CPF and apprenticeship inspections: the State's priorities for 2026-2027

A circular that went largely unnoticed outside specialist training-law circles is nonetheless set to shape two years of administrative inspections: circular n° DGEFP/MOC/2026/30 of 17 February 2026, on inspection priorities in vocational training for 2026 and 2027. For anyone setting up a training provider (OF) or an apprentice training centre (CFA), it spells out very concretely where the regional control services (SRC) attached to the DREETS will focus their attention over the next two years — and therefore where to concentrate compliance efforts.

A circular that sets the course through 2027

Published by the Directorate General for Employment and Vocational Training (DGEFP), this circular follows on from Law n° 2026-534 of 25 June 2026 on the fight against social and tax fraud, itself an extension of the Cazenave law of 30 June 2025. About fifteen articles of this 115-article law directly concern vocational training and apprenticeship: strengthened powers for inspection officers, and wider information-sharing between funders (CPF, OPCOs, France Travail) and administrations. The February 2026 circular translates these new tools into operational priorities for field services.

CPF and apprenticeship: at least 75% of regional inspections

The central element of the text: actions financed through the Personal Training Account (CPF) and those falling under apprenticeship must make up at least 75% of the inspections run by regional services in 2026 and 2027. According to the DGEFP, these two funding channels have concentrated most of the fraud observed in recent years — a targeting choice that mechanically leaves less room for inspections of other funding sources (OPCOs, skills-development plans, regional funding). In practice, a provider heavily dependent on EDOF listing or a CFA whose learners are mostly under apprenticeship contracts falls within the priority target by construction, without this implying any wrongdoing.

What inspectors will check first on CPF-funded actions

For CPF-financed training, the circular spells out several points of attention that largely overlap with already-known eligibility criteria, but with heightened scrutiny:

• the certifying nature of the training offered (registration on the RNCP or the specific directory, consistency with the filed listing);
• the provider’s actual qualification to deliver the claimed action;
• consistency between the stated learning objective and the content actually delivered to trainees;
• communication and advertising practices, in line with the rules governing CPF canvassing;
• the subcontracting arrangements used to produce the action.

Particular attention also remains on remote training (virtual classrooms, e-learning, asynchronous formats), for which proof of genuine attendance and follow-up remains a classic, recurring inspection point.

CFAs: authorisation, content, and the 14 duties set out in the Labour Code

On the apprenticeship side, inspectors will focus on the CFA’s authorisation to deliver the targeted training, consistency between the content taught and the professional qualification being prepared for, compliance with administrative and accounting obligations, and the actual performance of the duties assigned to CFAs by the Labour Code. The differences in status and obligations between a CFA and a standard training provider are decisive here: a CFA carries apprenticeship-specific pedagogical obligations on top of the common baseline that applies to any training provider.

Subcontracting: an explicit targeting criterion

Another notable point: the circular lists significant use of subcontracting among the objective criteria for scheduling inspections, alongside the volumes financed through CPF or apprenticeship. A provider that delegates a significant share of its pedagogical production to third parties is therefore statistically more likely to be inspected — which makes a precise subcontracting agreement setting out respective responsibilities, and a consistent BPF declaration, all the more useful.

New CFAs: quick inspections from day one

For newly created CFAs, the circular provides for short, targeted inspections designed to verify, from the very first months of activity, that the training actions delivered are genuine — well before the 18-month Qualiopi surveillance audit comes due. The stated aim is to weed out structures set up with fraudulent intent quickly, rather than waiting through several cohorts of apprentices.

A precedent that illuminates the logic of tighter control

This tightening of controls on an individual training-funding scheme is not unique to France. The best-documented precedent is the UK’s Individual Learning Accounts, launched in 2000 on a principle close to the CPF: a study by Bill Lee published in 2010 in Critical Perspectives on Accounting (« The individual learning account experiment in the UK: A conjunctural crisis? ») shows how a scheme opened without sufficient prior control of providers was exploited on a large scale, until its abrupt suspension in 2001. That is precisely the scenario French authorities are seeking to prevent by strengthening ex-post control of the CPF rather than restricting trainees’ access to the scheme.

Preparing before the end of 2027: the checklist

• Check that every CPF-listed action matches an active, up-to-date certification on your EDOF listing.
• Document, session by session, the consistency between the announced programme and the content actually delivered.
• Formalise your subcontracting agreements with clear clauses on pedagogical oversight and the split of responsibilities.
• For a CFA, keep evidence of the performance of each of the 14 duties set out in the Labour Code up to date, not only the ones covered by the Qualiopi audit.
• Revisit the DREETS inspection preparation checklist: the documentary discipline it requires largely overlaps with the points listed in this circular.

Take action

The Complete Kit Certif (€297, 14-day guarantee) provides subcontracting agreement templates and the evidence table for the 32 indicators, ready to use in the face of a CPF or apprenticeship inspection. The ebook “Create your training organisation in 30 days” (€67) lays the right groundwork from the declaration of activity onward. The full pack (€347) bundles both at a preferential price.