Qualiopi V10: the future indicator 33 for apprenticeships, what the 2026 draft decree provides

A draft decree from the Ministry of Labour and Solidarity, revealed in early July 2026 by the specialist vocational-training press, plans to take the National Quality Framework from 32 to 33 indicators. The novelty: an indicator entirely dedicated to apprenticeships, a first since the framework was created in 2019. On 16 July 2026, the Minister of Labour and Solidarity, Jean-Pierre Farandou, confirmed in an interview with Les Échos that an official publication was imminent. Here is what is known so far, what remains uncertain, and how a CFA can start preparing without waiting for the final text.

What the draft decree would change

The National Quality Framework (RNQ) underpinning Qualiopi certification is set by Decree No. 2019-565 of 6 June 2019, issued under Law No. 2018-771 of 5 September 2018. Its annex lists the indicators — 32 since the framework’s origin — that every auditor checks criterion by criterion. The draft decree now circulating, referenced by the professional press under the number NOR TRSD2609875D, would specifically replace this annex.

Two points are established by converging sources:

• The planned entry into force is set for 1 November 2026;
• The number of indicators would rise from 32 to 33, with a new indicator 33 specific to apprenticeships.

One point, however, still needs strict confirmation: at the time of writing, the text had not yet been published in the Official Journal. Until it is, the framework and reading guide currently in force remain the only enforceable basis before an auditor — a draft decree, however widely discussed, has no legal value until it is signed and published.

The expected content of indicator 33

According to converging analyses from several Qualiopi consulting firms, indicator 33 would require CFAs to set up a device for apprentices themselves to evaluate content and teaching, distinct from the general satisfaction survey.

This distinction is the heart of the change. Indicator 30 — collection of stakeholder feedback already requires every provider, CFAs included, to collect and use feedback from trainees, funders and teams on the course as a whole. The future indicator 33 would go further by specifically targeting the pedagogical quality as perceived by the apprentice: clarity of content, relevance of teaching methods, and how well what is taught matches what is actually useful on the job. A general end-of-course satisfaction questionnaire would therefore no longer cover both indicators: a dedicated tool and timing for evaluating the teaching itself would be needed.

Why this change, and why now

The move fits into a broader tightening of Qualiopi requirements in 2026. Since 1 July 2026, only providers actually certified Qualiopi — no longer those merely having started the process — are eligible for certain funding such as FAFCEA, following a transition period opened at the start of 2026. In this context, the minister justified the future indicator 33 by the wish to make certification bear on actual pedagogical quality rather than on documentary compliance alone, which had been seen as too dominant in audits.

This shift is not unique to France. Research on student/apprentice evaluation of teaching confirms both the value of the approach and its methodological pitfalls. A study by Wafudu, Kamin and Marcel, published in 2022 in Humanities and Social Sciences Communications, on the validity of a pedagogical quality-assurance questionnaire in vocational and technical education, shows that such a device only produces usable information if it is built and validated rigorously — an improvised questionnaire yields unreliable data (see the study on Google Scholar). A literature review by Zhao, Xu, Chen and Yan, published the same year in Frontiers in Psychology, on student evaluations of teaching in higher education, further notes that the reliability of this type of evaluation depends heavily on item wording and on when the evaluation is administered (see the study on Google Scholar). For a CFA, the lesson is direct: improvising a tool the day before an audit would likely produce fragile evidence, even if the formal indicator is technically covered.

Who would be affected — and who would not

Like the indicators already specific to apprenticeships — indicator 14 (apprentices’ civic engagement), indicator 15 (apprentices’ rights and duties) and indicator 20 (dedicated CFA staff) — indicator 33 would only apply to providers delivering apprenticeship training. A classic continuing-training organisation with no CFA activity would have nothing new to produce under this heading: its scope would remain the current 32 indicators. Our guide to the apprenticeship supervisor’s obligations and our article on coordinating work-study learning remain the right starting points for pinning down your CFA scope precisely.

What is certain, and what is not yet

Here is the state of knowledge as of this article’s publication date:

Element	Status
Move from 32 to 33 indicators	Announced by several converging professional sources, not yet published in the Official Journal
Indicator 33 dedicated to apprenticeships (teaching evaluation)	Content reported by the specialist press, subject to change before publication
Entry into force on 1 November 2026	Target date announced, not guaranteed until the text is signed
Immediate applicability in audits	No — the 32-indicator framework remains the only enforceable basis until publication

This caution is not a minor detail: overhauling your quality system based on an unpublished text risks having to readjust everything if the final version differs from the draft currently circulating. Our article on Qualiopi monitoring (indicators 23, 24, 25) explains how to organise a legal watch that alerts you as soon as the text is actually published, rather than relying on draft versions.

How a CFA can prepare now

Without waiting for the final version, three actions limit the risk of a non-conformity at the first audit following entry into force, should it happen as announced:

• Start distinguishing, today, the evaluation of teaching from the general satisfaction questionnaire — even as an extra question or module specific to apprentices, this sets up the expected structure;
• Document what this evaluation surfaces: content judged unclear, a teaching method to adjust, exactly in line with the continuous-improvement approach already required by existing indicators;
• Track the official publication through your certification body or a dedicated watch, to adjust the tool as soon as the final text — not the draft — is known, rather than locking in a device built on a still-shifting basis.

A CFA that has already structured its indicators 14, 15 and 20 already has much of the necessary groundwork: the dialogue channel with apprentices already exists; what would be needed is mainly to give it a precise pedagogical object rather than starting from nothing.

Take action

Anticipating a regulatory change still in draft form is easier when the documentary foundation of the current 32 indicators is already solid. The Complete Kit Certif (€297, 14-day guarantee) provides evidence templates for all indicators applicable to CFAs, kept up to date with ongoing legal monitoring. Starting a CFA or training organisation? The ebook “Create your training organisation in 30 days” (€67) sets the administrative foundations from day one, and the full pack (€347) brings both resources together. Browse all our blog articles to follow Qualiopi regulatory news as it is published.