New entrant Qualiopi status: which indicators get adapted audit terms for a first audit with no track record

Setting up a training organisation creates an awkward equation: you need to obtain Qualiopi certification before having trained a single learner, even though several indicators in the framework seem to ask for proof of results already achieved. The national quality framework provides an answer to this paradox through “new entrant” status, which adapts the audit terms on a specific set of indicators — without ever exempting a provider from meeting them.

Who qualifies for new entrant status

The framework defines a new entrant as any provider in its first year of activity, but also any already-certified organisation launching a new category of skills-development actions (training, skills assessment, VAE, apprenticeship). The status is therefore assessed category by category: an organisation certified for three years in continuing education that opens a CFA (apprenticeship centre) activity becomes a new entrant again for the indicators specific to apprenticeship, while remaining fully audited on its established activity. This is why two organisations with very different track records can end up under the same adapted terms, as soon as they launch the same category of action at the same time.

The 11 indicators with adapted audit terms

Qualiopi V9, in force since 8 March 2024 with no transition period, provides adapted audit terms for new entrants on eleven specific indicators:

Indicator	Subject
Indicator 2	Publication of results indicators
Indicator 3	CFA completion and job-placement rates
Indicator 11	Evaluation of goal achievement
Indicator 13	Coordination of work-study learning
Indicator 14	Exercise of citizenship by apprentices
Indicator 19	Learning resources available to beneficiaries
Indicator 22	Staff skills development
Indicator 24	Monitoring of trades and skills
Indicator 25	Pedagogical and technological monitoring
Indicator 26	Welcoming people with disabilities
Indicator 32	Continuous improvement

By nature, these are indicators that either require hindsight (results achieved, placement rates, goal achievement) or an established practice (organised monitoring, staff skills development) that a brand-new organisation cannot yet materially have produced.

What the auditor actually checks at the initial audit

On these eleven indicators, the auditor only checks the existence and formalisation of the process at the initial audit — not yet its concrete application. In practice: a monitoring procedure for trades and skills must exist and name a person responsible along with a frequency, but the organisation doesn’t have to produce a monitoring report dating back several months. A template for assessing disability-related needs must be ready to use, without a case involving a beneficiary with a disability necessarily having already been handled. This nuance changes everything about preparation: a new entrant needs to build solid framework documents, not simulate a track record it doesn’t have.

The other 21 indicators in the framework get no leniency at all: public information requirements, the training programme, assessment methods, or complaints handling all have to be fully compliant and demonstrable from day one of the audit, whether or not there has already been a trainee.

The special case of CFAs and new categories of action

Three adapted indicators (3, 13, and 14) concern apprenticeship exclusively: they therefore apply as of right to any apprenticeship training centre that hasn’t yet taken a cohort of apprentices through to completion — a material condition for having a measurable completion or placement rate. A continuing-education organisation already certified for several years that opens a CFA activity finds itself, on this specific scope, in the same situation as a brand-new organisation: the adapted terms apply to the new scope, not to the rest of its activity.

Preparing without a track record: build the processes before the usage evidence

The best strategy for a new entrant is to treat these eleven indicators as a documentation project to complete before the initial audit, rather than a problem to defer. Concretely: write the trades-and-pedagogical monitoring procedure and name who runs it, prepare the materials for staff skills development (internal training plan, annual review template), formalise the disability-assessment template and identify the disability liaison officer, and define the method for collecting and publishing future results indicators. Once this groundwork is verified as existing at the initial audit, all that remains is to demonstrate it has actually been applied at the surveillance audit.

The surveillance audit: the moment of reckoning

The surveillance audit, which takes place 18 months after the initial audit, is precisely the point where the auditor checks the effective implementation of the processes formalised earlier on these eleven indicators. Its duration is extended by 0.5 day compared with a standard surveillance audit to cover this additional check. To understand how the three stages of the certification cycle fit together, our article on the differences between initial, surveillance, and renewal audits details the timelines, durations, and stakes specific to each.

What research says about upfront investment in quality certification

This logic of an upfront formalisation effort made before reaping the benefits echoes a broader finding documented in quality-economics research. A study by Didier Wayoro and co-authors, published in 2025 in the journal International Economics under the title “Upfront efforts for upcoming benefits? ISO 9001:2015 certification and firms’ performance in 33 countries,” shows, using firm-level data from 33 countries, that organisations certified to ISO 9001:2015 post total sales 48.3% higher than uncertified ones, with a particularly marked benefit for small and medium-size enterprises (see the study on Google Scholar). Applied to Qualiopi, this finding reinforces the case for taking the adapted-terms indicators seriously from day one: the formalisation effort required upfront, even without a track record to show, is what conditions the benefits measured afterwards.

Plan for new entrant status rather than being caught out by it

New entrant status is neither a bonus nor a penalty: it’s a realistic acknowledgment that a brand-new organisation cannot produce a track record it doesn’t yet have. In exchange, it imposes a clear requirement — full formalisation of processes from the initial audit onward — and a moment of truth eighteen months later. Providers who prepare these eleven indicators with the same rigour as the other 21, rather than leaning on the lighter terms, walk into their surveillance audit with no unpleasant surprises.

Take action

The Complete Qualiopi Kit (€297, 14-day guarantee) provides procedure templates and the evidence expected for all 32 indicators, including the framework documents needed for the 11 indicators with adapted terms for new entrants. If you’re just starting out, the ebook “Create Your Training Organisation in 30 Days” (€67) places this preparation within the chronological order of setting up your organisation, and the complete pack (€347) brings both resources together.