Training organisation or CFA: what actually differs in status and Qualiopi obligations

“Should I set up a training organisation or a CFA?” This question comes up often among people who want to train apprentices, without always knowing that the legal distinction disappeared back in 2018. What does remain, however, are genuinely different administrative obligations and a different Qualiopi scope. Here is what actually changes.

A CFA is no longer a distinct legal status

Before the Avenir professionnel law of 5 September 2018, a CFA (centre de formation d’apprentis) operated under a specific authorisation regime, separate from the declarative regime that applies to training organisations. That is no longer the case. Since the reform, an apprentice training centre is a training organisation that runs, in whole or in part, an apprenticeship training activity — the legal texts now use the term “organisme de formation par apprentissage” (OFA), even though “CFA” remains the common everyday label.

In practice, a CFA can take any legal form already available to a standard training organisation: a non-profit association, a commercial company (SASU, SARL, EURL…), a chamber of commerce or trade, a local public education establishment, or an in-house training department within a company. There is no longer a separate “CFA” authorisation distinct from the standard activity declaration — but additional obligations do apply, precisely because the activity involves apprentices.

What stays strictly identical between the two

The regulatory base is shared, and this is often what surprises people who imagine an entirely separate CFA regime:

• the activity declaration (Cerfa 10782) and the resulting NDA, following the same timeline and the same process with the regional labour authority (DREETS);
• the annual pedagogical and financial report (BPF), due before 31 May, including for apprenticeship activity;
• the baseline documentation requirements: training programme, attendance sheets or proof of participation, internal rules;
• access to Qualiopi certification, based on the same National Quality Framework (RNQ) and the same 7 criteria, regardless of provider type.

A CFA that only trains apprentices therefore remains subject to all the administrative obligations of a “standard” continuing-training organisation. The real differences lie elsewhere.

What actually changes for a CFA

The learner’s legal status

This is the most structural difference. A continuing-training participant signs an agreement or a training contract with the organisation. An apprentice, by contrast, holds employee status: they sign an apprenticeship contract with a company, and the CFA is only one of two training locations, alternating with the workplace. This distinction shapes everything else: the pedagogical schedule, coordination with the employer, and the labour-law protections that apply to the apprentice.

A UAI number on top of the NDA

Beyond the standard activity declaration, a CFA must obtain a UAI number (unité administrative immatriculée — 7 digits and 1 letter), issued by the regional education authority (rectorat) and recorded in the RAMSESE registry. This registration is specific to apprenticeship: a continuing-training organisation that does not train apprentices does not need one.

The mandatory “conseil de perfectionnement”

Article L6231-3 of the French Labour Code requires every CFA to set up a conseil de perfectionnement (perfectionnement council), tasked with overseeing its organisation and pedagogical operation. It brings together management, one or more representatives of the operating body, representatives of employer and employee professional organisations, elected staff and apprentice representatives (and parent representatives for level IV and V programmes), and must meet at least three times a year. Nothing equivalent exists for a standard continuing-training organisation.

Public-interest missions

The Labour Code assigns CFAs missions that go beyond delivering training: supporting apprentices in difficulty, helping them find an employer or housing, preventing contract terminations, and facilitating national and international mobility. A continuing-training organisation carries no such broader social-support obligation.

Different funding

Standard continuing training is funded through quotes, OPCO cost coverage, or CPF funding. An apprenticeship contract is funded through the niveau de prise en charge (NPEC) — a funding level set by professional branches and France Compétences for each certification, paid by the employer’s operateur de compétences (OPCO). The CFA does not invoice the apprentice, whose training is free.

Qualiopi: the same framework, a wider scope for CFAs

This is the least-known point, and yet a decisive one when preparing for an audit. The National Quality Framework has 32 indicators, but not every provider is audited against the same number:

Provider type	Indicators audited
VAE / skills assessment	23 (common indicators only)
Standard continuing-training organisation	27 (common + indicators shared with apprenticeship)
CFA	32 (the full framework)

A CFA is therefore audited against all 32 indicators, 9 of which specifically concern apprenticeship — 5 that apply to CFAs only, and 4 shared with training organisations that also run alternance programmes:

• Indicator 3 — CFA completion and job-placement rates
• Indicator 7 — Alignment of content with the targeted certifications
• Indicator 13 — Coordination of alternance learning
• Indicator 14 — Apprentices’ exercise of citizenship
• Indicator 15 — Informing apprentices of their rights and duties
• Indicator 16 — Registration and entry for certification exams
• Indicator 20 — Dedicated CFA staff: referents and the perfectionnement council
• Indicator 28 — Training in a work situation and alternance
• Indicator 29 — Job placement of apprentices (CFA)

During audits, these indicators account for a disproportionate share of non-conformities, precisely because they require evidence that cannot be improvised the day before: perfectionnement council minutes, documented tracking of coordination with employer companies, traceable job-placement follow-up. An organisation already certified for its continuing-training activity that opens an apprenticeship activity will need to extend its quality system to these 9 indicators and adjust its certification scope accordingly.

Should you register as a CFA, or stay a standard training organisation?

The answer hinges on a single legal criterion: the type of contract you offer your learners. If you take on young people or adults under an apprenticeship contract, you are running a CFA activity and must follow the associated steps (UAI, perfectionnement council, wider Qualiopi scope). If your beneficiaries remain continuing-training participants — employees in career transition, jobseekers, CPF or standard OPCO funding — you remain a “standard” training organisation, without the apprenticeship-specific obligations.

Nothing prevents combining both activities within the same structure, provided you formally open the apprenticeship activity (the UAI process) and adjust your Qualiopi certification accordingly.

Take action

Whether you’re starting a continuing-training activity or opening a CFA, the activity declaration and the initial documentation base are the same. The Complete Qualiopi Kit (€297) provides ready-to-customise procedures and evidence templates, including groundwork for the apprenticeship-specific indicators, and the ebook Create Your Training Organisation in 30 Days (€67) walks step by step through the activity declaration — both bundled in the complete pack at €347.