Moving from sole trader to a company: do you need a new NDA and a new Qualiopi audit?

Turnover durably exceeds the micro-entreprise threshold, a partner joins the project, or the need to deduct real expenses starts to bite: sooner or later, many independent trainers move from sole trader (auto-entrepreneur) status to a company — EURL, SASU, sometimes a multi-partner SARL. What few anticipate is that this change of status isn’t just an accounting formality. From a regulatory standpoint, it comes close to recreating the training organisation from scratch, with direct consequences for your NDA and — often overlooked — for the Qualiopi certification you already hold.

The principle that changes everything: a new legal entity

A sole proprietorship, including under the micro-entrepreneur regime, has no legal personality distinct from the individual who runs it. The SIREN number assigned to it is the entrepreneur’s own. Setting up a company — EURL, SASU, SARL — creates a new legal entity, with its own SIREN number, separate from its founder’s.

That shift is what sets it apart from a simple change of legal form between two companies that already exist: converting a SASU into a SAS to bring in a partner, or an EURL into a SARL, doesn’t create a new legal entity — the SIREN number stays the same, and an amended declaration is enough. Moving from a sole proprietorship to a company, on the other hand, creates a new rights-holder in the administration’s eyes, even if the training activity, premises and teaching team stay exactly the same.

A new NDA, on the same terms as a brand-new registration

Because the SIREN number changes, the activity declaration number (NDA) attached to your micro-entreprise doesn’t transfer to the new company. The company must file its own activity declaration (Cerfa 10782) on the “Mon Activité Formation” portal, with the same supporting documents as an initial declaration: proof of the new company’s registration, the director’s criminal record extract (bulletin n° 3), and a first training agreement or contract signed in the company’s name — not the former sole proprietorship’s.

Since decree no. 2025-728 of 29 July 2025, DREETS has two months to review this file, just like any initial declaration; our article on the NDA processing time covers what to do if the administration stays silent beyond that deadline. In practice, expect six to eight weeks between filing and receiving the new number — a timeline to factor in as soon as you decide to set up the company, not once the first client signs with the new entity.

What happens to your Qualiopi certification

This is the point most often discovered too late: Qualiopi certification earned as a sole trader is issued to a specific legal entity, identified by its SIREN number. It doesn’t automatically follow the move to a company, under exactly the same logic that applies to a change of director or the sale of a training organisation: when the SIREN number changes, the certificate doesn’t transfer mechanically.

Two outcomes are possible with your certification body:

• A full initial audit for the new company, under the same terms as an organisation that has never been certified — this is the default scenario, even if the activity, trainers and procedures stay unchanged.
• A lighter transition audit, which some certifiers accept when the file demonstrates full continuity: same premises, same trainers, same documented quality system, with only the legal vehicle having changed. This option is neither automatic nor guaranteed; it’s negotiated case by case with the certifier, ideally before the new NDA is even filed.

Either way, inform your certifier as soon as setting up the company is underway: the earlier you plan ahead, the better your chances of getting the cheaper, faster option — and of avoiding a stretch with no valid certificate right when your funders ask for proof of one. This kind of legal-entity switch falls squarely under the monitoring expected by indicator 23 of the National Quality Framework: a surveillance audit that uncovers an untracked, unanticipated change of SIREN number is an avoidable finding, and keeping your public-facing materials consistent with your actual structure also falls under indicator 1.

BPF and EDOF: two more processes that start over

Two further obligations follow the same fate as the NDA and the certification:

• The annual activity report (BPF): the former sole proprietorship must file a final BPF covering the period actually worked before the switchover, exactly as in a cessation of activity. The new company starts its own annual BPF cycle, tied to its new NDA.
• EDOF listing for CPF funding: tied to the SIREN/NDA pair, this doesn’t transfer either. The company must file a new EDOF listing request, with its own processing time on top of the NDA and Qualiopi audit timelines.

Planning the timeline to avoid losing funding

The real risk in this transition isn’t regulatory but financial: the NDA, the Qualiopi audit and the EDOF listing aren’t granted at the same time, and each can take several weeks. A trainer who switches to a company too quickly, without planning for these timelines, can end up unable to invoice CPF or OPCO funding under the new entity for several months — even though the training activity itself never stopped.

The safest approach is to run the steps in parallel rather than in sequence: start the new activity declaration and reach out to the certifier as soon as the company is registered, while continuing to invoice under the former sole proprietorship until the new NDA, the new certificate and the new EDOF listing are all in place. Once those three pieces are secured, the commercial switchover can happen without any gap in invoicing or funding.

What research says about very small business growth

Moving from sole trader to a company corresponds, in the management research literature, to a typical formalisation step for growing very small businesses. A study by Jacques Arlotto, André Cyr, Olivier Meier and Jean-Claude Pacitto, published in 2011 in the journal Management & Avenir under the title “Très petite entreprise et croissance : à la découverte d’un continent inexploré” (“Very small business and growth: exploring an uncharted continent”) (see the study), shows that growth in very small businesses remains a poorly understood and heterogeneous phenomenon, where crossing regulatory and organisational thresholds weighs on the trajectory as much as commercial momentum alone. Applied to an individual training organisation, the lesson is to treat the move to a company as a project in its own right — with its own administrative timeline — rather than a mere formality triggered after the fact once turnover has already crossed the micro-entreprise threshold.

Sole trader to company transition checklist

• Is the new company registered, with its own SIREN number distinct from the former sole proprietorship’s?
• Has a new activity declaration (Cerfa 10782) been filed on Mon Activité Formation, with a first agreement signed in the company’s name?
• Has the Qualiopi certifier been told about the planned change of status, before the new NDA is even filed?
• Has the Qualiopi transition path (full initial audit or lighter transition audit) been clarified with the certifier, with a quote and a timeline?
• Is the sole proprietorship’s final BPF planned for, and the company’s first BPF cycle anticipated?
• Has a new EDOF listing request been started so CPF invoicing can continue without a gap?
• Does invoicing under the former structure continue until the new NDA, the new certificate and the new EDOF listing are all in place?

Take action

Planning the move to a company before turnover forces the switch under time pressure is what separates a smooth transition from a months-long gap. The Complete Kit Certif (€297) provides the process timeline and the evidence tables for all 32 indicators, ready to rebuild for the new company — a condition for a lighter transition audit rather than a full-price initial audit. Just starting out as a sole trader? The ebook Create Your Training Organisation in 30 Days (€67) sets the right habits from day one, and the complete pack (€347) bundles both resources. Browse all our blog articles on training organisations’ administrative obligations.