Mandatory career development interview for French training organisations: the 2026 reform

You have probably heard of the mandatory staff register or the required clauses of an employment contract. But as soon as your training organisation hires its first employee — a trainer, a pedagogical coordinator, an administrative assistant — another obligation kicks in, one often overlooked until an inspection or a dispute arises: the career development interview (entretien professionnel). This obligation has just been thoroughly reformed by the law of 24 October 2025, which changes its name, its timeline and its content. Here is what a training organisation acting as an employer now needs to know.

Who is concerned, and from when

The obligation, set out in article L. 6315-1 of the French Labour Code, applies to every employer, from the first employee onward, with no staff-size threshold. A training organisation incorporated as a company that hires a trainer on a permanent or fixed-term contract, even part-time, must hold these interviews.

You are not concerned if:

• you run your organisation alone, as a sole trader (auto-entrepreneur) or solo director with no employees (see our article on the auto-entrepreneur training organisation);
• you only work with subcontracted or independent trainers invoiced as service providers, or trainers under umbrella-company arrangements: it is their respective legal employer who holds the interview, not the client organisation. Our guide on obligations toward subcontracted trainers details this distinction.

What changes with the law of 24 October 2025

Law n° 2025-989 of 24 October 2025, which transposes three national interprofessional agreements (ANI) on the employment of experienced workers and social dialogue, took effect the day after its publication in the Official Journal — 26 October 2025. It renames the entretien professionnel as the entretien de parcours professionnel (career development interview, EPP) and changes its timeline:

	Before the reform	Since 26 October 2025
First interview	Within 2 years of hiring	Within the first year of hiring
Subsequent frequency	Every 2 years	Every 4 years
Recap review	Every 6 years	Every 8 years

Two dedicated milestones are now added to the calendar: an interview within the two months following the mid-career medical check-up, and an interview within the two years before the employee’s 60th birthday, intended as preparation for the end of their career.

Richer content

The career development interview keeps the core purpose of the former entretien professionnel — it is not a performance review, but a discussion of the employee’s development prospects — while broadening its content: career and qualification prospects, training wishes, a review of training actions completed since the previous interview, and any certifications or partial certifications obtained. For a training organisation, this interview is often the natural moment to check in with a salaried trainer about their skills development — the same logic required for trainers under indicator 22 of the Référentiel National Qualité, even though the career development interview is not itself a piece of Qualiopi evidence.

Transition period: organisations under a collective agreement

If your organisation applies a branch or company collective agreement currently in force that already sets a specific frequency for the entretien professionnel, the new legal rule does not apply immediately: the agreement continues to apply but must be renegotiated to comply with the law before 1 October 2026. For every other organisation, without a derogating collective agreement, the reform has applied since 26 October 2025. In practice, if you have an interview scheduled between these two dates, check with your accountant or your collective bargaining agreement (IDCC 1516 for most training organisations) to see which rule applies to your situation.

The penalty: a 3,000 € corrective CPF top-up

The Labour Code (article L. 6323-13) provides for an automatic financial penalty for non-compliance, but it only applies to companies with at least 50 employees: the employer must then pay a corrective top-up of 3,000 € into the employee’s personal training account (CPF). The French Supreme Court for civil matters (Cour de cassation) has ruled that this penalty is subject to two cumulative conditions: the employee must have both missed their mandatory interviews and not followed any non-mandatory training during the reference period. If either condition is not met — for instance if the employee did complete a training course, even without a formal interview — the top-up is not owed.

The vast majority of training organisations have fewer than 50 employees and therefore escape this automatic penalty. This does not remove the underlying legal obligation: an employee who has never been given a career development interview can raise this failure before the labour tribunal, particularly in the context of a broader dispute over the termination of their contract.

Why document it, even below the 50-employee threshold

Beyond the legal risk, the career development interview remains significantly underused in small organisations. A study by Céreq (the French public research centre on qualifications), authored by Danièle Guillemot and Jean-Claude Sigot, «Les entretiens professionnels, un appui aux carrières internes ou à la sécurisation des parcours?» (Céreq Bref n° 364, 2018), found that the uptake of these interviews, made mandatory by the March 2014 law, remained modest and considerably more common in large companies with well-resourced HR functions, while small organisations often treated it as one more administrative burden rather than a genuine skills-management tool. For a training organisation, that is something of a paradox: you sell pedagogy and skills development to your clients while sometimes neglecting the same exercise for your own staff. A properly held and documented interview (date, topics covered, agreed actions) protects the organisation legally and, indirectly, feeds into the competence file of your salaried trainers, detailed in our article on the trainer competence file.

Compliance checklist

• Identify every employee of the organisation and the date of their last career development interview
• Check whether a derogating collective agreement applies, and its compliance deadline (by 1 October 2026 at the latest)
• Schedule a career development interview within the first year for every new employee
• Reschedule subsequent interviews on a 4-year cycle, with a recap review at 8 years
• Add mid-career and pre-retirement interviews to the HR calendar for the employees concerned
• Keep a dated written record of each interview (even a brief signed summary)
• If the organisation has 50 or more employees, check every year for any risk of the corrective top-up

Take action

The career development interview adds to the list of administrative obligations every employing training organisation must master alongside Qualiopi preparation. The Kit Certif Complet (€297, 14-day guarantee) provides the documents and evidence expected during an audit, including for managing the competences of your salaried trainers. If you are starting out and making your first hire, the ebook “Créer son organisme de formation en 30 jours” (€67) walks through a new employer’s obligations step by step, and the full Pack (€347) bundles both resources. Find more legal obligations explained on our blog.