Qualiopi surveillance audit: timing and preparation
Updated
The Qualiopi surveillance audit takes place between the 14th and the 22nd month after the certification is obtained, under the Order of 6 June 2019. It checks that you continue to apply the National Quality Framework. It is conducted remotely as a rule. A major non-conformity must be corrected within three months, failing which the certification is suspended.
Where the surveillance audit sits in the cycle
The Qualiopi certification is issued for three years (article R6316-2 of the French Labour Code). The cycle includes three audits:
- the initial audit, which leads to the issuing of the certification;
- the surveillance audit, which ensures the framework is being properly applied;
- the renewal audit, which takes place during the third year, before the certification expires, if you wish to keep it.
The Order of 6 June 2019 on audit procedures sets the surveillance audit window between the 14th and the 22nd month following the date the certification was obtained. In practice, if your certificate is dated January 2026, the surveillance audit will take place between March and November 2027. Your certifier schedules it with you: do not wait, get in touch as soon as the window opens to choose a date that leaves you time to prepare.
Remote or on site
The surveillance audit is conducted remotely as a rule. The Order nevertheless provides for it to take place on site in certain cases, in particular when the certifier has received reports, when the risk analysis from the previous audit justifies it, or to sample one or more sites of a multi-site organisation. Your certifier tells you which format applies when scheduling the audit.
Remotely, the audit relies on video interviews and on screen or document sharing. The quality of your digital filing therefore matters as much as the content of the evidence: the auditor must be able to reach the right document quickly.
What the auditor checks
The initial audit checks that your processes exist. The surveillance audit checks that they work over time. The auditor therefore focuses on what has happened since certification:
- Sessions delivered. Programmes, learner positioning, attendance sheets, assessments of learning, certificates.
- Results indicators. Published information (satisfaction rates, success rates where relevant) must be up to date and consistent with your data.
- Continuous improvement. Have stakeholder feedback and complaints been collected, analysed and followed by action?
- Monitoring. Legal monitoring, monitoring of skills and occupations, educational and technological monitoring: the auditor looks for dated records and how you used them.
- Staff skills. Training attended, updates, trainer evaluation.
- Subcontracting. If you use subcontractors, how you ensure they comply with the framework.
- Minor non-conformities from the previous audit. They must have been addressed.
Decree no. 2026-728 of 1 August 2026 updates the national framework and enters into force on 1 November 2026. If your surveillance audit falls after that date, ask your certifier which version of the framework and reading guide it will apply, and review the amended indicators.
How non-conformities are handled
Each applicable indicator is assessed as compliant, as a minor non-conformity or as a major non-conformity.
- Minor non-conformity. You must correct it. If it has not been cleared by the next audit, it is reclassified as a major non-conformity.
- Major non-conformity. Corrective actions must be effective within three months and verified by the certifier before any decision. Otherwise, the certifier notifies the suspension of the certification. The suspension is lifted when you provide evidence of the return to compliance and the major non-conformities are cleared.
A suspension has consequences: the certification requirement is assessed on the date of the agreement with the funder or of its funding approval (article R6316-8). A certification suspended at the wrong time can therefore block funding.
Preparing month by month
The schedule below starts from the date the certification was obtained.
- Months 1 to 3. Address the minor non-conformities from the initial audit. Record each corrective action with its date and evidence.
- Months 4 to 9. Keep the system running: collection of feedback, complaints register, documented monitoring, updating of published indicators. A quarterly review is enough, provided you keep a record of it.
- Months 10 to 12. Carry out an internal audit or a mock audit covering all applicable indicators, based on sessions actually delivered.
- Months 12 to 13. Contact your certifier to set the date, within the 14th to 22nd month window. Update your action plan.
- Two to three weeks before the audit. Check the evidence folder structure, test the video conferencing tool, prepare the people who will be interviewed.
- After the audit. Plan corrective actions without delay, keeping in mind the three-month deadline for a major non-conformity.
Common mistakes
- Treating the certification as a given. The auditor expects evidence produced since the initial audit, not the original file.
- Forgetting minor non-conformities. If not cleared, they become major.
- Publishing outdated results indicators. Figures that have not been updated on the website or in sales documents are easy to spot.
- Monitoring without follow-through. A list of subscriptions is not enough: show what monitoring has changed in your services.
- Booking the audit too late. At the end of the window, auditor availability shrinks, and so does the margin for corrections.
- Ignoring changes to the framework. A change of version between two audits alters what is expected.
Key takeaways
- The surveillance audit takes place between the 14th and the 22nd month after the certification is obtained.
- It is conducted remotely as a rule, except in the cases provided for by the Order of 6 June 2019.
- It checks that the quality system works over time, with recent evidence.
- An uncleared minor non-conformity becomes major; a major one must be corrected within three months, otherwise the certification is suspended.
- The framework updated by the decree of 1 August 2026 enters into force on 1 November 2026.
Sources
- French Labour Code, article R6316-2 (three-year duration)
- French Labour Code, article R6316-8 (date on which certification is assessed)
- Order of 6 June 2019 on audit procedures
- Order of 31 May 2023 on various measures regarding quality certification
- Decree no. 2026-728 of 1 August 2026 on the national quality framework
- French Ministry of Labour, reading guide to the national quality framework
A surveillance audit is prepared over time, with dated evidence and a quality system that works. The Mentivis administrative team supports training organisations in their Qualiopi process: mock audit, action plan, evidence file, audit preparation. See Qualiopi support
Read also: How to obtain the Qualiopi certification · How to prepare and pass a Qualiopi renewal audit · How to manage training subcontracting legally