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Qualiopi 2026 framework: what changes in November

By International Horizon DevelopmentPublished on 7 min read

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What the decree says

Decree No 2026-728 of 1 August 2026 was published in French Official Journal No 0180 of 4 August 2026. It updates the national framework setting the assessment indicators for the seven quality criteria of vocational training. Training providers are certified against this framework, a certification known under the Qualiopi mark.

The text is short. Its Article 1 replaces part I of the annex to Chapter VI, Title I, Book III of Part Six of the French Labour Code, that is, the list of indicators. Its Article 2 sets entry into force on 1 November 2026. The decree contains no transitional provision.

Before signature, the text received the opinion of the National Commission for Collective Bargaining, Employment and Vocational Training on 8 July 2026. France compétences deliberated on it on 15 July 2026.

Certification is still required for providers that wish to receive funds from the funders listed in Article L. 6316-1 of the Labour Code. The seven criteria of Article R. 6316-1 do not change. What is rewritten is their indicators, that is, the items checked during an audit.

The indicators that change

We compared the new text with Decree No 2019-565 of 6 June 2019, which created the framework. The number of indicators rises from 32 to 33. Several existing indicators are clarified or made more demanding.

IndicatorCriterionWhat the 2026 text adds
1Public informationType of recognition, funding arrangements, and no statement likely to mislead the public
2Public informationCalculation methods for outcome indicators, set out transparently
7DesignProven ability to deliver the targeted certification, including as an authorised body
12SupportPrevention and handling of violence, harassment and discrimination
19Teaching resourcesChecking that remote modules are actually followed; a lead trainer above a set number of trainers
27Professional environmentTraceability of compliance in subcontracting agreements
32Feedback and complaintsContinuous improvement approach and risk analysis on training quality
33Feedback and complaintsNew indicator: learners' evaluation of content, for apprenticeship only

Other apprenticeship-specific indicators are also expanded, notably indicators 14, 15 and 20. Criterion 7, on feedback and complaints, now covers indicators 30 to 33.

Three changes that affect every provider

Distance learning must be evidenced

Indicator 19 previously covered making teaching resources available. The 2026 text adds a clear requirement: where modules are delivered remotely, the provider must check that learners actually follow them.

This mainly concerns virtual classrooms, online modules and blended programmes. Putting content online is no longer enough. The provider must be able to show that learners really followed it.

Indicator 19 also provides for a lead trainer per course above a certain number of trainers. That threshold is not in the decree: it is to be set by order of the minister responsible for vocational training.

Communication must not mislead

Indicator 1 already required accessible, detailed and verifiable information. It now requires that communication contain no misleading statement, in particular on access conditions, content, teaching methods, funding or the rights conferred by the training.

For artificial intelligence training, this point carries real weight. The market is full of promises of transformation, quantified productivity gains or obligations presented as absolute. A programme that promises what it cannot guarantee now exposes the provider to an audit finding.

In practice, a course page must say what the programme enables learners to acquire, under what conditions and with what possible funding. It must not suggest that a course confers a right it does not confer, or that funding is secured when it is not. Published outcome indicators, for their part, must state how they are calculated, under indicator 2.

This requirement also protects buyers. A company comparing several AI training offers now has a regulatory basis for demanding verifiable information.

Violence prevention enters the framework

Indicator 12 covered learner engagement and the prevention of drop-outs. It now requires the provider to ensure the prevention and handling of any situation of violence, including sexist and sexual violence, harassment or discrimination. This requirement applies to all categories of training, not only apprenticeships.

The decree does not specify the form these measures must take. The provider must be able to show at audit that it has planned how to prevent such situations and how to handle them if they occur, including during remote sessions.

The timeline at a glance

DateStep
6 June 2019Decree No 2019-565: framework created, 32 indicators
8 July 2026Opinion of the National Commission for Collective Bargaining, Employment and Vocational Training
15 July 2026France compétences deliberation
1 August 2026Decree No 2026-728 signed
4 August 2026Publication in Official Journal No 0180
1 November 2026The 33 indicators come into force

Between publication and entry into force, providers therefore have about three months to adapt their practices. The text grants no additional period.

What does not change

Decree No 2026-728 only affects part I of the annex. Part II, which describes the audit arrangements, is not amended by this text. As worded in the 2019 decree, it provides for three-year cycles, with an initial audit, a surveillance audit and, where applicable, a renewal audit. Non-conformities are still classified as minor or major.

In our reading, the absence of any transitional provision means that an audit carried out from 1 November 2026 relies on the new indicators, including a surveillance audit. A provider certified under the previous framework should therefore prepare now.

What it means for you

For a training provider

The timetable is tight: the new indicators apply from 1 November 2026. The priorities are marketing communication, evidence that remote modules are followed, and the arrangements for preventing violence and harassment.

Providers that use external trainers have one more point to address. Indicator 27 now requires compliance with the framework to be traceable in subcontracting agreements. A standard contract that says nothing about these obligations will need to be revised.

For a freelance trainer working as a subcontractor

A trainer working on behalf of a certified provider will see their contracts change. The commissioning provider must be able to show that it ensures its subcontractors comply with the framework. It will therefore ask for more precise commitments, for example on monitoring remote learners or passing on complaints.

This shift favours trainers who already document their practice: written objectives, up-to-date materials, monitoring records. It penalises improvised sessions that are hard to justify at audit. For a trainer running online sessions, evidence that learners actually take part becomes central to the relationship with the commissioning provider.

For a company buying training

The tightened framework provides new selection criteria. A certified provider will need to show how it checks that an online module is followed and how it handles a complaint. These questions are worth asking when consulting providers.

For a funder or an OPCO

The funders listed in Article L. 6316-1 of the Labour Code are named in the decree as concerned parties. The text strengthens the guarantees expected from the providers they fund, particularly on the accuracy of published information.

Our recommendation

At IHD, we design artificial intelligence training applied to technical professions, with assessable objectives and clear information on what each programme does, and does not, deliver. The 2026 framework moves in the same direction: it rewards providers that promise accurately and can prove what they do.

To understand the role of AI in energy professions, our guide to AI in engineering consultancies sets out practical uses and their limits. Our analysis of Article 4 of the AI Act on AI literacy completes the regulatory picture.

To train your teams, explore our AI training or contact us for a programme tailored to your business.

Frequently asked questions

When does the new Qualiopi framework come into force?

On 1 November 2026. Article 2 of Decree No 2026-728 of 1 August 2026 sets this date, and the decree contains no transitional provision.

How many indicators does the Qualiopi framework have from November 2026?

It has 33, spread across the seven criteria of Article R. 6316-1 of the French Labour Code. The text of 6 June 2019 had 32. The new indicator 33 applies only to apprenticeship training.

What changes for distance learning?

Indicator 19 now requires the provider to check that learners actually follow the modules delivered remotely. Making resources available is no longer enough: the provider must be able to show they were followed.

Does the new framework regulate how training providers advertise?

Yes. Indicator 1 adds that the provider's communication must contain no statement likely to mislead the public, in particular on content, funding or the rights conferred by the training.

Do the Qualiopi audit arrangements change?

Decree No 2026-728 only replaces part I of the Labour Code annex, that is, the indicators. The audit arrangements are set out in part II of that annex, which this decree does not amend.

Sources

Every fact in this article refers to one of these sources, consulted on the date shown.

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