Setting up an online training organization in France (100% remote)
Updated
A 100% remote training organization has the same obligations as any training organization in France: activity declaration, an annual training activity report (BPF), and Qualiopi certification to access public or pooled funding. On top of that come the rules for distance learning: the programme provides technical and pedagogical assistance, informs learners about remote activities and their average duration, and includes assessments (article D6313-3-1 of the French Labour Code). To be paid by a funder, you must prove delivery with records that go beyond login data.
A training action like any other
The Labour Code defines a training action (action de formation) as a learning path that leads to a professional objective. It states that it can be delivered wholly or partly at a distance (article L6313-2). An online course therefore falls under the same regime as a classroom course: same procedures, same controls.
The common obligations
- The activity declaration (déclaration d'activité). It is filed as soon as the first training agreement or contract is signed, and within three months at the latest (article L6351-1). The ground for refusal based on the lack of premises, in force since June 2026, concerns apprenticeship training actions.
- The training activity report (bilan pédagogique et financier, BPF). It is filed every year (article L6352-11).
- Qualiopi. Certification is mandatory if your courses are funded by an OPCO (skills operator), the State, a region, the Caisse des Dépôts, France Travail or Agefiph (article L6316-1). A course paid for directly by a company or an individual does not require it.
- Contractual documents. Training agreement or contract and detailed programme: distance learning does not exempt you from them.
The three requirements specific to distance learning
Since 1 January 2019, article D6313-3-1 requires, for any action delivered wholly or partly at a distance:
- Appropriate technical and pedagogical assistance to support the learner. In practice: an identified tutor, a contact channel, a stated response time, technical support.
- Information on the remote activities and their average duration. Each module states what the learner must do and how long it takes.
- Assessments that mark the stages of the action or conclude it: quizzes, marked assignments, practical exercises, final assessment.
A course sold as open access to videos, with no tutoring and no assessment, does not meet these requirements.
Proving delivery: logins are not enough
The DREETS of Corsica points out that a login record alone does not justify the training hours. It relies on a ruling of the Toulouse administrative court of 2 November 2023: the organization must also prove the support provided and the assessments organized.
The Mon Compte Formation terms of use (version 15, May 2026) list the documents the Caisse des Dépôts may request for a distance course:
- login credentials and attendance records, with durations and times;
- evidence of work completed remotely;
- evidence of support: reminders encouraging the learner to log in, information on the work to be done;
- evidence of technical and pedagogical assistance;
- evidence that milestones and assessments were completed.
These documents may be requested for five years. They must also make it possible to identify with certainty the trainee who took the course.
Controls are tightening. Since 27 June 2026, training control officers may use an assumed identity (identité d'emprunt) to check an organization that trains at a distance or takes enrolments online (article L6362-8-1). A decree must set the conditions. The same law allows controls by sampling and extends the recovery period to ten years, in particular in cases of fraud.
What your platform must allow
The texts cited here do not require any particular tool. But the obligations above assume that your learning platform (LMS) can:
- identify each learner reliably;
- record time-stamped activity data, not just logins;
- track progress by learning milestones;
- store assessment results;
- keep the history of exchanges with the tutor and of reminders;
- export this data per learner and keep it for at least five years.
Check these functions before choosing a tool. Mentivis publishes its own platform, MentivisOS; the same criteria apply to any solution.
Mon Compte Formation: the rules for distance learning
Listing follows the general rules described in our guide EDOF: listing your courses on Mon Compte Formation. Several points directly concern online courses:
- The entry date. Sending login details and connection tests do not count as entry into training. Entry is the date on which the trainee actually starts.
- The completion rate. At a distance, it is measured by the learning or assessment milestones completed, which the organization must be able to trace.
- Drop-outs. Below 25% attendance, the organization receives 25% of the price; between 25% and 80%, payment pro rata; above 80%, the full price. These payments require that fewer than 10% of trainees drop out before 25% of the course, and a reminder system. Otherwise, the organization may lose the advance payment scheme and face reinforced checks.
- Cold canvassing. Prospecting CPF holders by phone, email or social networks is prohibited.
Qualiopi applied to distance learning
The seven criteria of the national quality framework (article R6316-1) apply as they stand. Three require particular attention online: public information on services, access times and results; adapting reception, support, monitoring and assessment arrangements; and the adequacy of teaching, technical and supervisory resources. The framework updated by the decree of 1 August 2026 applies to audits from 1 November 2026: check the indicators in the current reading guide.
What about an online CFA?
Article L6211-2 allows the teaching of an apprentice training centre (CFA) to be delivered wholly or partly at a distance. Training in the centre represents at least 25% of the contract duration. However, since 27 June 2026, registration of the activity declaration may be refused to an organization that does not have premises allowing it to deliver apprenticeship actions (article L6351-3). A CFA can therefore teach at a distance, but not without premises. Its articles of association must also mention the apprenticeship activity.
Business model points
- Tutoring is a recurring cost. Pedagogical assistance requires human time, which grows with the number of learners.
- Drop-outs weigh on CPF-funded revenue, because of pro rata payment.
- Pricing follows CPF rules: the holder's 150 euro contribution since April 2026, unless exempt, and a 1,500 euro cap for a Specific Register certification.
- Customer acquisition must work without cold canvassing of CPF holders.
Frequently asked questions
Can you set up a training organization that works only online? Yes. The procedures are those of any training organization, plus the requirements of article D6313-3-1.
Do you need premises? The refusal ground based on premises concerns apprenticeship training actions. It does not apply to other actions.
Can a 100% e-learning course without a tutor be funded? Not as it stands. Technical and pedagogical assistance is part of the regulatory definition of a distance action.
What evidence should you keep? Time-stamped activity data, assessment results, exchanges with the tutor, reminders, attendance certificates. Keep them for at least five years.
Can a CFA be 100% remote? Its teaching can be, but it must have suitable premises for its declaration to be registered.
Key takeaways
- Same obligations as any training organization: activity declaration, BPF, Qualiopi for public or pooled funding.
- Three requirements specific to distance learning: assistance, information on activities and their duration, assessments.
- Logins alone do not prove delivery: you must prove support and assessments.
- On Mon Compte Formation, entry is the actual start and the completion rate is measured by milestones.
- A CFA can teach at a distance, but must have premises.
Sources
- French Labour Code, article D6313-3-1 (distance learning)
- French Labour Code, article L6313-2 (training action)
- French Labour Code, article L6351-1 (activity declaration)
- French Labour Code, article L6351-3 (refusal of registration)
- French Labour Code, article L6352-11 (training activity report)
- French Labour Code, article L6316-1 (Qualiopi)
- French Labour Code, article R6316-1 (quality criteria)
- French Labour Code, article L6211-2 (apprenticeship)
- DREETS Corsica, distance learning: the regulatory framework
- Mon Compte Formation specific terms for training organizations, version 15, May 2026
- Centre Inffo, strengthened investigation and control powers (29 June 2026)
- Mon Compte Formation, the mandatory financial contribution
- Mon Compte Formation, 2026 caps
Activity declaration, Qualiopi, funding listings: Mentivis's administrative team supports setting up training organizations, including those that train at a distance.
Further reading: Activity declaration of a training organization · EDOF: listing your courses on Mon Compte Formation · How to set up a CFA in France in 2026