Qualiopi indicator 27: subcontracting and wage portage — the evidence that passes the audit

Do you entrust course delivery to freelance trainers, a partner company or a trainer under wage portage? Then indicator 27 of the Qualiopi framework applies to you: “where the provider uses subcontracting or wage portage, it ensures compliance with the framework”. Translation: you remain responsible, towards the certifier and the funders alike, for the quality of what you delegate. Here is what the auditor actually checks, the evidence that works and the classic traps — from the prime contractor’s side.

What indicator 27 really requires

The indicator, attached to criterion 6 (anchoring in the professional environment), rests on a simple idea: the learner and the funder make no distinction between your salaried trainers and your subcontractors — the service is sold under your name and covered by your certificate. The framework therefore asks you to demonstrate three forms of control:

1. Select: you choose your subcontractors against defined criteria (competencies, experience, administrative compliance), not on the fly.
2. Frame: each assignment is covered by a subcontracting contract specifying deliverables, quality requirements and compliance with your procedures.
3. Evaluate: you measure the quality of subcontracted services and act on the results (renewal, support, termination).

The full indicator sheet, with obligations and FAQ, is available on our page indicator 27 — subcontracting and wage portage.

The expected evidence, item by item

The selection procedure. One page is enough: required criteria (diplomas or experience, their own NDA where applicable, professional liability insurance, references), documents requested, who decides. The auditor is not looking for a bureaucratic machine; they are looking for proof that the choice is not improvised.

The file per external trainer. For each active subcontractor: up-to-date CV, copies of diplomas or certifications, competency file, insurance certificate, and depending on the case their NDA and the URSSAF vigilance certificate (mandatory from €5,000 excl. VAT of services per year). It is the same file as for your internal trainers (indicator 21), plus the administrative layer.

The signed contracts. One contract per assignment, or a framework contract with purchase orders, including a quality clause: compliance with your Qualiopi procedures, transmission of attendance sheets and assessments, participation in your improvement process. On a CPF-funded action, add the subcontracting declaration: the specific rules are detailed in our article on subcontracting and the CPF.

The evaluation evidence. Satisfaction questionnaires from sessions run by subcontractors (analysed like the others, indicator 30), and a trace of periodic review: a simple annual table “subcontractor / sessions / satisfaction / decision” demonstrates the full loop. This is the piece of evidence most often missing in audits.

The transmission of your requirements. Proof that the subcontractor knows your procedures: the email sending your facilitation kit, a signed external-trainer charter or booklet, minutes of a pre-session brief — which also feeds indicator 18 on trainer coordination.

Wage portage: same logic, extra vigilance

A trainer under wage portage is an employee of a portage company but works like a freelancer: for indicator 27, treat them exactly like a subcontractor (competency file, contract with the portage company, evaluation). Check that the three-party agreement clearly assigns quality responsibilities — the auditor knows this arrangement and will ask who, between you and the portage company, guarantees what.

Why the framework insists: certification as a signal

The requirement may look bureaucratic, but it answers a well-identified economic problem: a buyer (here, the funder or the learner) cannot directly observe the quality of a provider they do not know. A study by Terlaak and King published in 2006 in the Journal of Economic Behavior & Organization showed that quality certification works precisely as a signal: ISO 9000-certified firms grow faster than their non-certified competitors, especially where buyers struggle to observe actual quality — and that is the signal your certificate carries for your entire subcontracting chain (study on Google Scholar). If your system for selecting and evaluating subcontractors is empty, the signal itself becomes misleading: that is why failures on indicator 27 are treated severely.

The mistakes that cost a non-conformity

• The “invisible” subcontractor: a freelance trainer who has been delivering for years with no written contract and no file. Seniority is not compliance.
• The stale file: a 2019 CV, an expired insurance certificate. Set an annual reminder to renew the documents.
• The missing evaluation: satisfaction questionnaires collected but never linked to the subcontractor, hence no trace of monitoring their quality.
• Confusing subcontracting with co-contracting: in a consortium, each co-contractor contracts with the client and must be certified for funded actions — a different arrangement, detailed in our article on co-contracting.
• Forgetting the BPF: subcontracted services are declared in specific sections of the annual activity report (BPF), and inconsistencies between the BPF and what you tell the auditor get noticed.

Take action

Indicator 27 is solved with a one-page procedure, a standard file per trainer, a solid contract and an annual monitoring table — provided you start from good templates. The Complete Kit Certif (€297, 14-day guarantee, documents in French) includes the subcontractor selection procedure, the contract template and the evidence tables for the 32 indicators. To structure your whole activity, the kit + ebook pack (€347) remains the fastest route.