Indicator 26: making your training genuinely accessible

An obligation of means, not of results

Let us clear up the number-one misunderstanding in audits right away. Indicator 26 does not require that you have already welcomed learners with a disability, nor that every course be accessible to every disability. It requires that the provider mobilise the expertise, tools and networks needed to welcome, support, train or refer these audiences. An obligation of means, and of documentation.

The indicator covers the four categories of actions contributing to skills development: training, skills assessments (bilans de compétences), VAE, and apprenticeship. No one is exempt. And a track record with no RQTH trainee exempts you from nothing: you must demonstrate conformity even if no relevant learner has ever crossed your threshold.

The auditor is looking for one specific thing: a documented process that is ready to be triggered. An identified referent, an intake procedure that raises the question of need upstream, adaptation options that can be mobilised case by case. A dormant, but operational, arrangement.

Why this indicator is unforgiving

Here is what sets 26 apart from almost every other indicator in the RNQ, and what too many directors discover on the morning of the audit: it can never give rise to a minor non-conformity. The slightest gap tips straight into a major non-conformity.

What follows is mechanical. In the event of a major non-conformity, the organisation has three months to implement corrective actions and provide proof of them, on pain of suspension of its Qualiopi certification. Three months slip by fast when you have to appoint a referent, train them, build a network and document everything after the fact, under pressure.

The disability referent, keystone of the arrangement

The referent is the linchpin. Another stubborn myth: this is neither a dedicated position nor a specialised diploma. The legal threshold of 250 employees (article L5213-6-1 of the Labour Code), above which a referent becomes mandatory, concerns only a minority of organisations.

In a one-person structure, the director can perfectly well be their own referent. The auditor does not check that a position exists, but that the referent is identified, reachable, and can show that they have built up their skills: a training course, a webinar, use of Agefiph's resources.

On this point, the Ressource Handicap Formation (RHF) in your region, run by Agefiph, is your best ally, and it is free. It helps you build your process, trains your referent, and on its own counts as solid proof that you have mobilised your network. Not calling on it, when it exists precisely for you, amounts to leaving money on the table.

Waiting for your first RQTH trainee before getting organised means you have already failed.

The invisible first, the ramp second

Say disability in training, and the image of a wheelchair springs to mind, and with it the question of premises accessibility. Wrong focus. In France, roughly 80% of disabilities are invisible: dys disorders, autism, ADHD, psychological disorders, chronic illnesses, hearing loss. Nearly 9.5 million people.

The underlying issue, then, is not the access ramp, it is pedagogical adaptation: an adjusted pace, legible materials, extra time, accessible digital tools. Sylvie's case proves it. The accessibility register for her premises could have been impeccable, and a single untagged PDF was enough to exclude her. A video call with no subtitles produces the same result.

Context gives the requirement its weight. In 2024, 3.3 million people were administratively recognised as disabled, that is 8.1% of 15-64 year-olds, with an unemployment rate of 12%, almost double that of the general population. Training is a major lever for inclusion, provided it does not add one more barrier.

What the RNQ V9 changes in 2026

Version 9 of the standard, applicable in 2026, does not overturn the logic of the indicator. It tightens how it is read on one point: traceability. The requirement now bears explicitly on a referent who is identified, trained and reachable, and on a formalised procedure for mobilising partners (Agefiph, Cap emploi, RHF), with proof that the written process is genuinely applied on the ground.

In practical terms, every piece of evidence is dated, named and archived. An up-to-date list of partners, an intake procedure, the referent's CV or training certificate, examples of pedagogical adaptations, the premises accessibility register. A referent with no trace of training or applied procedure moves into major non-conformity, even when the intention is there. Intention cannot be proven, dated documents can.