Training Subcontracting: Indicator 27 Revised by the August 2026 Qualiopi Decree

Decree n° 2026-728 of 1 August 2026, which expands the Qualiopi framework to 33 indicators from 1 November 2026, is not limited to harassment prevention or apprenticeship. It also revises indicator 27, which covers the use of subcontractors and employee-leasing trainers — see our guide to the evidence expected at indicator 27. For any training provider that outsources all or part of a training service, this is one of the most concrete changes to prepare for before the next audit.

What indicator 27 required until now

In its current version, indicator 27 requires the certified provider to demonstrate that it selects subcontractors using objective criteria (CV, references, experience) and ensures the compliance of their services. In practice, many providers rely on a fairly generic subcontracting agreement, backed up by a handful of scattered supporting documents. The August 2026 decree tightens this requirement considerably.

A written subcontracting contract becomes mandatory

From 1 November 2026, auditors must be able to review a formalized subcontracting contract for each such relationship, explicitly setting out the split of responsibilities between the principal provider — the certified organization that remains accountable to the client and the funder — and the subcontractor delivering the service. An email exchange or a simple purchase order is no longer sufficient evidence. Our article on the essential clauses of a subcontracting contract remains the reference for drafting this document, but it must now cover the following points as well.

Contractual traceability of compliance with the framework

This is the heart of the revision: the contract must now set out, in writing, how the principal provider ensures — and can prove — that the subcontractor complies with the National Quality Framework. In practice, this means contractually providing for:

• systematic transmission of attendance sheets or remote-learning attendance evidence;
• delivery of the learning-assessment evidence produced by the subcontractor;
• a process for escalating beneficiary complaints and incidents, consistent with the principal provider’s own complaint-handling process;
• the control arrangements by which the principal provider monitors compliance with these commitments throughout the service.

It is no longer enough to select a good subcontractor at the outset — providers must now document active oversight throughout the engagement.

Employee-leasing trainers now explicitly covered

The text extends the scope of indicator 27 to trainers working under employee-leasing (portage salarial) arrangements. This model, often perceived as closer to hiring than to subcontracting, sometimes escaped equally rigorous formalization. The decree closes this gray area: whether a trainer works under standard subcontracting or employee leasing, the same level of contractual traceability now applies.

CPF subcontracting: a separate obligation that remains unchanged

This revision of indicator 27 does not alter the specific rules governing subcontracting of CPF-funded actions in force since April 2024: mandatory Qualiopi certification of the subcontractor above a certain revenue threshold, a cap on the share of subcontracted delivery, and declaration on the EDOF platform. The two obligations now stack: certification of the subcontractor on one hand, contractual formalization and traceability of its compliance on the other.

Why this requirement is not arbitrary

Tightening contractual oversight of external providers is not unique to vocational training. A study by Steven, Dong and Corsi, published in 2014 in the Journal of Operations Management, examined the link between the concentration of outsourced suppliers and the frequency of quality defects in international supply chains; it found that growing reliance on external providers, without a structured monitoring mechanism, is associated with a measurable increase in quality incidents (see the study). Applied to training delivery, the finding echoes the logic behind the decree: the more a provider outsources, the more contractual traceability of compliance becomes the only safeguard against a quality drift it can no longer directly control.

What this changes for your audit file

For a surveillance or renewal audit scheduled after 1 November 2026, the auditor may request, for each active subcontractor, the formalized contract and the resulting monitoring evidence. Two situations to fix as a priority:

1. Old or informal contracts: review every current subcontracting agreement and confirm it explicitly states the split of responsibilities and how evidence is escalated.
2. Unformalized employee leasing: if you work with employee-leased trainers without a contract covering this level of detail, this is the most urgent point to address, since it is the least anticipated change in the text.

How to document traceability day to day, without red tape

In practice, formalizing this traceability does not mean multiplying spreadsheets. Three habits usually suffice:

• An amendment rather than a new contract: if your existing subcontracting agreements already cover selection and evaluation of the provider, a one-page amendment is enough to add the split of responsibilities and the evidence-escalation process — no need to redraft everything.
• A checkpoint at the end of each session: systematically requesting attendance sheets and assessment evidence from the subcontractor at the end of each session avoids scrambling for documents right before the audit.
• A named contact on the subcontractor’s side: the contract should designate a person responsible for escalating complaints and incidents, so a beneficiary’s report never falls between two organizations.

These traces of active monitoring, more than the contract itself, are what the auditor will look for: a perfectly drafted contract that is never followed up during delivery does not provide the expected proof.

Timeline: what to do before 1 November 2026

The detailed timeline for the move to the 33-indicator framework remains the reference for all deadlines. On the subcontracting front specifically:

• list every subcontractor and employee-leased trainer currently or recently engaged;
• for each, confirm a written contract exists covering the split of responsibilities;
• add, where needed, a traceability clause (attendance, assessments, complaints) and the associated monitoring mechanism;
• document this update in your corrective action plan if a contract needs to be reworked before the next audit.

Take action

The Complete Kit Certif (€297, 14-day guarantee, documents in French) includes the indicator 27 sheet of the current framework (subcontracting procedure and evidence table), to be completed with the traceability and monitoring clauses expected from 1 November 2026. Already setting up your training organization and recruiting external trainers? The ebook “Create your training organization in 30 days” (€67) lays the right contractual foundations from the start, and the Complete Pack (€347) bundles both resources. Browse all our blog articles to secure every relationship with your external providers.