NDA cancellation in 2026: what France's anti-fraud law changes for training organizations

Since June 27, 2026, obtaining or keeping a training activity declaration number (numéro de déclaration d’activité, or NDA) has become harder for certain training organization profiles. Law n° 2026-534 of June 25, 2026 on combating social and fiscal fraud, published in the Official Journal on June 26, 2026, adds three new grounds for refusing registration and one new cancellation cause, while also strengthening the powers of control agents. Here’s what actually changes, and why every training organization founder should now check their own record before filing.

An anti-fraud law that tightens control over professional training

The June 25, 2026 law contains 115 articles and primarily targets fraud against public and social benefits, with a section specifically dedicated to the personal training account (CPF) and apprenticeship — two schemes identified over the past several years as favored entry points for organizations created in a purely opportunistic logic. Three articles directly concern the activity declaration of training organizations: articles 45, 72, and 73.

This reform follows on from decree n° 2025-728 of July 29, 2025, in force since August 1, 2025, which had already simplified the a posteriori control procedure for training organizations by removing the mandatory prior administrative claim. The administration’s message has been consistent for a year now: control faster, and above all, block access to the system for those who have already abused it.

Three new grounds for refusing registration (article 72)

Article 72 amends the legal framework for the activity declaration set out in articles L. 6351-1 and following of the French Labor Code by adding three cases in which the regional authority (DREETS) can now refuse to register a declaration.

1. A director already hit with an NDA cancellation within the past four years

This is the most discussed measure. Until now, a director whose organization had its registration cancelled could, in practice, set up a new structure — new company name, new SIREN number — and refile an activity declaration without that history appearing in the file. The law closes this loophole: it is now the person, de jure or de facto director, who carries the prior offense, not just the structure that was sanctioned. Regardless of the new structure’s legal form, the administration can refuse registration if the director had an NDA cancelled within the four years preceding the request.

2. A director with an unpaid fund repayment

Second ground: a director who, within the preceding five years, was subject to a decision rejecting expenses and requiring a fund repayment following a DREETS audit, without having proven settlement of the amount owed, can now be refused registration of a new activity declaration. The logic is the same: prevent a debt owed to the administration from simply disappearing because its debtor changes legal wrapper.

3. Lack of premises suited to apprenticeship training

The third ground specifically targets organizations declaring an intent to deliver apprenticeship training actions within the meaning of point 4° of article L. 6313-1 of the Labor Code, without having premises that actually allow them to do so. This ground primarily targets CFAs created on paper, without genuine teaching capacity — a profile the administration has identified as recurring in CPF and apprenticeship fraud cases in recent years.

A mirror cancellation cause for existing NDAs (article 73)

Article 73 completes the framework for organizations already holding an NDA: the “inadequate premises for apprenticeship” ground no longer applies only at entry (refusal of registration) — it also becomes a ground for cancelling an existing registration if the administration finds, during the organization’s life, that this condition is no longer met. A CFA that loses access to its premises without replacing them is therefore directly exposed to losing its NDA, independently of any other non-conformity.

As with the other grounds for cancellation or refusal, the decision must respect the adversarial principle: the organization is given the opportunity to present its observations before any final decision. The law also allows these cancellation decisions to be publicized on a dedicated website, for a period limited to one year — a deterrent lever that did not previously exist.

Article 45: more frequent controls, not just tougher ones

Beyond the refusal and cancellation grounds, article 45 strengthens the powers of professional training control agents, notably by authorizing sample-based verification rather than an exhaustive review of every file — a change in method that allows many more organizations to be actually audited with the same resources. Combined with the new refusal and cancellation rules, the intended effect is clear: make documentary fraud statistically riskier, at every stage of an organization’s life cycle.

Why targeting director recidivism changes the equation

Choosing to place the sanction on the person rather than solely on the structure is not incidental. A study by Australian legal scholar Helen Anderson, «The Proposed Deterrence of Phoenix Activity: An Opportunity Lost?», published in 2012 in the Sydney Law Review, shows that a director disqualification loses most of its deterrent effect unless it is paired with a mechanism that actively prevents the sanctioned director from resuming the same activity under a new legal wrapper — a phenomenon known as “phoenix activity.” That is exactly the gap article 72 closes for French training organizations: without a lock on the director as a person, an NDA cancellation used to cost little more than the time to fill out a new form.

What this actually changes for you

If you are creating your training organization or CFA from scratch, with a clean record and no prior offense, these new grounds change nothing about your filing process. Two situations, however, deserve particular attention:

• You are buying or taking over an existing structure, or partnering with a director who has already run a training organization: check their administrative record before filing — a refusal grounded in article 72 blocks the entire project.
• You are creating a CFA: secure your premises and their suitability for apprenticeship training actions before filing, and keep supporting evidence (lease, floor plan, capacity) in your evidence file — this point will be scrutinized both at registration and throughout the organization’s life.

Either way, these new grounds add to the list of known checkpoints when filing the initial activity declaration or an amending declaration, and complete the risk overview already covered in our article on sanctions applicable to training organizations. They also fall squarely within the spirit of indicator 23 of the National Quality Framework, which already requires every Qualiopi-certified organization to maintain active legal and regulatory monitoring — this reform is a concrete example to fold in now, rather than wait for the next audit.

Quick checklist

• No director of the structure has had an NDA cancelled within the past four years.
• No unpaid fund repayment remains outstanding after a control within the past five years.
• For a CFA: premises genuinely allow the declared apprenticeship training actions, with supporting evidence.
• The declaration or amendment file is filed on Mon Activité Formation with all documents up to date.
• The organization’s regulatory monitoring already covers this reform and its articles 45, 72, and 73.

Take action

Securing your activity declaration from the outset avoids unpleasant surprises as the regulatory framework tightens. The Kit Certif Complet (€297, 14-day guarantee) includes the legal and regulatory monitoring checklist expected under indicator 23, along with the evidence tables for all 32 indicators of the framework. If you’re just starting your organization, the ebook Create your training organization in 30 days (€67) secures your initial declaration step by step, and the Pack complet (€347) bundles both resources to cover creation and certification.