On-site quality checks by OPCOs: what changes with the 27 February 2026 decree

Since 1 March 2026, a skills operator (OPCO) funding one of your courses is no longer limited, when checking its quality, to reviewing your administrative documents. Decree n° 2026-133 of 27 February 2026, published in the Journal officiel on 28 February, explicitly opens the possibility of an on-site check. A quiet change in the text, but one that concretely changes what a training organisation funded by an OPCO needs to prepare for.

What the text says

The decree amends Article R. 6332-26 of the French Labour Code, which sets out how skills operators satisfy themselves that the courses they fund are properly delivered. It now specifies that OPCOs may carry out document-based and on-site checks of the quality of funded courses, in line with Articles L. 6316-3 and R. 6316-7 of the same code, which establish the general principle of quality control for actions contributing to skills development.

This text is part of a broader trend of strengthening the oversight powers of vocational training funders, under way for several years and reinforced by the 2026 reforms — including the anti-fraud law of 25 June 2026, which also tightened the conditions for refusing or cancelling a training organisation’s activity declaration.

A check distinct from the service-delivered control

This new power should not be confused with the service-delivered check, which already existed and continues to apply to every file before payment: the OPCO verifies there that the course actually took place, on the agreed dates and for the agreed duration, based on the completion certificate and attendance sheets.

The on-site quality check goes further. It does not only look at whether the course actually happened, but at the conditions under which it is delivered: do the premises used match what was declared, are the teaching and technical resources presented in the file actually available and put to use, does the teaching supervision match the programme? These are points that a remote document review can rarely verify with certainty.

Why this change now

Opening up this on-site check is not an isolated text. A mirror decree, Decree n° 2026-134 of 27 February 2026, caps OPCOs’ management, information and mission fees, and now clearly identifies, among the capped but budgeted expenses, the costs linked to checking the delivery and quality of funded courses. In other words: OPCOs now have an identified budget line to fund these checks, including when they require a site visit — which makes a gradual scaling-up of this type of control over the coming months more credible, without it being possible at this stage to predict its exact extent.

On substance, the logic echoes a well-documented finding in regulatory economics: a check based on direct observation, rather than solely on documents submitted by the party being checked, generally produces more reliable information about the actual service delivered. A study by Esther Duflo, Michael Greenstone, Rohini Pande and Nicholas Ryan, published in 2013 in the Quarterly Journal of Economics under the title «Truth-telling by Third-Party Auditors and the Response of Polluting Firms», conducted within an environmental monitoring scheme in India, shows that the reliability of a check depends heavily on its independence from the entity being checked and on its ability to confront declarations with reality observed on the ground — a principle that, on its own scale, is echoed in this shift from a purely document-based check to one that can now include a visit.

Who is affected

This check applies to courses funded by OPCOs’ pooled funds: apprenticeship contracts, professionalisation contracts, and the skills development plan for companies with fewer than 50 employees. The CPF, funded and checked by the Caisse des Dépôts via EDOF, follows a separate process, as do the administrative and financial checks carried out by the DREETS, which remain a state prerogative independent of the OPCOs.

Holding Qualiopi certification does not exempt you from this check: the certifier’s audit assesses compliance with the quality framework at a given moment, whereas the OPCO check targets a specific funded course, potentially at any time of the year.

How to prepare

In practice, the points an on-site check is likely to verify largely overlap with the evidence already expected for a Qualiopi audit — which limits the extra effort if your documentation is up to date:

• Consistency between the funding file and what can be observed: the title, duration, dates and location of the course as declared to the OPCO must match exactly what actually happens on your premises or remotely.
• The teaching and technical resources declared: equipment, materials, distance-learning platform — if they appear in the funding file, they must be available and demonstrable.
• Compliance of the teaching staff: the trainers delivering the course must match the profiles and skills presented, in line with what Indicator 17 of the Qualiopi framework already requires regarding human and technical resources.
• Immediate availability of documents: agreement, programme, attendance sheets, completion certificate — the same documents already required for the service-delivered check, ready to be produced without delay.

The best approach remains building documentary consistency upstream, from the moment the funding file is submitted, rather than scrambling to reconstruct it once a check is announced.

What is at stake in case of non-compliance

The decree does not create a new specific penalty: the consequences of non-compliance found during an OPCO quality check remain those of ordinary training-funding law, namely a reasoned refusal or rejection of funding, potentially combined with a request to repay sums already paid. The available remedies are the same as those detailed in our article on OPCO funding refusal, and the most serious failures can, as with any funder, be reported to the authorities as part of the penalties applicable to training organisations.

Take action

A funding file consistent with what can actually be observed at your organisation — premises, teaching resources, staffing — remains the best protection against an OPCO quality check, whether document-based or on site. The Complete Kit Certif (€297, 14-day guarantee) provides evidence tables aligned with the 32 indicators of the Qualiopi framework, directly reusable to maintain that consistency over time. If you are just starting out, the ebook “Create your training organisation in 30 days” (€67) sets out the right documentary habits from your very first funding file, and the Complete Pack (€347) bundles both resources.