Employer's resource declaration for apprenticeships: what disappears under France's 2026 simplification law

Until recently, a CFA processing an apprenticeship contract file checked a specific document in the employer’s paperwork: a declaration stating that the company had the human, material and organizational resources needed to organize the apprenticeship under good conditions. This formality, set out in article L. 6223-1 of the French Labor Code, has just disappeared. Law n° 2026-403 of 26 May 2026 on the simplification of economic life removed it, effective 28 May 2026. Here is what this change actually alters in the apprenticeship file your CFA handles — and, more importantly, what it does not change.

What article L. 6223-1 required before its repeal

Before the reform, every employer signing an apprenticeship contract had to attach a declaration to the file committing to having taken the measures necessary to organize the apprenticeship, and guaranteeing that working conditions, health and safety, along with the equipment and teaching resources made available, would allow for satisfactory training of the apprentice. In practice, it was often the CFA or the provider supporting the signing process that reminded the employer of this document, sometimes tucked in among the papers to tick off before submission to the skills operator (OPCO).

What the 26 May 2026 simplification law changes

Article 38 of law n° 2026-403 simply repeals article L. 6223-1 of the Labor Code. Since 28 May 2026, the day after the law’s publication in the Official Journal, this declaration no longer has any legal existence: it can no longer be required as part of the file, either by the skills operator handling the submission or by the CFA when enrolling the apprentice. This provision is part of a broader push to simplify apprenticeship and hiring procedures under the same law, on several administrative fronts — including, on an entirely different topic, the removal of the prefectoral accreditation for training CSE elected members.

In practice, for an employer hiring an apprentice today, the contract file (Cerfa FA13) no longer includes this separate declarative document. For your CFA, that means one less line in the pre-signing support checklist — but not one less line in the real monitoring of onboarding quality at the host company.

What stays the same: the employer’s substantive obligations

This is the point lawmakers were careful to spell out in the law’s preparatory work: removing the declaration takes nothing away from the employer’s substantive obligations. The employer remains required to:

• organize the apprentice’s welcome and pedagogical support throughout the contract;
• appoint an apprenticeship mentor meeting the professional competency conditions set by the sector’s collective bargaining agreement or, failing that, by regulation;
• comply with working-time, health and safety rules applicable to apprentices, with enhanced protection for underage apprentices;
• provide the equipment and teaching resources needed for satisfactory training.

Only the formal documentary proof of this commitment disappears from the initial administrative file. In the event of an inspection or a contract termination linked to inadequate onboarding conditions, the labor inspectorate and the administration continue to assess these obligations on their merits, regardless of whether a declaration was signed upfront.

Why your CFA should keep its own vigilance

The disappearance of an administrative document should not be mistaken for the disappearance of the issue it covered. A CFA remains responsible, under indicator 13 of the National Quality Framework on coordinating work-study learning, for the quality of the link between the training center and the host company — which in practice means still making sure the material and human conditions promised by the employer are actually there.

Education research converges on this point: it is not the paper declaration that determines the quality of a work-study path, but the actual nature of the workplace offered to the learner. A landmark study by Alison Fuller and Lorna Unwin, published in 2003 in the Journal of Education and Work, distinguishes “expansive” workplace environments — which multiply learning opportunities and involve the apprentice in the life of the company — from “restrictive” ones, which confine the apprentice to repetitive tasks with little real support — a distinction that weighs far more heavily on apprenticeship success than any box ticked on a form (see the study). For a CFA, the practical takeaway is direct: the removal of the L. 6223-1 declaration is an opportunity to shift from a box-ticking logic to genuine on-the-ground follow-up — a regular check-in with the apprenticeship mentor, feedback from the apprentice mid-contract, early alerts on any warning sign.

On a broader economic level, removing declarative formalities of this kind fits a pattern documented by research: a now-classic study by Simeon Djankov, Rafael La Porta, Florencio Lopez-de-Silanes and Andrei Shleifer, published in 2002 in the Quarterly Journal of Economics, shows that lightening administrative procedures tied to hiring and business activity reduces compliance costs without necessarily degrading actual practice quality, provided substantive obligations remain monitored through other channels — exactly the logic at play here, since the apprentice’s welcome and supervision obligations remain, with only the paper declaration disappearing.

What to actually update in your CFA process

Three simple actions let you make the most of this change without losing rigor:

1. Remove the L. 6223-1 declaration from your document checklist at contract signing — it no longer has a legal basis, and its presence in a file no longer means anything for an inspection.
2. Replace it with a structured contact point with the host company before signing: a short exchange with the employer or the future apprenticeship mentor about actual onboarding conditions, logged in the apprentice’s file, usefully feeds the monitoring expected under indicator 18 on coordinating internal and external contributors.
3. Update your internal materials (welcome booklet, employer guide, enrollment procedure) that still reference this declaration, to avoid requesting a document that no longer serves any purpose — a useful reminder of the regulatory watch expected under indicator 23 of the National Quality Framework.

This simplification is part of a broader wave of administrative reform affecting apprenticeships in 2026; if your CFA also manages contract terminations, our article on the apprenticeship contract termination procedure details the steps to follow when onboarding conditions still deteriorate during the contract.

Take action

Continuously tracking regulatory changes affecting your CFA is part of what a Qualiopi audit expects, just as much as the real quality of your company partnerships. The Complete Kit Certif (€297, 14-day guarantee, documents in French) includes the indicator 13 sheet on work-study coordination and a regulatory watch procedure, to be adjusted for these 2026 changes. Starting your CFA or training organization? The ebook “Create your training organization in 30 days” (€67) lays the groundwork from day one, and the Complete Pack (€347) bundles both resources. Browse all our blog articles to stay on top of upcoming changes to apprenticeship regulations.