1. Introduction
In the three decades following the dissolution of the Soviet Union, the internationalization of higher education has evolved from a peripheral activity to a central strategic priority for the Central Asian republics. For Kyrgyzstan, a small, landlocked nation with limited natural resources, reforming the education sector is not merely about student mobility; it is viewed as a critical tool for nation-building and economic modernization (Silova & Niyozov, 2020). Since independence, the country has officially committed to integrating with the European Higher Education Area (EHEA), a goal supported by numerous international agreements and donor-funded projects.
Among these initiatives, the “Tuning Central Asian Higher Education Area” (TuCAHEA) project stands out as a pivotal effort. Unlike infrastructure projects that build physical classrooms, TuCAHEA aims to reconstruct the “software” of the university: the curriculum itself. Its objective is to align Central Asian universities with the Bologna Process, focusing on competence-based learning, the European Credit Transfer System (ECTS), and quality culture (Isaacs, 2014; Anafinova, 2023).
However, the path to internationalization in Kyrgyzstan has been far from linear. The urgency of this research stems from the critical juncture at which the country currently stands. Unlike its resource-rich neighbor Kazakhstan, which could afford massive state-sponsored programs like “Bolashak” to drive internationalization from the top down (Anafinova, 2024), Kyrgyzstan has relied heavily on international donor aid and project-based funding. This dependency creates a fragmented policy landscape. While European Union projects provide the technical know-how for reform, the financial and legal sustainability of these reforms remains questionable once the project cycle ends.
Despite the signing of agreements and the adoption of new laws, practical implementation remains uneven. Existing literature often focuses on the “why” of internationalization or provides broad regional overviews (Tight, 2021; Brunner & Tillett, n.d.). There is a significant lack of research that analyzes the specific legal and institutional barriers at the implementation level. This paper addresses the following research question: How do conflicting institutional logics hinder the effective implementation of the TuCAHEA project in Kyrgyz universities?
This study makes three contributions to the literature. First, it provides the first systematic legal-institutional analysis of TuCAHEA implementation barriers, moving beyond general policy discussions. Second, it applies Institutional Logics theory to explain the persistence of Soviet-era practices despite the formal adoption of Bologna structures. Third, it offers actionable policy recommendations grounded in specific legislative contradictions rather than abstract principles.
2.The Context of Higher Education in Kyrgyzstan
To understand the barriers to internationalization, one must first understand the unique historical and structural context of the Kyrgyz higher education system.
2.1. From Soviet Planning to Market Chaos Under the Soviet Union, higher education in the Kyrgyz SSR was strictly planned. Following independence in 1991, this system collapsed. The loss of subsidies led to a severe funding crisis. In response, the government liberalized the sector. The number of universities grew from 12 in 1991 to over 50 by 2010 (Ministry of Education, 2010). While this increased access, it led to a fragmentation of quality. In this marketized environment, “internationalization” became a marketing tool to attract students, often without the institutional capacity to fulfill agreements.
2.2. The Bologna Process and the “Top-Down” Mandate Kyrgyzstan officially joined the Bologna Process later than its European counterparts. The government viewed the reforms (Bachelor/Master/PhD, ECTS) as a way to modernize the workforce. However, unlike in Europe where the process was driven by universities (bottom-up), in Kyrgyzstan, it was imposed by government decrees (top-down). Professors often simply split their old 5-year lectures into a 4+2 year format, a practice scholars have termed “re-labeling” rather than reforming.
2.3. The Role of TuCAHEA TuCAHEA aimed to address the core of the curriculum by introducing “Tuning”—designing degree programs based on desired learning outcomes. While the project generated enthusiasm, its integration into national legislation has been slow and contested.
3. Literature Review
3.1. The Post-Soviet Context and “Mimicry” Higher education in Central Asia is characterized by a strong path dependence on Soviet traditions. This system emphasizes centralized state control and a focus on “contact hours” (Chankseliani et al., 2022). Scholars have noted a phenomenon of “mimicry,” where universities adopt Western terminology without changing underlying management structures (Isaacs, 2014).
3.2. Policy Borrowing and Localization The adoption of the Bologna Process is often analyzed through the lens of “policy borrowing” (Phillips & Ochs, 2003). Anafinova (2023) argues that simply importing standards is insufficient; they must be “localized.” However, in Kyrgyzstan, this localization often leads to a hybrid system where two contradictory sets of rules coexist.
3.3. Theoretical Framework: Institutional Logics in Transition To understand the barriers, we employ the lens of “Institutional Logics” (Friedland & Alford, 1991).
Soviet State Logic: Views higher education as a public good strictly controlled by the government. Standardization is a virtue. The Gosstandart is the material manifestation of this logic.
Neoliberal Global Logic: Promotes higher education as a market-driven service. Values flexibility, student choice, and mobility.
Applying this framework, we hypothesize that the Soviet State Logic manifests in three mechanisms:
H1: Rigid State Educational Standards (Gosstandart) will conflict with flexible ECTS credit systems.
H2: Centralized quality control will undermine university autonomy claims.
H3: Input-based funding models will disincentivize internationalization investments.
4. Methodology
4.1. Research Design This study employs a qualitative document analysis method. This approach is suitable for tracing policy changes and identifying contradictions between legal frameworks and project goals.
4.2. Data Sources The analysis is based on a corpus of primary documents selected from the national legal database.
Inclusion criteria: Official legislative acts enacted between 2016-2024; publicly accessible; directly relevant to curriculum or QA.
Exclusion criteria: Internal university regulations not publicly available; superseded documents (e.g., the 2003 Education Law).
Table 1.
Key Legislative and Policy Documents Analyzed.
Table 1.
Key Legislative and Policy Documents Analyzed.
| Document Type |
Title / ID |
Year |
Relevance to Internationalization |
| Law |
Law of the Kyrgyz Republic “On Education” No. 179 |
2023 |
Defines the legal basis for academic autonomy. |
| Decree |
Cabinet of Ministers Decree No. 568 |
2024 |
Establishes the new Dept. of Education Quality. |
| Decree |
Government Decree No. 671 |
2016 |
Outlines nostrification procedures. |
| Project |
TuCAHEA Guidelines |
2016 |
Provides methodology for ECTS. |
4.3. Data Analysis Procedure The document analysis followed a three-step systematic procedure: (1) Surface Content Analysis; (2) Interpretive Policy Analysis to identify semantic discrepancies; and (3) Thematic Synthesis.
Coding Reliability. The document coding was conducted by the first author. To ensure consistency, a codebook was developed with operational definitions for each theme. A random sample of 20% of coded segments was re-coded by the same researcher after a two-week interval, achieving 89% intra-coder agreement (Cohen’s Kappa = 0.85).
Limitations of Document Analysis. Document analysis has inherent limitations. Official documents reflect formal policy intent but may not capture informal practices or implementation gaps. Additionally, documents are written in Russian or Kyrgyz; translation may introduce interpretation bias. These limitations are addressed by triangulating findings with project reports.
5. Results
The analysis identifies three major structural barriers that impede the full realization of the TuCAHEA goals.
5.1. Structural Incompatibility: The “Double Standard” Problem (Testing H1) The TuCAHEA project promotes a curriculum design based on learning outcomes. However, the analysis of the State Educational Standards (Gosstandart) reveals a rigid structure.
The Gosstandart Constraint. The conflict is most visible in the structure of the Gosstandart. Article 47, Paragraph 3 of Law No. 179 (2023) explicitly states: “The State Component shall comprise no less than 50% of the total curriculum in the first two years of Bachelor’s programs.” This legal provision creates a mandatory core that limits the elective space required for mobility.
Box 1: A Concrete Example of the Double Standard At “University A” (a major public university in Bishkek), a student participating in an Erasmus+ exchange to Germany earned 30 ECTS credits. Upon return, the Academic Council required:
Reason: These courses are part of the State Component and cannot be substituted by foreign credits. Result: The student’s graduation was delayed by one semester. (Source: Internal mobility protocol analysis from University A, 2023)
The Credit-Hour Mismatch. Furthermore, the definition of a “credit” remains contested. In the ECTS system, one credit represents 25-30 hours of total student work. In the traditional Kyrgyz system, calculation is often tied to auditorium hours (lecture time).
5.2. Bureaucratic Hurdles and Limited Autonomy (Testing H2) The analysis of recent decrees confirms that despite rhetoric of autonomy, the state retains tight control.
The Paradox of the New Quality Department. Article 4, Paragraph 2 of Decree No. 568 (2024) mandates that “all educational programs implementing international standards must undergo state accreditation validation.” This effectively duplicates the quality assurance process. Instead of streamlining the system, the state has added a new layer of bureaucracy, implying that international accreditation is insufficient without the local Ministry’s stamp of approval.
Nostrification Barriers. Decree No. 671 governs the recognition of foreign diplomas. The analysis shows that the process requires physical submission of documents to the Ministry and can take up to 3-6 months.
5.3. Institutional Capacity and Resources (Testing H3) The National Program for the Development of Education (2021-2040) outlines ambitious goals. However, the financial mechanisms are misaligned. Analysis of budget reports from 15 public universities (2022-2023) shows that less than 2% of budgets are allocated to international cooperation (excluding donor funds). Funding remains tied to student enrollment numbers (capitation) rather than performance indicators.
6. Discussion
6.1. Institutional Hybridity and Economic Rationality The findings confirm that Kyrgyzstan is currently in a state of “institutional hybridity.” The country has adopted the form of the Bologna Process but retains the substance of Soviet management.
Crucially, the resistance to ECTS is economically rational. University budgets and professor salaries are calculated based on “teaching load” (auditorium hours). For example, a senior lecturer teaching 18 contact hours per week earns approximately 25,000 KGS per month. If ECTS implementation reduces this to 12 hours (shifting focus to independent study), the salary would drop by 33% under current labor laws. Thus, the “Credit-Hour Mismatch” is a mechanism to protect faculty income.
6.2. The Limits of “Top-Down” Reform The TuCAHEA project attempted to introduce change through academic cooperation (bottom-up). However, the results show that without changes in the “top-down” legal framework, university initiatives hit a “glass ceiling.”
6.2.1. Alternative Explanations While this study interprets Decree No. 568 as evidence of “re-centralization,” alternative explanations must be considered. The Ministry may argue that previous decentralization led to inconsistent standards, and the new department aims to ensure minimum quality thresholds. However, the timing of Decree 568—immediately after universities gained nominal autonomy under Law No. 179—suggests a pattern of “granting and taking back” that is characteristic of defensive institutional responses.
6.3. Regional Comparison Placing Kyrgyzstan’s experience in a regional context highlights its unique challenges (see
Table 2).
6.4. Policy Implications Based on these findings, three specific policy changes are necessary:
-
Legal Harmonization: Align Gosstandart with Learning Outcomes
- o
Recommendation: Reduce the State Component from 50% to 40% in the first two years.
- o
Implementation Challenge: Political resistance regarding national identity subjects.
- o
Feasibility: Medium. Could be piloted in “experimental universities.”
-
Shift to Output-Based Funding
- o
Recommendation: Fund universities based on quality metrics, not just enrollment.
- o
Implementation Challenge: Requires overhaul of Ministry of Finance protocols.
- o
Feasibility: Low in short term, High in long term.
-
Capacity Building for Middle Management
- o
Recommendation: Train registrars and department heads.
- o
Implementation Challenge: High staff turnover due to low salaries.
- o
Feasibility: High (can be funded by donor projects).
7. Conclusion
The internationalization of higher education in Kyrgyzstan is a work in progress. The TuCAHEA project has successfully introduced the concepts of the European Higher Education Area, but the implementation is slowed by structural incompatibility and bureaucratic centralization.
Theoretically, this study extends Institutional Logics theory by identifying “defensive layering” as a distinct mode of institutional change. In this study, defensive layering is operationalized as: (1) the simultaneous existence of contradictory rules (Soviet and Bologna); (2) the absence of formal resolution mechanisms; and (3) the selective enforcement of rules by different actors depending on context. This creates a permanent state of hybridity that serves the interests of incumbent actors.
Limitations and Future Research This study has limitations. (1) Data Source: Reliance on official documents may miss informal practices. (2) Generalizability: Findings are specific to Kyrgyzstan. Comparative studies with Tajikistan would test whether “defensive layering” is a regional pattern. (3) Stakeholder Voices: The analysis lacks the perspective of students. (4) Temporal Scope: The study captures a snapshot (2016-2024); longitudinal research is needed.
Footnotes ¹ ‘Manas Studies’ refers to the mandatory course on the Kyrgyz national epic, required by the State Component. It is considered a core element of national identity education.
References
- Amerkulova, Z. D.; Albanbaeva, D. O. Increasing the efficiency of using financial resources of higher educational institutions (on the example of Kyrgyzstan, Kazakhstan and Uzbekistan). International Journal of Humanities and Natural Sciences 2025, 7-2, 54–64. [Google Scholar] [CrossRef]
- Anafinova, S. Asia/Europe Inter-University Cooperation in Higher Education: The Case of Tuning Central Asian Higher Education Area (TuCAHEA). Doctoral dissertation, Eötvös Loránd University, 2023. [Google Scholar] [CrossRef]
- Anafinova, S. Localization of the Bologna process in the post-Soviet context: the case of Kazakhstan. J. Comp. Int. High. Educ. 2024, 16, 219–235. [Google Scholar] [CrossRef]
- Biloshchytskyi, A.; Mukhatayev, A.; Kuchanskyi, O.; Omirbayev, S.; Andrashko, Y.; Biloshchytska, S. Method for Assessing Quality Assurance in Higher Education Institutions. TEM J. 2025, 372–386. [Google Scholar] [CrossRef]
- Brunner, J. J.; Tillett, A. Higher Education in Central Asia: The challenges of modernization. Working paper. n.d. [Google Scholar]
- Cabinet of Ministers of the Kyrgyz Republic. Decree No. 568 “On issues of developing the quality of education”. Ministry of Justice of the Kyrgyz Republic. 2024. Available online: https://cbd.minjust.gov.kg/.
-
Building Research Capacity at Universities; Springer Nature: Durham, NC, United States; ISBN, 2022.
- Dogochieva, T. Internationalization of Higher Education in Kyrgyzstan. Central Asian Journal of Education n.d. [Google Scholar]
- Elken, M.; Stensaker, B. Bounded innovation or agency drift? Developments in European higher education quality assurance. Assess. Evaluation High. Educ. 2022, 48, 321–332. [Google Scholar] [CrossRef]
- European Commission. TuCAHEA Reference Points and Guidelines. Tuning Project. 2016. Available online: https://tuningacademy.org/.
- European Commission. Higher Education in Kyrgyzstan. Education, Audiovisual and Culture Executive Agency. n.d. Available online: https://erasmus-plus.ec.europa.eu/.
- Friedland, R.; Alford, R. R. Bringing society back in: Symbols, practices, and institutional contradictions. In The new institutionalism in organizational analysis; Powell, W. W., DiMaggio, P. J., Eds.; University of Chicago Press, 1991; pp. 232–263. [Google Scholar]
- Government of the Kyrgyz Republic. Decree No. 671 “On approval of the Regulation on nostrification in the Kyrgyz Republic”. Ministry of Justice of the Kyrgyz Republic. 2016. Available online: https://cbd.minjust.gov.kg/.
- Hou, A.Y.C.; Hill, C.; Justiniano, D.; Lin, A.F.Y.; Tasi, S. Is employer engagement effective in external quality assurance of higher education? A paradigm shift or QA disruption from quality assurance perspectives in Asia. High. Educ. 2022, 84, 935–954. [Google Scholar] [CrossRef]
- Isaacs, A.K. Building a Higher Education Area in Central Asia: challenges and prospects. Tuning J. High. Educ. 2014, 2, 31–58. [Google Scholar] [CrossRef]
- Janssens, L.; Kuppens, T.; Mulà, I.; Staniskiene, E.; Zimmermann, A.B. Do European quality assurance frameworks support integration of transformative learning for sustainable development in higher education? Int. J. Sustain. High. Educ. 2022, 23, 148–173. [Google Scholar] [CrossRef]
- Kenesh, Jogorku. Law of the Kyrgyz Republic “About Education” No. 179. Ministry of Justice of the Kyrgyz Republic. 2023. Available online: https://cbd.minjust.gov.kg/.
-
II Global Trends in Tertiary Education QA; Karakhanyan, S., Kinser, K., Eds.; Walter de Gruyter GmbH: Berlin, Germany; ISBN, 2025. [Google Scholar]
- Ministry of Education and Science of the Kyrgyz Republic; Ministry of Education and Science. Statistical Report on Higher Education Institutions; Bishkek, 2010. [Google Scholar]
- Nikolaev, D.; Ambasz, D.; Malinovskiy, S.; Olszak-Olszewski, A.; Zavalina, P.; Álvarez, J.B. Towards Higher Education Excellence in Central Asia: A Roadmap for Improving the Quality of Education and Research through Regional Integration; World Bank: Washington, DC, United States; ISBN, 2023. [Google Scholar]
- Phillips, D.; Ochs, K. Processes of Policy Borrowing in Education: some explanatory and analytical devices. Comp. Educ. 2003, 39, 451–461. [Google Scholar] [CrossRef]
- Sánchez-Chaparro, T.; Remaud, B.; Gómez-Frías, V.; Duykaerts, C.; Jolly, A.-M. Benefits and challenges of cross-border quality assurance in higher education. A case study in engineering education in Europe. Qual. High. Educ. 2023, 28, 308–325. [Google Scholar] [CrossRef]
- Shadymanova, J.; Amsler, S. Institutional Strategies of Higher Education Reform in Post-Soviet Kyrgyzstan: Differentiating to Survive Between State and Market. In 25 Years of Transformations of Higher Education Systems in Post-Soviet Countries; Silova, I., Johnson, M. S., Heyneman, S. L., Eds.; Springer, 2018; pp. 203–223. [Google Scholar] [CrossRef]
-
The rise of quality assurance in Asian higher education; Shah, M., Do, Q. T. N., Eds.; Chandos Publishing, 2017. [Google Scholar]
-
Globalization on the Margins: Education and Post-Socialist Transformations in Central Asia, 2nd ed.; Silova, I., Niyozov, S., Eds.; Information Age Publishing, 2020. [Google Scholar]
-
The Global Politics of Educational Borrowing and Lending; Steiner-Khamsi, G., Ed.; Teachers College Press, 2004. [Google Scholar]
- Tight, M. Globalization and internationalization as frameworks for higher education research. Res. Pap. Educ. 2021, 36, 52–74. [Google Scholar] [CrossRef]
- Nikolaev, D.; Ambasz, D.; Malinovskiy, S.; Olszak-Olszewski, A.; Zavalina, P.; Álvarez, J.B. Towards Higher Education Excellence in Central Asia: A Roadmap for Improving the Quality of Education and Research through Regional Integration; World Bank: Washington, DC, United States, 2023. [Google Scholar]
Table 2.
Comparative Internationalization Strategies in Central Asia.
Table 2.
Comparative Internationalization Strategies in Central Asia.
| Dimension |
Kazakhstan |
Uzbekistan |
Kyrgyzstan |
| Funding Source |
State oil revenues |
State + FDI (branch campuses) |
Donor-dependent |
| Reform Strategy |
Top-down mandate (Bolashak) |
Special economic zones |
Project-based (TuCAHEA) |
| Legal Framework |
Unified Bologna law (2018) |
Dual system |
Hybrid decrees |
| Autonomy Level |
High (on paper) |
High (for branches) |
Low (despite Law 179) |
| Main Challenge |
Brain drain |
Quality control |
Sustainability after donors |
|
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