ESU’s opinion on the mid-term review of the European Education Area

I. Introduction

The European Students’ Union (ESU) has been working on the European Education Area (EEA) since its inception, focusing on key elements:

• Supporting the creation of an European Education Area which is ambitious and inclusive, bringing meaningful change to all students within the European Union  countries, thus ensuring it does not lead to a two-speed system
• Maintaining the European Education Area consistent and coherent with the wider European Higher Education Area
• Ensuring adequate stakeholder participation via an EEA governance framework, that ensures the process is transparent and stakeholders co-own the policies. This includes student participation in all relevant bodies and a stronger role for the European Parliament
• Boosting the budget of Erasmus+ to be conducive to achieving the aims of the EEA, integration of all policy areas related to (higher) education
• EEA governance bodies in charge of ensuring the synergies of funding streams allocated to education through the Cohesion funds, regional funds, digitalisation, research or RRF

Through this written contribution to the public consultation, we want to acknowledge the successes achieved so far, but also draw attention to the fact that essential pieces of the puzzle are still missing and without which a well-rounded and functioning EEA cannot be achieved, such as the inclusivity framework and a framework for adequate student participation. These topics are sine-qua-non conditions for an EEA that delivers for students.

Over the years and the numerous topics related to the EEA and the external events that have occurred, the role and place of students have always been at the centre of our priorities. In this document, we chose to summarise our positions in regards to all the relevant developments indicated in the European Strategy for Universities, as it’s the guiding document for higher education when it comes to EEA.

As the main stakeholders in Higher education, students are the ones who will benefit from it the most, or the ones who will be most affected by its shortcomings if not well thought through. Therefore, it is essential that students have a voice in the development and implementation of the EEA.

ESU has been at the forefront of raising student voice on the EEA. We have met with policymakers, stakeholders, and other decision-makers to share our concerns and recommendations. Through our multiple events and projects, we gathered inputs from students across Europe.

Our analysis shows that students are concerned about a number of issues related to the EEA, including: the lack of student participation in the decision-making process, the high cost of education and the lack of mobility funding & opportunities.

We believe that these concerns must be addressed if we want EEA to be a success. We call on policymakers to ensure that students have a meaningful voice in the development and implementation of the EEA. We also call on stakeholders to work together to address the concerns of students.

The EEA is still a work in progress. There are many challenges that need to be addressed, while we have also progressed a lot. With the involvement of students and other stakeholders, the EEA can be a truly inclusive and democratic space where all students can thrive.

II. Analysing the progress in achieving the European Strategy for Universities

1. Four flagships to boost the European dimension in higher education and research

– ‘Expand to 60 European Universities with more than 500 universities by mid-2024, with an Erasmus+ indicative budget totalling EUR 1.1 billion for 2021-2027.’

As the main initiative from the EEA, several points will have to be directly addressed: this is the starting point of a numerous reflection. Even though ESU is strongly supporting the European university initiative, we remain aware that Alliances cannot thrive without respect to fundamental values, and especially towards ensuring proper student participation and student rights guaranteed at alliance level. The tendency of downward convergence by finding the lowest common denominator as the set of implicit student participation and student rights in alliances must be reversed. This should happen through both upward convergence in alliances and a set of participatory rights agreed at European level. This also translates in the student participation in the steering of the initiative at European level, mainly in EEA. While participation has steadily improved recently, it is still yet to be embedded in all policy cycles in EEA, at least in clear contrast with EHEA. The risk of tokenism and, through it, commodification of education through it is still high.

Moreover, the initiative is stretched, budget wise, as a lot has to be implemented and created. As a policy vehicle, the Alliances are expected to tick a lot of boxes, thus avoiding specialisation. While we believe some policy goals have to be embraced by all Alliances, due to their nature of fundamental values or principles of the European Union, such as inclusivity, others can be left for Alliances to prioritise.

The future of the initiative depends on the funding that will be available. Alliances should be transformative for the whole educational community and meaningfully impactful to all students.

Finally, the Alliances, especially the oldest one, have to start reflection on how to engage with the wider student community. So far many students in Alliances are not engaged in and do not feel these changes, they should be onboarded in the initiative and the policies designed to have an impact in the community in general and in the learning and teaching practices in particular. Indeed, now only a few students know what the Alliances are and what opportunities they are offering. For a given Alliance, it’s usually students from the same background and the others are not involved as the field of study doesn’t match. The Alliances should have the ambition to be for all the students.

The lessons learned from Alliances should serve policy goals at EU and national level to provide innovative solutions to enhancing the quality and relevance of HE for individuals, as well as the inclusiveness of HE systems, in order not to create parallel processes and leave no student behind. We should as compass to avoid any creation of a two-tier system: the European University Alliance vs all the other HEIs not members of an Alliance.

Actions to be done:

• Adoption of a student participation framework at EEA level, either separately or through a framework for EEA governance. If necessary, this can also be done also through the QA of Alliances
• Maintain the focus of the Alliances on the education component – this needs also to be shown in funding. Any potential new goals (e.g. research) should imply new funding streams and not compromise on the priority focus of Alliances.
• After the adoption of the new Multiannual Financial Framework and the set up of the investment pathway, launch the call for new Alliances alongside investing in currently existing ones.

– ‘Work towards a legal statute for alliances of universities by mid-2024: pilot as of 2022 under Erasmus+ the implementation of existing European instruments.’

So far, only the pilot projects gave us a bit of view about what is needed, the barriers and the expected outcomes. But we are still waiting for more concrete steps. However, it might be more complicated than initially thought as it may go against the Treaties as Education is only a support competence. All the project ended with a similar conclusion: what exists at national or European level is not sufficient. There is a need to create a specific structure for the special need that the Alliances have. In any case, no matter what is created or updated, students should be part of the governance of the Alliance. At the moment, we still have some Alliances from the 1st and the 2nd call who still haven’t included students in their decision-making process.

Moreover, involved students should be democratically elected. Indeed, a lot of them are selected by the administration, which goes against the fundamental values of EHEA, against EU values, against the goals of the initiative. Sometimes this is even  based on ridiculous claims that student representatives are ‘politicised’ because they run in elections, which seems to be not an issue for management positions such as rectors.

ESU adopted some views about the legal status in a resolution adopted in May 2022:

• Higher Education Institutions must be free to choose whether to associate in alliances, and within this framework whether to establish a common legal structure, and using what instrument;
• The legal statue poses several questions and challenges, especially moving decision-making power from HEIs and national frameworks for hiring, financing, issuing degrees;
• This is especially problematic as the student participation in Alliances is far lower than general student participation in decision-making processes in HEIs, thus the legal statute may be the strongest enabler of student participation.

Moreover, about governance, ESU approved a resolution on the framework of student representation in the Alliances in May 2024. The key points are the following:

• The Student representatives must be directly elected by the students or democratically appointed by the student council of their home university
• The Student representatives need to be part of the highest decision making body and to have the right to vote on important decisions within the alliances;
• Student representatives need to have the funds to meet regularly;
• To guarantee the functions of the Student representatives at the alliance level by a Charter of the Rights of the Student Representatives, adopted into each Alliance and valid for all their Student Representatives at the Alliance level, as well as considered minimum standards for all levels.
  • The should have the right to negotiate and to have flexibility regarding their academic responsibilities when they interfere with the exercise of their functions as representatives must be guaranteed
  • Student representatives should be compensated for their work, with modalities which might change between each member HEI within an alliance, but ensuring the same treatment in terms of protection while avoiding any possible conflict of interests vis a vis the administration of the HEIs.
• To receive training courses from the universities, or from other education stakeholders, on key elements regarding the origin of the initiative, internationalisation or the functioning and objectives of the Alliances
• The Alliances and their member universities must provide the necessary information for the correct execution of Student representatives functions
• At least two Student representatives of any member university should be included in the representation of the student council of the Alliance
• Strong link between local unions and the Student representatives inside of the student body of the alliances to ensure an advocacy close to the students’ needs
• The highest decision making bodies of the alliances should evolve from a Rectors’ meeting to a fully representative body, which would include all the internal stakeholders of the Alliance (students, academic and administrative staff)
  • Should be full and equal members of all the decision-making bodies of the Alliance and thus receive all documents pertaining to how the Alliance is led and managed, have all the rights of the other members of the body, such as being able to propose agenda points to be voted upon during meetings, having the right to speak and vote on every point and on every step of the decision-making process and to nominate representatives in all committees or bodies that the Alliance has.

– Examine options and necessary steps towards a joint European degree by mid-2024: pilot as of 2022 under Erasmus+ the first steps towards a joint European degree, in particular the development of European criteria for the award of a European Degree label.

ESU published its opinion about the Blueprint for a European Degree (label). ESU considers that the most important work to be undertaken is the full, swift and comprehensive implementation of Bologna tools. We believe that the main rationale of a European degree ‘label’ should stand as a proof of successful compliance with Bologna tools and commitments and international cooperation, thus also enhancing the quality of education provision, democratic student participation and further promoting mobility and its benefits. Joint degrees is only one of the measures to establish a more interconnected European (Higher) Education Area and internationalisation measures should be expected in all higher education systems and institutions.

But overall, students are raising questions about the fees, the admission system or even the funding of this initiative. Moreover, what matters to them is that their joint degree leads to relevant, coherent learning outcomes, incorporates and combines good practices from various higher education institutions, offers unique international opportunities and includes up-to-date curriculum which fulfils their personal aspirations, their needs for professional development and can offer added value on the European labour market. There are also voices raising the issue pertaining to such kind of intense hyper-mobility: how can the sending & receiving institutions ensure the access to services?

In the aforementioned ESU’s opinion, we also described the expected modifications for what regards the proposed criterias.

• Students have access to services in all participating HEIs in equivalent conditions as all enrolled students, including services such as accommodation, academic guidance and psychological services, digital infrastructure.
• Democratically elected students’ representatives are part of the decision-making process to define the joint policies, procedures and/or arrangements and in its implementation.
• The joint programme uses student-centred approaches, fosters flexible learning paths, embedded interdisciplinary and/or intersectoral components and acquisition of transversal/soft skills.
• The joint programme offers the possibility for students to participate in activities promoting democratic values and addressing societal needs of the local community(ies), including volunteering, and to receive ECTS for it.
• During the joint programme, each student is exposed to at least 2 different EU languages within the study programme.
• The joint programme ensures wide participation by fostering socially and geographically diversity, equity, and inclusion and by adopting tailored measures to support students and staff with less opportunities. The joint programme does not include tuition fees.

Moreover we have a resolution, approved in May 2022 about our views regarding the European Degree (label) stating that:

• We already have minimum quality standards agreed at Bologna Process level: the European Standards and Guidelines on QA and the European Approach to Joint Degrees
• Thus, the ‘label’ could be useful only through the lenses that if the joint degree for which it is offered complies with certain policy requirements that are important as linked to European values/priorities, thus motivating HEI policy: for example, requiring a mobility experience within the joint programme in order to qualify as joint degree
• However, the requirements should not be restrictive in terms of the pursued goals, the end goal is to bring added value and clarity to students (‘if it’s a European degree, it means it has a mobility component, it has an integrated curriculum etc’)
• In any case though, the requirements should be linked to criteria relevant for students (e.g. creating shared facilities, learning outcomes, support systems) especially linked to learning & teaching, and have a compulsory element of social dimension, in order not to transform ‘European degrees’ in elitist degrees that are inaccessible for all students.
• The ‘label’ should be offered by QA agencies, not by an EU/governmental authority or through project application

– Scale up the European Student Card initiative by deploying a unique European Student Identifier available to all mobile students in 2022 and to all students in universities in Europe by mid-2024.

The European Student Card Initiative (ESCi) is one of the key points of the European University Strategy. It is being developed by a number of organisations working on the three pillars: the European student card, Erasmus Without Paper and the Erasmus+ App. The ESCI is an important tool, which aims to create a single, open access space of services for students across Europe. It will enable students to travel more easily and take part in educational and cultural activities in other European countries.

Regarding the access to it, we are really far from it. In March 2024, we have only 2.35 million students^[1] with an active European Student Card and according to BPIR 2024, EU countries are totalising 19.38 students^[2]. It means that at the moment only 12% of students have at their disposal a European Student Card. This is barely the number of mobile students. In addition to this issue of access, the question of the synergies between the 3 pillars is also central. At the moment, we couldn’t say that the linkage between them 3 is working well. There are problems of interconnection with one another.

Unfortunately, considering these data, we estimate that the ESCI is not moving fast enough to keep pace with the development of higher education at European level which sometimes means more confusion for students & staff members rather than an effective improvement of digitisation of the procedures. In the end, it usually means less opportunities for students to be fully & easily integrated in the Alliance during a mobility in another member HEI.

With the arrival of the new tender, we hope that the 3 pillars will finally work better together and that a new working tool -and especially for what regards the ‘European Student Card’ in itself- that is not profit-seeking will finally end up in the hands of the students. We should avoid commodification of higher education through the Student Card.

– Review the Recommendation on further European cooperation in Quality Assurance in higher education in 2023 to further develop a European Quality Assurance and Recognition System.

ESU published its opinion about the Council Recommendation on Quality Assurance & Recognition. We highlight that the documents within the spring package, as goes with the whole EEA, should have as a starting point the policies, practices and commitments within the Bologna Process and should aim to support and enhance the implementation of the Bologna Process, without creating diverging or parallel practices. This is especially important regarding commitments linked to quality assurance, recognition and joint programmes, even more so that for quality assurance an entire architecture and coherent, well functioning system has been built within the European Higher Education Area (EHEA).

Furthermore, a balance must be struck in terms of the scope of intervention of the spring package documents. On one side, it is expected that additional emphasis is put on elements related to transnational cooperation, where EU added value is most obvious, and to instruments or initiatives stemming from EEA itself (such as European University Alliances or a common approach to microcredentials). On the other side, the EEA and the values it underpins must impact and leverage all students and higher education institutions, irrespective of the place or conditions of study, and as such policy initiatives linked to quality assurance and recognition, academic careers or rules related to joint programmes must be broadly applicable in all circumstances, considering the additional need for intervention in relation to what already exists.

Finally, while there may be convergence in objectives among various policy-makers and stakeholders, the ambitions of the proposed initiatives should be complemented by additional effort in getting on board the grassroot academic communities, aiming to reach a common, more concrete long-term vision of EEA and its initiatives.

These general principles, stemming from previous statements and resolutions adopted by the Board of ESU on the EEA or its components, will guide ESU’s contribution below to each of the three components of the package.”

Adequate financial support to higher education and research

-Facilitate the access to EU and national funding for quality projects that could not be funded under Erasmus+: first, a certificate from the Commission will be delivered to be tested for the 2022 European Universities Call for Proposals; second, the Seal of Excellence tool could be implemented under Erasmus+, as is currently the case under Horizon Europe.

There are 2 points here. The first one about a Certificate from the Commission and the second one about the Seal of Excellence. On the first one, ESU is not aware of such Certification from the Commission. Was it done? Or not? Was it effective? If yes, it means that stakeholders were not involved in these discussions. On the other hand, about the Seal of Excellence for the project not selected as European Universities, ESU sees no added-value about them. Unfortunately, for these projects with a Seal of Excellence, as there is no follow-up on them and no funds available, it’s complicated for the member HEIs to develop activities. They are not included in the discussion on the evolution of the project. It’s a consolation prize with no effect.

– As part of the mid-term review of the MFF programmes, develop an investment pathway that takes into account regional, national and European funding.

More generally for regards the funding, ESU adopted a resolution on the topic in November 2022 with the following points:

• The EU should not rely on national co-financing of the Alliances. This would create discrimination as national governments have different funding capacities (creating differentiation between members of alliances) but also different funding models and policy priorities (creating differentiation between members of alliances and other HEIs). Thus, national/regional level should be considered only a top-up.
• Erasmus+ should be the main source of funding, ensuring coherent and sustainable core funding for alliances through Erasmus+ or another funding stream (Alliances fund) that would bundle different funding streams.
• The focus of the core funding should be on education delivery and learning and teaching, while Horizon should be used for research purposes. The funding model should not incentivize alliances to ‘ignore’ the first mission
• There should be a coordination body, together with stakeholders, that ensures a smoother link with other EU funding initiatives (e.g. Cohesion Funds, NRRPs)
• There should be long term funding (e.g. 7 years, based on the multiannual financial framework) that should include a mid-term review (based on a framework which could take the monitoring framework as a starting point). Initiatives such as E+ accreditation on youth could serve as inspiration. The Alliances should be quality assured for being eligible for funding.

The European Commission started exploring the so-called ‘investment pathway’ for mainstreaming and creating synergies between the funding sources of the European Alliances. The main path pointed out by the Commission for the post 2027 framework looks into synergies with national and regional level funding, expecting member states to chip in for supporting the initiative.  About this, we are waiting for more insights especially from the member states and how they are willing to participate, in regards to the pilot project on synergies for the funding streams submitted.

In addition to the above, the Commission calls on Member States:

– To maximise the impact of EU interventions, by seeking further synergies with national financing, notably in the context of European Universities.

– To develop adequate funding mechanisms for universities.

– To ensure flexibility in funding programmes to allow for interdisciplinarity.

In addition, we should also take into consideration that nowadays, some member states are already funding the Alliances. But, it is done at very different levels. Indeed, some member states are funding their member HEIs as part of an Alliance more than others. Meaning that it creates differences of implication for HEIs from the same Alliances (as some would have more financial means), it can also creates differences of actions between Alliances strongly supported by member states and Alliances not really supported. In the end, the only way to achieve equity for the Alliances in the funding they are receiving, is to centralise at European level, the money received from national & regional level and then  to have it redistributed them equally.

Lighthouses of our European way of life

Strengthen quality and relevance for future-proof skills

– Propose by 2023 a European framework for attractive and sustainable careers in higher education, in synergy with the research career framework developed under the ERA.

ESU published its opinion on the sustainable & attractive academic careers proposal from the Commission.

– Boost Erasmus+ traineeships abroad, reaching more than 100 000 trainees every year, through student peer reviews and traineeships in start-ups and entrepreneurial organisations.

About traineeships, the Commission put forward the package on traineeships, composed of a Directive and a Council Recommendation. The package will be negotiated during the incoming Hungarian Presidency. ESU prepared a briefing for you below so you are aware of the most important elements of the package.  ESU has been involved in the consultation processes for the package, an aspect also expressed and acknowledged in the staff working document accompanying it.

First, about the Council Recommendation on a Quality Framework for Traineeships (QFT) – revises the 2014 QFT.

Applicability

• The QTF is extended to also include student trainees, defined as ‘ traineeships that are part of curricula of formal education and training (the most important thing for us!) and those of which their completion is mandatory to access a specific profession (e.g., medicine, architecture, etc. The previous QTF only applied to traineeships in the labour market, which can, of course, also be students, but it is not linked to student status.
• It applies to trainees who are defined by national law as workers (so not the student trainees) only insofar as higher protections don’t apply deriving from their status as workers.
• It applies to apprentices (an apprenticeship being defined as ‘ paid formal VET schemes that combine learning in education or training institutions with substantial work-based learning in companies and other workplaces, leading to a qualification) only insofar as the  Council Recommendation of 15 March 2018 on a European Framework for Quality and Effective Apprenticeships doesn’t offer higher protections.
• The implementation of this Recommendation should not constitute valid grounds for reducing the general level of protection afforded to trainees covered by this Recommendation.

Rights and provisions

• ensure that traineeships are based on a written agreement, including  the learning and training component, including its objectives, the working conditions, the tasks to be carried out, the arrangements for mentorship, supervision and evaluation, details on social protection coverage, including with regards to coverage for sickness and healthcare as well as for accidents at work and occupational disease
• ensure that trainees are consulted when setting the specific learning and training objectives of the traineeship in order to help trainees acquire practical experience and relevant skills. The tasks assigned to the trainee should enable these objectives to be attained.
• ensure that trainees are fairly paid
• ensure that traineeship providers designate a supervisor
• ensure that traineeship providers designate a mentor
• ensure that traineeship providers provide an appropriate, safe and healthy working environment, including equipment and work organisation in the case of remote and hybrid traineeships.
• ensure a reasonable duration of traineeships that does not exceed six months, unless objective reasons apply
• ensure that employers do not require candidates for traineeships to have previous work experience in the field of activity, unless objective reasons apply
• ensure, in cooperation with competent authorities, channels for trainees to report malpractice
• ensure that trainees have access to adequate social protection (very important for us!!)
• transparency of vacancy notices, offering certificates of completion, principle of non-discrimination and equal treatment
• use of gender-neutral and inclusive language
• ensure that traineeship programmes, including workplaces, trainings, digital tools, office and work equipment, are adapted to the individual needs of trainees where relevant, in particular for trainees with disabilities
• encourage career guidance
• ensure that representatives of workers may engage in any relevant judicial or administrative procedure
• offer incentives to traineeship providers for offering trainees a regular employment relationship after the successful completion of a traineeship

Monitoring

• The monitoring will be done via the European Semester process
• Countries have to submit action plans within 18 months of the adoption

About the Traineeships Directive

Applicability (very technical and complicated)

• Does NOT apply to student traineeships (as we have advocated for, but almost nobody supported our push)
• Does NOT apply to labour market (‘open’) traineeships unless the national law considers those trainees as workers OR they are in a regular employment relationship which is disguised as a non-employment traineeship
• Applies to apprentices only insofar as they are also considered by national law as workers

Rights and provisions

• The sole fact of being a trainee cannot constitute grounds for less favourable treatment compared to regular employees in the same establishment
• Right of fair pay based on their work (but saying they ‘ban unpaid internships’ is exaggerated as the directive offers new protection ONLY for trainees that should be considered workers but are in a traineeship which is not considered employment, but which should have been considered so in light of some criteria). If the traineeship is not an employment nor should it be considered so under national law, there is no pay required
• effective measures to ensure that all relevant Union law applicable to workers is fully implemented and enforced in relation to trainees which are considered or should be considered workers
• Right to redress, right to union protection, right of protection against adverse treatment

Implementation

• Member states have 2 years since the adoption of the Directive to transpose it in national legislation

Foster diversity, inclusiveness and gender equality

– Develop a European framework for diversity and inclusion, including on gender gaps, identifying challenges and solutions for universities, and the needed support of public authorities.

This commitment to create an inclusive framework for the EEA and the Alliances have been repeated in the Communication for establishing the EEA and in the European Strategy for Universities ; but little steps have been taken so far. Research suggests that Alliances are composed of big, well off, research-intensive HEIs, which can in turn lead to elitisation. While several Alliances aim to promote social inclusion, the transformative potential is usually limited.

Thus, ESU believes that the social dimension of EEA is essential for its success. The Alliances should further promote inclusion and in any case proactive measures need to be taken to ensure that all students benefit from their establishment. In addition to that, the inclusivity framework should have as a starting point the Principles and Guidelines on Social Dimension agreed in the Bologna Process.

Moreover, we also ask for a revision of the 2012 Council conclusions on social dimension, so that meaningful initiatives on social dimension are pursued and tracked in the EEA flagship initiatives. This is especially important in the development of Alliances and their joint degrees: we need to look into and work on admission system, grant and fees policies, student support systems and inclusive learning environments created within Alliances, policies for disadvantaged students (including in the mobilites that are expected to represent an important milestone for Alliances), etc

In addition to the above, the Commission calls on Member States:

– To encourage universities to implement institutional change through concrete measures for diversity and inclusion, including voluntary, quantified targets for inclusion and inclusive gender equality plans, building on the Rome Communiqué.

In 2020 through the Rome Communiqué, the ministers adopted the Principles and Guidelines (PaGs) for Strengthening the Social Dimension of Higher Education in EHEA, which were elaborated by a working group co-chaired by ESU. They represent high-level political commitments of ministers for how to achieve an inclusive EHEA by 2030, touching upon a wide range of topics such as strategies, inclusive learning environments, financing costs of education (e.g. through grants), mobility, counselling and guidance services, data collection, lifelong learning policies, recognition of prior learning and others.

A month ago, the Tirana Communiqué was approved and with it, the “Indicators and Descriptors for the Principles of the Social Dimension in the European Higher Education Area” document. It was created in EHEA, in order to follow-up on the work and give more concrete impetus to public authorities, as well as guide them in the implementation of the Principles & Guidelines. They will support the operationalisation and monitoring of the PaGs. While we would have liked them to be mandatory, they will only serve as a ‘toolbox’ to be used by public authorities – while they still have to implement the PaGs (and this has been questioned as well), they can prove progress in achieving this goal also through other means than through the adopted indicators.

            This ‘toolbox’ with the PaGs should be used as a starting point for the Inclusive Framework mentioned above. As well as saving time, this would allow more synergies between the EEA and the EHEA.

– To develop national support schemes and support access to higher education of refugees and individuals seeking asylum, including the establishment and scaling of complementary pathways for refugee students and the related support, in line with the Commission Recommendation on legal pathways to protection in the EU.

ESU is proposing a number of recommendations to improve the educational experiences of forcibly displaced students. These recommendations focus on policy changes, application processes, legal protections, and support services.

Policy changes include advocating for robust policies concerning Learning Pathways and Recognition of Qualifications. This includes ensuring legal certainty in admissions and recognition of qualifications. The ESU also recommends that countries prioritise accessibility and individualised adaptation for all students.

We endorse changes to application processes to ensure they are non-discriminatory and transparent. This includes offering consistent, inclusive, and equitable access and support. The ESU also recommends establishing integration programs to support students who may lack required language proficiency or have incomplete transcripts.

In addition, we propose legal protections for forcibly displaced students, such as prohibiting deportations from campuses. They also recommend establishing specific student visas for at-risk students and students in refugee-like situations.

Finally, we would recommend a number of support services for forcibly displaced students. These include preparatory programs to facilitate enrollment, tailoring teaching and learning methods to meet the needs of these students, and providing academic counselling. The ESU also recommends establishing integration initiatives to help students integrate into the social life of the university.

Actors of change in the twin green and digital transitions

Develop skills, competences and technological innovation for the green transition

Sustainability is a major topic in today’s world, due to the urgency of climate change. Higher education institutions have a responsibility to do their part to build a greener and more sustainable future for generations to come. To do so, several paths could be explored in the higher education sector such as incorporating sustainability into curriculum. This could involve offering courses on sustainability, integrating sustainability concepts into existing courses, or requiring students to complete a sustainability-related project or internship. The idea of making campuses more sustainable is also key since it could involve reducing energy consumption, water usage, and waste production. Thus, the campuses would be more friendly and sustainable for the future generation. Finally, we truly believe that support research on sustainability needs to be enhanced. This could involve funding research projects, providing facilities for research, or disseminating research findings.

We should continue to bring together all the higher education stakeholders in our countries to maintain the academic sector’s focus on the production and protection of knowledge on the topic of climate change, sustainability, education to sustainable development, to initiate and continue the transitions of our institutions, and to work towards achieving the sustainable development goals. A full realisation of the EEA also passes by taking into consideration the real issues raised by climate change.

Making it happen: monitoring and governance

– Set-up a data-focused European Higher Education Sector Observatory in 2023, with a European Higher Education Sector Scoreboard as one of its deliverables.

The Higher Education Observatory is a European Commission initiative aimed at improving understanding of the functioning of European higher education and the complex relationships between its stakeholders. The idea is to have an institution that can collect and analyse data on European higher education systems, students, teachers and staff, institutions and policies. This data is essential for a better understanding of higher education and for the development of effective policies. They can help identify good practice, assess the performance of higher education systems and identify areas for improvement. However, the Observatory and the data produced should only be used for descriptive purposes and not prescriptive as it can lead to rankings.

However, even if it’s still in the reflection phase, ESU believes that to reach its full potential, it is important that students are involved in its governance. Students are the main users of higher education services and are therefore best placed to voice their needs and how data can be better exploited to improve higher education as a whole.

– Promote synergies between the European Education Area, the European Research Area and the European Higher Education Area in a fit-for-purpose and flexible manner.

ESU believes that the future of education in Europe lies in an integrated European Higher Education Area, where fundamental values, automatic recognition of degrees, upward convergence of student rights and democratic and effective student representation on all levels (from local to European and transnational) are practised. To this end, the European Education Area can help in enabling the processes to remove the obstacles to further integration, but the measures to achieve that need to be designed and implemented with the thorough involvement of all the stakeholders – including students – and need to be available for all the Higher Education Institutions operating in the Area. ESU believes that Higher Education Institutions and national Higher Education systems must maintain the right and the ability to adapt their offer to the needs and specificity of their communities and societies. In order to achieve this, the European Education Area should comply with the commitments of the European Higher Education Area as all EU member states already agreed on what should look like a common area for education. Moreover, the governance body of the EEA should represent all the EU institutions, European stakeholders and the Member States delegations, within which at least 25% shall be democratically elected student representatives.

ADDITIONAL POINTS

Monitoring framework

The Commission worked on a monitoring framework for the initiative, with ESU being involved. However the framework is set for monitoring the impact of the initiative as a whole, not as a progress of individual alliances. The first piloting of the monitoring framework is happening right now with results being expected in October.

On one side, it is good that now we have a systemic overview of the potential and impact of alliances, as it is too early to address individual impact. But from this point we will also need an impact assessment of each Alliance in the future. The monitoring should engage all stakeholders, currently only coordinators are expected to contribute to the survey.

For monitoring, we need to look more into what has already happened than into what the plans are. For foresight, we need to also collect their future plans. We are calling for a more holistic perspective into the topics to be monitored, not to be limitative to some policy goals of the Commission. For the long-term impact of the initiative, we need to look into governance, strategy, outreach/students involved, quality processes and social dimension.

Quality assurance

Even though the two topics are taken together (Quality Assurance and recognition), because they are interlinked, there are actually relevant differences between them in their nature. From our resolution on automatic recognition adopted in November 2022, here are the main points:

• It is mainly a problem of level of competencies: we see that when the automatic recognition is done at national level (as opposed to institutional level) it goes more smoothly
• We already have all the tools in place (the Council Recommendation of 2018, the ESGs, the Qualification Frameworks) so that countries implement the automatic recognition adequately, it is more a matter of bureaucracy or prioritisation than a matter of political will.
• There is still some misunderstanding at institutional level that ‘automatic recognition’ means ‘admission’, which is not the case (you simply recognise that a bachelor is a bachelor, a master is a master etc, you don’t automatically recognise that with this bachelor you can enter this study programme).
• There are equal problems in automatically recognising learning periods abroad (Erasmus+) as for full qualifications, even though there is an agreement
• However this is a matter of EU policy in general, not only for Alliances, as all degrees should be automatically recognised and Alliances have the same regulatory framework as all other HEIs.

In addition to these points, our resolution on student participation also mention participation in QA:

• In comparison with the automatic recognition element, where there is a scope for EU intervention, we do not see much added value for a regulatory framework on QA, as this would create a two-speed Bologna while we already have established and working tools in QA in Bologna: the ESGs (proposed by E4), the European Approach to Joint Degrees. The ecosystem of QA in EHEA (with ESGs, E4 cooperation and EQAR) is functioning
• The added value of EU intervention would be in supporting the EHEA framework through analysis, peer support and funding
• There is a scope for an emphasis towards microcredentials – even though they are covered by ESGs, there could be more specific QA standards where the EU could get involved.
• The most relevant scope of EU intervention is for the quality assurance of Alliances.
• ESU believes that Alliances should be both internally and externally quality assured. For the external quality assurance, we see the need of a framework which could use the results of the EUNIQ project as a starting point. The external QA should be voluntary at the beginning, but afterwards (e.g. from 2027) be linked to the Erasmus+ funding received from the Commission. In long-term we can see other potential consequences of external QA of alliance (e.g. giving the possibility to issue joint degrees without individual accreditation using the European Approach) but the evaluation cannot and should not in any way replace national arrangements for HEIs (institutional/programme level accreditation or evaluation)
• The biggest priority now should be the internal QA system. Alliances do not have a proper internal QA system, as they haven’t moved past project-perspective narrative. There is a QA system in place, but for the project, not for the education delivery and the alliances as a whole. Alliances should create meaningful criteria, QA units at alliance level (that go beyond a gathering of QA units or project officers at university level) and ensure meaningful student participation in the creation and implementation of QA policies at joint programme and alliance level. So far the participation is ostensibly lower than in other QA proceedings.

Erasmus+ mobility on the scope of the EEA

Mobility is an important means to use for the achievement of EEA. Related to it, several issues are brought up.

As part of the key point of the European strategy for universities, mobility and the target of having 50% of the students in an Alliance who did mobility during their study is important.

It raises the question of the capacity of the program to endorse this amount of mobility and with it the question of virtual exchange.

Mobility is an important means to achieve the EEA. It allows students to gain new skills and knowledge, experience different cultures, and make lifelong connections. The European Strategy for Universities includes a target of having 50% of students in an alliance participate in mobility during their studies. This is an ambitious target, and there are a number of challenges that need to be addressed in order to achieve it.

One challenge is the capacity of the program to support this level of mobility. The Erasmus+ program, which is the main funding source for student mobility, is already under strain. There is also a need to ensure that there are enough high-quality opportunities available for students to participate in.

Another challenge is the cost of mobility. For many students, the cost of living and studying abroad can be a barrier. There is a need to find ways to make mobility more affordable, such as through scholarships and grants. Moreover, grants are currently calculated on country-basis, however, this absolutely does not reflect the real cost of living the mobile student will face while abroad. Indeed, the cost of living depends on the city: housing costs in Paris & Saint-Etienne (in France) are widely opposite. Finally, when it comes to the grants, we have to mention that there is a simple measure that could already ease majorly the life of students: the monthly payment of the grant. Indeed, not all students can afford to pay in advance all the costs related to mobility: travels, housing, deposit, insurances, etc. It is a simple measure of accessibility, yet, not put in place.

Specifically on the topic of housing, it is mentioned in the Erasmus Annual Work Plan 2024, page 24 that: “active support to incoming mobile participants throughout the process of finding accommodation, including through collaboration with the relevant stakeholders for the provision of appropriate and affordable housing” should be done for higher education mobile students. Yet, none to very few actions have been taken in that sense. It is a high priority for students, hence, should be reflected in the general policies.

Virtual exchange is one way to address the challenges of mobility. It allows students to connect with peers from other countries online. This can be a valuable way to gain international experience without having to travel. However, virtual exchange is not a replacement for physical mobility. There are some things that students can only learn by being immersed in a different culture. The European Strategy for Universities therefore emphasises the importance of both physical and virtual mobility.

Virtual exchange

From our internationalisation and mobility policy paper, ESU believes that virtual exchange is a form of online learning that has an integrated international and intercultural component. However, this is not mobility as it doesn’t include physical movement abroad. Virtual education activities provided across countries can be used as a positive tool for increased internationalisation if the activities are of high quality. It is an add-on, not a replacement for physical mobility, as the international experience gained by mobile students can only be truly experienced in person. Therefore when counting participants in international mobility, participants in virtual activities should not be counted as mobile students but as another category, and funding for these activities should not be taken from the budgets for student mobility. ESU opposes the narrative that virtual international activities are a way of widening access to mobility for underrepresented groups, nor can they be used as a tool to reach mobility targets. Groups who are currently underrepresented should not be given virtual options as a “discount solution” to widening access – rather access to high-quality international education, including physical mobility, should be widened for all.

Virtual exchange should foster internationalisation and promote further physical mobility of the whole student body, especially targeting those students who were not originally eager to engage in mobility. It should also be used to encourage the exchange of students who cannot or do not want to be mobile because of their socio-cultural background and status, disabilities and chronic diseases, family and parental obligations, financial issues or language proficiency. Furthermore, new competencies such as digital communication skills, flexibility, teamwork and creativity are given an especially strong boost. However, participation in virtual exchange should be an option and not an unavoidable choice. Virtual exchange programs require the allocation of adequate resources to ensure the quality of offered courses, provide necessary online infrastructure, training for academic staff to create and facilitate virtual exchange, etc. Virtual exchange cannot be used as an instrument to avoid investing in physical mobility to make it more inclusive for students from disadvantaged backgrounds, as that would be at the expense of equality and the versatility of learning opportunities.

It also raises the question of the accessibility of Erasmus+ and the link between Erasmus and the EEA (as they are still separate, even intricate, programs).

Reassociation of Region 14

Mentioning the accessibility of Erasmus+, despite the whole inclusivity topic that we will address in the Erasmus+ mid-term review, there is the question of the reassociation of Region 14. United-Kingdom, Switzerland and Faroe Islands should be part of Erasmus+ which is directly linked to achievement of the EEA. Indeed, talking about the EEA means that all the continent should be onboard if we want harmonised practices without any countries left behind. In the Switzerland case, the CULT opinion on EU-Switzerland relations, on point 5, highlighted the will of Swiss students to be part of Erasmus. On UK-TCA discussion in CULT, the report also supports and raises the voice of British students to be part again of Erasmus+. Students are ready. Now it’s the turn of the member states to move forward on these issues and follow the wishes of those primarily concerned.

In terms of access to Erasmus+, the governments and the European Commission should constructively work on common solutions for enabling access to the program. The integration of the countries from Region 14 represents an extension of opportunities for young Europeans since they are offering a diversified range of learning and cultural experiences and helping strengthen the European identity. The current lack of access to the Erasmus+ programme puts them at a disadvantage, especially in regard to the financial aid available for mobility. It is crucial to promote mobility between Europe and the rest of the world without forgetting the immediate neighbourhoods which are not included for political reasons. That is why the Erasmus+ mobility programme needs to be decoupled from non-related political negotiations in order to safeguard the student’s interests and a strong European education sector. As the EEA and its flagship initiative, the European Universities, is mainly about mobility, across the continent, the reassociation of Region 14 should be addressed as part of an holistic continental view of equal opportunities.

---

^[1] Figure is from NTT Data presentation

^[2] European Commission / EACEA / Eurydice, 2024. The European Higher Education Area in

2024: Bologna Process Implementation Report. Luxembourg: Publications Office of the

European Union.