CPF and subcontracting: the Qualiopi rules you cannot afford to miss

Where this tightening comes from

Between 2020 and 2023, the CPF fed a small industry of arrangements. A Qualiopi-certified organization would sign up on Mon Compte Formation, then pass the entire service on to non-certified subcontractors, often at the end of cascading chains impossible to trace. The listed provider was no longer training anyone. It collected the money, it redistributed it, it served as a front.

Decree no. 2023-1350 of 28 December 2023, supplemented by the so-called Pareto order of 3 January 2024, targets precisely these circuits. It sets out four requirements: the subcontractor must be Qualiopi-certified, the share of CPF revenue that may be subcontracted is capped at 80%, cascade subcontracting is prohibited, and an annual declaration of the use of subcontracting on EDOF becomes a compliance milestone. The provisions of Article 2 apply to new contracts concluded on or after 1 April 2024.

The subcontractor's Qualiopi: the rule and its only exception

The principle no longer allows for interpretation. For any CPF-eligible training action, the subcontractor must hold Qualiopi certification, exactly like the listed prime contractor. Delegating delivery to a non-certified provider while hiding behind your own certificate is no longer acceptable.

There is a single exception, and it is narrow. A subcontractor under the micro-social regime (micro-entrepreneur) whose annual revenue remains below 77,700 € excluding tax is exempt from the Qualiopi obligation and from the accreditation requirements. Do not turn it into an architecture. This door is meant for the occasional subcontractor who delivers a portion of the training, not for circumvention at scale. An auditor who discovers a fleet of micro-entrepreneurs handling the bulk of your sessions will not see an exception. They will see a scheme, and they will document it as such.

The 80/20 cap: on which revenue, exactly

This is the most frequent mistake, and it is a costly one. The 80% cap is not calculated on the company's total revenue. It applies solely to the revenue generated on Mon Compte Formation, in other words the tuition fees invoiced to the Caisse des Dépôts. This is the so-called Pareto rule of the order of 3 January 2024.

In plain terms: at least 20% of your CPF delivery must remain in-house, with your own trainers. The classic trap is to discover the ratio at year-end close, with contracts signed and services already committed. Too late to put things right. Manage it continuously, on your Mon Compte Formation revenue and that alone. For the first declaration campaign, the reference period is exceptional: nine months, from 1 April to 31 December 2024.

Cascade prohibited and EDOF declaration mandatory

Two rules that are underestimated, at one's peril. First, the cascade is prohibited: your subcontractor cannot re-subcontract the action you entrusted to it. The prohibition must appear in black and white in the contract, and be verifiable in practice, not only in the clauses.

Second, the annual declaration on EDOF concerns ALL listed organizations, whether or not they have subcontracted. Not having subcontracted exempts you from nothing: in that case you declare zero use. The first campaign opened on 12 June 2025 and closes on 30 November 2025 for the 2024 financial year. Forgetting to declare is grounds for sanction on the same footing as exceeding the cap, and it feeds the targeting of the 1,000 inspections scheduled for 2025.

What the auditor looks at, on both sides

Expect a two-sided audit scope. At the prime contractor's, the Qualiopi auditor scrutinizes indicator 27: the selection process, the written contract, the monitoring, the assessment of subcontractor quality. At the subcontractor's, they check the activity declaration number, the Qualiopi certification, compliance with legal, social and tax obligations, and the actual teaching capacity, not the capacity that is advertised.

Here is the point that changes everything: a compliant subcontractor does not cover your liability. The prime contractor remains solely accountable for quality and compliance to the Caisse des Dépôts and to the auditor. A failing subcontractor can get the party that engaged it delisted. So lock down the contract BEFORE any work begins. It must specify the tasks entrusted, the content and the certification outcome of the training, the resources mobilized, the conditions of delivery and monitoring, the duration and the delivery period, as well as the amount of the service. An incomplete contract is, in practice, the first point of non-conformity raised in an audit.

A compliant subcontractor does not cover your liability: the prime contractor remains solely accountable for compliance, and it is the prime contractor that gets delisted.