Qualiopi indicator 22 (skills development): expected evidence and mistakes to avoid

Proving that your trainers are competent is not enough: Qualiopi also requires you to demonstrate that they will remain so. That is the whole point of indicator 22, attached to criterion 5, where a gap is classed as a major non-conformity — including for the independent trainer who forgot to train themselves. Here is what the indicator requires, the evidence that convinces the auditor and the mistakes that appear most often in audit reports.

What indicator 22 requires

Attached to criterion 5 of the framework (staff competencies), the indicator 22 fact sheet requires the provider to maintain and develop the skills of its employees and trainers over time. In practice, three obligations follow one another:

• identify professional development needs, based on evaluations, monitoring and interviews;
• plan actions to meet them: training courses, certifications, webinars, trade fairs, networks;
• prove their completion, with certificates and traces to back it up.

Three characteristics make this indicator particularly demanding: it applies to all categories of providers (training organisations, apprenticeship centres, VAE, skills assessments), it provides no adjustment for new entrants, and a gap is sanctioned as a major non-conformity. You can place this requirement within the framework as a whole using the table of the 32 indicators.

Indicator 22 directly complements indicator 21: after proving, through the trainer’s skills file, that your trainers are competent today, you must demonstrate that they will remain so tomorrow. And the scope is broad: trainers, administrative staff, and the head of the organisation themselves when they deliver the training.

The skills development plan: the centrepiece

The central piece of evidence for indicator 22 is a skills development plan — a document that does not need to be sophisticated, but must be complete and alive. Its minimum content:

• the people concerned (every employee, every regular trainer, the head of the organisation);
• the identified needs for each of them;
• the planned actions: training, webinar, trade fair, participation in a network;
• the deadlines;
• the completion status, updated as you go.

For a small organisation, a simple table kept up to date, backed by the certificates, is enough. A realistic rhythm: an update after each completed action, and a full review once a year, for instance at the time of the interviews or the organisation’s annual review. What matters is not the form but the logic: the auditor must be able to follow the thread between an identified need, a planned action and proof of completion. If your organisation also supports its clients on this subject, our article on the corporate skills development plan details the mechanics on the employer’s side.

This investment is not just an audit constraint. The literature review by Herman Aguinis and Kurt Kraiger published in 2009 in the Annual Review of Psychology (« Benefits of Training and Development for Individuals and Teams, Organizations, and Society ») documents the measurable benefits of continuing staff training on individual performance, team performance and organisational performance. The skills maintenance required by indicator 22 is therefore an investment whose effects are solidly established by research.

The case of the organisation head and the independent trainer

This is the classic trap of this indicator: the head of the organisation who built a plan for their employees… and forgot themselves. Yet the obligation applies including to the head of a single-person organisation, as soon as they deliver the training.

For an independent trainer, the expectation is clear: at least one documented professional development action per audited period. Several formats are acceptable:

• a training course attended (pedagogy, subject-matter expertise, digital learning);
• a certification prepared or obtained;
• a certificated MOOC;
• active participation in a professional network (community of practice, trainers’ association).

Free webinars are acceptable, on one strict condition: keep a usable trace — attendance certificate, confirmation email, programme and working notes — and be able to link them to an identified need. A webinar attended “because it happened to be on” convinces less than a webinar chosen to fill a weakness spotted in your evaluations or your Qualiopi monitoring (indicators 23 to 25). The right reflex for an independent trainer: treat yourself as your own employee, with a dedicated line in the skills development plan, fed every year.

The evidence that convinces the auditor

On audit day, here is the typical file that secures indicator 22:

• a skills development plan or table, per person and per year;
• the certificates and attestations for training courses attended — including the head of the organisation’s;
• the registration invoices for training courses, conferences or trade fairs;
• the signed professional interview reports for employees — the professional interview is both a Labour Code obligation and a natural source of needs;
• the evidence of participation in networks or communities of practice;
• the documented link between identified needs (trainee evaluations, monitoring) and completed actions.

This last point makes the difference between an average file and a solid one: the auditor is looking for a loop, not a pile of certificates. An evaluation that flags a weakness in remote delivery, a “virtual classroom” course planned then attended, an archived certificate: that is the thread they want to be able to follow. Also think about anticipating it from the hiring stage: our guide to recruiting an employed trainer shows how to build skills development in from a new trainer’s arrival.

The mistakes that cost a major non-conformity

The gaps recorded on indicator 22 look alike from one audit report to the next:

• no action carried out or planned: the most serious case, the indicator is empty;
• a theoretical plan with no proof of completion: intentions listed, no certificate behind them;
• the trainer-manager left out of the arrangement: the plan covers the employees, never the person who delivers the most hours;
• self-study declared without a verifiable trace: “I read a lot” does not constitute evidence;
• professional interviews missing or untracked for employees;
• a plan disconnected from the real needs raised by evaluations and monitoring — a catalogue of actions with no link to what your trainees experience.

The good news: each of these mistakes can be fixed in a few weeks, provided you act before the audit. An honest Qualiopi self-assessment, indicator by indicator, remains the best way to spot an empty indicator 22 before the auditor does.

Take action

The Complete Kit Certif (€297, 14-day guarantee) includes the skills development plan template, the professional interview report template and the evidence table for indicator 22, ready to customise. The ebook “Create your training organisation in 30 days” (€67) builds the head of the organisation’s professional development in from the organisation’s creation, and the full pack (€347) bundles both.