Individual distance-learning protocol (FOAD): content and template

A well-designed e-learning module is not enough to pass a Qualiopi audit if nothing proves, learner by learner, that the obligations specific to distance learning were met. That is exactly the role of the individual training protocol: a document naming one beneficiary, drawn up before training starts, that formalises the support provided, the remote activities, and how they are tracked. Here is what it must contain, how to draft it, and how it fits with the rest of your pedagogical file.

Why this document exists: what the Labour Code says

Article L6313-2 of the French Labour Code allows a training action to be delivered “in whole or in part remotely.” The legal framework for FOAD sets out the two obligations that come with this flexibility: appropriate technical and pedagogical support to accompany the beneficiary through their course, and information on the pedagogical activities to be completed remotely along with their estimated average duration. Evaluations that punctuate or conclude the course are added on top.

The Labour Code does not name the document that formalises these three points, but professional practice — echoed by Fffod (the digital training industry forum), several OPCOs, and many auditors — has settled on the term “individual training protocol” (sometimes called a distance-learning protocol). This is not one more administrative box to tick: it is the most direct way to turn a general regulatory obligation into a dated, individualised commitment, enforceable in the event of a dispute or an inspection.

What the protocol must contain

A complete individual training protocol brings together six categories of information.

1. Identification of the course and the beneficiary

The beneficiary’s name and contact details, the exact course title, the session’s opening and closing dates, and a reference to the agreement or contract that frames it. These mentions link the protocol to the rest of the file and stop it becoming a stand-alone document.

2. The split between in-person, live, and self-paced activities

For each major sequence of the course: the delivery mode (in-person, live virtual session, self-paced module), its estimated duration, and — for self-paced remote activities — a description precise enough that an auditor understands what is actually asked of the beneficiary. Not just “module 3,” but the nature of the work (watching a video, reading, an exercise, a quiz) and the average time needed to complete it.

3. Technical and pedagogical support

The name of the pedagogical contact and, if different, the technical contact; the channel to reach them (messaging, video call, moderated forum, phone); an announced response time. This is the point Qualiopi auditors check first on this delivery mode, since a module left with no identifiable human point of contact is the most common non-conformity found in FOAD.

4. Technical access arrangements

The platform used, login credentials and the connection procedure, hardware requirements (browser, bandwidth, equipment), and what to do in case of a technical issue — a point already covered in general terms by the training programme, but which the protocol individualises for the specific session.

5. The evaluations that punctuate or conclude the course

The nature of the evaluations (quiz, case study, simulated task), when they occur, and pass criteria where relevant. This section directly answers the third requirement set by the texts governing FOAD.

6. How attendance will be evidenced

What the provider commits to collecting to prove the course was actually completed remotely: connection logs, tracking of progress through the modules, records of participation in live sessions. The detail of which evidence to archive is covered in our article on attendance evidence in FOAD — the protocol only sets the principle and commits to it contractually.

When and how to use the individual training protocol

The protocol must reach the beneficiary before training starts, alongside the joining instructions or the welcome booklet, not after the fact. A document produced retroactively, at audit time, carries no evidential weight: what matters to the auditor, as to the funder, is the issue date relative to the session’s start date.

It fits alongside three other documents without replacing any of them:

• the training programme, which describes the action in general terms and forms the basis for every individual protocol drawn from it;
• the agreement or training contract, which organises the contractual and financial relationship and the terms of cancellation;
• the welcome booklet, which informs the beneficiary more broadly about how the provider operates, their rights, and how to raise a complaint.

An inconsistency between these documents — a protocol naming a different contact than the one listed in the welcome booklet, or a remote-activity duration that does not match the programme — is a red flag auditors consistently pick up on, since it calls the reliability of the whole file into question.

The link with the Qualiopi framework

The individual training protocol is not evidence for a single indicator: it feeds several at once, which makes it a particularly efficient document to build correctly just once.

• Indicator 8 on entry-level positioning is strengthened when the protocol restates the technical prerequisites identified beforehand.
• Indicator 9 on delivery conditions is directly served by sections 1, 2, and 4 of the protocol.
• Indicator 10 on adapting the service, welcome, and follow-up relies on the section covering technical and pedagogical support.
• Indicator 19 on pedagogical resources finds in the protocol the demonstration that remote resources are designed to be followed, not just published online.

An audit file that presents a coherent individual training protocol for every FOAD beneficiary answers, in a single document, requirements the auditor would otherwise have had to piece together indicator by indicator.

Why formalising individualisation reduces dropout

Formalising support is not just a compliance exercise: research in education science shows that how a learner perceives the support available directly shapes their ability to see a remote course through to the end. In a landmark study on learner self-direction in open training, researcher Annie Jézégou (University of Lille) shows that autonomy for FOAD beneficiaries is not simply decreed: it depends on the conditions the scheme is designed with — including how clearly pedagogical support is communicated — rather than on the learner’s willpower alone (Jézégou, “Formations ouvertes et autodirection de l’apprenant,” Savoirs, 2008). A protocol that names a contact, announces a response time, and details the activities expected is therefore not just audit evidence: it is one of the concrete conditions that help a beneficiary stay engaged through to the end of their course.

Mistakes to avoid

• A generic protocol never individualised: dates, named contact, and schedule left blank or identical from one session to the next, which betrays the absence of real tracking.
• A document delivered after training has already started, when it must be communicated before training begins to carry evidential weight.
• Support mentioned without a concrete channel or response time: “a trainer is available” does not meet the requirement if the beneficiary does not know whom to contact or how quickly to expect a reply.
• No archived copy of the signed protocol in the beneficiary’s file, when it must be kept alongside the programme, the agreement, and the attendance evidence.

Take action

The Complete Kit Certif (€297, 14-day guarantee, documents in French) includes an individual distance-learning protocol template ready to personalise, plus the 32 evidence documents expected at audit across the whole framework. If you are launching your training business, the ebook « Créer son organisme de formation en 30 jours » (€67) guides you step by step through building your first courses, including remote ones, or choose the full pack (€347) to cover creation and certification in one go.