers and propose the following definition to help handle this diversity: ‘Transnational education is a form of education that borrows or transfers elements of one country’s higher education, as well as that country’s culture and values, to another country.’

International collaboration and networking have never been more important than at this time of geopolitical and geoeconomic disruption and a decline in multilateral mechanisms. But TNE’s expansion is matched by growing risks.

International student mobility at risk

International degree student mobility (when students pursue a bachelor, master and/or doctoral degree abroad) continues to be dominant, with over six million students studying abroad, double the number of 10 years ago. It is anticipated that this number will further increase in the coming decade to over 8 million, but its growth is decreasing, and its geographical path from the ‘global south’ to the ‘global north’ is shifting towards a more diverse direction. Geopolitical and nationalist forces as well as concerns about adequate academic services (accommodation in particular) in high-income countries in the global north are recent factors in the slowing down of the growth in student mobility to Australia, North America and Europe, the leading destinations. The increased availability and quality of higher education, primarily at the undergraduate level, in middle-income countries in Asia, Latin America and parts of the Middle East, also shape the decrease in student mobility towards the global north.

Several ‘sending countries’, for instance, China, South Korea and Turkey, are also becoming receiving countries. Countries like Kazakhstan, Uzbekistan, Ukraine (until the Russian invasion), Egypt and some of the Caribbean countries have also become study destinations for students from neighbouring low-income countries. These countries provide them with higher education and other forms of postsecondary education sometimes in their public sector but mostly in private institutions and by foreign providers.

An alternative TNE model?

Given the increased competition for international students and the resulting risks of falling numbers and related financial security for universities, TNE has emerged as an alternative source of revenue. According to Ilieva and Tsiligiris (2023), United Kingdom TNE topped more than 530,000 students in 2021. In the same year, its higher education institutions attracted approximately 680,000 international students. It is likely that TNE will surpass inward student mobility.

 As the United Kingdom case makes clear, TNE originally was primarily a ‘north-south’ phenomenon, in which universities from high-income and mostly Anglophone countries, offered degree programmes through branch campuses, franchise operations and articulation programmes. Asia was the recipient region of most TNE arrangements, followed by the Middle East. As in student mobility, TNE is more diverse globally both in provision and in reception.

The big trend in TNE is the shift to online education with limited in-person teaching. A (2024) report of Studyportals found over 15,000 English-taught online programmes globally. And although 92 per cent of these programmes are supplied by the four big Anglophone countries – the United Kingdom, United States, Canada and Australia – the number of programmes offered outside those four doubled since 2019 from 623–1212, primarily in Business and Management, Computer Sciences and IT.

Private higher education institutions

This global growth in online delivery of education goes hand in hand with the growth in various forms of private higher education. Over 50% of the institutions of higher education and over one-third of global enrolment are in private institutions, many of which are commercial in nature. Private higher education has become the dominant growth area in higher education, as a result of the lack of funding for public higher education as well as traditional HE’s sluggish response to diverse learner needs. Although most private higher education, in particular for-profit, is taking place in the global south, it is also present in high-income countries, and one can see a rise in private higher education recently in Western Europe, for instance, Germany and France.

TNE is often a commercial activity. It is increasingly a way for public universities to support international and other operations as public funding wanes. Most for-profit private higher education targets particular fields and education services and tends to be more online than in person. There is an array of ownership and institutional structures, involving a range of players.

Establishing regulations and standards

TNE, especially online TNE, is likely to become the major form of international delivery of education for local and international students especially where growing demand cannot be met domestically. Growth is also increasingly motivated by an institution’s or country’s financial challenges or strategic priorities – situations that are likely to intensify. This shift could help overcome some of the inequities associated with mobility and address concerns associated with climate change but online TNE is significantly more difficult to regulate.

A concerning feature of the global TNE market is how learners and countries can easily become victims. Fraud is associated with the exponential rise in the number of fake colleges and accreditors, and document falsification. This is partly due to different conceptions and regulatory approaches to accreditation/QA of TNE and the absence of trustworthy information. Indeed, the deficiency in comprehensive and accessible information is partly responsible for on-going interest in and use of global rankings as a proxy for quality.

A need for clearer and stronger TNE and online quality assurance

The trend in growth of private for-profit higher education, TNE and online delivery is clear and given its growing presence requires more policy attention by national, regional and global agencies. As mentioned, public universities are increasingly active in TNE and online education targeting countries and learners underserved in their home countries whilst  looking for other sources of income as a result of decreasing public support and other factors.

The Global Convention on the Recognition of Qualifications makes clear the importance of ensuring there are no differences in quality or standards between learners in the home or host country regardless of whether the delivery of education programmes and learning activities is undertaken in a formal, non-formal or informal setting, in face-to-face, virtual or hybrid formats, traditional or non-traditional modes. Accordingly, there are growing concerns about insufficient regulation and the multilateral framework covering international education, and especially online TNE.

In response, there is a need for clearer and stronger accreditation/quality assurance and standards by national regulators, regional networks and organisations such as UNESCO, INQAAHE, the International Association of Universities (IAU) with regards to public and private involvement in TNE, and online education. This is an emerging frontier for tertiary education, and much more research is required on this growing phenomenon.

Professor Ellen Hazelkorn is Joint Managing Partner, BH Associates. She is Professor Emeritus, Technological University Dublin.

Hamish Coates is professor of public policy, director of the Higher Education Futures Lab, and global tertiary education expert.

Hans de Wit is Professor Emeritus and Distinguished Fellow of the Boston College Center for International Higher Education, Senior Fellow of the international Association of Universities.

Tessa DeLaquil is postdoctoral research fellow at the School of Education at University College Dublin.


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More roadworks on Quality Street

by Paul Temple

Trust is the magic ingredient that allows social life to exist, from the smallest informal group to entire nations. High-trust societies tend to be more efficient, as it can be assumed that people will, by and large, do what they’ve agreed without the need for constant checking. Ipsos-MORI carries out an annual “veracity index” survey in Britain to discover which occupational groups are most trusted: “professors”, which I think we can take to mean university academic staff, score highly (trusted by 83% of the population), just below top-scoring doctors and judges, way above civil servants (60%) – and with government ministers playing in a different league on 16%. So most people, then, seem to trust university staff to do a decent job – much more than they trust ministers. It’s therefore a little strange that over the last 35 years the bitterest struggles between universities and governments have been fought in the “quality wars”, with governments claiming repeatedly that university teachers can’t be trusted to do their jobs without state oversight. Disputes about university expansion and funding come and go, but the quality wars just rumble on. Why?

From the mid-1980s (when “quality” was invented) up to the appearance of the 2011 White Paper, Higher Education: Students at the Heart of the System, quality in higher education was (after a series of changes to structures and methods) regulated by the Quality Assurance Agency, which required universities to show that they operated effective quality management processes. This did not involve the inspection of actual teaching: universities were instead trusted to give an honest, verifiable, account of their own quality processes. Without becoming too dewy-eyed about it, the process came down to one group of professionals asking another group of professionals how they did their jobs. Trust was the basis of it all.

The 2011 White Paper intended to sweep this away, replacing woolly notions of trust-based processes with a bracing market-driven discipline. The government promised to “[put] financial power into the hands of learners [to make] student choice meaningful…[it will] remove regulatory barriers [to new entrants to the sector to] improve student choice…[leading to] higher education institutions concentrating on high-quality teaching” (Executive Summary, paras 6-9). On this model, decisions by individual students would largely determine institutional income from teaching, so producing better-quality courses: trust didn’t matter. Market forces can be seen to drive forward quality in other fields through competition, why not in universities?

Well, of course, for lots of reasons, as critics of the White Paper were quick to point out, naturally to no avail. But having been told that they were to operate in a marketised environment where the usual market mechanisms would deal with quality (good courses expanding, others shrinking or failing), exactly a decade later universities find themselves being subjected to a bureaucratic (I intend the word in its social scientific sense, not as a lazy insult) quality regime, the very antithesis of a market system.

We see this in the latest offensive in the quality wars, just opened by the OFS with its July 2021 “Consultation on Quality and Standards”. This 110-page second-round consultation document sets out a highly-detailed process for assessing quality and standards: you can almost feel the pain of the drafter of section B1 on providing “a high quality academic experience”. What does that mean? It means, for example, ensuring that each course is “coherent”. So what does “coherent” mean? Well, it means, for example, providing “an appropriate balance between breadth and depth”. So what does…? And so on. This illustrates the difficulty of considering academic quality as an ISO 9001 (remember that?) process with check-lists, when probably every member of a course team will – actually, in a university, should – have different, equally valid, views on what (say) “appropriate breadth and depth” means.

Government approaches to quality and standards in university teaching have, then, over the last 30 or so years, moved from a largely trust-based system, to one supposedly driven by market forces, to a bureaucratic, box-ticking one. In all this time, ministers have failed to give convincing examples of the problems that the ever-changing quality regimes were supposed to deal with. (Degree mills and similar essentially fraudulent operations can be dealt with through normal consumer legislation, given the will to do so. I once interviewed an applicant for one of our courses who had worked in a college I hadn’t heard of: had there been any problems about its academic standards, I asked. “Not really”, she replied brightly, “it was a genuine bogus college”.)

Why, then, do the quality wars continue? – and we can be confident that the current OFS proposals do not signal the end of hostilities. It is hard to see this as anything other than ministerial displacement activity. Sorting out the social care crisis, or knife crime, will take real understanding and the redirection of resources: easier by far to make a fuss about a non-problem and then be seen to act decisively to solve it. And to erode trust in higher education a little more.

Dr Paul Temple is Honorary Associate Professor in the Centre for Higher Education Studies, UCL Institute of Education, London. His latest paper, ‘The University Couloir: exploring physical and intellectual connectivity’, will appear shortly in Higher Education Policy.


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Examining the Examiner: Investigating the assessment literacy of external examiners

By Dr Emma Medland

Quality assurance in higher education has become increasingly dominant worldwide, but has recently been subject to mounting criticism. Research has highlighted challenges to comparability of academic standards and regulatory frameworks. The external examining system is a form of professional self-regulation involving an independent peer reviewer from another HE institution, whose role is to provide quality assurance in relation to identified modules/programmes/qualifications etc. This system has been a distinctive feature of UK higher education for nearly 200 years and is considered best practice internationally, being evident in various forms across the world.

External examiners are perceived as a vital means of maintaining comparable standards across higher education and yet this comparability is being questioned. Despite high esteem for the external examiner system, growing criticisms have resulted in a cautious downgrading of the role. One critique focuses on developing standardised procedures that emphasise consistency and equivalency in an attempt to uphold standards, arguably to the neglect of an examination of the quality of the underlying practice. Bloxham and Price (2015) identify unchallenged assumptions underpinning the external examiner system and ask: ‘What confidence can we have that the average external examiner has the “assessment literacy” to be aware of the complex influences on their standards and judgement processes?’ (Bloxham and Price 2015: 206). This echoes an earlier point raised by Cuthbert (2003), who identifies the importance of both subject and assessment expertise in relation to the role.

The concept of assessment literacy is in its infancy in higher education, but is becoming accepted into the vernacular of the sector as more research emerges. In compulsory education the concept has been investigated since the 1990s; it is often dichotomised into assessment literacy or illiteracy and described as a concept frequently used but less well understood. Both sectors describe assessment literacy as a necessity or duty for educators and examiners alike, yet both sectors present evidence of, or assume, low levels of assessment literacy. As a result, it is argued that developing greater levels of assessment literacy across the HE sector could help reverse the deterioration of confidence in academic standards.

Numerous attempts have been made to delineate the concept of assessment literacy within HE, focusing for example on the rules, language, standards, and knowledge, skills and attributes surrounding assessment. However, assessment literacy has also been described as Continue reading

Vicky Gunn


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Learning Analytics, surveillance, and the future of understanding our students

By Vicky Gunn

There has been a flurry of activity around Learning Analytics in Scotland’s higher education sector this past year. Responding no doubt to the seemingly unlimited promises of being able to study our students, we are excitedly wondering just how best to use what the technology has to offer. At Edinburgh University, a professorial level post has been advertised; at my own institution we are pulling together the various people who run our student experience surveys (who have hitherto been distributed across the institution) into a central unit in Planning so that we can triangulate surveys, evaluations and other contextual data-sets; elsewhere systems which enable ‘early warning signals’ with regards to student drop-out have been implemented with gusto.

I am one of the worst of the learning analytics’ offenders.  My curiosity to observe and understand the patterns in activity, behaviour, and perception of the students is just too intellectually compelling. The possibility that we could crunch all of the data about our students into one big stew-pot and then extract answers to meaning-of-student-life questions is a temptation I find too hard to resist (especially when someone puts what is called a ‘dashboard’ in front of me and says, ‘look what happens if we interrogate the data this way’). Continue reading