Reporting procedure for harassment and discrimination: the template for Qualiopi indicator 12

On 1 November 2026, indicator 12 of the National Quality Framework changes in nature. Decree n° 2026-728 of 1 August 2026, which we covered in detail when it was published, now requires a documented, identifiable procedure for handling any situation of violence, harassment or discrimination reported by a beneficiary. As we announced in early August, a general clause in the internal rules is no longer enough. The most practical question for a training organisation or a CFA remains: how do you write this procedure so it holds up in front of an auditor? Here is a five-step template, ready to use.

What the auditor actually checks

Indicator 12 has historically covered beneficiary engagement and dropout prevention. The 1 August 2026 decree adds an explicit component on violence, harassment and discrimination, with three precise expectations during audit:

• an identified contact person, known to beneficiaries before any incident occurs;
• a formalised handling process, with an indicative response timeframe;
• evidence of distribution of this information — welcome booklet, on-site signage, contract, or digital environment depending on the training modality.

The auditor no longer simply reads a document: they can question a trainer or a trainee on site to check that the process is genuinely known, not just written down. This shift — from documentary compliance to operational compliance — is exactly why a carefully written procedure matters.

The five-step template

1. Name a single contact person

Choose an individual (director, pedagogical manager, quality referent) responsible for receiving reports. State their name, role, and a direct means of contact — phone number or dedicated email. For a multi-site organisation or one working with pedagogical subcontractors, designate a contact per site, or require the subcontractor to apply the same process and make it known to their own trainees.

2. Choose an accessible reporting channel

A simple channel is enough: a dedicated email address, a phone number, or failing that, direct contact with the referent. What matters is that this channel appears on at least two different materials — for instance the welcome booklet and the internal rules — so a beneficiary can find it without having to ask.

3. Set a handling timeframe

Formalise an indicative timeframe — acknowledgement of receipt within 48 hours, first measures taken within a week, for example. A precise figure, even a modest one, is worth more than a vague phrase like “as soon as possible”, which gives the auditor no way to verify that the commitment was met.

4. Describe the handling steps

The procedure should lay out, in a few lines, what happens after a report is received: listening to the person concerned, assessing the situation, protective measures if needed (temporary separation, group reassignment), and closure with feedback to the person. This follows the same logic already used for handling complaints and incidents: the same principles of traceability, applied to a specific ground.

5. Distribute it and keep proof of distribution

A procedure that exists but is never distributed is worth nothing in audit. Include it in the welcome booklet given at the start of every course, display it if you have physical premises, and keep proof that it was delivered (sign-off sheet, mention in the contract, screenshot of the digital environment for remote training). This proof of distribution, more than the text itself, is often what makes the difference during a surveillance audit.

The special case of CFAs: indicators 14 and 15

For an apprenticeship training centre, the procedure does not stop at indicator 12. Indicator 14 requires “without delay” handling of dropouts linked to violence or discrimination suffered by an apprentice, including at the host company — so the process needs to cover both the training centre and the workplace. Indicator 15 adds a requirement specific to minor apprentices: enhanced information about their rights and the systematic communication of the apprenticeship mediator’s contact details, to be included in the same welcome booklet.

Mistakes to avoid

• Relying on the internal rules alone. A generic legal clause does not replace an operational process spelled out in writing.
• Leaving out a timeframe. A procedure with no set deadline gives the auditor no way to check whether it is actually applied.
• Not training staff. A trainer unable to name the referent during an audit interview undermines the documentary evidence, however well written.
• Forgetting remote training. In remote learning, the reporting channel needs to be visible within the digital environment, not only on a paper document that is never consulted at a distance.

A landmark study on this topic, by Bergman, Langhout, Palmieri, Cortina and Fitzgerald, published in 2002 in the Journal of Applied Psychology (based on more than 6,400 respondents), found that whether someone actually uses a reporting channel depends less on its formal existence than on how clearly the process is perceived and how much trust exists in the outcome. That is exactly what a Qualiopi auditor now checks under indicator 12: not whether a document exists, but the real likelihood that a beneficiary knows who to turn to.

Fold this evidence into your quality file

Once written, this procedure joins the other evidence expected in audit: keep it in the same file as your corrective action plan and your proof of distribution to beneficiaries. If a report comes in before the new text takes effect, document it the same way right now — it becomes additional evidence that the process actually works, and it will count toward your next audit.

Take action

The Complete Kit Certif (€297, 14-day guarantee, documents in French) includes the indicator 12 sheet of the current framework, with a model procedure to customise; the stricter requirements that apply from 1 November 2026 are to be added from this article. Starting a training organisation or a CFA? The ebook “Create your training organisation in 30 days” (€67) sets the foundations from day one, and the full pack (€347) brings both resources together. Browse all our blog articles to get ready for the new framework’s entry into force.