Indicator 10 of the Qualiopi framework — the implementation and adaptation of the service — is, from experience, the one that causes the most non-conformities during audits. Not because organizations work poorly: but because they don't document what they do. Here's what the auditor actually checks, the evidence that works, and the three mistakes that lead to a discrepancy. By an educational director and quality reference person for a CFA, with audits successfully passed since 2021.
What Indicator 10 truly requires
The text of the framework can be summarized in one idea: you must implement the service in accordance with what you have announced, and adapt it to individual situations when necessary — learner difficulties, absences, accommodations, specific needs.
In other words: the auditor is not asking if you track your learners. All organizations do. They are asking you to prove it, with a file in hand. And this is exactly where the gap widens between what is done and what can be demonstrated.
The typical question during an audit interview
It almost always comes in the same form: “Show me this learner's file. How has their journey been monitored and adapted?”
Note the trap: the auditor chooses the learner, not you. They proceed by sampling — they pick a name from your list. A perfectly prepared showcase file will not protect you: it is the homogeneity of your system that is being tested. If your monitoring works for everyone, any file will hold up. If it only works for three prepared cases, the audit will reveal it in ten minutes.
Evidence that works
No need for a complex system. Three types of evidence are sufficient, and their combination is convincing:
- An individualized monitoring procedure — a clear page: who monitors, how often, what triggers an adaptation. Not ten pages that no one applies.
- A genuinely updated monitoring table — with dates spread out over time: interviews, alerts, decisions. This is the centerpiece.
- Traces of concrete adaptations — an interview report, an adjusted timetable, a third-time accommodation put in place, a support plan. Dated, even if briefly written.
The rule I always give: dated, real evidence that can be found in less than two minutes is better than ten theoretical procedures.
The three errors that lead to a discrepancy
1. The table rebuilt the day before
This is the classic mistake — and the easiest for an auditor to detect. A monitoring file that is supposed to be updated monthly, but was created three days before the audit: the document modification dates speak for themselves. A living table, even imperfect, with three columns filled in over time, is infinitely more convincing than an exhaustive table created for the occasion.
2. Real adaptation that is not documented anywhere
You adjusted the timetable for an apprentice in difficulty, organized support, called the employer. But nothing is written down. For the auditor, what is not documented does not exist — this is not bad faith, it's the rule of the audit game: they observe, they don't take your word for it. Three dated lines in a table are enough to transform an invisible practice into evidence.
3. The procedure never applied
The opposite of the previous case: a nice individualized monitoring procedure… and no concrete cases to show. The auditor doesn't read your procedure for its own sake — they ask you the last time it was used. Every procedure in your quality system must have at least one dated example of application.
Why is this indicator so penalized?
Two reasons combine. Firstly, Indicator 10 is one of the indicators where a discrepancy is directly qualified as a major non-conformity: no half-measures are possible, certification is blocked or suspended until correction is demonstrated. Secondly, it is an indicator of daily practice: it cannot be caught up in a week of preparation, precisely because what is audited is the trace of time passing.
That's also why it's an excellent compass: if your Indicator 10 is solid, it generally means that your entire system is truly alive.
The self-diagnosis in one question
Ask yourself one question: has your monitoring table been modified at least once in the last 30 days — excluding audit preparation?
If the answer is no, you know your priority. And the good news is, it's never too late to start documenting: monitoring that starts today, honestly dated today, defends itself very well in an audit — unlike an backdated history, which never defends itself.
Where to start
If your audit is approaching, start by taking stock: our free D-30 checklist covers, indicator by indicator, what is actually checked in an audit — with the expected evidence for each.
And to get to the bottom of the matter, the Qualiopi Audit Guide deciphers all 32 indicators using the same framework as this article: expectations, the auditor's real questions, effective evidence, and observed pitfalls — 32 pages, written based on real audit experiences, with updates included for 12 months.
Article written by the founder of Objectif Certif, educational director and quality reference for an active CFA — initial, surveillance, and renewal audits validated since 2021. Reference texts: decree n°2019-565 of June 6, 2019, and the National Quality Framework reading guide (Ministry of Labor). Always check the current version of the reading guide before your audit.