BPF and subcontracting: how to declare it as prime contractor and as subcontractor

You deliver courses on behalf of another organisation, or you hand sessions over to freelance trainers: come spring, those flows must appear in your BPF (bilan pédagogique et financier, the annual activity return every registered French training provider files) — and not just anywhere. Subcontracting is one of the BPF’s most error-prone areas, because it shows up on both sides of the form depending on the role you play. This article explains what gets declared, where, and how to avoid the inconsistencies that catch the regional control service’s eye. New to the BPF? Start with our general article on the bilan pédagogique et financier and our section-by-section completion guide.

Two roles, two declarations

Where subcontracting is concerned, a training organisation can occupy two positions — sometimes both in the same year:

• Subcontractor: you deliver courses on behalf of another organisation, which invoices its own clients and pays you. Your income comes from a fellow training provider, not from an end funder.
• Prime contractor (donneur d’ordre): you sell the training to your clients, but you entrust all or part of its delivery to a third party — another organisation or a freelance subcontracting trainer — whom you pay.

The BPF handles these two situations in different parts of the form: income for the subcontractor, costs and delegated trainees for the prime contractor. Mixing up the two logics is the number-one source of error.

As a subcontractor: income on its own line, never under “companies”

The BPF section covering the origin of income breaks down your training turnover by who pays you directly: companies, joint funding bodies (OPCOs), public authorities, individuals… and a dedicated line for contracts concluded with other training organisations. That line, and only that line, is where your subcontracted assignments belong.

The golden rule, already set out in our completion guide: every euro is classified by direct payer, not by end beneficiary. An assignment invoiced at €15,000 to a fellow organisation goes on the inter-organisation line, even if the trainees are employees of that organisation’s corporate client. Filing that income under “companies” is the number-one mistake in first-time BPFs — it distorts the statistics and creates an inconsistency with the prime contractor’s BPF, which has declared the same trainees on its side.

One situation not to confuse with this: co-traitance (joint contracting), where several organisations each contract directly with the buyer. Each co-contractor invoices the end client and declares that income according to the client’s nature, not on the inter-organisation line — our article on co-traitance and consortiums covers the difference.

As a prime contractor: costs, and delegated trainees

When you are the prime contractor, subcontracting appears in two places:

• In the costs of the training activity: amounts paid to your subcontractors are purchases of training services. They are declared as such, distinctly from your overheads — an invoice for subcontracted teaching is not of the same nature as rent or a software subscription.
• In the trainee section: the form distinguishes trainees you train yourself from those you hand over to subcontractors. The two populations are declared separately; your subcontractor, meanwhile, accounts for its activity in its own BPF.

On the income side, however, nothing changes for you: you declare the full turnover invoiced to your clients (companies, OPCOs, individuals…), including the share you then pass on to your subcontractors. The BPF does not reason in net margin: income is gross, and subcontracting surfaces in the costs.

A worked example (fictitious)

Take two imaginary organisations, with round figures chosen purely for illustration:

Alpha Formation, prime contractor, posts €100,000 of training turnover for the year: €60,000 invoiced to companies, €30,000 to an OPCO, €10,000 to individuals. It hands two sessions to a subcontractor, Bravo Pédagogie, which it pays €20,000. Of the 150 trainees enrolled during the year, 30 were trained by Bravo.

Who	Income declared	Subcontracting costs	Trainees
Alpha (prime contractor)	€100,000 broken down by direct payer (companies, OPCO, individuals)	€20,000 as purchases of training services	150 declared, of which 30 identified as handed to subcontractors
Bravo (subcontractor)	€20,000 on the line for contracts with other training organisations	—	Its own activity, reported in its own BPF

Three takeaways: Alpha declares the full €100,000 of income (not €80,000 — subcontracting is not deducted from income); Bravo declares nothing under “companies” or “OPCO”, because its only direct payer is Alpha; and the 30 trainees appear in Alpha’s return as handed to a subcontractor, not as trained in-house.

Common mistakes

• Double-counting trainees. Declaring trainees handed to a subcontractor as if trained in-house, when the form separates them precisely to avoid misleading additions across the two organisations’ BPFs.
• Subcontracting missing from income. A trainer working exclusively as a subcontractor sometimes files a “nil” BPF, believing the prime contractor’s return covers their activity. It does not: every NDA holder declares their own income.
• Subcontracted income filed under “companies”. The classic subcontractor’s error — reasoning by end beneficiary instead of direct payer.
• Confusing purchases of teaching services with overheads. Burying subcontractor invoices among miscellaneous costs erases exactly the information the form is designed to capture.
• An unexplained gap with the accounts. Total declared income must match the training turnover in your books; subcontracting costs must show up in your purchases. Any silent discrepancy is a red flag for the control service.

Why BPF/contract consistency matters during a check

The BPF is declarative, but every figure must be justifiable. During a regional control or a Qualiopi audit, your subcontracting declarations will be cross-checked against your contracts: the written subcontracting agreement is the document tying a cost amount, a number of delegated trainees and an actual teaching reality together. A BPF showing purchases of training services with no matching contracts — or the reverse, subcontracting contracts that leave no trace in either costs or delegated trainees — weakens the whole file.

The stakes go beyond the form itself: the specific obligations attached to subcontracting in training (written contract, the subcontractor’s own NDA, CPF rules) form a whole together with the annual return. An inspector who spots an inconsistency in the BPF will naturally go on to check the rest of the chain.

The right reflex: structure the information all year round

Reconstructing in April who subcontracted what, for how much and with how many trainees, from scattered invoices, is the most expensive scenario — in time and in error risk. This matches a well-established research finding: the study by Donald Moynihan, Pamela Herd and Hope Harvey, published in 2015 in the Journal of Public Administration Research and Theory under the title “Administrative Burden: Learning, Psychological, and Compliance Costs in Citizen-State Interactions” (see the study on Google Scholar), breaks administrative burden down into learning, psychological and compliance costs — and shows that the latter drop sharply when the required information is structured and available upstream, rather than pieced together at filing time.

In practice: add two columns to your session-tracking spreadsheet — “subcontracted to” and “received as subcontractor from” — with the contract amount and the number of trainees involved. Thirty seconds per session, and your spring return no longer requires any archaeology.

Take action

To declare your subcontracting without reconstructing the year at the last minute, the Complete Kit Certif at €297 includes the BPF tracking template, a compliant subcontracting contract model and the evidence expected for indicator 27. Just starting out? The ebook Create Your Training Organisation in 30 Days at €67 sets out your filing obligations from day one, and the Kit + Ebook Pack at €347 combines both to cover creation, declarations and certification in one go.