Technical guide to Foreign Awarded Programmes: quality assurance, authorisation and monitoring for education providers, awarding bodies and operators in the sector

The Malta Further and Higher Education Authority has launched a consultation on a new Policy for the quality assurance, authorisation and monitoring of Foreign Awarded Programmes offered in Malta. The proposal introduces four Quality Assurance Pathways and new documentary and operational requirements for local providers and foreign awarding bodies.

Foreign Awarded Programmes are meant, in this context, as programmes delivered in Malta whose final title or award is conferred by a foreign body, including through franchises, partnerships, collaborative provisions or branch campuses.

The proposal covers programmes delivered, in whole or in part, in Malta when the award is conferred by a foreign body. It includes franchises, partnerships, collaborative provisions, branch campuses and other forms of transnational education, without distinction by level or mode of delivery.

The consultation on Foreign Awarded Programmes may therefore involve Higher Education institutions, licensed local institutions, approved centres, providers introducing foreign qualifications, awarding bodies and, depending on the final interpretation, also awards and micro-credentials.

With this policy, the MFHEA aims to create a transparent, proportionate and risk-based system, which enhances reliable external quality assurance and avoids duplication, a central aspect in the Maltese education market.

Foreign Awarded Programmes: the four quality assurance pathways

The core of the proposal is the creation of four Quality Assurance Pathways. The rationale is to scale the level of MFHEA intervention according to the quality and coverage of the external quality assurance already applied to the programme.

What a provider should check now

The provider does not have to independently assign a pathway, a decision reserved to the MFHEA, but verify that the dossier contains the evidence necessary for the reliance assessment.

In operational terms, the provider should be able to document at least:

• status and powers of the awarding body and recognition of the QA body;
• program, scope, validity, conditions and possibilities of international delivery;
• coverage of the review on partners, location and delivery methods in Malta;
• agreements, responsibilities and local capacity on staff, assessment, resources, support, IQA and student protection.

The role of the awarding body becomes central

The proposal gives the awarding body ultimate responsibility for the academic standards of the programme. Areas include programme design, learning outcomes, mode of delivery, assessment framework, moderation, academic oversight, certification and qualification.

An approval letter or a generic agreement may not be enough. The documents must clarify approval of the program and faculty, management of assessments and moderation, information flows, monitoring of complaints and results, and procedures in case of criticality.

The awarding body will therefore also have to be available to participate in the Maltese regulatory process and provide evidence. A commercial collaboration that does not include this availability can become a weak point in the authorisation or monitoring phase.

The presence of a foreign awarding body does not transfer responsibility for actual delivery to Malta abroad. The Policy assigns responsibility to the licensed local institution for staffing, learning resources, student support, assessment administration, local quality assurance and student protection.

The provider must demonstrate operational capacity and an effective IQA system: it is not a simple intermediary, but remains responsible for local governance, delivery, student management and corrective actions.

External quality assurance: it is not enough to prove that it exists

The MFHEA will assess not only the existence of an EQA accreditation or report, but also the quality, scope and applicability of the process to the Maltese delivery specification.

A distinction must be made between accreditation of the awarding body, the programme, the programme reviews and a review that also includes partners or the Maltese office: non-equivalent situations, which may lead to different pathways.

The dossier should include official decision and report, conditions, deadline, methodology and scope; a link to the registry or a certificate may not demonstrate verification of the program and local delivery.

Pathway 2: the point to follow with particular attention

Pathway 2 may allow authorisation without a separate MFHEA programme EQA audit when the Maltese programme and delivery are already covered by recognised external QA.

However, an MFHEA audit remains envisaged, for which the draft does not yet specify documents, panels, visits, times and costs. This is a decisive point to avoid substantial duplication of the external audit.

It is therefore prudent for providers not to assume, at this stage, that the presence of external QA automatically involves a shortened process. It will be necessary to verify the final version of the Policy and the related application procedures.

Distinction between Higher and Further Education and online and blended provision

The Policy is applicable to all levels, but for Pathways 3 and 4 it refers to Higher Education standards: clarification is therefore needed for MQF 1–4 programs and related awards.

Further Education practitioners should therefore closely follow the outcome of the consultation. Prior to final adoption, it would be useful for the MFHEA to explicitly indicate which framework will be applied to Foreign Awarded Programmes that are not part of Higher Education.

The new Policy applies to Foreign Awarded Programmes regardless of the mode of delivery. This does not mean that awarding to one of the four pathways replaces the MFHEA requirements already applicable to online or blended learning.

For Higher Education, the Policy must be coordinated with the Regulations for Quality Assurance: Higher Education Online Learning 2025 and, where relevant, with Communication MFHEA 04/2026 on fully online provision.

For an online program, the validity and QA of the foreign award, digital delivery rules and compliance of the Maltese provider’s operating model must be checked separately. The QA of the awarding body does not replace local responsibilities.

Material changes: an internal control system will be required

The proposal gives importance to material changes, i.e. changes capable of affecting academic standards, programme content, student protection, governance or quality assurance. Communications to the MFHEA are also envisaged and, for some changes, a prior approval.

Pending final criteria, providers can adopt a change-control register and verify, before any significant change, compatibility with the awarding body, impact on external QA and obligations towards the MFHEA.

This step is particularly relevant in collaborative programmes, where an apparently operational change can simultaneously affect the contract with the awarding body, foreign accreditation and Maltese authorisation.

Student protection and public information

The Policy dedicates specific space to the protection of students. The student agreement should clearly indicate awarding body, licensed local institution, program, quality assurance arrangements, any professional recognition, complaints and appeals procedures and possible limitations or conditions.

Websites, brochures, advertisements and documents for students must correctly indicate awarding body, program, status and QA arrangements, in accordance with agreements and application forms.

A prior review avoids presenting as “MFHEA accredited” a program based instead on recognized foreign accreditation or other authorization mechanism.

Monitoring: Authorization does not close the process

The proposal configures quality assurance as an ongoing process. The MFHEA may request reporting, inspections, physical or virtual spot checks, thematic reviews, engagement with students and staff, and additional QA-related evidence.

The authorization dossier should become part of routine compliance, with updated evidence on enrolment, results, staffing, complaints, QA and changes.

The expiration of external QA may result in reassessment, conditions, recruitment limits, suspension or withdrawal of authorization.

The main areas requiring clarification in the proposal

The MQE analysis identifies some points to be clarified before adoption, so that the system is predictable, proportionate to the risk and consistent with the current framework.

Policy Scope and Further Education

For MQF 1–4 programs, the applicable standard must be expressly indicated, avoiding the improper use of a framework designed for Higher Education.

Definition of Foreign Awarded Programme and branch campuses

The inclusion of branch campuses contrasts with a definition that assumes distinct legal entities; the text should eliminate the inconsistency.

Nature of authorisation

The basis, effect and registration of the “authorisation” must be clarified, as well as the relationship with the licence, programme accreditation, approval of foreign accreditation and Regulation 43(4) of S.L. 607.03.

External QA Reliance and EQAR’s Role

Comparability should be based on the substantial equivalence of QA, also clarifying the weight of EQAR status and avoiding mere methodological differences preventing reliance.

Access to Pathway 1

Access to Pathway 1 should depend not only on MFHEA institutional agreements, but also on objective and published criteria related to program, provider and risk.

Pathway 2 and possible duplication

Pathway 2 verification should be documentary and targeted, with escalation only in the presence of specific risks, so as not to replicate an already recognised external audit.

Criteria for the assignment of pathways

A public Reliance Assessment Matrix should translate concepts such as robustness, track record and significant concerns into consistently applicable indicators.

Time and costs of the procedure

Service standards and fees are needed for each pathway, because duration and costs affect intakes, personnel, locations, contracts and investments.

Material changes

It must be distinguished in advance which material changes require prior approval, prior notification or ex post communication, coordinating this distinction with the term of ten working days.

Complaints, representations and appeals

The framework should indicate how to challenge assignments, reassignments, conditions and other decisions, connecting to the MFHEA appeal mechanisms already in place.

Transitional provisions

The transitional period, still indicated with a placeholder, must be defined to protect authorized programs, ongoing cohorts and adaptation of QA agreements and systems.

Coordination with existing MFHEA tools

The Policy must be formally coordinated with Programme Accreditation Standards, EQA frameworks and rules on online learning, avoiding competing interpretations.

Why these gaps impact the market

Uncertainty about criteria, timeframes, costs and reliance makes it difficult to assess market entry and can increase compliance without a corresponding assurance benefit.

The control must protect students and academic standards, but remain proportionate to the risk and consider the checks already carried out by reliable bodies, with public and consistent criteria.

For micro-credentials and short awards, simplified and proportionate procedures are needed, maintaining guarantees on assessment, awarding status, protection and public information.

The link with ESG 2015

ESG 2015 remains the European reference for Higher Education. The risk-based approach is compatible with methodologies suitable for the purpose, provided that criteria and processes are better defined.

• ESG 2.2–2.3: proportionate methodologies, consistently defined and applied processes;
• ESG 2.5–2.6: public criteria, consistent outcomes and clear reporting;
• ESG 2.7: Clearly defined and communicated complaints and appeals.

The final version should distinguish substantive equivalence from mere methodological identity and make criteria, steps and remedies transparent.

What is not yet appropriate to give for definitive

The proposal is subject to consultation and some aspects still need to be defined. Operators should avoid building new business models or making contractual commitments based on the assumption that the final version will remain unchanged.

Elements to be followed in the consultation phase include:

• criteria for the assignment of pathways, EQAR role and verification of Pathway 2;
• standards for Further Education, times, service standards and fees;
• duration of authorisations, QA expiry and classification of material changes;
• appeals, transitional period and coordination with the 2025 standards and online learning.

How to prepare for the possible entry into force

A provider of Foreign Awarded Programmes does not have to wait for the conclusion of the consultation to verify the quality of its dossier. The useful preparatory activities are mainly documentary and organisational and remain valid even if the final text is amended.

• map programs, awarding bodies, QA bodies, status, scopes and deadlines;
• collect decisions, reports, conditions and follow-up evidence, verifying the coverage of the Maltese delivery;
• review agreements, responsibilities, AQI, staffing, support, assessment and contingency arrangements;
• Align public information and record material changes, notifications, and specific requirements for online/blended provision.

What the consultation means for the sector

The consultation allows operators to report, with concrete examples, duplications, uncertainties and burdens that are not proportionate to the risk, proposing alternatives.

Stakeholders can contribute to a system that protects students and academic standards and values external QA when credible and relevant.

The goal is not to reduce control, but to commensurate it with the risk, make the criteria predictable and avoid repetitions without a concrete regulatory reason.

The quality of the final version will therefore also depend on the ability of operators to submit precise technical comments, distinguishing between protection needs that must be maintained and procedural aspects that can be made clearer, more proportionate or consistent with the framework already in place.

Download the MQE guidelines

Malta Quality Education has prepared an operational guide to the consultation, with questions and guidance for providers, awarding bodies and other stakeholders.

The guide helps each stakeholder to make autonomous and reasoned observations based on their operating model.

Main references

• MFHEA, Policy on the Quality Assurance, Authorisation and Monitoring of Foreign Awarded Programmes, draft submitted for consultation, 2026.
• Further and Higher Education Act, Chapter 607, Laws of Malta.
• Further and Higher Education (Licensing, Accreditation and Quality Assurance) Regulations, S.L. 607.03.
• MFHEA, Programme Accreditation Standards and Procedures for Higher Education, 2025.
• MFHEA, External Quality Assurance Provider Accreditation Manual for Higher Education Institutions.
• MFHEA, Regulations for Quality Assurance: Higher Education Online Learning, 2025.
• MFHEA Communication 04/2026, Additional clarifications on Fully Online Provision.
• Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG), 2015.