Pre-employment medical check-up: what a French training organisation owes its first salaried trainer

The first permanent contract is signed, the trainer is on board, the hiring declaration has gone to social security — and then a call comes in from the occupational health service that nobody had thought about. Moving from freelancer to employer surfaces an obligation many training-organisation founders discover late: the pre-employment medical check-up. It is neither optional nor a Qualiopi formality — it is a Labour Code obligation that applies to every employer, including a training organisation that has never had a single employee before this hire.

Joining an occupational health and prevention service

Before any visit can happen, the employer must join an occupational health and prevention service (SPST) — the current name for what used to be called “médecine du travail” since the law of 2 August 2021. This membership is mandatory from the very first employee, whatever their contract: permanent, fixed-term, part-time, or the sector-specific usage fixed-term contract.

For a training organisation hiring its first salaried trainer, this is often the very first “employer” administrative step to complete — even before the single staff register. The SPST charges an annual fee per employee, and the amount varies by provider, so it is worth comparing a few services before signing: follow-up quality and appointment lead times differ noticeably between them.

The information and prevention visit (VIP): what it replaced

Since the occupational health reform, the traditional pre-employment medical examination has given way to the information and prevention visit (VIP) for most positions. It can be carried out by an occupational physician, but also by an occupational-medicine intern, a collaborating physician, or an occupational health nurse — which partly explains why appointment lead times remain manageable despite the shortage of occupational physicians.

Its purpose, set out in Article R4624-10 of the Labour Code, is to ask the employee about their health, inform them of any risks associated with the position, raise awareness of prevention measures, and refer them to the occupational physician if needed. It is therefore not, strictly speaking, a fitness-for-work examination for a trainer’s position — unless the role falls under enhanced individual monitoring, which stays rare in a training organisation outside specific risk exposure (for example, a trainer who also runs hands-on workshops involving machinery or working at height).

The deadline: three months, with exceptions worth knowing

The general rule sets the VIP within a maximum of three months after the employee actually starts the job. Three situations tighten that window:

• Apprentices: the visit must take place within two months of hiring — a point not to miss for a training centre hiring its own apprentice-trainer or hosting apprentices.
• Minors: the visit must happen before they start the job.
• Night workers: same rule — the visit must happen before they are assigned to the position.

An exemption exists: if the employee has already had a VIP within the five years preceding the hire, for an equivalent position without particular risk and with the same or an equivalent SPST, the employer may be exempt under strict conditions (equivalent position held, no reported unfitness, no individual accommodation measure in place). When in doubt, arrange the visit anyway — a wrongly applied exemption does not protect the employer during an inspection.

Who arranges it, and who pays?

It is the employer who:

• takes the initiative to schedule the appointment, generally through the SPST once membership and the employee’s registration are in place;
• covers the full cost — the SPST fee, the visit’s duration paid as working time, and travel expenses if the visit takes place away from the usual premises;
• cannot pass any part of this cost on to the employee.

In practice, registering the employee with the SPST should happen as soon as the contract is signed, to avoid missing the deadline — appointment slots can book up several weeks in advance depending on the region.

The risk of forgetting

Failing to arrange the VIP exposes the employer to a criminal penalty: a fine set for fifth-class offences, with a risk of imprisonment on a repeat offence within three years. That risk is rarely the top priority of a standalone labour inspection, but it takes on a very different weight after a workplace accident: a documented lack of medical follow-up can aggravate the employer’s liability and complicate the organisation’s defence before the health insurance fund or, if inexcusable fault is alleged, before a court.

On the actual effectiveness of these visits, the scientific literature invites some nuance without undermining the obligation itself: a 2016 Cochrane review by Schaafsma and co-authors (“Pre-employment examinations for preventing injury, disease and sick leave in workers”, see the study) found that general pre-employment medical examinations have a limited effect on preventing accidents and sick leave, unlike examinations targeted at the tasks actually performed in the role. For a training organisation, the practical takeaway is clear: the administrative VIP does not replace genuine vigilance over the real risks of the position — carrying loads for a trainer running hands-on workshops, prolonged standing, or heavy screen use — which belongs in the workplace risk assessment document.

The link with Qualiopi: a quiet but real one

The VIP is not itself an indicator in the national quality framework, but it indirectly feeds several pieces of evidence expected at audit:

• Indicator 17 — human and technical resources: a complete employer file (hiring declaration, single staff register, VIP arranged) reassures the auditor that the teaching team is genuinely structured, beyond the trainer’s résumé alone.
• Indicator 21 — trainers’ competencies: the trainer’s competency file is naturally completed by an employer-side administrative section, which includes the medical visit.
• The workplace risk assessment document, updated from the first employee onward, is where a VIP’s conclusions concretely connect with prevention at the trainer’s workstation.

An auditor will never ask to see the VIP appointment itself, but an employer file that ignores it entirely, while other social obligations are otherwise well kept, can raise doubts about the overall rigour of the administrative management — shaky ground on neighbouring indicators.

Take action

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