Qualiopi portage: operating under another structure's certification — how it works, fees, limits

You don’t hold Qualiopi, but a structure offers to “carry” your training courses under its own certification, for a commission. This practice, which the market commonly calls “Qualiopi portage,” attracts many trainers who want access to French public funding without going through the audit themselves. It actually covers very different arrangements: some are fully regulated and legitimate, others amount to outright fraud. Here is how to tell them apart, what this model really costs, and when it becomes better to create your own training organisation.

What “Qualiopi portage” actually covers

The expression refers to billing your training through an already-certified third-party structure, instead of obtaining your own certification. The trainer finds the clients, designs and delivers the sessions; the host structure — a certified training organisation, or an umbrella company (société de portage salarial) holding a training activity number (NDA) and Qualiopi — signs the contracts, collects the funding and pays out the balance after deducting its commission.

This model belongs to a well-documented broader trend: the study by Lawrence F. Katz and Alan B. Krueger, “The Rise and Nature of Alternative Work Arrangements in the United States, 1995–2015,” published in 2019 in the ILR Review, describes the rise of alternative work arrangements where independent workers operate through platforms or third-party structures rather than directly (see the study on Google Scholar). Qualiopi portage is the French incarnation of this intermediation logic, applied to a market where access to funding is conditional on a certification.

But not all forms of intermediation are legally equal. Two forms are legitimate; a third is a red line.

The two legitimate forms of portage

Subcontracting for a certified lead organisation

First arrangement: you work as a subcontractor for a certified training organisation, which sells the course under its own brand and entrusts you with delivering it. This scheme is explicitly provided for by the French National Quality Framework: indicator 27 covers both subcontracting and umbrella employment, and requires the lead organisation to demonstrate control over the quality of the service — selecting the trainer, contracting, passing on quality requirements, evaluating the delivery.

That control is precisely what makes the arrangement lawful: the host is not a mere invoicing desk, it takes on quality responsibility end to end. In return, expect to provide your CV, references and proof of maintained skills — we detail what the lead organisation may require in our guide to the obligations of subcontracting trainers.

Umbrella employment through a certified company

Second arrangement: you become a salaried employee of an umbrella company that itself holds an NDA and Qualiopi certification. The company contracts with your clients, taps into public funding where applicable, and pays you a salary. This scenario, the checks to run beforehand and the status question are covered in detail in our article on umbrella employment for trainers and Qualiopi; the economic essence is this: you trade a share of your revenue for the structure’s administrative, social-protection and “certification” coverage.

Fees: what host structures charge

The business model of Qualiopi portage rests on a commission proportional to invoiced revenue. Its level varies widely depending on the scope of services included:

• full administrative management (agreements, invitations, attendance sheets, certificates) or mere re-invoicing;
• handling of the EDOF listing and case files where relevant;
• production and archiving of quality documents usable in an audit;
• professional liability insurance covering the delivery.

In umbrella employment, management fees commonly run around 5 to 10% of invoiced revenue, on top of which employee and employer social contributions are deducted from the salary paid. In subcontracting for a lead training organisation, there is no market rate card: the host’s margin is negotiated case by case, depending on who brings the client and who produces the quality evidence. Before signing, demand a written breakdown: a commission in exchange for which services, exactly? A high commission can be justified by a genuine back office; a high commission with no services attached is the first sign of a dubious setup.

The legal limits: what changed on 1 April 2024

Qualiopi portage long thrived in a grey area: a single certified entity at the top of the chain, uncontrolled trainers below. The French legislator closed that door for the CPF. Since 1 April 2024, under decree no. 2023-1350 of 28 December 2023:

• the subcontractor delivering CPF-eligible training must hold its own Qualiopi certification, unless it operates under the micro-social regime with annual revenue below €77,700 excluding VAT;
• the lead organisation cannot subcontract more than 80% of its CPF revenue;
• chain subcontracting is prohibited: the subcontractor cannot subcontract in turn.

In practice, for CPF-funded training, portage through simple subcontracting now only works for micro-entrepreneurs under the threshold — and within the 80% cap on the host’s side. We detail these rules and the EDOF declaration duties in our article on CPF subcontracting and the Qualiopi requirement. Outside the CPF (OPCO funding, companies, self-funded trainees), subcontracting without your own certification remains possible, under the lead organisation’s quality responsibility.

The red line: “renting” a certification

Then there is the arrangement some offers barely disguise: the pure rental of a certification. The pattern is always the same — the “host” invoices and takes its commission, but exercises no real control over the service: no trainer selection, no quality control, no trainee management. The certificate serves as a shopfront, nothing more.

This setup is high-risk for every party involved:

• for the host: delisting from EDOF by the Caisse des Dépôts and withdrawal of the Qualiopi certification, since indicator 27 requires precisely the control it does not exercise;
• for the trainer: requalification of their situation, loss of the invoicing channel overnight, and exposure in the fraudulent case files they contributed to.

The test is simple: if the host structure never asked for your CV, your course programme or a single piece of quality evidence, this is not portage — it is shopfront rental. Remember also that outside public and pooled funding, selling your training without Qualiopi remains perfectly legal: better to invoice directly outside funded schemes than to enter a fraudulent setup to capture CPF money.

Portage, subcontracting or creating your own organisation: the decision tree

Criterion	Umbrella employment (certified company)	Subcontracting for a certified organisation	Creating your own certified organisation
Qualiopi to obtain yourself	No	No outside the CPF; yes for the CPF except micro-social < €77,700 excl. VAT	Yes
Recurring cost	Management fees ~5 to 10% of revenue + social contributions	Lead organisation’s margin, negotiated	Certification and audit costs
Access to funding	Indirect, through the structure	Indirect, capped at 80% of the host’s CPF revenue	Direct
Brand and quality track record	Stay with the host	Stay with the lead organisation	Belong to you

In short:

1. Occasional activity or early days, clients brought by training organisations: subcontracting is the natural path — without your own certification outside the CPF, and with the micro-social exemption under conditions for the CPF.
2. Steady volume but no desire to run a structure: umbrella employment through a certified company buys simplicity, at the price of the commission and social contributions.
3. Direct clients, recurring OPCO/CPF funding, a brand to build: renting someone else’s certification is neither sustainable nor, for the CPF, legal beyond the cases provided for. It is time to create your own training organisation and obtain your own certification.

Take action

If the trade-off points towards your own certification, don’t start from a blank page: the Complete Kit Certif at €297 (14-day guarantee) provides document and evidence templates for all 32 indicators — including indicator 27 if you become a host structure yourself. The ebook “Create your training organisation in 30 days” at €67 walks you step by step through the activity declaration and administrative set-up, and the Kit + Ebook Pack at €347 combines both to move from portage to certified independence.