The order of 23 June 2026: what changes for RGE qualifications

The RGE framework moved in 2026. The order of 23 June 2026, published in the French Journal officiel of 26 June 2026, amends the order of 1 December 2015 on the qualification criteria required to benefit from energy-renovation subsidies — the text that has structured, for ten years, companies’ access to the quality mark and therefore their customers’ access to subsidies.

This article offers a deliberately cautious reading: what the text opens, what remains to be specified by the qualification bodies, and above all what to do with it in a company timetable. On a subject where commentary travels fast, the useful reflex is to separate what is written from what is anticipated.

What the text changes

Two directions emerge from the reform.

A route through experience. The order opens recognition of the quality mark through the recognition of acquired experience, alongside the classic route running through the technical referent’s training. The stated aim is to open qualification to professionals whose competence is established by practice rather than by a recent course.

A revised proportionality of controls. Adjusting the audit regime to the company’s activity profile is among the changes carried by the reform, in a logic of easing the load for low volumes without lowering requirements on subsidised projects.

A two-stage entry into force. This is the most important point for your calendar: not all provisions apply on the same date. Part of the text only takes effect on 1 March 2027. A company building its commercial plan on a deferred arrangement risks being exposed for several months.

Why a reform, and why this one

The RGE scheme has lived from the start with a tension. On one side, it conditions access to public money: it must therefore control. On the other, it structures market access for a fabric of very small firms and sole traders: too heavy, and it excludes competent professionals and thins out supply exactly where renovation demand is strong.

That tension is measurable. Marie-Laure Nauleau, in an econometric evaluation published in 2014 in Energy Economics (“Free-riding on tax credits for home insulation in France: An econometric assessment using panel data”), estimates from a panel of nearly 24,000 French households that the average share of beneficiaries who would have carried out the work even without the tax incentive lies between 40% and 85% after 2006. In other words, a substantial share of public spending finances work that would have happened anyway.

Faced with that, two levers exist: cut the subsidy, or better target and better control the quality of what it finances. The second has been favoured for ten years — hence the rising requirements on companies. The 2026 reform adds a nuance: controlling better does not mean controlling uniformly, hence the idea of proportioning audits to activity volume.

What it means, concretely, for a company

If you are already qualified. Nothing collapses: your cycle continues under the applicable rules. The certificate is still issued for four years, with a validity certificate reissued each year once conditions are checked, and a site audit within the first twenty-four months — plus a second audit in year three for the critical qualifications, Qualibois and QualiPAC. Our article on preparing for audits stands as written.

If you are preparing an application. Do not suspend your process waiting for a more favourable arrangement. A qualification obtained under the current rules opens the same rights, and months of waiting are paid for in unsubsidised projects. The fundamentals — insurance explicitly naming the technology, a trained technical referent, documented project references, administrative compliance — disappear in no version of the text.

If your situation depends precisely on a deferred provision. Ask your qualification body about the timetable applicable to your case. An order sets a framework; it is the arrangements published by the bodies that determine the procedure you will actually follow.

The reading rule: text, then arrangements

On regulatory matters, the classic error is treating press commentary as a procedure. The chain is straightforward:

1. The text sets the framework: criteria, principles, entry-into-force dates. Read it in the version in force, not in a summary.
2. The qualification bodies derive operational arrangements from it: documents expected, forms, switchover calendars, transitional regimes.
3. Your application follows the arrangements in force when you file it.

Between steps 1 and 2 there is a lag — that is normal, and it is during that lag that the most approximate information circulates. If a new feature is meant to decide an investment, wait for your body to publish its arrangements.

A practical corollary for anyone advising customers: do not turn a reform announcement into a sales argument before the arrangements exist. Telling a household that a subsidy will be easier to obtain next year, or a fellow tradesperson that qualification is about to become optional, creates an expectation that the published arrangements may not meet. On a market where trust is already the scarce resource, an over-confident forecast costs more than a cautious “the framework is moving, here is what is confirmed today”.

The same caution applies to transitional situations. A cycle that spans a change of framework — a qualification obtained under one set of rules, renewed under another — is exactly the case where the body’s arrangements matter more than the text’s headline. If your renewal falls near a switchover date, raise it with your body rather than assuming the rule that applied at your last renewal will apply at the next one.

The blind spot: training

A reform touching the routes to competence mechanically touches the training market. For providers positioned on technical referents, two markers hold: courses must be delivered within an approved framework to count towards the qualification, and Qualiopi certification is still required for those courses to be financed from public or pooled funds. Our article on RGE training approval sets out those routes, and our overview of RGE-approved training gives the framework.

Opening a route through experience does not remove that market: it shifts part of it towards support and the assembly of evidence files — a neighbouring trade, which also requires knowing how to document competence.

Take action

Three useful moves this quarter: check the version of the text in force rather than a summary, consult the arrangements published by your qualification body, and do not suspend a live application on the grounds that a provision takes effect in 2027. The fundamentals of assessment — insurance, technical referent, project references — remain the best preparation for any version of the framework. The full picture of the scheme is on our Qualit’EnR page.