This papers explores the ways in which accreditation is integral to the realization of the European Higher Education Area and thus denotes a mobilizing technology imbedded in the Open Method of Coordination, a soft mode of governance practiced by the EU and the Bologna Process.

Taking inspiration in the instrumentation approach to policy studies (Brøgger, 2018; Lascoumes & Gales, 2007; Salamon, 2011) we argue that accreditation has become the dominant method of higher education evaluation throughout Europe. Accreditation is an external quality assurance and has been systematically imported in Europe during the past 20 years as part of establishing a European Higher Education Area through the Bologna Process (Brøgger, 2019; Saarinen & Ala-Vähälä, 2007). On one hand, it must be seen as a national effort to deregulate the public sector making the universities accountable for their performances and on the other hand as a supranational (or perhaps even federal) endeavor to accomplish European integration of higher education systems (Serrano-Velarde, 2014). Meanwhile, accreditation is not apolitical, not neutral or benign. It is a system that in many ways shift the powers from educators to administrators (Engebretsen et al, 2012; Harvey, 2004). Even though part of the initial ambition with regard to public accreditation was the control of the emergence of ‘for profit’ higher education providers (Stensaker, 2011), it still seems unclear whether it represents market or government regulation (Gornitzka & Stensaker, 2014; Hall, 2012). These considerations call for thorough investigations of the following research questions: In which ways may accreditation be seen as part of the governing technologies of the Open Method of Coordination practiced by the EU and the Bologna Process? Is the European Higher Education Area at risk of being entrusted to an emerging accreditation market?

Through the instrumentation approach, we investigate the emergence of an accreditation market by exploring the role of the European Association for Quality Assurance in Higher Education (ENQA) and the European Quality Assurance Register (EQAR) through a comparative study between Denmark and Norway. In particular we draw attention to the implementation of the European Standards and Guidelines (ESG, 2015) in national legislation and the degree to which Denmark and Norway recognizes EQAR-registered foreign agencies as part of their respective national accreditation procedures (Kalpazidou Schmidt, 2017). Moreover, the paper also explores how the ESGs are implemented and played out in accreditation reports presenting accreditation of businness schools within the two countries.

Already during the first years of the Bologna Process the national ministers agreed that Europe was in need of a more systematic approach to quality assurance (EHEA-ministers, 2003). At the same time, the ministers called upon the European Association for Quality Assurance in Higher Education (ENQA) to develop an agreed set of standards, procedures and guidelines on quality assurance. This resulted in the first version of European Standards and Guidelines (ESG) in 2005. At the Bucharest meeting in 2012, a revision of the ESG 2005 was approved (EHEA-ministers, 2012). Moreover, at the 2005 meeting, the ministers also welcomed another major initiative, a European register of quality assurance agencies. This proposal was subsequently approved at the London ministerial meeting in 2007 (EHEA-ministers, 2007). The so-called E4 group (ENQA, EURASHE, ESU and EUA) founded the European Quality Assurance Register (EQAR) in 2008. Furthermore, at the last Bologna meeting (2018) the ministers committed themselves to the promotion of a Database of External Quality Assurance Results (DEQAR) (EHEA-ministers, 2018). The work on this database is coordinated by EQAR and aims to enhance access to reports and decisions on higher education institutions/programs externally reviewed against the ESG, by an EQAR-registered agency.

Due to the subsidiarity principle education is not mandated by the EU as part of the competency of the union. This means that the EU influence education through the coordination of intergovernmental reform processes such as the Bologna Process through soft modes of governance such as the OMC. Following the instrumentation approach allows us to address aspects of the policy processes that otherwise remain invisible. It allows us to analyze how soft modes of governance is being operationalized through mobilizing technologies such as accreditation procedures incentivizing nation states to coopt themselves into the shared goals as in the case of the Bologna Process. Policy instruments are never neutral devices in the sense that they always produce specific effects and seem to bring about certain kinds of social and professional control. In this paper we explore accreditation as a governing technology and whether ENQA and EQAR should be interpreted as a step towards realizing a European ‘market’ for external quality assurance, in which nation states and higher education institutions are free to choose a quality assurance provider from their own country or another European country offering EQAR-registered agencies. In the paper, we investigate our research questions by analyzing policy documents on a transnational, national and institutional level. Firstly, we explore the transnational level of the Bologna process through core documents relating to ENQA, the EQAR Register, EQUIP (a project aiming to promote a consistent, efficient and innovative embedding of the ESG 2015), and Bologna follow-up meetings centering on the Communiqués and implementation reports between 2012 and 2018. Secondly, making use of a comparative case study including Denmark and Norway, we analyze country specific ENQA and EQAR reports on the accreditation and EQAR-registration of the Danish and Norwegian national accreditation agencies as well as national legislations in Norway and Denmark with regard to how accreditations procedures have been implemented and interpreted in new national regulations. Thirdly, in order to examine the implementation of ESG at institutional level, we also investigate examples of institutional accreditation in the case of Denmark and Norway using accreditation reports on business schools as an example.

The instrumentation approach enables an analytic attention towards the power of policy instruments. Examining not only institutional accreditation procedures but also the complex policy processes surrounding them, including the role of major transnational agencies such as ENQA points towards accreditation as a main governance technology ensuring not merely national deregulation but also a successful implementation of the Bologna goals. The increased systematization and standardization of this regulative work of establishing common procedures across countries in many ways seem to restrict the leeway of nations as well as institutions in choosing their own procedures. Meanwhile, the accreditation procedures of ENQA also seem to enable the emergence of an accreditation market materializing through the EQAR register. The market does not yet seem to have been fully realized but already many countries are allowed to include foreign agencies in domestic accreditation procedures. Present legal adjustments and political ambitions of public deregulation supports the claim that an accreditation market may very well be the future scenario. However, in a European context, this emergence of an accreditation market that inevitably involves the possible outsourcing of quality assurance in European higher education, seem not to emerge as a classic private sector involvement. Rather it seems that European accreditation has introduced a new quasi state-driven soft privatization of quality assurance that seems to be imbedded in the governing modes of the Bologna Process (Cone & Brøgger forthcoming).

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