The new Qualiopi framework: 33 indicators from 1 November 2026

"V10" still does not exist, and that is no longer the point

Let us put the hierarchy of texts back the right way up, because the market blurred it for two years. The binding framework, the one against which an auditor ticks compliant or non-compliant, does not live in a decree: it occupies part I of the annex to chapter VI of title I of book III of part six of the Labour Code. The 2019 decree wrote it in, the 2026 decree rewrites it. Until 31 October 2026 that is the wording from decree no. 2019-565 of 6 June 2019 and its 32 indicators. From 1 November, the wording from decree no. 2026-728 and its 33 indicators.

The Reading Guide, whose version 9 dates from 8 January 2024, is not the framework. It is an interpretation document: it sets out the level of proof expected, it creates no indicator. Hence the commercial misunderstanding around "V10", a label that never titled a single official text and that served as a sales argument throughout the consultation period.

The vocabulary debate is settled by one plain fact: there is now a decree. You are no longer following announcements, you are reading an annex. A new reading guide is expected to align the evidence expectations, but its absence suspends nothing. The decree applies on 1 November, guide or no guide.

Thirteen rewritten indicators, one more than the published counts

The decree publishes no table of its own amendments. It replaces the annex as a block, which forces you to do the comparison yourself. C2RP counts twelve amended indicators, the Lacour law firm speaks of about a dozen, and the firm Qualiview names them one by one: 1, 2, 7, 12, 14, 15, 19, 20, 27, 30, 31 and 32. We set all thirty-two indicators word for word against both annexes: there are thirteen. The twelve on that list, plus indicator 3, which those counts treat as unchanged even though its wording gains "en particulier les poursuites d'études". Nineteen indicators are carried over verbatim. The additions all pull the same way: what used to be an intention becomes a verifiable requirement.

Indicator 1, public information. It is the most audited indicator in the framework, and the decree adds to it a whole sentence that was absent in 2019: "Its communications shall contain nothing liable to mislead the public, in particular as to entry conditions, content, teaching arrangements, the funding of the courses, or the rights or absence of rights to further study conferred by the course being prepared." The list of information owed also grows by the type of recognition attached to the course and the funding arrangements. Your brochure, your pricing page and your marketing posts become audit exhibits: funding presented as secured, or a course sold as opening onto further study that it does not open, now fall under an indicator.

Indicator 2, results. They must now be published "specifying transparently how they are calculated, or relying on existing schemes". Displaying a 92 % pass rate is no longer enough: you have to state the denominator, and the period. Indicator 3, certifications: "onward pathways" was already in the 2019 wording, the decree inserts four words, "in particular further study".

Indicator 19, teaching resources. Two additions. For modules delivered at a distance, the provider "checks that learners actually follow them". And beyond a number of trainers per course set by ministerial order, it must have a pedagogical coordinator responsible for coordination. Indicator 20, governance: to mobility support, the disability officer and the improvement council are added the quality of course governance and "the participation of apprentices, trainers and companies in its governance", plus reinforced supervision if the share of hours delivered by permanent staff falls below a threshold, itself referred to an order.

Indicator 27, subcontracting. The principal no longer merely ensures the subcontractor complies: it "ensures traceability of that compliance in the subcontracting agreements". The contract becomes an audit exhibit in its own right. Indicator 32, finally: the "improvement measures" of 2019 become a "continuous improvement approach", together with "an analysis of the risks to the quality of the training delivered". The word risk enters the framework.

The decree does not publish the list of its own amendments. Reconciling the two annexes, indicator by indicator, is on you.

Violence, harassment, discrimination: the addition few providers saw coming

This is the heaviest change in workload, and the least discussed. Indicator 12 is no longer limited to preventing learners from dropping out. It adds a sentence: "It ensures the prevention and handling of any situation of violence, including sexist and sexual violence, harassment or discrimination in the course of their training."

Indicator 14 goes further still, and nobody is talking about it. Socio-professional, educational and citizenship support was a single sentence from 2019; the decree adds a second: "It shall have a procedure for handling without delay any breakdown arising from difficulties, violence or discrimination suffered by the apprentice in training or at the host company." Without delay, and reaching into the host company: it is the hardest obligation of the set, the only one that makes you handle what happens on someone else's premises. The wording targets the apprentice, the reading guide places this support among the duties of apprentice training centres, and the firm Qualiview classes indicator 14 among those that concern apprenticeship.

Indicator 15 goes further on the apprenticeship side. Informing apprentices of their rights and of health and safety rules becomes "reinforced where they are minors". Added to it: information on "the support, prevention and reporting arrangements for situations of violence", the people who can help them, the contact details of the apprenticeship ombudsman, and the duty to "report malfunctions to the labour inspectorate".

Translate that into evidence. Prevention and handling are two separate requirements, and handling is what is missing almost everywhere: what actually happens the day a learner reports something? A paragraph in the internal rules will not survive ten minutes in an audit. You need a written procedure, a named and reachable contact, information that was genuinely handed over, and a record of what was done with the reports received. For apprentice training centres, indicator 14 adds a deadline constraint: an entry point that works outside class hours, and a named route reaching into the host company.

Indicator 33: evaluating the teaching, not the satisfaction

The only genuinely new indicator closes criterion 7, which goes from 3 to 4 indicators. In full: "The provider puts in place a system for learners to evaluate content and teaching, separate from the general satisfaction survey, the results of which are shared with the teaching teams and give rise to a formalised continuous improvement approach, whose effectiveness it measures periodically."

One thing first, before building anything: C2RP presents indicator 33 as specific to apprentice training centres, and the Lacour law firm reads it as applying to those centres alone, under the apprenticeship category of point 4 of article L. 6313-1 of the Labour Code. The annex itself sets the applicability of each indicator by type of action, in a column we could not read reliably on Legifrance: that scope is the commentators' reading, not ours. If you do not train apprentices, indicator 33 asks nothing of you for now.

For an apprentice training centre, the expensive word is "separate". Your end-of-course questionnaire, the one that scores the welcome, the room, the pace and the teaching out of five stars, does not answer indicator 33. You need a second system, aimed at content and teaching, with four pieces of evidence behind it: the collection, the sharing with teaching teams, the decisions that follow, and the periodic measurement of their effectiveness. That last one is what providers forget.

That said, it is the annex's applicability column that governs, not the commentary. Open it for your own scope before concluding you are not concerned, and keep a record of the reading you make of it: that is what the auditor will argue with, not the news item that reassured you.

A satisfaction survey is not an evaluation of the teaching. Indicator 33 asks for both.

Your certificate holds, your next audit does not

A word on timing, because it is the first question asked. The decree runs to three articles and says nothing about the fate of existing certificates: its article 2 sets entry into force at 1 November 2026, and that is all. The rest is the commentators' reading, consistent but absent from the text. For the Lacour law firm, a certification that is currently valid is not called into question by the mere publication of the decree; compliance will be checked at the next audit scheduled after that date. C2RP writes for its part that audits carried out from 1 November 2026 will rely on the new provisions. In other words, the date that concerns you is not 1 November, it is the date of your next visit.

Two provisions remain pending. The number of trainers that triggers the pedagogical coordinator of indicator 19, and the threshold of hours delivered by permanent staff in indicator 20. Both are referred to an order of the minister responsible for vocational training. Until it is published, nobody can tell you which side of the threshold you sit on, and anyone selling you a figure is making it up.

The useful order of work comes in three stages. First the violence and harassment procedure, because in most providers it starts from nothing and because it engages your liability well beyond Qualiopi. Then the calculation method behind your results indicators and your subcontracting agreements: those are quick documentary fixes, a day's work. Finally, if apprenticeship concerns you, the system for evaluating teaching, because it needs a full training cycle to produce its first evidence. A provider who waits for the new reading guide before starting will have two weeks left.