Qualiopi for independent trainers: mandatory or not?

Updated 28 September 2026

Training OrganizationsCertification

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An independent trainer is not required to hold Qualiopi certification simply because they train. The obligation applies to providers funded by an OPCO, the Caisse des dépôts (CPF), the State, the regions, France Travail or Agefiph. If you work as a subcontractor for a certified organisation, you are in principle exempt, except for the CPF.

Who must be certified

Article L6316-1 of the French Labour Code requires certification of providers of actions contributing to skills development when they are funded by:

a skills operator (OPCO);
the commission referred to in article L6323-17-6 (professional transitions);
the State;
the regions;
the Caisse des dépôts et consignations, which manages the CPF;
France Travail;
Agefiph.

The test is therefore the source of funding, not the legal status. A trainer operating as a micro-entrepreneur, a single-member company or a sole proprietorship is subject to the same rule as an organisation with fifty employees as soon as they receive these funds directly. The requirement is assessed on the date of the agreement with the funder or of its funding approval (article R6316-8): that is when you must be certified.

Two points to distinguish:

The declaration of activity. Anyone who carries out training actions must file a declaration of activity upon the first training agreement or contract (article L6351-1). This obligation is independent of Qualiopi.
Funding not covered. A company that pays for your training from its own funds, without applying to an OPCO for coverage, or an individual who pays personally, are not funders within the meaning of article L6316-1.

The subcontracting case

Many independent trainers work on behalf of a training organisation. In this arrangement, it is the principal organisation that contracts with the client and receives the funding. Article L6316-1 targets providers funded by the funders it lists: the subcontractor, paid by the principal, is not directly concerned.

The National Quality Framework places the responsibility on the certified principal: when it uses subcontracting or umbrella employment (portage salarial), it must ensure compliance with the framework. Expect it to ask you for supporting documents (CV, evidence of skills updates, materials, participation in evaluations) and to govern your work through a contract.

Exception: the CPF. Since 1 April 2024, subcontractors delivering CPF-funded training must, with exceptions, be Qualiopi certified. Subcontractors under the micro-social scheme whose turnover stays below a ceiling set by the Mon Compte Formation general terms are not subject to this obligation. Check the ceiling in force and the other conditions (declaration of activity number, social and tax obligations up to date) in the Ministry's FAQ.

Micro-entrepreneurs: what changes and what does not

Micro-entrepreneur status does not create a general exemption. If you directly invoice training covered by an OPCO or funded by the CPF, you must be certified, whatever your turnover.

What changes is the scale of the audit. The audit rules set by order provide for a duration that varies with the turnover related to the training activity. An independent trainer with modest turnover therefore undergoes a shorter audit than a large organisation, which affects the certifier's quote. The framework requirements, however, remain the same: public information, appropriate design, monitoring and assessment, resources, skills, monitoring of the environment, collection of feedback and complaints (article R6316-1).

Costs and benefits

On the cost side:

audit fees invoiced by an accredited certification body, for the initial audit, the surveillance audit and then renewal, over a three-year cycle (articles L6316-2 and R6316-2);
time to achieve and then maintain compliance: programmes, questionnaires, complaints register, documented monitoring;
possibly support and tools.

On the benefit side:

direct access to OPCO, CPF, regional, France Travail and Agefiph funding;
the ability to contract directly with companies that apply for funding;
the freedom to work without depending on a principal;
the ability to act as a subcontractor on CPF training, if you do not fall under the micro-social exception.

The calculation depends on the share of your turnover that goes, or could go, through funds covered by article L6316-1. If that share is marginal, certification is mainly a cost. If it is significant, or if you are losing contracts for lack of certification, it becomes an investment.

Alternatives to certification

Work as a subcontractor for one or more certified organisations, accepting their documentation requirements and their margin.
Target clients who pay from their own funds, in particular companies that do not apply for funding, or individuals.
Work through umbrella employment (portage salarial) for certified organisations: the framework provides for this case and assigns its oversight to the certified provider.
Prepare for certification gradually, by adopting the framework's practices now, which makes it easier both to meet principals' requirements and to pass a later audit.

Key takeaways

The Qualiopi obligation depends on the source of funding, not on the trainer's status (article L6316-1).
A subcontractor of a certified organisation is not directly covered, but the principal must ensure that it complies with the framework.
For the CPF, subcontractors have had to be certified since 1 April 2024, with an exception for the micro-social scheme below a turnover ceiling.
The declaration of activity remains mandatory in all cases.
A micro-entrepreneur undergoes a shorter audit, but against the same requirements.

Sources

If certification becomes necessary for your business, the Mentivis administrative team supports you through the Qualiopi process: mock audit, action plan, evidence file, audit preparation. See Qualiopi support

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Advisory: Qualiopi support