VAT and training organizations in France: the exemption, its conditions and effects

A private training organization is not exempt from VAT by default. The exemption in article 261, 4, 4° a of the French General Tax Code requires a certificate issued by the authorities, requested from the DREETS (the regional labour and employment directorate). It is neither mandatory nor automatic: without a request, the organization charges VAT. Since a tax ruling of 23 September 2026, apprenticeship centres (CFA) no longer need the certificate for apprenticeship, but still do for continuing training. Before applying, weigh the effects: the exemption removes the right to recover VAT on purchases and can make the organization liable for payroll tax.

Who can be exempt

The exemption covers continuing vocational training as defined by the French Labour Code and its implementing texts. It applies to:

• public-law entities that provide continuing vocational training;
• private entities (companies, associations, self-employed trainers) holding a certificate recognising that they operate within the framework of continuing vocational training.

It covers training and the services closely linked to it. The organization's ancillary activities, such as consulting, selling books or writing articles, remain subject to VAT.

How to obtain the certificate

The request is made on form no. 3511-SD (cerfa no. 10219), sent to the regional control service of the DREETS covering the organization's main establishment. The DREETS has three months to decide; without an answer within that period, the request is deemed accepted. The exemption applies from the date the authorities receive the request, not from the date of the decision.

An organization that does not request the certificate remains subject to VAT under the ordinary rules: it is a management choice, not an obligation.

Apprenticeship centres (CFA)

For apprenticeship training, a CFA is exempt from VAT as technical and vocational education, without having to request a certificate from the DREETS (tax ruling BOI-RES-TVA-000272 of 23 September 2026). Two conditions apply: the services must fall under apprenticeship as defined by the Labour Code, and the provider must be a CFA with a registered activity declaration.

If it also provides continuing training, the CFA must request the certificate for that part of its activity.

Exempt or not: what changes

• Invoices are issued without VAT, stating the exemption and its legal basis.
• VAT on purchases (premises, equipment, subcontracting, software) can no longer be recovered: it becomes a cost.
• Payroll tax is due from employers that are not subject to VAT on at least 90% of their turnover (article 231 of the General Tax Code). An exempt organization with employees generally becomes liable for it.
• Clients are not all affected the same way. The exemption mainly benefits those who cannot recover VAT: individuals funded through the CPF, associations, public buyers. For a VAT-registered business client, which recovers VAT, the difference is neutral.

The right choice therefore depends on the client base, the weight of purchases and the payroll. It should be calculated before applying.

From 1 January 2027

French VAT rules move from the General Tax Code to the Code of Taxes on Goods and Services (CIBS), with no change in substance: articles are renumbered, the rules stay the same. The exemption for continuing vocational training is maintained under the same conditions. Transitional measures allow the former references to remain on invoices until 30 June 2028.

Key takeaways

• A private organization's VAT exemption is not automatic: it requires a DREETS certificate (form 3511-SD).
• The DREETS has three months to answer; silence means approval, and the exemption runs from receipt of the request.
• Ancillary activities (consulting, selling books) remain subject to VAT.
• CFAs are exempt without a certificate for apprenticeship, but not for their continuing training.
• Exemption removes VAT recovery on purchases and can make the organization liable for payroll tax.
• On 1 January 2027, the texts change code, not content.

Sources

• French General Tax Code, article 261
• Form no. 3511-SD, certificate request
• DREETS Corse, possible VAT exemption for training organizations
• BOFiP, VAT and education (BOI-TVA-CHAMP-30-10-20-50)
• BOFiP, ruling on VAT for CFA apprenticeship training (23 September 2026)
• BOFiP, payroll tax, taxable persons
• Weblex, VAT recodification in the CIBS on 1 January 2027

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Mentivis assesses the VAT regime best suited to your clients as part of setting up a training organization, and handles day-to-day administration through outsourcing.

Further reading: How to declare a vocational training activity · Training activity report (BPF) · DREETS inspection of a training organization