“We don't have any complaints.” This is the phrase Qualiopi auditors hear most often regarding indicator 31—and the one that makes them dig the most. Here’s why an empty log works against you, what the indicator truly requires, and how to maintain a reassuring log. By an educational director and quality reference person at a CFA, with audits successfully passed since 2021.
What Indicator 31 Requires
Indicator 31 requires you to handle encountered difficulties, complaints, and incidents within appropriate timeframes—and to maintain a complete record of them: reception, analysis, response, and closure.
The important word is not “complaints.” It is “incidents.” The scope is much broader than a letter of dissatisfaction: a request for postponement, an employer annoyed by a schedule, a room problem, a platform issue, a disagreement over a grade. Anything that disrupts the normal course of a service falls within its scope.
Why an Empty Log Is a Red Flag
Put yourself in the auditor's shoes. An organization that trains dozens or hundreds of people per year and has no recorded incidents does not exist. There are two possible explanations, and both are non-conformities:
- either the incidents exist but are not recorded—the system is not working;
- or the organization has such a narrow definition of "complaint" that it misses the requirement.
A log with a few realistic entries, each handled and closed, tells the opposite story: a living system. It's counter-intuitive, but in an audit, a few well-handled problems are infinitely better than zero declared problems.
What a Good Log Looks Like
A simple table is sufficient—no need for dedicated software. The columns that matter:
- Date of receipt and channel (email, oral, phone);
- Who—learner, company, trainer, funder;
- Subject—one line, factual;
- Action taken—what was done, by whom;
- Date of response and closure—this timeframe proves the "within appropriate timeframes" requirement of the framework;
- Follow-up if any—if the incident triggered an improvement, note it: this is a direct link to indicator 32, and auditors love to see this loop.
The Typical Interview Question
“Show me your log, and walk me through the handling of this one.” The auditor chooses a line and traces the process: does the provided response exist? Is the timeframe reasonable? Was the person informed? If your log references documents (a response email, a meeting report), keep them accessible—this is where the demonstration happens.
Warning: Indicator 31 Is Unforgiving
Indicator 31 is one of those indicators where a discrepancy is directly classified as a major non-conformity. There is no “partial” version: an non-existent or fictitious complaint handling system blocks certification until demonstrated correction. This is one of the reasons it consistently ranks among the top three most penalized indicators, along with 10 and 32.
Where to Start if Your Log Is Empty
Don't panic, and most importantly: do not backdate anything. Open your log today, honestly dated today, and fill it in as you go. Have a team discussion: “what issues have we had this quarter?”—you'll see, entries quickly accumulate. A request for postponement, a change of trainer, an access problem to the platform: all of these deserve a line.
To check your progress on the 31 other indicators, our free D-30 checklist lists, point by point, what the auditor checks and the expected evidence. And the Qualiopi Audit Guide deciphers each indicator with the actual questions asked during interviews.
Article written by the founder of Objectif Certif, educational director and quality reference person for an active CFA. Reference texts: decree n°2019-565 and RNQ reading guide – check the version in force before your audit.