Trainer file: CV, diplomas and competence evidence for Qualiopi (indicators 21 and 22)

On audit day, one question comes up every time: “How do you determine and verify your trainers’ competences?” Many organisations answer by handing over a CV — sometimes several years old — and walk away with a non-conformity. Yet the simplest and most robust defence exists: the trainer file, one folder (physical or digital) per trainer, gathering all the competence evidence plus the reasoning that links each profile to the courses they deliver. This article details what that file must contain, how to keep it alive, and the traps that cost non-conformities on indicators 21 and 22.

What indicators 21 and 22 actually require

Indicator 21 “Competences of trainers” demands three things, not one: the organisation determines the competences each course requires, mobilises trainers who hold them, and evaluates over time that this remains the case. It covers all trainers, employees and subcontractors alike. A pile of CVs only addresses the second part; what the auditor wants to see is the written reasoning — this course requires these competences, this trainer holds them for these reasons.

Indicator 22 extends the requirement: staff competences must be maintained and developed continuously. Hiring a good trainer in 2024 is not enough; you must prove they kept their skills current in 2025 and 2026.

A useful clarification: whether a diploma is legally required is a separate topic, covered in our dedicated article — no diploma is legally required to become a trainer. Here, the issue isn’t the qualification itself, but the traceability of competence, whatever its source.

The trainer file checklist

Build one file per trainer, containing the following:

• Up-to-date, dated CV: the update date appears on the document; recent training-delivery experience is listed.
• Diplomas and certifications: copies of qualifications held (both subject-matter and teaching-related), including FPA or RNCP-type certifications where relevant.
• Continuing-education certificates: certificates from courses attended, webinar attestations, MOOC badges — ideally dated within the last three years.
• Documented field experience: client or employer references, projects delivered, years of practice in the subject taught.
• Job description or internal competence framework: the document that formalises the competences the course requires and the reasoning matching them to the trainer’s profile.
• Evaluations: summaries of learner feedback (end-of-course and follow-up evaluations), reports from peer observations or co-teaching sessions.
• Evidence of professional monitoring: a monitoring log, professional subscriptions, participation in communities of practice — linked to indicator 22 and the ongoing monitoring the framework expects.

This file is your simplest weapon in an audit: when the auditor asks, you open the relevant trainer’s folder and all the evidence is there, organised and dated.

Consistency with Cerfa 10782: a common blind spot

The link between the trainer file and the activity declaration is often overlooked. Cerfa 10782, the form you filled in for your activity declaration with DREETS, includes a section on your organisation’s trainers: you declared who delivers training and in which fields. Three documents must remain consistent over time:

1. the declared list of trainers (and any updates to it);
2. your course catalogue and the associated marketing materials;
3. the individual trainer files.

An auditor — or a DREETS inspector — who finds a trainer delivering sessions without appearing anywhere, or declared fields that no longer match the actual catalogue, will read it as a sign of weak oversight. An annual consistency check, for instance when preparing the financial and educational report, is enough to eliminate the risk.

Subcontractors: same requirements, locked into the contract

External trainers are not exempt — quite the opposite: indicator 27 requires the contracting organisation to verify the competences of the subcontractors and umbrella-company trainers it uses. In practice, you must hold the same core evidence for each subcontractor as for an employee: dated CV, diplomas or certifications, references, and ideally their recent continuing-education certificates.

The most effective approach is to make this collection contractual: include a dedicated clause in your subcontracting agreement requiring the provider to supply their supporting documents at signature and at each annual update. The subcontractor has obligations of their own, but it is your organisation that will carry the non-conformity if their file is empty on audit day.

Subject-matter competence and teaching competence: the auditor checks both

A frequent mistake is documenting only subject-matter expertise: twenty years of accounting experience, and no trace of any ability to teach. Yet the framework — like common sense — distinguishes knowing a subject from knowing how to teach it, a distinction explored in our article on andragogy and adult learning.

This requirement is no bureaucratic whim: it is backed by experimental evidence. A study by Towler and Dipboye published in 2001 in the Journal of Applied Psychology, “Effects of trainer expressiveness, organization, and trainee goal orientation on training outcomes” (see it on Google Scholar), shows that the trainer’s specifically pedagogical qualities — how well the material is organised and how expressively it is delivered — directly influence what learners retain. In other words, for equal subject-matter expertise, a better-structured and more engaging trainer produces better learning outcomes. This is exactly why the auditor looks for teaching-related evidence in the trainer file (train-the-trainer courses, learner evaluations, observations) alongside subject-matter evidence.

Keeping the file alive: annual updates and the development plan

A trainer file built once and never touched eventually works against you: a CV dated 2019 presented in 2026 mainly proves that nothing has been tracked since. Set up an annual ritual — on a fixed date — where every file is reviewed: CV refreshed and re-dated, new certificates filed, the year’s evaluation summary added.

For indicator 22, formalise a competence development plan for your trainers, modelled on the corporate skills development plan: planned training, co-teaching sessions with debriefs, practice-analysis meetings, professionalisation goals per trainer. The auditor expects concrete, dated, traceable actions — not a general intention.

Solo owner-trainers are not exempt: document your self-training (MOOCs with certificates, webinars, professional reading logged in a monitoring journal, participation in a peer network). A simple table — action, date, duration, link to your courses — is enough to turn a real but invisible practice into auditable evidence.

Common mistakes that cost a non-conformity

• The fossil CV: never updated since the organisation was created, undated, missing recent training-delivery experience.
• The subcontractor with no file: the organisation knows its “trusted” provider well… but holds no supporting document about them.
• Confusing subject-matter and teaching competence: a file rich in technical expertise evidence but empty of any teaching evidence — or the reverse.
• No written reasoning: documents piled up with no job description or framework linking the required competences to the trainer mobilised.
• Inconsistency between documents: trainers delivering courses without appearing in the list from the activity declaration or in the catalogue.

None of these mistakes reflects a lack of actual competence; all of them reflect a lack of traceability — and traceability is what the audit sanctions.

Take action

The Complete Kit Certif includes ready-to-use trainer file templates — competence sheet, development plan, monitoring log — to satisfy indicators 21, 22 and 27 along with the other 29. Just starting out? The ebook Create Your Training Organisation in 30 Days guides you from the activity declaration to your first files, and the complete pack combines both resources to secure your launch and certification.