CPF subcontracting: does the subcontractor need Qualiopi certification? (rules since April 2024)

You run a training organisation listed on EDOF and rely on freelance trainers to deliver your CPF-funded sessions? Or you are a subcontracted trainer in France and a client has suddenly asked for your Qualiopi certificate? Since 1 April 2024, the rules have changed: decree no. 2023-1350 of 28 December 2023 requires, with one exception, that subcontractors working on CPF-eligible training hold their own Qualiopi certification. Here is what that means in practice — for the principal (donneur d’ordre) and for the subcontractor — and how to secure your contracts for 2025-2026.

What the decree of 28 December 2023 changed on 1 April 2024

Before this reform, an EDOF-listed provider could outsource the delivery of its CPF courses to non-certified subcontractors: only the principal needed Qualiopi, and its certification “covered” the whole chain. That set-up fuelled well-documented abuses — reselling EDOF access, mass subcontracting to trainers subject to no quality control at all — which the regulator decided to shut down.

Decree no. 2023-1350 of 28 December 2023, in force since 1 April 2024, lays down four structural rules for subcontracting CPF-eligible training:

• Qualiopi is mandatory for the subcontractor: anyone delivering CPF-eligible training on behalf of an EDOF-listed provider must hold their own Qualiopi certification, plus their own training activity declaration (déclaration d’activité).
• A targeted exemption: providers under the micro-social regime (micro-entrepreneurs) with annual turnover below €77,700 excl. VAT are exempt from Qualiopi for CPF subcontracting work.
• A subcontracting cap: the principal cannot subcontract more than 80% of the annual turnover it generates from the CPF.
• No cascading: the subcontractor cannot itself re-subcontract the work.

On top of this comes a declaration duty: subcontractors must be declared by the principal on EDOF. Breaching these rules exposes the provider to delisting from the platform by the Caisse des Dépôts — in other words, losing access to CPF funding altogether.

If you are the EDOF-listed principal: your four obligations

1. Check each subcontractor’s status

Before assigning any CPF work, there are only two scenarios:

Subcontractor profile	Qualiopi required?
Micro-entrepreneur (micro-social regime) with annual turnover < €77,700 excl. VAT	No, exempt
Any other provider (micro-entrepreneur above the threshold, sole trader, company, umbrella arrangement…)	Yes, own Qualiopi certification + activity declaration

In practice: request the Qualiopi certificate (check the certified scope — at least the “training actions” category — and its validity date), the activity declaration number, and, for exempt micro-entrepreneurs, a sworn statement covering their regime and turnover. These checks mirror the ones we detail in our guide to subcontracting obligations in professional training.

2. Stay within the 80/20 ratio

The 80% cap is assessed against the annual turnover generated from the CPF. A provider collecting €200,000 of CPF revenue in a year can therefore subcontract no more than €160,000 of it. Set up a simple tracker cross-referencing your EDOF receipts and your subcontractors’ invoices, updated quarterly, so you never discover an overrun at year end.

3. Declare your subcontractors on EDOF

Declaring subcontractors on the platform is not an optional formality: it is how the Caisse des Dépôts monitors the delivery chain. An undeclared subcontractor is grounds for sanctions, up to and including delisting.

4. Put it in the contract and keep the evidence

The subcontracting agreement must record the Qualiopi certification (or the micro-social exemption), the scope of the assignment and the ban on re-subcontracting. Our article on the clauses of a training subcontracting agreement lists the provisions to include. This formalisation is more than legal caution: a study by Handley and Gray published in 2013 in Production and Operations Management shows that the quality of an outsourced service rests precisely on the contractual incentive and monitoring mechanisms put in place by the principal (see the study on Google Scholar). The December 2023 decree transposes exactly that logic to the CPF: since the principal cannot oversee everything directly, the regulation imposes contractual safeguards and certification-based control.

If you are the subcontracted trainer: what should you do?

If you work as an independent trainer for EDOF-listed organisations, ask yourself two questions:

• Are you a micro-entrepreneur below €77,700 excl. VAT in annual turnover? If so, you are exempt from Qualiopi for CPF subcontracting. You still need a training activity declaration to operate as a training provider — see our guide to the obligations of subcontracted trainers.
• In every other case (company, sole trader under the standard tax regime, micro-entrepreneur above the threshold), you must obtain your own Qualiopi certification to keep delivering CPF-eligible training. Allow several weeks between preparation, the initial audit and the issue of the certificate: plan ahead before your clients drop you from their sessions.

Watch out for growth too: an exempt micro-entrepreneur who crosses the €77,700 threshold loses the exemption. If your CPF subcontracting business takes off, certification becomes unavoidable — and can also be your springboard to your own EDOF listing and direct sales.

And outside the CPF? Indicator 27 still applies

The requirement for the subcontractor to hold its own certification only covers CPF-eligible training delivered on behalf of an EDOF-listed provider. For courses funded by OPCOs, employers or learners’ own funds, subcontracting without your own Qualiopi remains possible.

However, the principal’s Qualiopi audit always covers subcontracting through indicator 27 of the framework: you must demonstrate that you verify the competence and compliance of your subcontractors (CVs, references, performance reviews, contract). In other words, even outside the CPF, an empty subcontractor file is a non-conformity waiting to happen at your surveillance or renewal audit.

Compliance checklist for 2025-2026

• Map your subcontractors: who works on CPF-funded courses, under which status, with what turnover?
• Collect Qualiopi certificates (scope + validity) or micro-social exemption statements, and set a reminder ahead of each certificate expiry.
• Write it into the contract: Qualiopi status or exemption, ban on re-subcontracting, duty to inform the principal if certification is lost or the turnover threshold is crossed.
• Track the 80/20 ratio on your CPF turnover, quarter by quarter.
• Declare every subcontractor on EDOF before they deliver anything.
• Keep an up-to-date subcontractor register: it is your evidence for indicator 27 and for any Caisse des Dépôts inspection.

Take action

Securing your CPF subcontracting starts with the right templates: subcontracting agreement, subcontractor register, evidence expected for indicator 27. The Complete Kit Certif at €297 gathers all the ready-to-use documents and audit evidence to pass your certification with confidence. If you are a subcontracted trainer who now needs your own certified structure, the ebook “Create your training organisation in 30 days” at €67 walks you through it step by step, and the Kit + Ebook Pack at €347 combines both to cover setting up and getting certified.