How long must a French training organisation keep its documents? The full table
A DREETS inspection looks at a session from four years ago, an OPCO asks for an agreement archived “somewhere” on a hard drive that’s since been replaced, a renewal auditor requests the evidence for an indicator validated at the initial audit three years earlier: in all three cases, the answer hinges on one question that wasn’t planned for in time — how long was this document supposed to be kept?
No single text sets one general retention period for a French training organisation (organisme de formation). Deadlines vary by document type and the rule that governs it: Labour Code, Commercial Code, or funder-specific rules. Here is the reference table.
The retention table by document type
| Document | Recommended period | Legal basis |
|---|---|---|
| Attendance sheets, agreements and purchase orders | 5 years | Art. L6362-6 of the Labour Code (inspection window) |
| BPF (annual training activity report) and supporting evidence | 5 years | Art. L6362-6, consistent with the administrative control cycle |
| Training programmes, teaching materials, certificats de réalisation | 5 years | Art. D6353-1 of the Labour Code (proof of delivery) |
| Evidence of compliance with the 32 Qualiopi indicators | Until the next audit (18 months, then 3 years) | Certification cycle set by the national quality framework |
| Actions funded by European funds (FSE+) | 10 years | Rules specific to European structural funds |
| Accounting records (ledgers, journals, supporting invoices) | 10 years | Art. L123-22 of the Commercial Code |
| Payslips and employment contracts of salaried trainers | 5 years after the employee leaves | Labour Code (employer obligations) |
| Déclaration d’activité (Cerfa 10782) and its amendments | As long as the activity is declared, kept longer after cessation | No dedicated statutory period, caution recommended |
This table gives floors, not ceilings. When in doubt about a document tied to a significant payment or public funding, keeping it longer costs nothing; destroying it too early can cost a full reimbursement of the funded action.
Why 5 years is the number to remember first
Most of the documents a training organisation produces day to day — attendance sheets, agreements, programmes, certificats de réalisation — follow the same logic: they serve as evidence in the event of an administrative check or a funder’s proof-of-delivery review.
Article L6362-6 of the Labour Code is the pivotal text: it requires the organisation to present, on request from the administration or the funder, all documents justifying the objectives, content, implementation and resources of the action. If these documents are not produced, the action is deemed not to have taken place, triggering reimbursement of the sums received — regardless of any separate Qualiopi non-conformity.
Using 5 years as a baseline comfortably covers the inspection windows typically used by OPCOs, the Caisse des Dépôts (CPF) and state services, while staying aligned with the Qualiopi certification cycle itself: an 18-month surveillance audit followed by a 3-year renewal audit both require being able to reach back over the entire period since the last visit.
The special case of Qualiopi evidence
Evidence gathered for an audit — attendance sheets tied to indicators 9 and 10, satisfaction surveys, traceability of regulatory watch, tracking of complaints — cannot simply be filed away once the certificate is obtained. The auditor who returns at 18 months, then at 3 years, samples sessions carried out since the last audit, not just the most recent ones.
In practice: an organisation certified in January 2024 must be able, at its January 2027 renewal audit, to produce evidence covering the entire three-year period, including sessions held right after the initial audit. Archiving continuously — one folder per session, filed by date — avoids the last-minute scramble the night before an audit, a scenario that ranks among the most common audit-preparation mistakes.
Subcontracting: the same period applies to the subcontractor
When a service is delivered through subcontracting, the organisation holding the contract remains accountable to the funder and the auditor, even if the attendance sheets and materials were produced by the subcontractor. The subcontracting agreement should therefore explicitly require the subcontractor to keep its own evidence for the same period and hand it over without delay in the event of a check or audit — a point often overlooked that exposes the lead organisation when indicator 27 is audited.
Accounting and payroll: distinct, longer rules
Strictly accounting documents — ledgers, journals, general ledger, customer and supplier invoices — follow a different logic under the Commercial Code: article L123-22 requires a 10-year retention period. That is also the figure to remember for actions co-funded by European funds (FSE+), which are subject to stricter archiving rules specific to structural funding.
On the HR side, payslips and employment contracts for salaried trainers must be kept for 5 years from the date the employee leaves, under the employer’s general obligations in labour law — a period that should not be confused with the one for teaching documents, even though it often ends up being the same number.
Paper or digital: what matters for probative value
The law does not require paper storage. Digital archiving is fully acceptable, provided it guarantees:
- integrity over time (no possible alteration after signature or validation);
- lasting readability, independent of changes to the software used to produce the document;
- traceability of access and, if needed, of exports to an inspector or auditor.
A session folder organised by date, grouping the agreement, programme, attendance sheets and certificat de réalisation under one consistently named directory, is sufficient in most cases — there is no need to invest in a legally certified archiving solution for a modest-sized organisation, unless volume is very high or a funder’s contract specifically requires it.
Best practices to avoid losing anything
- Set one rule per document family (teaching-related: 5 years, accounting: 10 years) rather than managing exceptions case by case.
- Archive at the close of each session, not at year-end: a complete folder filed immediately avoids gaps discovered months later.
- Never destroy a document without checking the archiving clause of the relevant funding contract, especially for European funds.
- Keep a copy of the déclaration d’activité and its amendments for as long as the organisation exists: this document has no statutory expiry, but its absence blocks every administrative process.
- Prepare for the next audit by keeping evidence organised by indicator, not just by session — this considerably speeds up preparation for a surveillance or renewal audit.
Take action
The Complete Qualiopi Kit includes a ready-to-use archiving template that shows, indicator by indicator, which evidence to keep and for how long — along with every document template expected under the framework (€297, 14-day guarantee). If you’re setting up your organisation, the ebook Create your training organisation in 30 days builds good archiving habits in from day one, or choose the full pack — kit plus ebook.
Frequently asked questions
+How long should attendance sheets (feuilles d'émargement) be kept?
At least 5 years, in line with the inspection windows used by OPCOs, the Caisse des Dépôts and the administration under article L6362-6 of the French Labour Code. That period comfortably covers the Qualiopi certification cycle (3 years) and its 18-month surveillance audit.
+Should Qualiopi evidence be kept after the audit?
Yes, at least until the next audit: evidence produced for the initial audit must remain available for the 18-month surveillance audit, then for the 3-year renewal, since the auditor can request justification for the entire period since the last visit.
+Does the retention period change for CPF- or OPCO-funded training?
The baseline stays 5 years, but each funder can impose a longer contractual period in its agreement or terms. For actions co-funded by European funds (FSE+), the retention period rises to 10 years: always check the archiving clause in the funding contract before destroying anything.
+What happens if a document was destroyed too early?
During a check, article L6362-6 of the Labour Code provides that an action not justified by the required documents is deemed not to have taken place: the provider must then reimburse the sums received, regardless of any Qualiopi non-conformity separately raised at audit.
- Qualiopi monitoring duty: organising and proving your legal, occupational and pedagogical watch (indicators 23, 24, 25)8 min
- Satisfaction, pass and employment rates: calculating and publishing your performance indicators8 min
- OPCO funding refusal: understanding the reasons and knowing how to bounce back7 min