Annual appraisal vs professional interview: differences, obligations and templates
Distinguish the annual performance appraisal (optional) from the career-path interview (EPP, mandatory every 4 years). Differences, 2026 obligations and ready-to-use templates.
Expert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
Quick answer. The professional interview — renamed the career-path interview (EPP) by the Act of 24 October 2025 — deals exclusively with career path, skills and training. Its frequency moves from two to four years (a comprehensive review every eight years). The annual performance appraisal, by contrast, is not required by law and covers performance and objectives. The two may be held on the same day, but their records must stay separate. Confusion costs the employer its proof of compliance and, in companies with at least 50 employees, a corrective €3,000 credit to the employee's training account (CPF).
2026 context: two distinct interviews, two legal purposes#
Many managers and HR leaders merge the mandatory professional interview and the annual appraisal into a single process to save time. This confusion, although it looks efficient, is one of the most common operational errors we see. It has two consequences:
- Legally, it satisfies neither obligation: a labour court will rule that the professional interview was not held, because performance evaluation "contaminates" the legal nature of the document.
- Financially, in a company with at least 50 employees, the lack of proof of a professional interview triggers, at the comprehensive review, a corrective €3,000 credit to the employee's personal training account (CPF).
Distinguishing the two and knowing each obligation has become essential to sound HR management in 2026 — all the more so since the reform has just changed the interview frequency.
The professional interview: legal framework and obligations#
The professional interview was created by the Act of 5 March 2014 (Article L6315-1 of the Labour Code). It is a legal obligation applying to all employers, regardless of company size, and to all employees, whatever their contract (permanent, fixed-term, apprenticeship, professionalization). For the detail of sanctions and implementation, see our guide on the mandatory professional interview.
Legal definition#
Article L6315-1 devotes this interview to:
- Career development prospects in terms of qualification, employment and career.
- Non-mandatory training considered for professional development.
- Accessible certifications and qualifications, notably through prior-learning recognition (VAE).
- The employee's medium-term professional project.
- The personal training account (CPF): accrued rights, eligible training, access to career development advice (CEP).
Critical point: the professional interview does not assess the employee's work. The statute says so explicitly. The moment a rating, performance measure or objective enters the record, the interview is no longer compliant.
Frequency: what the Act of 24 October 2025 changes#
Act No. 2025-989 of 24 October 2025, transposing a national cross-industry agreement, turns the professional interview into the career-path interview (EPP) and lengthens its frequency.
| Item | Before the reform | Career-path interview (EPP) |
|---|---|---|
| Ordinary frequency | Every 2 years | Every 4 years |
| Comprehensive review | Every 6 years | Every 8 years |
| Return from leave (maternity, long absence) | Interview due | Interview due |
Key calendar point: the new four-year frequency applies by 1 October 2026 at the latest. Companies and industry branches with an agreement on interview frequency must revise it before that date to bring it into compliance.
The annual performance appraisal: what does the law say?#
The answer is short: nothing. No article of the Labour Code mandates an annual appraisal. It becomes an obligation only if:
- The applicable collective agreement requires it explicitly (the case in some sectors: accounting firms, banking, insurance).
- An enterprise agreement stipulates it.
- A workplace practice can be evidenced (consistent, general and settled practice).
Absent these conditions, the annual appraisal is a voluntary management practice, not a legal obligation.
What case law still requires#
Article L1222-3 of the Labour Code requires the employer to inform the employee, in writing and before the interview, of the evaluation criteria and methods. This protects the employee against opaque or discriminatory assessment. Even a voluntary annual appraisal must respect this transparency standard.
Purpose of the annual appraisal#
When it exists, it covers:
- Performance: achievement of objectives, work quality.
- Future objectives and expected results.
- Remuneration: increase, bonus, variable pay.
- Development of the employee (without replacing the mandatory professional interview).
Comparison table: key differences#
| Aspect | Professional interview (L6315-1) | Annual performance appraisal |
|---|---|---|
| Legal basis | Mandatory — Art. L6315-1 | None, unless agreement |
| Purpose | Career path, training, CPF, project | Performance, objectives, pay |
| Work evaluation | Prohibited | Its main purpose |
| Imposed frequency | Every 4 years (EPP, Act of 24 Oct. 2025) | None imposed by law |
| Written record for employee | Mandatory, signed | Optional, by practice |
| Sanction for breach | €3,000 CPF credit (50+ employees) + damages | No legal obligation |
| Can they be combined? | Yes, but separate records mandatory | Yes, with two distinct documents |
Special case: combining both interviews without risk#
Many companies, especially SMEs, hold both interviews on the same day to cut administrative load. This is accepted and often recommended for efficiency. Here is how to do it without legal risk.
Step 1: one invitation specifying both agendas#
You are invited to a joint interview on [DATE] at [TIME] at [LOCATION], with two separate sections:
- Career-path interview (Art. L6315-1) — career path, training, CPF.
- Annual performance appraisal — performance, objectives, remuneration. Two separate, signed records will be provided afterwards.
Step 2: two distinct records#
Each interview produces its own document, with an explicit heading and a separate signature. A hybrid form satisfies neither obligation.
Step 3: separate filing#
Keep both documents in the employee's HR file, clearly identified and dated.
Template 1: career-path interview (to adapt)#
Invitation#
Subject: Invitation to a career-path interview (Art. L6315-1 of the Labour Code)
You are invited to a career-path interview on [DATE] at [TIME] at [LOCATION].
It covers your development prospects, desired training, accessible certifications and professional
project. It will review your personal training account (CPF).
A signed record will be provided afterwards.
Record#
CAREER-PATH INTERVIEW — Article L6315-1 of the Labour Code
Employee: [NAME] Position: [ROLE] Hire date: [DATE] Interview date: [DATE]
1. Career development prospects: [...]
2. Non-mandatory training considered: [...]
3. Accessible certifications and qualifications (VAE, diplomas): [...]
4. Medium-term professional project: [...]
5. Personal training account (CPF): balance [AMOUNT] — eligible training [...] — CEP mentioned: yes / no
Agreed actions: [...]
Employee signature: __________ Employer signature: __________
Template 2: annual performance appraisal (to adapt)#
Invitation#
Subject: Invitation to an annual performance appraisal
You are invited to your annual performance appraisal on [DATE] at [TIME] at [LOCATION].
It will cover your performance over the past year, your results against objectives and your
development areas. The evaluation criteria and methods used are: [SPECIFY].
A signed record will be provided afterwards.
Record#
ANNUAL PERFORMANCE APPRAISAL
Employee: [NAME] Position: [ROLE] Period assessed: [DATE] to [DATE]
1. Objective achievement: Objective 1 [achieved / partial / not achieved] — Objective 2 [...]
2. Performance evaluation: quality, deadlines, skills, teamwork [adapt to your criteria]
3. Objectives for the coming year: [...]
4. Development and training (complement the professional interview, do not replace it): [...]
5. Salary changes: [increase / bonus / none]
Employee free comments: [...]
Employee signature: __________ Manager signature: __________
2026 points to watch#
- Revise agreements before 1 October 2026. The Act of 24 October 2025 requires aligning any industry or company agreement that sets interview frequency with the new four-year cycle (eight-year comprehensive review). Check your collective agreement.
- Keep a named schedule. Identify employees whose comprehensive review (now at eight years) is approaching. A list with hire dates and interview dates prevents oversights.
- The €3,000 credit targets companies with 50+ employees. Below that, the employer is not subject to the automatic credit but remains exposed to employment-tribunal damages if an employee contests a missing interview.
- Two documents, never one. Even held on the same day, the two interviews produce two distinct records, signed separately.
- Keep the evidence. Invitations, signed records and emails are the proof of compliance in a dispute.
Our expert-accountant analysis#
Recently, an SME director asked us to secure his HR processes before selling the business. During the social due diligence ahead of the sale, it emerged that the company merged both interviews into a single document, with no legal distinction. The doubt over compliance with the employer's HR and payroll obligations exposed the buyer to a post-acquisition corrective-credit risk.
We helped the director reconstruct and clarify the processes of recent years. Several favourable elements could be established (non-mandatory training taken, salary progression), which limited the exposure. But that effort could have been avoided with a clear process from the start. Clarity between the two interviews is not a formality: it is a light investment that offers strong protection.
Hayot Expertise advice. Set up an HR calendar that clearly separates the two interviews, with two distinct documents, even when held the same day. Appoint an HR lead or rely on social and payroll support to maintain the named table of hire dates, completed interviews and upcoming comprehensive-review deadlines (eight years under the EPP regime). Connect this tracking to your payroll and remuneration management and have the framework validated by your accounting firm. An annual light HR audit corrects drift before it costs €3,000 per employee.
Frequently asked questions
Can the annual appraisal replace the professional interview?+
No. The annual appraisal is not legally required (except by agreement), but if practised it keeps its own purpose. An appraisal record does not satisfy the legal obligation of the professional interview on career path and training. If you drop the annual appraisal, first check that your collective agreement allows it and notify employees in writing.
What happens if the professional interview is not held at the legal frequency?+
A missing interview exposes the employer to employment-tribunal damages and, in companies with 50+ employees, a €3,000 CPF credit to the employee at the comprehensive review (now eight years) if no non-mandatory training was taken. The sanction adds up: a company behind on all its interviews can build a large CPF liability.
Is the professional interview mandatory for fixed-term and apprenticeship contracts?+
Yes. All contract types are covered. For short fixed-term contracts, frequency adapts to contract length, but record-keeping remains mandatory.
Who conducts the professional interview: the manager or HR?+
The law sets no specific function. In practice, the direct manager often leads it, with possible HR or external support. What matters is that the record covers the legal topics and the employee receives it signed.
Should the professional interview be checked before a negotiated termination?+
Yes. An employee who never had one holds leverage to contest or renegotiate. Checking this before starting the procedure secures the agreement.
Can the interview be postponed if the employee is absent?+
Yes, absences do not suspend the obligation but reschedule the interview. If the employee returns after a long absence, the interview is offered on return.
Must the professional interview be in writing?+
Yes. An oral interview without a record given to the employee does not meet the obligation. The document must cover the legal topics and be signed by employee and employer.
Key takeaways#
- The professional interview — now the career-path interview — is mandatory every four years under the Act of 24 October 2025 (the new frequency applying by 1 October 2026 at the latest) and covers exclusively career path, training and CPF.
- The annual appraisal is not legally required (except by agreement) and covers performance and objectives.
- Merging both into one document is an error: two separate, signed records are mandatory.
- In companies with 50+ employees, breaching the comprehensive review (eight years) triggers a €3,000 CPF credit to the employee.
- Keeping a named table of hire dates and completed interviews is the main operational safeguard.
- Industry or company agreements setting the frequency must be revised before 1 October 2026.
Official sources#

Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
This topic is part of our service French payroll outsourcing | DSN, payslips, HR
Need a quote or personalised advice?
Our accountancy firm supports you through all your steps. Get a free quote to review your situation and receive a bespoke fee proposal, or contact us directly.