I would like to use this powerful set of images to raise the following idea: the legal frameworks of the state regulating accreditation of degrees and centres are the crouching dragon of the EHEA quality map. At first glance, they are not even there, or are in the dark (you just have to see how, of all the assessments we European agencies submit ourselves to, only the ESG are in the spotlight!); and yet, like the fine rain in Leonardo’s landscapes, they drench descriptions and analyses, soaking into the bones of our assessments. They work like Walcott’s crouching dragon, and ENQA clearly has some idea of this when it relentlessly recommends the adoption of friendly and flexible legal frameworks to EHEA ministers. The colour map we use to show progress in ESG compliance is both an underlying anatomy of veins and flaking regulations.
Let’s take Royal Decree 822/2021 as an example. In both its explanatory memorandum and its operative part, the regulation uses the language of innovation, or even rupture with the previous regulatory tradition: “societies in permanent mutation”, “mutation of teachings”, “digitalisation”, “community trust”, “flexibility”, “transformation of forms of learning”, and so on. These approaches and objectives are also reflected in the creation of advanced or even unprecedented legal figures: specific curricular structures, dual mention, open academic pathways, lifelong learning, micro-credentials, reformulation of learning outcomes, incorporation of the European Approach, etc. These positive additions of new material are doubled or enriched in terms of quality by what the regulation calls “procedural rethinking”, “simplification of administrative processes and necessary documentation” or “focus on the core of the formative academic project”.
This dual device is truly commendable: the dragon contemplates new realities and as a logical consequence is endowed with a faster and more agile nervous system.
However, here we believe that there is a degree of underlying danger, or rather a problem of application, of development, which again the poem helps us to enunciate: in the can leaning against the wall, the light of European culture detects Chardin or the beer-coloured glow of Vermeer; but perhaps it is a greater gift to see things as they are: “No art. Only the gift / To see things as they are, halved by a darkness / From which they cannot shift”.
In our opinion, the gift of seeing things as they are is particularly evident in the second set of key ideas, those that refer to and regulate the simplification of procedures and the resulting amendment of quality protocols. The mechanisms to achieve this simplification envisaged by the legislator are basically twofold: firstly, including the concept of institutional accreditation, regulated by another Royal Decree (640/2021), which allows the simplest processes to truly reside in the accredited centres; and, secondly, by resorting to the speedy instrument of shortening deadlines. Both mechanisms are logical and can be effective. However, with things being the way they are and split by a darkness from which it is difficult to escape (at least if we listen to Walcott), we believe that the success of these measures for reconnecting with institutional accreditation and shortening administrative deadlines will depend largely on the system’s ability to both implement an advanced model of institutional re-accreditation and energise, or at least arouse, the sympathy of our bureaucracy.
It goes without saying that the aforementioned expression “system capacity” calls on the quality agencies (in terms of competencies, technical imagination and benchmarking).
In this respect, we consider it especially important that they hold a dynamic vision of the state quality map at this time (understanding, for instance, that the protocols for implementing Royal Decree 822/2021 are not only updated or improved versions of pre-existing protocols and therefore tributary to Royal Decree 1393/2007, but include criteria directed towards an education in mutation and applicable to teachings or centres with a long history of quality). The times require agencies to be clear-sighted, i.e. the condition needed to move forward in a balanced way: “The light creates its stillness”.