The CPF canvassing ban: what a training organisation is still allowed to do

“Hello, your CPF training credits are about to expire…”: this kind of call, which plagued French households for years, is now illegal. Since law no. 2022-1587 of 19 December 2022, all unsolicited canvassing linked to the CPF (the French personal training account) is banned, whatever the channel. But this ban, too often summarised as “no more prospecting at all”, actually leaves room for perfectly lawful commercial activity. Here is the exact line between what is forbidden and what remains allowed.

Why this law exists: CPF fraud as the trigger

The CPF, credited in euros and usable in a few clicks on the Mon Compte Formation platform, attracted a wave of aggressive practices from 2020 onwards: mass calling, alarmist text messages announcing the “imminent loss” of credits, fake advisers posing as the Caisse des Dépôts, and the harvesting of social security numbers to enrol account holders without their knowledge. Unsolicited canvassing was the near-systematic entry point for these schemes.

Law no. 2022-1587 of 19 December 2022 on combating fraud against the personal training account answers on two fronts: it bans CPF-related canvassing, and it strengthens the anti-fraud toolkit — information sharing between administrations and recovery of unduly received sums by the Caisse des Dépôts. It belongs to a broader clean-up of the scheme, which continued with the tightening of EDOF listing rules and, more recently, the mandatory disclosures imposed on influencer promotion of training courses.

What exactly is banned

Every channel of unsolicited prospecting

The law prohibits any unsolicited commercial prospecting of CPF account holders when it pursues either of these two goals:

• collecting their personal data, in particular their Mon Compte Formation credentials or the balance of their training credits;
• concluding sales of services funded, in whole or in part, by the CPF.

The ban covers every channel: telephone, SMS and email, but also messages sent through social media. What matters is the unsolicited nature of the contact, not the technology used: a cold LinkedIn or Instagram private message selling a “CPF-fundable” course falls under the law just as a phone call does.

The ban extends to subcontractors and business introducers

A crucial and often underestimated point: the ban cannot be sidestepped by outsourcing the prospecting. An organisation that buys leads from a call centre, pays a business introducer or hands its “lead generation” to an agency remains concerned by its partners’ practices when they aim to conclude CPF-funded sales for its benefit. Knowingly exploiting contacts obtained through unlawful canvassing exposes the organisation itself — claiming ignorance of the provider’s methods is not a serious defence.

The answer is contractual: every agreement with a business introducer or marketing provider should explicitly prohibit unsolicited CPF-related prospecting, require traceability of the origin of each lead passed on, and provide for termination in case of breach.

The existing-client exception

The law carves out one precise exception: soliciting a client within the framework of an ongoing contract or an ongoing training course, to offer a service related to that relationship. In practice, an organisation may offer a trainee currently enrolled with it a complementary module or a higher level connected to their pathway. Contacting a former trainee months after their course ended to sell an unrelated service, on the other hand, does not fit within the exception.

What remains allowed: the inbound channel

The ban targets unsolicited outbound prospecting, not commercial visibility. The following therefore remain fully lawful:

• general untargeted advertising: billboards, spots, banners or social media posts presenting the offer to the public without individually soliciting CPF account holders;
• organic search and content: blog posts, optimised course pages, videos — drawing the prospect to you is not canvassing;
• answering an inbound enquiry: calling back someone who filled in a form, requested a quote or left their details on their own initiative;
• communicating with your own trainees during their course, within the limits of the exception described above;
• classic B2B prospecting for services unconnected to CPF funding (in-company training paid on the employer’s budget, for instance).

At a glance: banned / allowed

Practice	Status
Cold call, SMS, email or private message mentioning the CPF or training credits	Banned
Buying leads obtained through CPF canvassing, via an introducer or a call centre	Banned
Unsolicited collection of an individual’s CPF credentials or balance	Banned
General untargeted advertising (social media, billboards, press)	Allowed
Organic search visibility, blog, educational content	Allowed
Calling back a prospect who left their details voluntarily	Allowed
Offering a related service to a trainee during an ongoing course	Allowed

Penalties: the DGCCRF up front, EDOF close behind

Breaching the ban is punishable by an administrative fine imposed by the DGCCRF of up to €75,000 for an individual and €375,000 for a legal entity. The DGCCRF relies in particular on consumer reports, including through the SignalConso platform, and CPF-related canvassing has been among its recurring inspection priorities since the law came into force.

The risk does not stop at the fine. Unfair commercial practices taint an organisation’s whole file: they can feed a wider administrative inspection, with the penalties attached to training organisations’ breaches, and above all weaken the relationship with the Caisse des Dépôts. The EDOF terms of use require fair commercial practices: an organisation caught canvassing unlawfully faces a formal notice, or even a suspension or delisting of its EDOF account — in other words, the outright loss of access to the CPF market.

Good practices to keep your prospecting safe

Four habits let you keep growing the business without crossing the line:

1. Frame every business introducer in writing: a clause banning CPF canvassing, an obligation to document the origin of each lead, and immediate termination in case of unlawful practice.
2. Trace the consent of inbound prospects: time-stamped form entries, the initial email kept on file, a clear statement of the purpose of the data collection. This traceability ties in directly with your GDPR obligations as a training organisation — a prospect database with no documented origin is both a DGCCRF risk and a data protection risk.
3. Audit your existing campaigns: databases bought before 2022, automated emailing scenarios, call-back scripts — anything touching the CPF must be screened.
4. Align your communication with the EDOF terms of use: fair wording, no unqualified promise of “free training”, and consistency between the sales pitch and the offer actually listed.

What research says: canvassing as the classic fraud vector

The legislator’s choice to strike at the canvassing channel rather than only at the final fraud is anything but arbitrary. A study by Marguerite DeLiema, Martha Deevy, Annamaria Lusardi and Olivia S. Mitchell, published in 2020 in The Journals of Gerontology: Series B under the title “Financial Fraud Among Older Americans: Evidence and Implications”, documents the scale of financial fraud targeting individuals and shows that it relies heavily on unrequested commercial solicitations — calls, emails, cold contacts — which serve as fraudsters’ preferred entry point (see the study on Google Scholar). By cutting off the unsolicited-contact channel, the French CPF law attacks precisely that first link in the chain: without an imposed first contact, most CPF fraud scenarios lose their starting point.

Take action

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