Internal regulations for French training organisations: obligation, content and the 3-month deadline

Three months after setting up their organisation, many founders discover during an audit — or worse, during an inspection — that they should have drafted a document whose existence they didn’t even know about: the internal regulations applicable to trainees (règlement intérieur). Unlike a company’s internal regulations, reserved for organisations with 50+ employees, this one applies to every training organisation, from the very first trainee, including self-employed trainers with no staff at all.

What the law actually says

The obligation comes from article L6352-3 of the French Labour Code: “in every training organisation, internal regulations, drawn up by the person responsible for the organisation, set out the measures applying health and safety rules within the organisation, as well as the general and permanent rules on discipline.” The text also covers the arrangements for representing trainees, for training courses that require it.

This is not just good practice: it is a binding legal obligation, distinct from Qualiopi requirements, that applies whether or not you are certified, and whether your trainees are funded publicly or pay directly. An organisation that never intends to pursue Qualiopi certification is still bound by this obligation.

The three-month deadline

Articles R6352-1 and R6352-2 set the deadline: the internal regulations must be established within three months of the training organisation starting its activity, counted from the date on your activity declaration (déclaration d’activité). Past that deadline, the organisation is in breach, even if it has not yet faced any inspection.

In practice, waiting the full three months serves no purpose: the regulations must in any case be handed to each trainee before their final enrolment and before any payment, which means they must exist before the very first session goes on sale. For training aimed at employees, the accepted practice is to send the regulations to the employer, who is then responsible for passing them on to enrolled staff. If you are still at the setup stage, our guide creating a training organisation in 2026 places this step in the chronological order of the paperwork, alongside the activity declaration.

What the internal regulations must contain

The content required by articles L6352-3 to L6352-5 and R6352-3 onward of the French Labour Code covers three areas:

1. Health and safety

The measures applying hygiene and safety rules in the premises where training takes place. When training happens on the premises of a company or establishment that already has its own internal regulations, that establishment’s health and safety rules apply to trainees — the organisation’s regulations can then simply refer to those provisions.

2. Discipline

The nature and scale of sanctions that can be applied to trainees, along with the applicable disciplinary procedure. This is the most tightly regulated part, since the law protects trainees against any arbitrary sanction:

• No sanction can be imposed without the trainee first being informed of the grounds held against them;
• The notice for the preliminary meeting is in writing (registered letter or handed over against signature) and states the date, time and place;
• The trainee can be assisted by a person of their choice, including the trainee delegate where one exists;
• The sanction cannot take effect less than one clear day nor more than fifteen days after the meeting;
• It must be a written, reasoned decision, notified by registered letter or handed over against acknowledgement of receipt.

Permanent exclusion from a course follows the same adversarial procedure safeguards, set out in article L6352-5.

3. Trainee representation

For training courses longer than 500 hours, the regulations must set out how trainee delegates are elected or appointed to represent their peers with the organisation. Below that threshold — the case for the vast majority of short courses sold by small organisations — this section does not need to be developed.

Making it enforceable

Internal regulations sitting on a hard drive protect no one. To be enforceable, they must be brought to trainees’ attention before their final enrolment. Two methods are commonly accepted:

• Posting them in the training room, where the venue is fixed;
• Handing them over with the other administrative documents in the enrolment file — training agreement or contract, programme, attendance sheet, assessment methods — provided before the first day of training.

For distance learning, digital delivery (email, trainee portal, LMS) with a read or delivery receipt is generally sufficient, provided you can prove the document was brought to the trainee’s attention before enrolment.

Penalty for non-compliance

Article L6355-8 of the French Labour Code provides for a fine of up to €4,500, whether for a total absence of internal regulations or for regulations that are incomplete, i.e. missing any of the content required by article L6352-3. This risk exists independently of any Qualiopi process: an uncertified training organisation that seeks no public funding remains exposed to this inspection and this penalty.

The link with Qualiopi

The internal regulations are not named as mandatory evidence for a single specific indicator of the National Quality Framework, but they feed several checks in practice: indicator 9, which covers the conditions under which the service is delivered, and indicator 15 for CFAs, which checks that apprentices are informed of their rights and duties. An auditor who finds no internal regulations will logically raise a non-conformity on these indicators, on top of the fine risk under the Labour Code. Our Qualiopi audit preparation checklist places this document within the eight-week countdown before the audit.

The most common mistakes

• Confusing it with a company’s internal regulations: the latter only concerns employees of a structure with 50+ staff; the trainee regulations are a separate document, mandatory from the very first client, even for a self-employed trainer with no staff.
• Drafting it but never handing it over: internal regulations that are never communicated before enrolment are not enforceable, even if they exist in a drawer.
• Skipping the detailed disciplinary procedure: limiting the document to a general sentence about “good conduct” without detailing the procedure (notice, deadlines, notification) exposes the organisation to a fine for incomplete regulations.
• Failing to adapt it to the training venue: running a course on a client’s premises without stating that the client’s own safety rules apply.

Take action

Internal regulations are one of the administrative documents to secure even before thinking about Qualiopi — and they also feed into several indicators of the framework. The Complete Qualiopi Kit provides a compliant internal regulations template based on article L6352-3, ready to customise, along with all 32 indicators and their supporting evidence (€297, 14-day guarantee, documents in French). Just starting your activity? The ebook Créer son organisme de formation en 30 jours walks through the order of administrative steps, from internal regulations to the activity declaration — or choose the complete bundle that combines both.