Accounting for a French training organisation: mandatory annual accounts and activity separation
Many founders of French training organisations discover late that, beyond the BPF — an annual activity declaration — the Labour Code imposes genuine accounting obligations, distinct from whatever their usual accountant already handles. Balance sheet, income statement, activity separation: here is what the law requires, who it applies to, and how to comply without wasting time.
BPF and accounting: two different obligations
A common confusion among new organisations: the BPF (pedagogical and financial report) is an annual activity declaration filed with the administration on “Mon Activité Formation”. The obligations described here are a substantive accounting requirement, set out in articles L. 6352-6 and L. 6352-7 of the Labour Code, governing how you actually keep your books — well before that data is summarised in the BPF. The two overlap (box C of the BPF must match your training-activity accounts), but complying with one does not exempt you from the other.
Who must produce a balance sheet and income statement?
Article L. 6352-6 of the Labour Code requires every private-law training provider to produce, each year, a balance sheet, income statement and notes, under conditions set by article D. 6352-16.
This obligation does not apply to everyone in the same way:
- if your organisation has a single activity (training), the obligation applies once your annual revenue excluding tax reaches or exceeds €15,244.90;
- if your organisation has multiple activities (training and consulting, training and product sales, etc.), the obligation applies regardless of revenue.
In practice, a sole-trader (micro-entreprise) trainer whose only declared activity is training, and whose revenue stays below that threshold, can rely on their usual cash-based bookkeeping. As soon as either criterion flips — the threshold is crossed, or the activity becomes mixed — a full set of financial statements becomes mandatory, even if in simplified form for the smallest structures.
Separate accounting for multi-activity organisations
This is the least-known and most often overlooked point. Article L. 6352-7 of the Labour Code requires multi-activity organisations to track continuing vocational training activity (and apprenticeship, where applicable) separately from their other activities.
Three methods are accepted, at the organisation’s choice:
- separate accounting, kept autonomously and linked to the general accounts through a liaison account;
- isolation in dedicated sub-accounts, within the same chart of accounts;
- analytical (management) accounting, which breaks down revenue and costs by activity.
Concretely, this applies to a consultant who bills both advisory work and training sessions, a centre that rents out rooms in addition to delivering training, or an association that combines training with another purpose. Without a clear breakdown from the moment invoices are issued, reconstructing the split later — at BPF time or during an audit — becomes a headache, and a potential source of errors on the revenue actually eligible for the VAT exemption or OPCO funding.
The specific case of CFAs (apprenticeship centres)
For organisations delivering apprenticeship training, the requirement is even more formalised. The decree (arrêté) of 21 July 2020 (amended by the decree of 30 March 2023), issued under article L. 6231-4 of the Labour Code, sets out the precise rules for implementing the analytical accounting that CFAs must apply to break down their costs by training action. A CFA therefore cannot simply rely on sub-account separation: analytical accounting is the standard expected by funders (France compétences, OPCOs) and auditors alike.
Do you need a statutory auditor?
Appointing a statutory auditor (commissaire aux comptes) becomes mandatory for a private-law training provider once two of the following three thresholds are exceeded:
| Criterion | Threshold |
|---|---|
| Employees on permanent contracts | 3 |
| Revenue or resources | €153,000 excl. tax |
| Total balance sheet | €230,000 |
An organisation that stays under simplified accounting must still use the specific accounts and annexed tables required for training organisations — the simplification concerns presentation, not the nature of the information to be produced.
Penalties for non-compliance
Failing to comply with the separate-accounting requirement of article L. 6352-7, for a multi-activity organisation, is punishable by a fine of €4,500 (article L. 6355-11 of the Labour Code). Beyond the criminal penalty itself, an accounting failure weakens the entire file during a DREETS inspection: inability to justify the training revenue declared on the BPF, doubts over eligibility for the VAT exemption, and funding already received being called into question.
A study by Mbama and Éloundou published in 2024 in the journal Audit, Contrôle, Comptabilité, Recherche Appliquée (ACCRA, no. 20), based on 106 SMEs, shows that structuring the accounting function significantly improves financial transparency and facilitates access to bank financing (study on Cairn.info) — a very concrete concern for an organisation seeking OPCO or bank financing that must be able to justify its accounts without delay.
How to get compliant, step by step
- Identify your situation: single or multiple activity, revenue relative to the €15,244.90 threshold.
- Choose a separation method if you run a mixed activity: dedicated sub-accounts in your accounting software (the simplest solution for a small structure), or analytical accounting if you have several product lines to track precisely.
- Code your invoices at the point of issue: every invoice should be unambiguously attributable to the training activity or to another activity — this avoids a tedious reconstruction at year-end.
- Check consistency with your BPF: box C (revenue) and box D (costs) of the BPF must match your isolated training accounts.
- Review your setup with your accountant as soon as you start, or as soon as a second activity begins — a correctly configured chart of accounts from day one avoids a costly catch-up at year-end.
Take action
The administrative compliance checklist in the Complete Kit Certif (€297, 14-day guarantee, documents in French) includes the accounting points to review before an audit, alongside the reference framework’s 32 indicators. If you are just starting out, the ebook Créer son organisme de formation en 30 jours (€67) devotes a chapter to administrative and accounting obligations from day one — both bundled in the complete pack at €347.