CPF Subcontracting Declaration on EDOF: 2026 Campaign, Step by Step

Every year, between 1 May and 30 September, every training provider referenced on the EDOF platform must complete a step many discover too late: the annual declaration of whether — or not — it used subcontracting for actions funded through the Personal Training Account (CPF). Despite its name, this obligation is not limited to providers who actually subcontract part of their activity: it applies to all referenced providers, without exception. Here is how the 2026 campaign works and what to do before the 30 September deadline.

An obligation born from the 19 December 2022 law

The legal framework for CPF subcontracting was substantially overhauled by the law of 19 December 2022 on social security financing for 2023, then detailed by decree n° 2023-1350 of 28 December 2023, in force since 1 April 2024. This text introduced several safeguards to curb abuses observed on the CPF market: resale of EDOF referencing, cascading subcontracting, and providers operating without any quality control. We cover these substantive rules — the subcontractor’s own Qualiopi certification, the 80% cap, the ban on cascading — in our article on CPF subcontracting and the subcontractor’s Qualiopi obligation.

The annual EDOF declaration is the reporting side of this same framework: it lets the Caisse des Dépôts et Consignations, which manages Mon Compte Formation, verify that each provider actually complies with these rules on the ground, based on the data it reports itself.

Who must declare, and for which period?

The rule is simple to state but poorly known: every provider referenced on EDOF must declare, whether or not it used subcontracting. There is no exemption based on the provider’s size, how long it has been referenced, or the absence of a subcontractor.

• Reference period: services invoiced during calendar year 2025 (1 January to 31 December 2025).
• Declaration window: 1 May to 30 September 2026.
• Where to declare: on the provider’s professional EDOF account, in the dedicated subcontracting section.

A provider that used no subcontractor at all on CPF-eligible actions in 2025 must still log into its EDOF account, answer “No” to the question “Has your organization used subcontracting for CPF-eligible actions?”, and save this declaration of non-use. Doing nothing is not equivalent to a negative declaration: the absence of any declaration, regardless of the reason, constitutes a breach.

What you need to report if you did subcontract

If your organization used one or more subcontractors in 2025 for CPF actions, the declaration must identify each provider involved and the associated volume of activity. Before logging in, prepare:

1. The list of your active CPF subcontractors for the period (company name, SIRET, training activity declaration number);
2. The CPF revenue subcontracted to each one, to check that the total stays under the 80% cap of your annual CPF revenue;
3. Proof of each subcontractor’s Qualiopi status (a valid certificate) or its exemption under the micro-enterprise regime below the €77,700 excl. VAT annual revenue threshold.

This preparation work largely overlaps with the evidence already required by indicator 27 of the Qualiopi framework on controlling your subcontractors: a subcontractor register kept up to date throughout the year turns the EDOF declaration into a simple reporting formality, rather than a scramble for information in late September.

The step-by-step procedure on EDOF

1. Log in to your professional account on the EDOF platform with your usual credentials.
2. Find the “Subcontracting” section, or the declaration campaign highlighted on your dashboard from its opening in early May.
3. Answer the usage question: “Yes” if you subcontracted in 2025, “No” if not.
4. If “Yes”, complete the list of your subcontractors and the associated amounts, as requested by the form.
5. Validate and save your declaration before 30 September 2026, and keep proof of submission (screenshot or export, if the platform allows it) in your administrative records.

Do not leave this step to the last week of September: during periods of heavy platform traffic, it is better to declare as soon as the campaign opens on 1 May, especially if your subcontracting file is complex (several providers, changes during the year).

Penalties for non-compliance

Failing to declare, submitting an incomplete declaration, or a declaration that reveals a breach of the CPF subcontracting rules (the 80% cap, an uncertified subcontractor, cascading) exposes the provider to two types of penalties, which can be combined:

• Payment suspension on the EDOF platform, of up to 6 months;
• Delisting from Mon Compte Formation, of up to 12 months.

For a provider whose activity relies significantly on CPF, being delisted for several months can represent a cash-flow shock that is hard to absorb. The effectiveness of this type of reporting-based sanction is not unique to CPF: a study by Chen, Choi, Wright and Wu, published in 2023 in Accounting & Finance, on Australia’s continuous disclosure regime for listed companies, shows that even relatively light administrative sanctions produce a measurable deterrent effect on compliance among peers in the same sector (see the study) — a mechanism comparable to the one the Caisse des Dépôts is pursuing with the annual subcontracting declaration.

Preparing for the 2027 campaign starting now

The best way to approach each declaration campaign calmly is not to wait for it to open before reconstructing the past year’s history. Keep up to date, on an ongoing basis:

• a tracking table of your collected CPF revenue and the share subcontracted, month by month;
• a file per subcontractor with its Qualiopi certification (or exemption attestation) and its expiry date;
• a copy of the subcontracting contracts stating the ban on further subcontracting and the obligation to report any loss of certification.

This same tracking serves a double purpose: it feeds your EDOF declaration each year between May and September, and it constitutes the documentary evidence expected by your Qualiopi auditor on indicator 27, during your surveillance or renewal audit.

Take action

Securing your CPF subcontracting starts with having the right tracking tools and the evidence expected under indicator 27: the Complete Certif Kit (€297, 14-day guarantee) brings together ready-to-use subcontractor register templates, contracts, and audit evidence. Just starting your training organization referenced for CPF? The ebook “Create your training organization in 30 days” (€67) covers the administrative basics from day one, and the Complete Pack (€347) combines both resources. Browse all our blog articles so you never miss a CPF or Qualiopi deadline.