Indicator 27 — Subcontracting and wage portage
When you use subcontractors or trainers under wage portage, you must ensure they comply with the framework's requirements for the services they deliver on your behalf.
Applies to: OF · CFA · VAE · CBC
What the auditor actually checks
Indicator 27 only concerns organisations that engage third parties: subcontracted trainers (with their own structure), ported employees, or partner organisations to whom you entrust all or part of a service. If you deliver everything yourself, the indicator is declared not applicable — simply tell the auditor, who will note it.
If you subcontract, the auditor verifies that you remain responsible for the quality of what is delivered under your name:
- Selection: on what criteria do you choose a subcontractor (skills, references, possibly their own Qualiopi certification)?
- Contracting: is there a subcontracting contract stating the service, the quality requirements and the documents to return (sign-in sheets, evaluations)?
- Control: how do you verify that the subcontracted service follows your procedures — satisfaction questionnaires, supervision, an end-of-mission report?
A frequently misunderstood point: the subcontractor does not have to be Qualiopi-certified when working on your behalf — your certification covers the service. You must, however, prove you impose your standards on them.
Achieving compliance, step by step
1. Formalise your selection criteria
A simple grid: diplomas or certifications, field experience, client references, an up-to-date CV, professional liability insurance certificate, their NDA if the subcontractor is itself a training provider. Keep the collected documents for each contributor.
2. Sign a systematic subcontracting contract
The contract must state: the mission's object and duration, the programme and objectives to respect, the documents to use (your materials, your sign-in sheets, your questionnaires), the deliverables expected at the end and a quality clause referring to your Qualiopi procedures.
3. Control and trace
Apply to subcontracted sessions the same tools as your own: hot satisfaction questionnaire, return of sign-in sheets and evaluations, an end-of-mission report. Once a year, run a quick review of each subcontractor (average satisfaction, incidents, renewal decision) and keep a written trace.
Field advice
If you yourself subcontract for other organisations, indicator 27 concerns you only on the buyer side; but prepare for the auditor's symmetrical question about the exact nature of your activities. Finally, if you engage trainers under wage portage, treat them documentarily as subcontractors: contract, quality requirements, deliverable control.
The evidence the auditor expects
- P.1Subcontractor selection grid or procedure (criteria, required documents)
- P.2File per external contributor: CV, diplomas, references, liability insurance, NDA where relevant
- P.3Signed subcontracting contracts with a quality clause and expected deliverables
- P.4Satisfaction questionnaires from sessions delivered by subcontractors
- P.5Annual subcontractor review (evaluation, renewal decision)
- P.6Evidence your procedures and materials were transmitted to the subcontractor
Common mistakes in audits
- Engaging external trainers without any written subcontracting contract
- Believing the subcontractor must be Qualiopi-certified — or, conversely, imposing no quality requirement
- Not collecting the sign-in sheets and evaluations of subcontracted sessions
- Declaring the indicator not applicable while external contributors invoice delivery work
- No trace of control or review of subcontracted services
FAQ — indicator 27
+Must my subcontractor hold Qualiopi certification?
No. When they work on your behalf, your certification covers the service. You must however prove that you select them seriously, contract with them and impose your quality requirements.
+Does indicator 27 apply if I have no subcontractor?
No: if you design and deliver everything yourself, the indicator is not applicable and the auditor records it. Careful though: an external trainer paid on invoice is a subcontractor, even occasionally.
+What must a training subcontracting contract contain?
The mission's object and duration, the programme and objectives, the documents to use (sign-in sheets, questionnaires), the end-of-service deliverables and a quality clause referring to your Qualiopi procedures.