Indicator 22 — Developing staff competencies

Indicator 22 complements indicator 21: having proven your contributors are competent today, you must show they will remain so tomorrow. The framework expects genuine competency maintenance: needs identification, training or professionalisation actions, and delivery evidence. It applies to all staff — trainers, administrators — and to the owner personally when they deliver the training.

What the auditor checks on the day

The auditor looks for a living system, not a theoretical document. They examine:

• how you identify needs: professional interviews, self-diagnoses, session evaluation feedback, regulatory changes in your sector;
• a competency development plan, however simple, listing planned actions per person per year;
• delivery evidence: training certificates, webinar attestations, invoices, followed programmes, professional subscriptions;
• the variety of recognised formats: formal training, conferences, trade shows, communities of practice, co-development, documented specialist reading;
• for employers, compliance with the Labour Code’s professional interviews;
• the full loop: a need identified, an action delivered, an effect observed on the services.

At an initial audit, the auditor accepts a recent plan, but wants at least one action already delivered or under way and a credible calendar.

Achieving compliance, step by step

1. Create a competency development table: one row per person, with identified needs, planned actions, dates and delivery status.
2. Feed it from concrete sources: an end-of-course evaluation flagging a delivery weakness, new sector regulations, a new teaching tool to master.
3. Plan at least one professionalisation action per person per year: a course, a certifying webinar, a trade show, active membership of a professional network.
4. Archive each proof on receipt: attestation, invoice, digital badge, programme. One “professionalisation” folder per person prevents pre-audit panic.
5. For employees, keep the professional interview calendar and the signed summaries: the auditor may request them as needs-identification evidence.

Field advice

If you are an independent trainer, this indicator concerns you first and foremost: your own upskilling is the expected evidence. A train-the-trainer course, an attested MOOC, a renewed trade certification or documented active participation in a professional network all qualify. The classic mistake is declaring “I read a lot” with no trace: turn that watch into evidence by logging the conferences attended and keeping the attestations.

Systematically connect this indicator to your other obligations: needs spotted in beneficiary evaluations (indicator 30) and your watch activities (indicators 23 to 25) are excellent inputs for the plan. This cross-indicator coherence impresses auditors, because it shows an integrated quality system rather than a collection of binders.

On subcontractors: you do not have to fund their training, but if you work with them regularly, show that you periodically verify their competencies are current — for example by requesting an updated CV and recent attestations every year.

Finally, size the system to your structure. A two-person organisation needs no HR software: a shared table and an evidence folder suffice. What triggers a non-conformity is the total absence of documented professionalisation over the audited period, not the modesty of the plan.

Examples of evidence that passes the audit (real cases)

Documents actually shown in audits and deemed convincing for indicator 22:

• A living skills-development table: one row per person, identified needs, planned actions, dates, status. Mixed statuses (“done”, “planned”) prove the document lives — a table where everything is “planned” smells of audit eve.
• The certificate of a train-the-trainer course taken by the owner-manager: for an independent trainer, this is the flagship piece of evidence — your own professional development is the first thing the auditor looks at.
• An invoice plus the programme of a professional webinar or conference, filed in a per-person “professional development” folder: the invoice + programme pair dates and qualifies the action.
• A signed professional interview report, for organisations with employees: it is both a French labour-code obligation and the most natural source for identifying needs.
• Proof of active participation in a professional network: membership fee, meeting programmes, a talk given. Informal monitoring becomes admissible the moment it leaves a trace.
• A complete need → action → effect loop: a post-course evaluation flagging a weak point in delivery, the training taken in response, and the score rising on the following sessions. One such loop is worth ten plan lines.

Skills-development procedure outline (template)

Your procedure fits on one page, structured as follows:

1. Purpose and staff covered — trainers, administrative staff, owner-manager, and verification arrangements for regular subcontractors (updated CV and certificates requested every year).
2. Needs identification — sources: beneficiary evaluations (indicator 30), monitoring (indicators 23 to 25), professional interviews, regulatory changes.
3. Annual plan — at least one professional-development action per person per year, formalised in the skills-development table.
4. Implementation and evidence — certificates, invoices, programmes and badges archived on receipt, per person.
5. Professional interviews — schedule kept and signed reports for employees.
6. Annual review — plan review, effects observed on the services, feeding continuous improvement (indicator 32).

The complete version of this procedure, ready to customise field by field, is in sheet 22 of the kit — together with the ready-to-fill skills-development table.