Indicator 20 — Dedicated CFA staff: referents and improvement council
CFA-specific: you must have a national and international mobility referent, a disability referent and a functioning improvement council (conseil de perfectionnement), in line with the missions the Labour Code assigns to CFAs.
Applies to: CFA
Indicator 20 only concerns apprenticeship training providers. It transposes into Qualiopi legal obligations from article L. 6231-2 of the Labour Code: every CFA must have a mobility referent, a disability referent and an improvement council. If you open a CFA or add apprenticeship to your organisation, this indicator is unavoidable and closely checked.
What the auditor checks on the day
The auditor verifies that the three mechanisms really exist, not just their mention in an organisation chart:
- the national and international mobility referent: formal appointment, mission sheet, actions undertaken (informing apprentices about Erasmus+, partnerships, supporting departures);
- the disability referent: appointment, possible training, and how apprentices with disabilities are identified, welcomed and supported — overlapping with indicator 26;
- the improvement council: its composition (management, teams, employers, apprentices), its convocations, agendas and minutes, with a consistent meeting frequency;
- these people's visibility to apprentices: display, welcome booklet, website.
For a recent CFA, the auditor accepts an improvement council still being installed, but expects at minimum a settled composition, a first meeting scheduled or held, and formalised missions for both referents.
Achieving compliance, step by step
- Appoint both referents by name through a signed mission letter stating their missions, dedicated time and means. One person may hold both roles in a small CFA, provided each mission is described.
- Train or equip your referents: disability awareness (Agefiph resources, the disability referent network), mobility documentation (Erasmus+, Euroguidance).
- Form your improvement council: settle a representative composition, write simple operating rules and set a calendar of at least one or two meetings a year.
- Keep the traceability: convocations, agendas, signed minutes, decision logs and follow-ups. This is the king evidence for this indicator.
- Make these mechanisms visible: mention the referents in the apprentices' welcome booklet and on your website, with a direct contact channel.
Field advice
The classic trap is the "paper" improvement council: a member list never convened. Auditors detect it instantly by asking for the latest minutes and decisions. Convene your council before the initial audit, even by video, with a realistic agenda: enrolment review, exam results, pedagogical projects, apprentices' employment outcomes.
Give the referents' missions real substance. For mobility, a single documented annual information session on Erasmus+ with a signed attendance sheet beats an ambitious policy never applied. For disability, a register of situations encountered and accommodations made is precious evidence, reusable for indicator 26.
If you are a training provider becoming a CFA, anticipate: these obligations apply from the first year of apprenticeship contracts. A missing improvement council or unappointed referent leads to a major non-conformity, since these are legal obligations, not good practices. Conversely, a modest but genuinely functioning set-up passes the audit without difficulty: sincerity and traceability beat scale.
The evidence the auditor expects
- P.1Signed mission letters of the mobility referent and the disability referent
- P.2Settled composition of the improvement council and its operating rules
- P.3Convocations, agendas and minutes of the council's meetings
- P.4Documented mobility actions (Erasmus+ information, partnerships, attendance sheets)
- P.5Register of disability situations and accommodations made
- P.6Apprentices' welcome booklet and website mentioning the referents
- P.7Training or awareness certificates of the referents
Common mistakes in audits
- An improvement council formed on paper but never convened
- Referents appointed without a mission letter or any documented action
- Referents absent from the documents given to apprentices
- Council minutes with no decisions or follow-ups
- One person holding both roles without a distinct description of each mission
- Believing the indicator does not apply in the CFA's first year
FAQ — indicator 20
+Is the improvement council mandatory for every CFA?
Yes — an obligation under article L. 6231-2 of the Labour Code, carried into Qualiopi indicator 20. Every CFA must establish one, including small structures and training providers developing an apprenticeship activity.
+Can one person be both disability and mobility referent?
Yes, in a small CFA the combination is accepted. Each mission must nevertheless have a distinct description, with its own actions and evidence: mobility information on one side, disability support on the other.
+How often must the improvement council meet for Qualiopi?
The texts impose no precise frequency, but the practice expected at audits is at least one or two meetings a year, with convocation, agenda and minutes. A council never convened results in a non-conformity.
+Does indicator 20 apply to a subcontractor working for a CFA?
The indicator targets the CFA responsible for the apprenticeship contracts. If you act as a satellite unit or subcontractor, the lead CFA must demonstrate the mechanisms, but your coordination with its referents may be examined through indicators 18 and 27.