Indicator 21 — Trainers' competencies
You must define the competencies required for each service and demonstrate that your contributors, employees and subcontractors alike, genuinely hold them: diplomas, certifications, experience and fit with the audiences and content.
Applies to: OF · CFA · VAE · CBC
Indicator 21 opens criterion 5 with a simple question: are the people who deliver, support or assess your services competent to do so? The framework asks for two distinct things: defining the competencies required for each type of service, then proving that every deployed contributor holds them. Many founders only prepare the second part and discover the first at the audit.
What the auditor checks on the day
The auditor cross-references your services with your contributors' files. They examine:
- the existence of a definition of the expected competencies: a trainer job profile, a required profile per service or a recruitment grid;
- the individual files: up-to-date CV, diplomas, professional certifications, attestations, client references;
- the actual fit between profile and assigned service: an office-software trainer suddenly delivering a fire-safety course will trigger questions;
- your selection process: how you recruit or choose a subcontractor — interview, teaching test, reference checks;
- the regulatory requirements of certain fields: first-aid instructor approvals, vendor certifications, qualifications imposed by a certifier to prepare its title;
- for skills assessments and VAE, the specific qualification of consultants and support staff.
If you are an owner-trainer, your own competency file is examined in exactly the same way.
Achieving compliance, step by step
- For each family of services, write a contributor profile: expected diploma or level, minimum trade experience, teaching skills, mandatory approvals.
- Build one file per contributor: a CV dated within the year, copies of diplomas and certifications, experience attestations, a confidentiality undertaking where relevant.
- Formalise your selection process, however light: an interview grid or a document checklist suffices for a small organisation.
- Trace the assignment decision: a table crossing contributors and services, noting the elements justifying the fit.
- Update these files yearly and at every new service: an obsolete CV is one of the most frequent surveillance audit remarks.
Field advice
Do not confuse seniority with fit. The auditor does not judge a career's worth; they check the consistency between profile and service. A trade expert without a diploma can be perfectly compliant if their experience is documented and your job profile values experience; conversely, an off-topic PhD is not.
Demand the same documents from your subcontractors as from an employee: CV, diplomas, references. Write this requirement into your subcontracting contract — you will feed indicator 27 at the same time. Refusing to provide an updated CV should be grounds for non-selection.
If you start alone, polish your own file: a detailed CV, diplomas, a train-the-trainer certificate if you have one, testimonials or evaluations from your first sessions. Auditors watch one-person organisations displaying very wide catalogues: ten unrelated topics for a single trainer raise a fit question that is hard to defend.
Finally, think about certifying courses: many certification owners contractually impose precise qualifications on trainers and juries. The Qualiopi auditor may request the certifier's accreditation and check your contributors meet its specifications. File these requirements with your job profiles: the simplest way to demonstrate full command of the indicator.
The evidence the auditor expects
- P.1Job profiles or required-competency grids per family of services
- P.2Dated, current CVs of all contributors, including the owner-trainer
- P.3Copies of diplomas, certifications and approvals (first aid, titles, accreditations)
- P.4Interview grid or selection checklist for trainers and subcontractors
- P.5Contributor/service fit table
- P.6Client references or professional experience attestations
- P.7Certifiers' requirements for certifying courses and proof of compliance
Common mistakes in audits
- No prior definition of the required competencies: just a pile of CVs
- Undated, obsolete or missing CVs for subcontractors
- Obvious mismatch between a contributor's profile and the assigned service
- Missing regulatory approvals required in certain fields
- Forgetting the owner-trainer's own competency file
- A very broad catalogue with no competency justification per topic
FAQ — indicator 21
+Is a trainer's diploma required to pass indicator 21?
No, no trainer diploma is legally required. You must however demonstrate the fit between the contributor's profile and the service: trade experience, certifications, references. You define the required profile; the auditor verifies it.
+Which competency evidence for a Qualiopi subcontractor?
The same as for an internal contributor: an up-to-date CV, diplomas or certifications, references. Add the check to your selection process and write these requirements into the subcontracting contract — which also serves indicator 27.
+How does a solo independent trainer pass indicator 21?
Build your own file: a detailed, dated CV, diplomas, continuing-education attestations, client references. Also write the competency profile required for your services, to show the fit logic — not just the documents.
+Does the auditor check competencies for certifying courses?
Yes, doubly: under Qualiopi and under the requirements of the certifier whose certification you prepare. Keep the certifier's accreditation and the qualifications imposed on trainers and juries, with the matching evidence.