Promoting training through influencers: mandatory disclosures since April 2026

A content creator promotes your certifying training as “100% funded by the CPF” on Instagram or TikTok, without ever mentioning that this funding depends on eligibility conditions. Since 2 April 2026, this type of promotion is strictly regulated in France, and the training organisation that commissioned the content — not only the influencer — is directly concerned by this new obligation.

The 30 March 2026 decree: why this text exists

Decree n° 2026-233 of 30 March 2026, published in the Official Journal on 1 April 2026 and effective the following day, sets out the implementing details of article 5 of law n° 2023-451 of 9 June 2023, which regulates commercial influence and fights abuses on social media. It responds to a practice identified by French authorities: a surge in sponsored content presenting training courses as “free” or “unconditional” because they are funded by the CPF (Personal Training Account), the AIF, or an OPCO, without ever specifying that this funding is subject to precise eligibility rules. This opacity has fed aggressive commercial practices and enrolments decided on incomplete information — ground already covered, on the organisation’s side, by the fair-information duties of indicator 1 on public information.

Who is concerned: the influencer, but also your organisation

The decree’s scope is deliberately broad: it covers any natural or legal person carrying out a commercial influence activity who promotes a vocational training action funded, in whole or in part, by public funds — the CPF, France Travail, an OPCO, the State, or a Region. It applies even when the content creator operates from abroad, as soon as their content targets an audience residing in France. But the text doesn’t stop at the influencer: for a training organisation, it creates direct obligations as advertiser, with joint liability for content published on its behalf. In practice, if you pay, offer free training, or pay a commission to a content creator in exchange for promoting your publicly-funded courses, you are covered by this text just as much as they are.

The mandatory disclosure set out by the 26 May 2026 order

The decree left the exact wording of the disclosure to a follow-up text. That’s now done with the order of 26 May 2026, which sets the wording that any covered promotional content must now display:

“Obtaining public funding for a vocational training action is subject to rules and conditions that are binding on you.” (original French: « L’obtention d’un financement public pour une action de formation professionnelle répond à des règles et des conditions qui vous engagent. »)

This disclosure must be supplemented, depending on the format, by a link to the official page travail-emploi.gouv.fr/formation-et-influenceurs or, for constrained formats such as stories or short videos, by the hashtag “#MaFormationProfessionnelle, on en parle” (“my vocational training, let’s talk about it”). The stated goal of the authorities is to systematically direct the public toward a neutral source of information before any enrolment decision, rather than leaving the sole commercial narrative of the influencer or the organisation to stand unchallenged.

Your concrete obligations as advertiser

Beyond the disclosure itself, the decree and its practical implementation require a training organisation that uses a content creator to:

• verify in advance that the promoted training is genuinely eligible for the announced public funding, before any campaign;
• provide in writing to the influencer your legal name, your SIRET number, and the exact mandatory disclosures to include;
• frame the disclosure obligation and the publication schedule contractually, within the contract or agreement that binds you to the content creator;
• approve materials before publication, to make sure the disclosure is present, legible, and not cut off by editing or cropping;
• keep proof of published content (dated screenshots, content export) in case of a later check.

An organisation that was already working with content creators before April 2026 must review its existing contracts without delay: the absence of a clause on this obligation does not exempt the advertiser from joint liability.

Penalties for non-compliance

Failure to comply with this disclosure obligation falls under the penalty regime already set out by the 2023 influencer law for misleading commercial practices: up to two years’ imprisonment and a €300,000 fine for the natural or legal person responsible for the breach, with the training organisation potentially prosecuted as advertiser, jointly liable alongside the influencer.

The link with the transparency Qualiopi already requires

This decree does not create a new indicator of the National Quality Framework, but it extends a requirement the certification already imposes: fair and complete information for the public, including on funding conditions, at the heart of indicator 1 and the publication of results indicators. An organisation that let a content creator present a training course as free without nuance therefore faces a double risk: a penalty under the April 2026 decree, and exposure during a fair-information check as part of an audit or administrative review, particularly where listing the training on EDOF is at stake.

What research says about sponsored-content disclosure

The real-world effectiveness of this type of mandatory disclosure has been studied in digital marketing research. A study by Sophie Boerman, Lotte Willemsen, and Eva van der Aa, published in 2017 in the Journal of Interactive Marketing under the title “This Post Is Sponsored: Effects of Sponsorship Disclosure on Persuasion Knowledge and Electronic Word of Mouth in the Context of Facebook,” shows that a “sponsored” disclosure does activate the public’s awareness of advertising content — but that this effect is markedly stronger when the message comes from a celebrity than from a brand itself (see the study on Google Scholar). Applied to the 30 March 2026 decree, this finding sheds light on a deliberate regulatory choice: by imposing the disclosure on the influencer as well as the advertiser, the text aims precisely to activate that awareness where it is most effective — the moment the public receives the message from someone perceived as a peer rather than a seller.

How to become compliant now

If your organisation already works with, or is considering working with, content creators to promote courses eligible for CPF or other public funding, four actions secure your position without waiting for a check: audit ongoing partnerships and already-published content, insert a compliance clause into any new influence contract, provide a ready-to-use disclosure kit (exact wording, link, hashtag) to every content creator, and designate internally who is responsible for approving materials before they go live.

Take action

The Complete Kit Certif (€297, 14-day guarantee) provides the procedure templates and evidence expected to secure the fair public-information duties required by indicators 1 and 2 — the same ground shared with the obligations of the April 2026 decree on influencer promotion. If you’re just starting out, the ebook “Create Your Training Organisation in 30 Days” (€67) places these communication obligations within the full set of steps to set up your organisation, and the complete pack (€347) brings both resources together.