Mandatory professional review in France: obligations, sanctions and EPP 2026

Updated 25 May 2026 — Since Act n° 2025-989 of 24 October 2025, the mandatory professional interview (entretien professionnel) became the career development interview (entretien de parcours professionnel, or EPP). Files currently in progress, however, remain subject to the rules introduced by the Act of 5 March 2014 (Article L6315-1 of the Labour Code) for periods prior to the reform. Understanding both regimes, their respective sanctions, and their interaction with the Compte Personnel de Formation (CPF — the personal training account) is now essential for every employer operating in France.

In brief: the mandatory professional interview is an individual meeting focused on the employee's career path, competencies, and training — entirely separate from the annual performance appraisal. For employees hired before the 2025 reform, the review cycle was every two years, with a comprehensive six-year review. Where the conditions were not met in companies with at least 50 employees, the sanction is a compulsory corrective credit of 3,000 € to the affected employee's CPF account. Since 2025, the periodicity moves to four years and the comprehensive review to eight years.

Article L6315-1 of the Labour Code, introduced by Act n° 2014-288 of 5 March 2014 on vocational training, created the obligation for every employer to hold a professional interview with each employee. This interview is devoted to the employee's prospects for professional development, in particular in terms of qualifications and employment.

Three features distinguish the professional interview from any other HR meeting:

• It does not address performance evaluation or objective-setting.
• It is not used to negotiate pay.
• It produces a written record handed to the employee, which constitutes proof that the statutory obligation has been fulfilled.

The framework created in 2014 was substantially reformed by the Act of 24 October 2025, which introduced the EPP and changed the periodicity. The substance of the obligation remains the same; it is the rhythm and the comprehensive review that have changed.

Confusion between the two interviews is the most frequent operational error we encounter in the files we support. It exposes the employer to complete evidentiary risk: a written record that blends performance and training proves neither one.

Our reading: holding both interviews on the same day is legitimate and efficient. But the written records must be kept on two strictly separate documents, with two separate signatures. In the event of an employment tribunal dispute (contentieux prud'homal), the judge will examine whether the document explicitly identifies "career development" as its purpose and addresses the statutory topics. A hybrid form fulfils neither function.

The law specifies the topics that must be covered at each professional interview. An interview that does not address these points does not satisfy the statutory obligation, even if it took place and was formally documented.

The mandatory statutory topics are:

• The employee's prospects for professional development, in terms of qualifications, role, and employment.
• Training actions envisaged or desired: skills assessment (bilan de compétences), recognition of prior learning (VAE — validation des acquis de l'expérience), job-specific training.
• Certifications and qualifications the employee could access, including through VAE.
• The employee's professional project for the medium term.
• Use of the Compte Personnel de Formation (CPF): the employer must inform the employee of their accrued rights, eligible training options, and the possibility of consulting a professional development adviser (CEP — conseil en évolution professionnelle).

All five topics must appear in the written record handed to the employee. The absence of any one of them weakens the document's evidentiary value in the event of a dispute.

The change in periodicity introduced by the 2025 Act is a source of confusion, particularly in companies where employees are at different stages of their working life.

A collective agreement (accord collectif) may provide for a different periodicity. Under the EPP regime, the maximum permitted interval between two interviews remains four years, regardless of any agreement.

This is where the concrete financial risk lies for employers. Article L6315-1 provides that, every six years, the professional interview takes the form of a comprehensive review of the employee's career path over the period.

This review verifies that the employee has received:

1. The professional interviews required over the six years elapsed (a minimum of three interviews under the two-year cycle).
2. At least one non-mandatory training action linked to professional development, or a salary or professional progression, or the acquisition of a qualification or certification.

If either of these two conditions is not met in a company with at least 50 employees, the employer is required to credit the affected employee's CPF account with 3,000 €. This corrective top-up is provided for under Article L6323-13 of the Labour Code.

Quantified example: the cost of a poorly maintained calendar in an SME of 80 employees#

An SME with 82 employees conducted no professional interviews between 2018 and 2024. During an HR audit carried out ahead of the sale of the business, it emerges that 34 employees reached the six-year threshold without having received either the minimum three mandatory interviews or any non-mandatory training action.

Minimum cost of regularisation: 34 × 3,000 € = 102,000 € in CPF corrective credits, to which must be added the risk of individual damages claims if certain employees refer the matter to the employment tribunal (conseil de prud'hommes).

This type of situation comes to light most often during a social due diligence or following a contentious departure — not during a URSSAF audit. The longer the company waits, the higher the cost.

In a negotiated termination (rupture conventionnelle), an employee who has never received a professional interview holds a negotiating lever or a basis for contesting the termination before the employment tribunal. Specialist employment lawyers routinely check this point in termination files.

For companies with fewer than 50 employees, the compulsory 3,000 € corrective top-up does not apply automatically, but the employee retains the right to claim damages for harm suffered as a result of the employer's failure to meet its training obligation.

See also our analysis of rupture conventionnelle procedures to understand how the absence of a professional interview can interact with a challenge to the termination.

The Compte Personnel de Formation (CPF — personal training account) is at the heart of the professional interview. The employer has a duty to inform the employee of their CPF rights at each interview. This information must be recorded in the written account.

In practice, the professional interview provides a moment for dialogue on the use of the CPF, without the employer being required to co-finance any training considered. However, the total absence of any CPF information over the six-year period is one of the criteria used to establish a breach at the time of the comprehensive review.

For employees with specific needs relating to continued employment — in particular those with recognised disability worker status (RQTH — reconnaissance de la qualité de travailleur handicapé) — the professional interview is also the appropriate moment to discuss workplace adjustments or adaptation training. This point is developed further in our article on the advantages and disadvantages of RQTH status for the employer.

In a file involving an industrial SME with 120 employees, an employer initiates a dismissal procedure for professional insufficiency. The employee concerned has been with the company for seven years. Their legal counsel immediately raises the fact that no professional interview has ever been conducted during this period, despite the employee having been entitled to at least three.

The employment tribunal judge notes that the employer cannot invoke the professional insufficiency of an employee to whom it has never proposed training or career support. The procedure is weakened; a settlement agreement is reached.

This case illustrates a point we observe regularly: the professional interview is not an isolated HR formality. It interacts with career decisions, disciplinary procedures, and employment disputes. The absence of a paper trail creates a systemic vulnerability.

Rigorous compliance rests on five concrete steps:

1. Establish a named tracking table showing each employee's hire date, date of the last professional interview, date of the next mandatory interview, and the date of the next comprehensive review.
2. Send a written invitation specifying the statutory purpose of the interview: "professional interview relating to your prospects for professional development, pursuant to Article L6315-1 of the Labour Code".
3. Use a structured template covering all five mandatory statutory topics: career development, training, certifications, professional project, and CPF.
4. Produce a signed written record handed to the employee and archived in their HR file, retained at minimum until the end of the employment relationship.
5. Integrate returns from leave into the automatic trigger: any return from maternity leave, parental leave, long-term sick leave, or union mandate must generate an alert to check whether an interview is due.

The 2025 reform creates a transitional situation. Employees hired before 1 November 2025 remain subject to the 2014 regime for periods prior to the reform. Their six-year comprehensive reviews are calculated on the basis of interviews conducted — or not — under the old regime.

Priority checks:

• Identify employees whose six-year review under the 2014 regime has already passed or is imminent, and verify whether the conditions were met.
• Verify that interviews that were held covered all five statutory topics, and not merely performance objectives.
• Update written record templates to align them with EPP topics (career path, competencies, CPF, professional project).
• Anticipate the transition: for employees moving to the EPP regime, recalculate the next due dates on the basis of a four-year periodicity.

For a broader view of social obligations in 2026, the article on taxable and exempt bonuses usefully complements this piece on the fiscal and social dimension of the employment relationship.

In the event of a labour inspectorate audit or employment tribunal proceedings, the documents examined as a priority are: written invitations to professional interviews (with proof of receipt), signed interview records, and the internal tracking table enabling the calendar to be reconstructed over the six or eight-year period.

The absence of any written trace of the interview is treated, in practice, as the absence of the interview itself. An interview conducted verbally without a written record given to the employee does not fulfil the statutory obligation.

Our firm supports SMEs, startups, and mid-sized companies (ETI) in structuring their social obligations, including the implementation of a compliant professional interview calendar, written record templates adapted to both regimes, and deadline monitoring to prevent any risk of a corrective CPF top-up.

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This article is written for information purposes only. It does not replace a legal analysis of your specific situation, your collective agreements, and your HR history. The applicable rules depend on the size of your company, the hire date of each employee, and the collective bargaining provisions in force. Consult a qualified professional before making any individual decision.