OETH: the French disabled-worker employment quota for a training organisation as an employer

A training organisation that hires its first trainers, its teaching team or its administrative staff becomes an employer like any other — and, past a certain headcount, takes on an obligation many training-organisation owners confuse with the disability liaison officer required by Qualiopi: the disabled-worker employment quota, known in France as the OETH (obligation d’emploi des travailleurs handicapés). These are two entirely separate matters — one facing your learners, the other facing your own employees. Here is what you need to know so as not to mix them up.

Two different obligations, one common confusion

The disability liaison officer under indicator 26 of the National Quality Framework requires every Qualiopi-certified organisation to appoint someone responsible for supporting trainees and learners with disabilities. We covered this requirement in detail in our article on the disability liaison officer in a training organisation.

The OETH is an entirely different topic: it concerns the organisation’s own employees, in its capacity as an employer, regardless of any certification. A training organisation can be flawless on indicator 26 and still completely ignore its employer obligation once it crosses the headcount threshold — a confusion that is costly not in a Qualiopi audit, but in an Urssaf inspection.

The OETH in brief: threshold, quota, legal basis

The disabled-worker employment obligation stems from articles L5212-1 and following of the French Labour Code. It applies to any employer, regardless of sector, once its assessed headcount reaches 20 employees. The statutory quota is set at 6% of that headcount: a training organisation with 20 employees must therefore have at least 1.2 positions filled by a disabled-worker beneficiary (BOETH) to be compliant.

Below 20 employees, no contribution is owed, but the filing duty remains: every employer, whatever its size, must report the BOETH status of relevant employees monthly in the DSN (the French unified payroll declaration).

How the OETH is filed since the reform

Since the reform carried by law n° 2018-771 of 5 September 2018 on the freedom to choose one’s professional future — the same law that created Qualiopi — the OETH is no longer a stand-alone annual filing but is folded into the DSN (déclaration sociale nominative):

• every month, the employer declares the beneficiary status of relevant employees in the current DSN;
• once a year, the DOETH (mandatory declaration of disabled-worker employment) is filed in the April DSN, to be submitted in early May (the 5th or the 15th, depending on company size);
• where applicable, the Agefiph contribution owed for an unmet quota is calculated and paid at that point.

This deadline is worth adding to your training organisation obligations calendar as soon as you cross the 20-employee threshold or hire your first salaried trainers.

What changes in 2026

A notable adjustment applies in 2026: disabled workers aged 50 and over now count as 1.5 in the headcount used for the OETH, up from 1 in 2025. In practice, a training organisation employing a BOETH staff member over 50 sees its position weighted more favourably in the quota calculation — an explicit signal in favour of keeping disabled workers employed in the later part of their career.

Reaching your quota without necessarily hiring more

Several levers, which can be combined, help reach or approach the 6% quota:

• direct employment of BOETH staff, whether on permanent or fixed-term contracts;
• hosting BOETH trainees or apprentices, who count partially toward the assessed headcount — a natural lever for a training organisation or an apprenticeship centre (CFA);
• signing an approved agreement (company-, group- or sector-level) setting out a multi-year programme in favour of disabled-worker employment;
• subcontracting or co-contracting with the sheltered or adapted-work sector (ESAT, adapted enterprise), which reduces the contribution owed without requiring direct hiring.

What the research says about quota effectiveness

Disabled-worker employment quotas do not mechanically produce the expected effects. A study by Duryea, Martínez and Smith published in 2024 by the Inter-American Development Bank, «Disability Employment Quotas: Effects of Laws and Nudges», examines the introduction of a quota in Chile and finds a 15-to-20% rise in the employment of disabled workers at affected firms — but notes that about a third of that effect comes from simple reclassification of already-employed staff rather than genuinely new hires. For a training organisation, the lesson is direct: an up-to-date DSN filing is not enough to build a credible disability policy; what makes the difference — toward Agefiph as well as, for the welcome of learners, toward your Qualiopi certification body — is the real effort put into hiring, retention and workstation adaptation.

Is a training organisation really affected?

Most training organisations created in France remain sole-owner structures or very small teams, often below the 20-employee threshold: in that case, only the monthly DSN filing applies, with no contribution to pay. The topic becomes central once your organisation grows — hiring a salaried teaching team, opening a secondary establishment, structuring into a CFA — and crosses that 20-employee threshold. That is also the moment to check that your single staff register properly records, where applicable, the beneficiary status of relevant employees.

OETH vs. Qualiopi indicator 26: the table that avoids confusion

	OETH	Qualiopi indicator 26
Target population	The organisation’s employees	Trainees, learners, apprentices
Legal basis	Labour Code, art. L5212-1 et seq.	RNQ decree of 6 June 2019
Threshold	Assessed headcount of 20 employees (filing from the 1st employee)	All Qualiopi-certified organisations, no threshold
Oversight body	Urssaf / Agefiph	Qualiopi certification body
Penalty for non-compliance	Financial contribution (Agefiph)	Major non-conformity, risk of losing certification

Take action

If your organisation hires a salaried team and crosses the 20-employee threshold, the OETH joins your list of employer obligations — independently of Qualiopi. For everything related to certification itself, including indicator 26 and all 32 indicators, the Complete Kit Certif (€297, 14-day guarantee) provides ready-to-use templates and evidence. If you are starting your business, the ebook “Create your training organisation in 30 days” (€67) structures your obligations as a founder step by step, from legal status to your first hires — or choose the full pack (€347) that brings both together.