Complaints and contingencies in a French training organisation: the procedure Qualiopi expects (indicator 31)

A complaint from a trainee, a trainer unavailable the day before a session, a flooded classroom the same morning: these are not incidents to hide from the auditor — they are exactly what indicator 31 of the National Quality Framework expects to see handled. Many founders of French training organisations dread this indicator because they confuse “having complaints” with “not knowing how to manage them.” Here is how to build the procedure and the evidence that reassures the auditor.

What indicator 31 actually requires

Indicator 31, part of criterion 7 of the National Quality Framework (“Gathering and taking into account feedback and complaints”), states that the provider must “implement and communicate a procedure for handling difficulties encountered by stakeholders, complaints expressed by them, and contingencies arising during the course of the service.” It applies to every category covered by Qualiopi — continuing training, apprenticeship, VAE, skills assessment — and its non-conformity is classed as major: unlike other indicators, there is no more lenient “minor” version.

Three distinct notions are covered under this single indicator:

• Difficulties encountered by a trainee, funder, trainer, or partner, which are not necessarily a formal complaint;
• Complaints as such, expressed by a stakeholder dissatisfied with some aspect of the service;
• Contingencies, i.e. unforeseen events that disrupt the running of a session (trainer absence, technical failure, unavailable room, logistical incident).

The difference with indicator 30

Indicator 30 covers gathering feedback: hot and cold satisfaction surveys, distributed on your own initiative to trainees, funders, and teaching staff. Indicator 31, by contrast, covers handling a negative signal triggered by a third party or an external event. The two indicators overlap in practice — an unsatisfactory response on a satisfaction survey can turn into a complaint — but the auditor assesses them separately, with distinct evidence.

The four pieces of evidence the auditor expects

1. A written, communicated procedure

Having an informal “system” in the founder’s head is not enough: the procedure must exist in writing and be accessible to stakeholders (welcome booklet, internal rules, training agreement or contract, website). It must specify at minimum:

• The channel for submitting a complaint (dedicated email, form, direct contact);
• The acknowledgement-of-receipt deadline;
• The person responsible for handling it (the founder themselves for a sole trader, a named person in a larger structure);
• The steps from submission to closure (analysis, response, possible corrective action).

2. An up-to-date log

The log of complaints and difficulties records every report, however minor, with its date, origin, handling, and closure. For a new entrant who has not yet received any complaint, an empty but ready-to-use log is accepted — provided its structure demonstrates it would actually work if needed.

3. Examples of handled cases

Once your activity has started, the auditor expects to see at least one concrete example: a dated acknowledgement of receipt, correspondence with the complainant, the response given, and a closure note. A total absence of examples after several months or years of activity raises suspicion, even with a well-written procedure on paper.

4. A continuity plan for contingencies

Beyond complaints, the indicator covers managing unforeseen events that threaten a session’s smooth running: a trainer’s absence, an unavailable room, a connection failure in remote sessions, an unavailable key contributor. A continuity plan lists these likely risks and the planned solution for each (an identified substitute trainer, a backup room, a postponement with an amendment, a fallback remote session). Evidence of actually managing a contingency — an information email to trainees, a postponement amendment, a substitution note — is worth more than a theoretical list never put to the test.

Building your procedure step by step

1. Define a single channel for receiving reports: a dedicated email address is the simplest solution to trace and present at audit.
2. Set realistic deadlines: an acknowledgement of receipt within 48 to 72 hours and a substantive response within 15 days are common practices among certified organisations, even though the framework does not formally require them.
3. Appoint a single person responsible, even for a sole trader — stating that it is you removes any ambiguity on audit day.
4. Create the log as a simple table (date, origin, nature, handling, closure) — a spreadsheet is enough, provided it is genuinely used.
5. List the likely contingencies of your activity and the planned response for each.
6. Link closed complaints to your continuous improvement process: a recurring complaint must translate into an action in your continuous improvement system, or you risk a cross non-conformity with indicator 32.

The mistakes that trigger a major non-conformity

• No log at all, or a log visibly created the day before the audit, with no credibly dated entries;
• Handling done verbally only, with no written trace of the response given to the complainant;
• No deadline defined in the procedure for acknowledgement of receipt or handling;
• No continuity plan for a trainer’s absence or an unavailable room — a common oversight for organisations that have not yet experienced this kind of contingency;
• No link to continuous improvement: closed complaints lead to no visible corrective action in the indicator 32 improvement plan.

This is in fact one of the most frequent non-conformities in surveillance audits: the process presented at the initial audit existed on paper but was never actually used eighteen months later. To place this indicator within your overall preparation, our Qualiopi audit preparation checklist breaks down the countdown indicator by indicator, and our article on the most frequent Qualiopi non-conformities lists the other classic pitfalls.

Take action

The procedure for handling complaints and contingencies is one of the documents most often copy-pasted in a hurry — and therefore one of the most often rejected at audit. The Complete Qualiopi Kit provides a ready-to-customise procedure, a log template, and a standard continuity plan for indicator 31, along with the full document set for all 32 indicators (€297, 14-day guarantee, documents in French). Just starting your activity and want to cover all the administrative basics before tackling certification? The ebook Créer son organisme de formation en 30 jours guides you step by step — or choose the complete bundle that combines both.