Disability referent in a French training organisation: legal duty or Qualiopi requirement?

“Do I need a disability referent in my training organisation?” The answer hinges on a detail few founders know: the rule is not the same whether you run a CFA (apprenticeship centre) or a standard training organisation. One is a legal obligation, the other a certification requirement — confusing the two is a costly mistake at audit time.

What the law actually says

Only apprenticeship training centres (CFAs) carry a direct legal duty to appoint a disability referent. It stems from law n° 2018-771 of 5 September 2018 on the freedom to choose one’s professional future, which amended article L6231-2 of the French Labour Code, in force since 1 January 2019. This referent supports the integration of apprentices with disabilities, both at the training centre and in the host company.

For a standard training organisation (outside apprenticeship), no law names a disability referent as mandatory. However, the decree of 6 June 2019 on the National Quality Framework (RNQ) made the welcoming of people with disabilities a full certification criterion under Qualiopi — and Qualiopi itself has been mandatory since 1 January 2022 for any organisation seeking public or pooled funding (CPF, OPCO, France Travail, Regions). The practical outcome: if you target that funding, the disability referent becomes a de facto obligation, even without a dedicated law. To check whether Qualiopi applies to you, see our article Is Qualiopi mandatory for you?

Indicator 26: the real source of the obligation for a training organisation

In version 9 of the National Quality Framework, the obligation sits in indicator 26, part of criterion 6 (“Positioning within the professional environment”). It applies to every category of action covered by Qualiopi — training, apprenticeship, VAE, skills assessment — and its non-conformity is classed as major. Concretely, the auditor checks three things:

1. A named, identifiable disability referent, whose name appears on a document accessible to the public (website, welcome booklet, training programme);
2. A network of mobilisable partners for adaptation needs beyond the organisation’s own skills: Agefiph, the Ressources Handicap Formation (RHF) network, Cap emploi, MDPH, specialist associations in your sector;
3. A formalised welcome and adaptation procedure: how the need is detected (a question asked at enrolment), how adaptations are analysed, and what happens if the organisation cannot adapt (a documented referral).

This check applies even if you have never welcomed a trainee with a disability: the indicator evaluates organisational capability, not a track record. This is in fact the most common finding in audits — “we’ve never had that case” is not an acceptable answer.

Who can take on the role of disability referent?

No diploma, status, or seniority is required. In a small structure, the referent can be a member of management, the pedagogical team, or the admin staff. For a self-employed trainer, auditors accept that the owner is their own disability referent — in fact the most common situation for this profile — provided the role is explicitly taken on and written down, and the person can explain its content out loud.

The only real prerequisite is a minimal level of awareness: knowing the main categories of disability, knowing who to contact in case of doubt, and being able to run a needs-detection conversation without missteps.

The referent’s concrete missions

• Welcoming and directing requests linked to an adaptation need, from the prospecting or enrolment stage onward;
• Analysing possible adaptations with the beneficiary (duration, teaching materials, pace, accessibility of premises or of the remote platform);
• Mobilising the external network (Agefiph, RHF, Cap emploi) when the adaptation exceeds internal resources;
• Tracking every step, even in the absence of a request, through a log or tracking table;
• Keeping a minimal watch on disability compensation schemes and regulatory changes.

Getting trained without a budget or wasted time

No certifying training is required, but proof of awareness training strengthens the audit file considerably. Two free, fast options:

• Agefiph webinars, dedicated to disability referents in companies and training organisations, with a downloadable attendance certificate;
• Workshops from the Ressources Handicap Formation (RHF) networks, present in every French region, which also offer individual support and ready-to-use tools (detection questionnaires, adaptation sheets).

Always keep the certificate: it is the first piece of evidence the auditor will ask for to back up the referent’s appointment.

The mistakes that trigger a major non-conformity

• No visible name: the referent exists “internally” but appears on no document a prospective trainee could consult.
• A network mentioned only verbally, never formalised: auditors systematically ask for a written contact list, even a basic one.
• No trace of needs detection: the enrolment questionnaire never asks the question, suggesting the topic is not built into the process.
• No request log: even empty, it must exist — it proves the process is ready to operate.
• Confusing this with physical accessibility of premises: the topic is broader than a wheelchair ramp; it also covers pedagogical adaptation and invisible disabilities.

These gaps are common because the topic seems secondary until an affected trainee actually shows up — which is precisely what indicator 26 is designed to correct. To place this requirement within your overall preparation, our Qualiopi audit preparation checklist breaks down the 8-week countdown, indicator by indicator.

Take action

The disability referent is just one of 32 indicators to secure before a Qualiopi audit. The Complete Qualiopi Kit provides a ready-to-customise welcome and adaptation procedure, a request-log template, and the evidence table for indicator 26 — along with the full document set for all 32 indicators (€297, 14-day guarantee, documents in French). Just starting your activity? The ebook Créer son organisme de formation en 30 jours covers the administrative basics before you tackle certification — or choose the complete bundle that combines both.