Qualiopi audit between October and December 2026: which framework applies, 32 or 33 indicators?

If your next surveillance audit, renewal audit, or even your initial audit is scheduled somewhere between late October and December 2026, one very concrete question comes before anything else: will the auditor check the current 32 indicators, or the 33 introduced by decree n° 2026-728 of 1 August 2026? The answer directly determines which evidence to prepare, and getting it wrong is a costly mistake the night before an audit.

The rule that decides: the audit date, not the contract or certification date

The decree is clear on one point: the National Quality Framework that applies to an audit is the one in force on the day the audit is actually carried out, regardless of when the certification contract was signed, when the certificate was first obtained, or when the audit was originally scheduled months in advance.

In concrete terms:

• an audit carried out on 31 October 2026 is assessed against the current framework, 32 indicators;
• an audit carried out on 1 November 2026 or later is assessed against the new framework, 33 indicators, with strengthened indicators 12, 14 and 15 and, for CFAs, the new indicator 33 on apprentices evaluating their own training.

No transitional provision grants any tolerance or grace period beyond this cutover. Nor is there a rule that would lock in the applicable framework at the date the contract was signed with your certification body: only the actual audit date counts.

Case 1 — Your audit takes place before 1 November 2026

Nothing changes from your usual routine: the auditor applies the current Qualiopi reading guide and the 32 indicators spread across the 7 criteria. Your usual preparation checklist remains entirely valid, whether it’s an initial audit, an 18-month surveillance audit, or a 3-year renewal audit.

One piece of advice all the same: if your organisation has time before the audit, start formalising a reporting channel for violence, harassment and discrimination now (see below). It isn’t required for an audit before 1 November, but the auditor may reasonably raise it as something to anticipate, and you will need it for your next surveillance audit regardless.

Case 2 — Your audit takes place on or after 1 November 2026

The auditor checks the 33 indicators, which in practice means three points of attention that cut across every organisation, whatever category of certified action is involved:

1. An identifiable reporting channel for violence, harassment and discrimination under indicator 12 — internal rules that merely forbid harassment are no longer enough. Our 5-step template lets you draft one quickly;
2. Verifiable results indicators and communications: success rates, career outcomes and terms displayed must be justifiable on request, following the same logic already applied to client reviews;
3. For CFAs only: the new indicator on apprentices evaluating their training, and stronger information requirements for underage apprentices about their rights.

The indicator-by-indicator overview covers every adjustment in detail if you want to check your compliance point by point before the audit.

The tricky case: a postponement that shifts the audit across the cutover

This is the most common situation in practice: an audit initially set for 27 or 28 October 2026 slips by a few days for an organisational reason — an unavailable auditor, a technical issue during a remote audit, a scheduling conflict on the organisation’s side — and ends up in early November. In that case, it is the new date that fixes the applicable framework, not the originally agreed one. Our article on postponing an audit date covers the procedure and deadlines for a postponement, but keep this direct consequence for the audit’s content in mind.

If your audit runs over several consecutive days (multi-site organisation, several certified categories of action), certification bodies generally use the audit’s opening date, as shown on the notice and the final report, as the reference date. Without explicit written confirmation from your certification body on this point, ask for it before the audit rather than finding out on the day.

How to protect your file whatever date ends up applying

Given this scheduling uncertainty, the safest strategy for an organisation whose audit falls in the grey zone (mid-October to mid-November 2026) is to prepare a file that meets the 33-indicator framework, even if the audit ultimately takes place before 1 November:

• a file that meets the new framework passes an audit still run under the old one without difficulty, since it covers every existing requirement plus the new ones;
• the reverse is not true: a file that only covers the current 32 indicators is exposed to an immediate non-conformity if the audit slips past 1 November;
• it also avoids doing the work twice, since your next surveillance audit, 18 months from now, will fall under the new text regardless.

Document every adjustment (reporting procedure, updated welcome booklet, verification of published figures) in your usual corrective action plan: it’s the same written record that demonstrates your continuous-improvement approach to the auditor, whichever framework ends up applying on the day.

What research says about regulatory transition periods

This scheduling uncertainty isn’t unique to Qualiopi: it affects any organisation facing a regulatory change whose effective date doesn’t line up with its own audit cycle. A study by Francesco Trebbi and Miao Ben Zhang, published in 2022 by the National Bureau of Economic Research (The Cost of Regulatory Compliance in the United States), measured, using US firm data from 2002 to 2014, the share of the wage bill spent on regulatory-compliance tasks: 1.34% on average, with substantial variation across industries and an upward trend over the period studied (see the study). The finding illustrates a simple point that applies just as well to certification: compliance has a real cost in staff time, and that cost is best kept under control when it is anticipated rather than rushed the night before an audit.

Take action

The Complete Kit Certif (€297, 14-day guarantee, documents in French) provides a model procedure and an evidence table for each of the 32 indicators of the framework that applies until 31 October 2026, including dropout prevention (indicator 12). If your audit takes place from 1 November, add the decree changes described above. Getting ready to set up your training organisation? The ebook “Create your training organisation in 30 days” (€67) lays the groundwork from day one, and the Complete Pack (€347) bundles both resources. Browse all our blog articles to keep up with regulatory news as it happens.