First training contract before the NDA: the exact order of the French process

To obtain your French training activity number, the administration requires… your first signed training contract. But how do you sell a course when you don’t have a number yet? This apparent paradox — the chicken-and-egg of setting up a training business in France — needlessly stalls many trainers at the start. In reality, the law organises this transition phase very precisely. Here is the exact order of the steps, and what you can (and cannot) do while waiting for your NDA (numéro de déclaration d’activité, the registered activity number).

The paradox isn’t one: it’s the mechanism the law intends

Article L. 6351-1 of the French Labour Code requires anyone providing vocational training for a fee to declare the activity — and the scheme provides that this declaration be filed within three months of concluding the first training agreement or contract.

In other words, the legislator chose a regime where you declare an activity that has already started: the first sale precedes the number, by design. The first contract is not an obstacle to work around; it is the cornerstone of the file: it proves your training activity is real, and its programme lets the DREETS (regional inspection service) verify that it genuinely falls within vocational training.

The exact timeline, step by step

Step	When	What is at stake
1. Signing the first contract or agreement	Day 0	The three-month countdown starts
2. Delivering the first course (if scheduled)	From day 0	Legal: you are inside the window the law provides
3. Filing the declaration on “Mon Activité Formation”	As early as possible, before month 3	Signed contract + detailed programme + documents on the structure
4. Processing by the DREETS	~30 days	Requests for missing items possible; silence beyond the deadline counts as registration
5. Receipt of the certificate with the NDA	At the end	Update all your documents with the regulatory wording

Two pieces of field advice: do not “use up” the three months — file as soon as the contract is signed, since processing itself takes weeks; and polish the attached programme (objectives, audience, prerequisites, duration, content, assessment methods), because that is what the administration reads first. The full filing procedure is covered in our guide to the activity declaration (Cerfa 10782).

Drafting your first documents without a number

Your first quotes, agreements and invoices will go out without an NDA. Three rules for this period:

• Invent nothing. No fictitious number, no “accreditation pending” — registration does not amount to State approval anyway. A fake number on a training agreement is serious misconduct, not a workaround.
• Transparency is allowed. Nothing prevents you from telling your client that your activity declaration is being filed with the DREETS — it is the plain truth, and informed clients know the three-month mechanism.
• Prepare the update. As soon as the number arrives, add the regulatory wording to all your templates: « Déclaration d’activité enregistrée sous le numéro [NDA] auprès du préfet de région de [region] ». While you are at it, check that your agreement already carries all the mandatory clauses of a French training agreement.

The real limits of the transition period

The three-month window authorises activity, but it does not grant every right:

• No VAT exemption for training yet: the tax attestation is requested from the DREETS by a declared organisation — your first invoices therefore follow your ordinary VAT regime (including the small-business franchise, where applicable).
• No public or mutualised funding: OPCOs and the CPF require a valid NDA — and Qualiopi certification in any case. Your first client will, in practice, pay out of their own pocket.
• Buyers who demand the number: some procurement departments refuse to contract without a verifiable NDA. If your first prospect is a large account, negotiate a calendar that accommodates the registration timeline.

And one absolute limit: this tolerance only covers the legal window. Continuing to train beyond the three months without having filed tips you into operating without a valid declaration — the risks are detailed in is the NDA mandatory?.

A regime designed not to kill vocations

This sequence — sell first, declare afterwards, free of charge and online — is an advantage easily taken for granted from inside France. Economic research shows how heavily entry formalities weigh on business creation: the study by Kaplan, Piedra and Seira published in 2011 in the Journal of Public Economics, exploiting the staggered rollout of a Mexican programme simplifying firm registration, measures an increase of about 5% in monthly start-ups in eligible industries (Entry Regulation and Business Start-Ups: Evidence from Mexico).

The French declaratory regime plays the same role: it does not ask your permission to begin — only that you make yourself known once the first sale is concluded, then keep your obligations over time.

Take action

Your first signed contract is the key that opens everything else: file the declaration without delay, with a solid programme, and prepare now for the obligations that follow. The complete guide to the French training activity number (NDA) sums up the steps, the deadlines and the traps — with a free ebook walking you from signature to an active number.