Professional training in companies is based on a legal framework that has significantly changed between 2024 and 2026. The 2018 Law for the Freedom to Choose One’s Professional Future, followed by successive decrees on the CPF, and then ceilings introduced by the 2026 finance law: the rules of the game are changing for both employers and employees.
Understanding these changes allows us to distinguish between what is legally mandatory, what depends on HR strategy, and what remains unclear in practice.
Financial participation in the CPF: what recent texts modify
Since the decree n° 2024-394 of April 29, 2024, any employee who uses their Personal Training Account must pay a flat participation fee of 100 euros per training session. As of January 1, 2025, this amount was increased to 102.23 euros. Only job seekers and certain cases of employer contributions are exempt from this fee.
The 2026 finance law (law n° 2026-103 of February 19, 2026, article 203) goes further. It introduces ceilings on mobilizable rights depending on the nature of the training. The stated objective: to direct spending towards priority certifications (retraining, core business skills) and limit uses deemed peripheral.
For companies, this dual constraint (co-payment and ceilings) changes the game. The co-financing arrangements between the employee’s CPF and the employer’s training budget become more complex to coordinate.
HR services that support the individual projects of their employees must now integrate these regulatory limits into their skills development policy. Finding professional information on OK Formation can help map out the schemes still available depending on each situation.
Skills development plan: legal obligations and gray areas
The skills development plan (PDC) has replaced the old training plan. It encompasses all actions decided by the employer to adapt employees to their positions, maintain their employability, and develop their skills. All employees are concerned, including those on apprenticeship or professionalization contracts, without any seniority conditions.
The employer remains free to choose who benefits from training, provided that this choice is not based on discriminatory criteria. However, the boundary between mandatory training and non-mandatory training is not always clear in practice.
Mandatory training and optional training: a distinction that matters
Mandatory training (workplace safety, job adaptation, compliance with sector regulations) takes place during working hours, and remuneration is maintained. For non-mandatory training, feedback from the field varies on this point: some companies integrate them into working hours, while others negotiate specific terms through collective agreements.
This distinction has concrete consequences on the training budget. An action classified as “mandatory” cannot be refused by the employee without disciplinary risk. A “non-mandatory” action theoretically requires the employee’s agreement, but available data do not allow us to conclude that this consent is systematically formalized in small and medium-sized enterprises.
Qualiopi and training funding: what changes in 2026
The Qualiopi certification conditions access to public and pooled funds for training organizations. The reference framework evolved in 2026, with strengthened requirements on the traceability of pathways and the evaluation of results. For companies financing external training, this means an additional filter: a non-Qualiopi certified organization can no longer be covered by an OPCO.
At the same time, a reform of the OPCOs scheduled for October 2026 questions the payment subrogation. If this measure comes into effect, companies will have to advance training costs before reimbursement, which particularly penalizes organizations with tight cash flow.
- Check the Qualiopi certification of the organization before any registration, or risk not benefiting from any coverage
- Anticipate the impact of the possible end of subrogation on the annual training budget
- Consult your OPCO to know the updated funding modalities according to the size of the company and the sector of activity
Forecasting skills management: beyond the training catalog
The PDC is not just a list of courses. It is part of a logic of forecasting jobs and skills management (GPEC), which involves anticipating skills needs based on the company’s strategy. Employee representatives are consulted each year on this plan.
Three levers make up the PDC beyond traditional training actions:
- Skills assessments, which allow for evaluating aptitudes and identifying individual development needs
- Validation of acquired experience (VAE), which offers official recognition of skills acquired in the workplace
- Training actions in work situations (AFEST), which formalize learning directly on the job
The AFEST deserves particular attention. This format, recognized since the 2018 law, remains underutilized compared to traditional classroom or e-learning training. It requires structured support from an internal tutor and a documented reflective phase. Companies that adopt it report better appropriation of professional gestures, but its implementation requires an investment in pedagogical engineering that not all organizations can mobilize.
Apprenticeship and alternation: a development lever under budgetary pressure
Apprenticeship constitutes another axis of skills development in companies. Hiring aids for apprentices have fluctuated in recent years, and the government regularly calls on companies to recruit alternates. Thousands of young people in training remain without a host company each year, raising questions about the adequacy between public incentives and the financial constraints of employers.
The regulatory framework for professional training in companies is becoming denser year by year. Between the mandatory contribution to the CPF, the ceilings of the 2026 finance law, the changes in Qualiopi, and the possible end of OPCO subrogation, the margins for maneuver are shrinking for small structures. Building a coherent skills development plan now requires ongoing regulatory monitoring, not just a budget and a catalog.
