CPF Subcontractor: How to Verify Compliance Before Signing (EDOF v15)

Since the publication in May 2026 of version 15 of the general and special terms of use of Mon Compte Formation, the Caisse des Dépôts has tightened the framework applicable to subcontracting for CPF-funded actions. Beyond the annual declaration of subcontracting use, already well known to EDOF-referenced providers, this new version introduces a habit that many providers have not yet built into their sales process: checking a subcontractor’s referencing status before signing with them, not after the fact. Here is why this step has become essential and how to put it in place.

What version 15 of the EDOF terms changes on subcontracting

Version 15 strengthens control and traceability across the CPF subcontracting chain on several fronts: the annual declaration obligation remains unchanged in principle but is monitored more closely, eligibility conditions for certain funding schemes are tightened, and — most importantly — a dedicated module now lets training providers check, from their professional account, the referencing status of a provider they are considering contracting with.

This module addresses a very concrete problem: until now, a principal provider had little way to confirm, at the point of choosing a subcontractor, that it actually met the referencing conditions required under Article L. 6323-9-1 of the French Labour Code. The issue was sometimes only discovered when the provider’s own annual declaration was reviewed — too late to avoid the consequences.

Why checking upfront protects you, the principal

This is the point most misunderstood by training providers who subcontract part of their CPF activity: when a subcontractor fails to meet referencing requirements, the sanction does not only target that subcontractor. The Caisse des Dépôts can also sanction the principal provider that used its services, with a payment suspension of up to 6 months and delisting from the EDOF platform for up to 12 months — a duration that can represent a major cash-flow shock for a provider whose CPF activity makes up a significant share of revenue.

In other words, choosing a subcontractor based solely on pedagogical or pricing criteria, without checking its administrative standing on EDOF, means carrying a risk for your own organization that you do not directly control. This chain-liability logic is not unique to the CPF: a study by Bill Lee, published in 2010 in Critical Perspectives on Accounting, on the failure of the UK’s “Individual Learning Accounts” scheme — the early-2000s equivalent of the CPF in the United Kingdom — shows that lax upfront controls on referenced providers directly enabled the large-scale fraud that led to the scheme’s abrupt closure in 2001 (see the study). The parallel is instructive: the more an individual training-funding scheme relies on a wide network of providers, the more upfront verification of each link in the chain determines the sustainability of the whole system — and of every organization taking part in it.

Checklist before signing with a CPF subcontractor

Before signing any subcontracting agreement covering CPF-fundable actions, make it a habit to check and document the following:

1. EDOF referencing status of the subcontractor, via the dedicated module in your professional account — keep a dated record of this check (screenshot or export).
2. Valid Qualiopi certification of the subcontractor, or proof of exemption for eligible micro-enterprises — a separate check, required since April 2024.
3. No cascading subcontracting beyond the authorized tier: request a signed statement if the contract does not explicitly exclude it.
4. A contractual clause requiring immediate notice in case of loss of certification or suspension of referencing during the contract.
5. Relationship history: if the subcontractor already works with you, re-check its status at regular intervals, not only at initial signature — a status valid one day can be suspended the next.

These records directly overlap with the evidence expected by your Qualiopi auditor under indicator 27 on subcontracting and umbrella employment: better to build them once, as you go, than to reconstruct them in a rush before an audit.

What to do if a subcontractor loses its referencing mid-contract

If you discover — through the consultation module or a direct alert — that a subcontractor currently working with you has lost its EDOF referencing, do not wait until the current engagement ends to react:

• Immediately suspend any new enrollment of CPF trainees toward that subcontractor, without waiting for the situation to be resolved.
• Document the date you discovered the irregularity and the actions taken: this response time can be decisive in the event of an audit, to demonstrate your good faith and diligence.
• Trigger the contractual notice clause mentioned above to request explanations and a remediation timeline from the subcontractor.
• Prepare a fallback solution (another referenced subcontractor, or bringing the delivery back in-house) so as not to interrupt the path of trainees already enrolled.

How this connects to the annual subcontracting declaration

This upfront check obviously does not replace the annual declaration of subcontracting use on EDOF, open every year from 1 May to 30 September. The two steps complement each other: verification protects your organization at the point of choosing a partner, while the declaration then documents, each year, how subcontracting was actually used. A provider that systematically checks its subcontractors upfront also approaches its annual declaration with far more peace of mind, since its records stay current all year round rather than being pieced together in a rush at the end of September.

Also formalize these practices in your subcontracting agreement clauses, so that checking a subcontractor’s EDOF referencing and Qualiopi certification becomes a systematic step in your sales process, rather than something left to each account manager’s discretion.

Take action

Securing your CPF subcontracting chain starts with having the right tracking tools and the evidence expected under indicator 27, right from the moment you sign your contracts. The Complete Kit Certif (€297, 14-day guarantee) includes ready-to-use subcontractor register templates, contracts, and audit evidence to document every check. Just starting your CPF-referenced training provider? The ebook “Set Up Your Training Organization in 30 Days” (€67) covers the administrative basics from day one, and the Complete Pack (€347) combines both resources. Browse all our blog articles to stay on top of every CPF or Qualiopi deadline.