Subcontracting trainer in France: NDA, Qualiopi, BPF… your obligations when working for other training providers

You deliver training on behalf of other organisations, without ever signing with the end client: you are a subcontracting trainer. A comfortable position on the surface — no funder prospecting, no training agreements to manage — but one that exempts you from almost none of the regulatory obligations. NDA, BPF, Qualiopi, VAT, insurance: here is everything you need to have in order in 2026, from the subcontractor’s point of view, and what your clients are entitled to ask of you.

The NDA: mandatory even if you only work as a subcontractor

It is the most widespread misconception: “I work under my client’s number, I don’t need my own.” Wrong. As soon as you sign a contract to deliver training services and invoice them, you are yourself a training provider within the meaning of the Labour Code. You must therefore file your own declaration of activity (Cerfa 10782) with the DREETS within 3 months of signing your first subcontracting contract.

In practice, the supporting document to attach is precisely that first subcontracting contract — hence the importance of drafting it properly, with the clauses detailed in our guide to the training subcontracting agreement. Serious prime contractors systematically check their trainers’ NDA: it is expected evidence on their side under indicator 27.

Qualiopi: not required… except on the CPF

In the general case — you work on courses funded by companies, OPCOs or individuals outside the CPF — you do not need Qualiopi certification: the certification is carried by the prime contractor, which remains solely responsible for compliance towards its certification body and funders.

The exception has become a major one since 1 April 2024: on CPF-funded courses, the subcontractor must itself hold Qualiopi certification, even with no contact with the beneficiary. The only way out: operating under the micro-social regime with annual turnover not exceeding €77,700 excl. VAT. If you exceed that threshold, or trade as a company, certification becomes unavoidable to keep subcontracting on the CPF — with the budget and lead times that implies, detailed in our article on the price of Qualiopi certification. The full picture on the prime contractor’s side (the 80% cap on subcontracted CPF turnover, Caisse des Dépôts checks) is covered in our article on subcontracting in vocational training.

The BPF: an annual obligation, even at 100% subcontracting

As an NDA holder, you must file your training activity and financial return (BPF) online every year, even if all your activity goes through prime contractors. The form has a specific section for turnover generated on behalf of other training organisations: that is where your subcontracting activity is declared. Beware of the silent penalty: two missed BPF filings trigger the lapse of your declaration of activity — and a lapsed NDA means, for your clients, a non-compliant subcontractor in their evidence chain.

VAT, insurance, legal status: the rest of the foundation

• VAT: with your NDA, you can apply for the tax VAT exemption certificate (Article 261-4-4° a of the French Tax Code), which also covers services invoiced to training organisations. Without it, you fall under ordinary rules or the small-business franchise.
• Insurance: professional liability insurance is almost systematically required by prime contractors, certificate in hand.
• Legal status: the micro-enterprise remains the most common vehicle to start with — our article on the auto-entrepreneur training provider details its ceilings and limits, not to be confused with the €77,700 threshold specific to CPF subcontracting.

What your clients will ask you for (and why)

A certified organisation that entrusts you with a course must prove to its auditor that it controls its subcontracting. Expect to provide: CV and proof of qualifications, a copy of your NDA, a professional liability certificate, a Qualiopi certificate or proof of micro-social status for CPF work, and evidence that you maintain your skills — indicator 22 on skills development also applies to external trainers on the prime contractor’s side. A complete, up-to-date trainer file is a genuine commercial argument: it makes you the “no-risk” subcontractor a certified organisation prefers to call back.

This professionalisation requirement is not unique to training: a study by Ashford, Caza and Reid published in 2018 in Research in Organizational Behavior, “From surviving to thriving in the gig economy”, shows that independent workers who succeed over the long term are those who actively build their professional legitimacy — reputation, network, proof of competence — rather than enduring the precarity of the status. In vocational training, that legitimacy capital has a very concrete translation: a flawless administrative file and positive session evaluations.

The mistakes that cost subcontractors dearly

• Working without an NDA, believing you are covered by the prime contractor’s — a personal breach, liable to penalties and a deal-breaker for your clients.
• Skipping the BPF because “we have no direct trainees” — two misses and the NDA lapses.
• Accepting a CPF assignment above the threshold without certification — the prime contractor risks its EDOF referencing, and you risk the business relationship.
• Invoicing the end client directly: that is no longer subcontracting, and the arrangement will be requalified during an inspection.
• Signing contracts with no quality clause and no allocation of documents: at the first dispute or audit, each party blames the other.

Take action

The Complete Qualiopi Kit (€297, 14-day guarantee) includes the subcontracting agreement template, the standard trainer file and all the evidence expected across the 32 indicators — useful to prime contractors and to subcontractors aiming for their own certification alike. Structuring your freelance training activity? The ebook “Create your training organisation in 30 days” (€67) covers NDA, BPF, VAT and legal status step by step — or choose the full pack (€347).