Preventing violence, harassment and discrimination: the coming Qualiopi obligation under indicator 12

The draft decree set to tighten the National Quality Framework from 1 November 2026 is not limited to creating a future indicator 33 for apprenticeships. It also touches, more quietly, one of the framework’s most cross-cutting indicators: indicator 12, on beneficiary engagement and dropout prevention. According to converging analyses from several Qualiopi consulting firms, this indicator — along with indicators 14 and 15, specific to CFAs — would now require precise, documented obligations to prevent and handle violence, harassment and discrimination occurring in the training context. Here is what is known so far, what still needs confirming, and how a training organisation can start preparing without waiting for the final text.

A draft decree still circulating, not yet published

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. The draft decree now circulating in the professional press, referenced under the number NOR TRSD2609875D, would replace the annex setting the current 32 indicators, with a planned entry into force on 1 November 2026. On 16 July 2026, the Minister of Labour and Solidarity, Jean-Pierre Farandou, confirmed that an official publication was imminent — but at the time of writing, the text had still not been published in the Official Journal.

This caution is not a mere formality: until the decree is signed and published, the framework and reading guide currently in force remain the only enforceable basis before an auditor. Our article on the future indicator 33 for apprenticeships covers the other major strand of the same draft decree; this one focuses on the violence- and discrimination-prevention strand, which concerns a far broader audience than CFAs alone.

What indicator 12 already requires today

To measure the scale of the announced change, it helps to first recall what indicator 12 covers in its current form. Applicable to all categories of actions — continuing training, apprenticeships, VAE, skills assessments — it requires the provider to describe and implement measures that foster beneficiary engagement and prevent course dropouts: detecting warning signs of disengagement, tracked follow-ups, support, and handling dropouts when they occur despite everything. The auditor assesses a three-stage system — prevent, detect, react — similar in logic to what is already required under indicator 31 on complaints and incidents.

The draft decree would not replace this logic: it would extend it to a cause of course disruption so far handled implicitly, at best relegated to the internal rules — situations of violence, moral or sexual harassment, and discrimination experienced by a beneficiary during training or, for apprentices, at the host company.

What the draft decree would actually change

Based on information available so far, three changes stand out:

• A documented obligation, no longer merely a declared one. A general reminder-of-the-law sentence in the internal rules would no longer be enough: an identifiable procedure would be required, formalised, describing who receives a report, how it is handled, and within what timeframe.
• Handling “without delay” of reported situations, a responsiveness requirement explicitly mentioned for apprentices via indicators 14 and 15, and which would follow the same logic for indicator 12.
• Systematic verification during audits, both at initial audit and at surveillance and renewal stages — prevention of violence and discrimination would therefore not be a one-off checkpoint, but a recurring element of both documentary and on-the-ground review (staff actually knowing the procedure, not just its existence on paper).

For CFAs, the tightening would be twofold: the general obligation carried by indicator 12, plus a specific requirement under indicators 14 and 15 on informing apprentices of their rights, civic engagement in the workplace, and the role of the apprenticeship mediator when a report is made.

Why a “known” procedure matters more than a document

The most significant point of the draft decree is not the addition of a new theme, but the shift in the requirement itself: from documentary compliance to operational compliance. This is a finding echoed by research on the effectiveness of harassment-prevention systems in professional settings. A study by Roehling and Huang, published in 2018 in the Journal of Organizational Behavior, on the effectiveness of sexual harassment prevention training, shows that a purely formal device — a written policy or an isolated awareness session, without a clear reporting procedure, genuine staff buy-in, or follow-up over time — has a limited, sometimes null, effect on actually reducing problematic situations (see the study on Google Scholar). In other words: ticking the “we have a document” box while nobody on the team actually knows who to direct a struggling trainee to is exactly the kind of fragile evidence this draft decree appears designed to rule out.

For a training organisation, the practical translation is direct: the expected evidence would no longer be just a clause in the internal rules, but a known circuit — who listens, who decides, within what timeframe, with what record kept.

Who would be affected

Organisation	Expected obligation
Any Qualiopi-certified provider (continuing training, VAE, skills assessments)	Strengthened indicator 12: documented procedure to prevent and handle violence, harassment, discrimination
CFAs and apprenticeship training providers	Strengthened indicator 12, plus indicators 14 and 15: informing apprentices of their rights, handling “without delay”, role of the apprenticeship mediator
Multi-site organisations or those using pedagogical subcontractors	Procedure to be rolled out across every site and written into subcontracting agreements, with the subcontractor applying the same circuit

How to prepare now, without waiting for the final text

Three actions limit the risk of a non-conformity at the first audit following entry into force, should it happen as announced on 1 November 2026:

• Name a designated contact person to receive reports of violence, harassment or discrimination — the same logic as the disability referent already required under indicator 26, or the dropout-prevention referent already expected under current indicator 12;
• Write a one-page handling procedure: who receives the report, within what timeframe it is handled, how the person concerned is kept informed, and how the incident is logged — modelled on the procedure already expected for complaints and incidents (indicator 31);
• Fold this circuit into the organisation’s continuous-improvement loop, so that each handled report feeds, where relevant, a corrective action — in line with the Qualiopi continuous-improvement approach already required under indicators 30 to 32.

An organisation that has already structured its internal rules and its complaints procedure already has much of the groundwork in place: what would mainly be needed is naming an explicit circuit dedicated to violence and discrimination, rather than leaving it scattered across general documents.

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 procedure and evidence templates for all applicable indicators, including indicator 12 and complaints handling, kept up to date with ongoing legal monitoring. Starting a 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.