Indicator 22 — Developing staff competencies
You must maintain and develop the competencies of your employees and contributors over time: identify needs, plan professional development actions and prove their delivery — including for the head of a one-person organisation.
Applies to: OF · CFA · VAE · CBC
Indicator 22 complements indicator 21: having proven your contributors are competent today, you must show they will remain so tomorrow. The framework expects genuine competency maintenance: needs identification, training or professionalisation actions, and delivery evidence. It applies to all staff — trainers, administrators — and to the owner personally when they deliver the training.
What the auditor checks on the day
The auditor looks for a living system, not a theoretical document. They examine:
- how you identify needs: professional interviews, self-diagnoses, session evaluation feedback, regulatory changes in your sector;
- a competency development plan, however simple, listing planned actions per person per year;
- delivery evidence: training certificates, webinar attestations, invoices, followed programmes, professional subscriptions;
- the variety of recognised formats: formal training, conferences, trade shows, communities of practice, co-development, documented specialist reading;
- for employers, compliance with the Labour Code's professional interviews;
- the full loop: a need identified, an action delivered, an effect observed on the services.
At an initial audit, the auditor accepts a recent plan, but wants at least one action already delivered or under way and a credible calendar.
Achieving compliance, step by step
- Create a competency development table: one row per person, with identified needs, planned actions, dates and delivery status.
- Feed it from concrete sources: an end-of-course evaluation flagging a delivery weakness, new sector regulations, a new teaching tool to master.
- Plan at least one professionalisation action per person per year: a course, a certifying webinar, a trade show, active membership of a professional network.
- Archive each proof on receipt: attestation, invoice, digital badge, programme. One "professionalisation" folder per person prevents pre-audit panic.
- For employees, keep the professional interview calendar and the signed summaries: the auditor may request them as needs-identification evidence.
Field advice
If you are an independent trainer, this indicator concerns you first and foremost: your own upskilling is the expected evidence. A train-the-trainer course, an attested MOOC, a renewed trade certification or documented active participation in a professional network all qualify. The classic mistake is declaring "I read a lot" with no trace: turn that watch into evidence by logging the conferences attended and keeping the attestations.
Systematically connect this indicator to your other obligations: needs spotted in beneficiary evaluations (indicator 30) and your watch activities (indicators 23 to 25) are excellent inputs for the plan. This cross-indicator coherence impresses auditors, because it shows an integrated quality system rather than a collection of binders.
On subcontractors: you do not have to fund their training, but if you work with them regularly, show that you periodically verify their competencies are current — for example by requesting an updated CV and recent attestations every year.
Finally, size the system to your structure. A two-person organisation needs no HR software: a shared table and an evidence folder suffice. What triggers a non-conformity is the total absence of documented professionalisation over the audited period, not the modesty of the plan.
The evidence the auditor expects
- P.1Competency development plan or table per person per year
- P.2Attestations and certificates of training followed, including by the owner
- P.3Registration invoices for courses, conferences or trade shows
- P.4Signed professional interview summaries for employees
- P.5Evidence of participation in networks or communities of practice
- P.6Documented link between identified needs (evaluations, watch) and delivered actions
Common mistakes in audits
- No professionalisation action delivered or planned over the period
- A theoretical training plan with no delivery evidence
- Forgetting the owner-trainer in the competency development system
- Declaring self-training with no verifiable trace
- Missing or untraced professional interviews for employees
- A plan disconnected from the real needs raised by evaluations and watch
FAQ — indicator 22
+What must a competency development plan contain for Qualiopi?
At minimum: the people concerned, the identified needs, the planned actions (course, webinar, trade show, network), the deadlines and the delivery status. A simple, updated table backed by the matching attestations suffices for a small organisation.
+Must an independent trainer keep training to keep Qualiopi?
Yes. Indicator 22 applies to the owner-trainer: at least one documented professionalisation action per audited period is expected. A course, a certification, an attested MOOC or active participation in a professional network all qualify.
+Do free webinars count as evidence for indicator 22?
Yes, provided you keep a trace: participation attestation, confirmation email, programme and exploitation notes. The auditor accepts varied formats as long as they are documented and tied to an identified need.
- IND. 21Trainers' competencies