Sole-Trader Training Providers: The First-Contract Waiver for France's NDA (Order of November 24, 2025)

Until now, anyone starting a training organization in France had to attach a copy of their very first signed contract to their activity declaration (déclaration d’activité) file — the centerpiece of the NDA registration file, as detailed in our article on the first training contract before the NDA. Since the order (arrêté) of November 24, 2025, micro-entrepreneur trainers have an alternative: a brief activity summary, on a template the ministry has now set, that waives the requirement to attach that copy. Here is what this text actually changes, who qualifies, and what stays the same.

What the November 24, 2025 order changes

Decree n° 2025-728 of July 29, 2025 — already known for extending the NDA review period from 30 days to two months — also amended Article R. 6351-5 of the Labor Code on a second, quieter point. Its section II now provides that micro-entrepreneurs under the simplified social-contribution regime, with revenue below the threshold applicable to their activity, are exempted from attaching certain documents to their declaration file — in particular, the copy of the first training contract or agreement. In exchange, they must complete the file with a brief summary of their activity.

This mechanism remained unusable in practice as long as the template for that summary did not exist: the order of November 24, 2025, issued to implement section II of Article R. 6351-5, fills that gap by finally setting the standard form to use. It is therefore this order that makes the waiver actually available to micro-entrepreneurs, several months after the decree that had opened the door to it.

Who qualifies

The waiver does not apply to every training organization, or even every sole trader — it is reserved for those meeting two conditions at once.

• The simplified social-contribution regime, set out in Article L. 613-7 of the Social Security Code — the streamlined contribution system for micro-entrepreneurs (formerly “auto-entrepreneurs”), with its own rules covered in our guide to micro-entrepreneur training organizations.
• Revenue below the threshold applicable to the activity, under Article 50-0 of the General Tax Code — the simplified tax regime’s ceiling, which depends on the type of service sold.

A micro-entrepreneur who exceeds that threshold, or who has chosen another legal structure (single-member LLC, simplified joint-stock company, or other company form), remains subject to the standard file: a full copy of the first contract or agreement, with its detailed program.

What actually changes in the file

On “Mon Activité Formation,” an eligible micro-entrepreneur can now replace the scanned contract copy with a brief activity summary matching the order’s template. Based on published information about this text, the standard form covers:

• the signing date of the first contract or agreement (less than three months prior, under the same conditions as for any training organization);
• the type of contract signed — an agreement with an individual, an agreement with a company, or a subcontracting agreement;
• the planned date of the training action, the trained population (number and status: employee, apprentice, self-employed, jobseeker, etc.), and the professional objective pursued;
• the trainer’s qualifications and credentials relevant to the action delivered;
• the technical and pedagogical resources deployed.

This form therefore does not remove the need to precisely describe the first service delivered: it summarizes the key elements instead of requiring the full contractual document. The stated goal of the administration is to standardize declarations to streamline processing — a trend that also runs through the identity documents now required, covered in our article on the director’s criminal record check.

What the waiver does not change

Common misconception	Reality
“I can file my NDA without having a client yet”	No: the first contract or agreement must always be signed before filing. Only the document to be submitted changes.
“I no longer need to keep the contract”	False: a copy must remain available to present to the authorities on request, even after registration.
“The three-month deadline to declare disappears”	No: the file must still be submitted within three months of signing, as required by Article L. 6351-1.
“Every other piece of the file is simplified”	No: only certain contract-related documents are affected. Other supporting documents (bylaws, director’s ID, etc.) remain unchanged.

How to proceed in practice

Three steps for a micro-entrepreneur trainer who wants to use this waiver:

1. Check your eligibility before getting started: an active simplified social-contribution regime and projected revenue below the threshold for your activity. If a mid-year threshold breach seems likely, it is safer to also prepare the contract copy in parallel.
2. Sign first, describe second: the brief summary is drafted from an actual, already-signed contract, not a project. The order of steps stays the same as for any training organization founder.
3. Archive the signed contract in an accessible file, alongside your other supporting documents, ready to be provided on request — particularly during an inspection or a request for additional documents from the regional labor authority (DREETS).

A simplification that matters for the self-employed

Trimming one administrative document may look like a small detail, but economic research shows that this kind of simplification has a real effect on the decision to register. A study by Braunerhjelm and Eklund, published in 2021 in Small Business Economics, finds that a 10% reduction in the administrative burden tied to filing obligations raises the likelihood of new business formation by 4%, with the effect strongest at the very start of the entrepreneurial journey (Taxes, the tax administrative burden and the entrepreneurial life cycle). For an independent trainer still weighing whether to start now or wait, removing a hard-to-gather contractual document in favor of a standardized form points in exactly that direction.

Take action

This waiver simplifies one step of the NDA file, but it changes nothing about what follows: a compliant first contract, filing within three months, and then all the Qualiopi compliance work that unlocks access to funding. The ebook “Créer son organisme de formation en 30 jours” walks through building the file and filing it on Mon Activité Formation step by step, and the full NDA registration number guide recaps the whole process, the deadlines, and the pitfalls to avoid.