Accounting for employee training in France 2026: accounts, CFP levy, OPCO and tax credit

Updated 12 May 2026. Accounting for training costs looks straightforward on the surface -- an expense, an invoice, an OPCO reimbursement. In practice it touches three distinct topics that business owners frequently confuse: the accounting treatment of the expense itself (which account, what VAT, which period), the mandatory vocational training levy (CFP, reported via DSN), and the director training tax credit under Article 244 quater M of the French General Tax Code (CGI). For a Paris-based SME with five employees, the difference between an approximate treatment and a rigorous one can amount to several thousand euros in unrecovered costs or a forgotten tax credit. This is Cabinet Hayot Expertise's analysis.

Labour Code art. L6313-1 onwards: definition of qualifying training actions#

Only training actions that meet the criteria of Article L6313-1 of the Labour Code qualify for OPCO financing and are deductible without restriction. Qualifying actions include training aimed at acquiring and developing professional skills, skills assessments (bilan de competences), prior learning validation (VAE) and literacy programmes. Training that does not meet these criteria may still be tax-deductible as a normal business expense, but it falls outside the scope of the mandatory contribution and cannot be funded through the skills development plan (PDC).

Vocational training levy (CFP): art. L6331-1 onwards#

Article L6331-1 of the Labour Code requires employers to contribute to the financing of continuing vocational training. This contribution, known as the CFP, forms part of the unified contribution to vocational training and apprenticeship (CUFPA). The 2025 rates are as follows:

These rates are to be confirmed for 2026 when the annual revaluation decree is published. The CUFPA as a whole (CFP + apprenticeship tax + CPF-CDD contribution, depending on headcount) averages around 1.68 % for companies with 11 or more employees. The CFP is collected by the sector OPCO to which the company is affiliated.

CGI art. 244 quater M: director training tax credit#

Article 244 quater M of the CGI provides a tax credit for directors who personally attend training. It applies to companies subject to corporate tax (IS) as well as to sole traders and liberal professionals taxed under income tax (BIC, BNC, BA). The credit is calculated as: number of training hours x gross SMIC hourly rate, capped at 40 hours per calendar year.

In 2025, the gross SMIC hourly rate was EUR 11.88 (to be confirmed for 2026), giving a maximum annual credit of approximately EUR 475 for a standard company. The Finance Act 2022 doubled this cap for microenterprises (balance sheet <= EUR 350K, turnover <= EUR 700K, headcount < 10), bringing the potential credit to approximately EUR 950 for microenterprises, subject to confirmation in the 2026 BOFiP update.

The skills development plan (PDC): employer-initiated training#

The PDC is the reference framework for company-funded training. The employer decides, plans and pays. Partial or full reimbursement by the OPCO is possible depending on the branch agreement and the type of action. PDC costs are recognised as expenses and, for the portion not reimbursed by the OPCO, constitute a definitive tax-deductible charge.

The CPF: a personal employee right, generally transparent for the employer#

The personal training account (CPF) is funded by Caisse des Depots via Mon Compte Formation using employer contributions (including the CFP). In principle, the employer does not pay for the employee's CPF training. The only accounting exception is the employer top-up: when the company voluntarily supplements the employee's CPF rights, this top-up is recorded in account 6228.

Pro-A: professional development and reskilling under an employment contract#

Pro-A (reconversion ou promotion par alternance) is an alternance scheme for employees in post, with possible OPCO funding. For the employer, tuition fees go in 6228 and any incremental payroll costs in 641x.

Apprenticeship: a specific regime outside the PDC#

Apprenticeship funding flows through the apprenticeship tax, not through the CFP. Accounting involves account 6311 for the apprenticeship tax and standard payroll accounts for the apprentice's salary.

Account 6228: continuing training -- third-party providers#

Account 6228 is the main account for training expenses paid directly by the company to a certified third-party provider holding an NDA (numero de declaration d'activite, issued by the DREETS). It covers tuition fees, registration costs and the portion not reimbursed by the OPCO.

Requirements to record the charge in 6228:

• Invoice from the training provider stating the NDA
• Demonstrated link with the beneficiary's professional activity
• Signed training agreement or vocational training contract
• Correct period matching (exercise of the training, not the invoice date)

Ancillary accounts: 6241 and 6258#

VAT on training: 20 % deductible as a general rule#

VAT on training invoices is in principle deductible for VAT-registered companies. Important caveat: some training providers apply a VAT exemption if the training is evidenced by an attendance certificate. QUALIOPI-certified programmes are often VAT-exempt; bespoke training invoiced as a service is generally subject to VAT. The provider's VAT status should be confirmed before booking the entry.

The CFP is a levy, not a training expense#

The CFP is a payroll-based levy, not a direct training charge. It is recorded as a debit to account 6311 (contributions to vocational training bodies, apprenticeship tax) and not to 6228. Conflating the two produces a distorted training cost analysis and may raise issues in a tax or URSSAF inspection.

DSN reporting: field S21.G00.81#

The CFP is reported via DSN on field S21.G00.81 (Contribution unique a la formation professionnelle et a l'alternance) in the annual December regularisation filing. Collection is carried out by the sector OPCO under the applicable collective bargaining agreement. Sector OPCOs include CONSTRUCTYS (construction), OPCO2i (manufacturing), ATLAS (financial services) and eight others. Cabinet Hayot Expertise verifies each year the consistency between the DSN filing, the OPCO payment schedules and the balance on account 6311.

The 11 OPCOs and sector affiliation#

Since the 2018 reform, 11 OPCOs have regrouped the former OPCAs. Affiliation depends on the applicable collective bargaining agreement, identified by the IDCC code. An employer uncertain of its OPCO affiliation should check with its accountant or consult the France competences website. Incorrect affiliation results in payments to the wrong OPCO and an inability to draw down training funds.

Account 7588 or account 791: how to choose#

When the OPCO reimburses all or part of the training costs:

• Account 791 (Transfers of operating charges): used when the reimbursement is certain and agreed before the training starts, in order to show the net training cost. This is the more transparent approach for management purposes.
• Account 7588 (Sundry operating income): used when the reimbursement is uncertain or arrives in a different financial year.

At Cabinet Hayot Expertise, we recommend 791 for OPCO approvals granted before the training takes place, and 7588 for partial or late reimbursements that were not pre-agreed.

Journal entries for a partial OPCO reimbursement#

Example: training EUR 8,000 excluding VAT, OPCO reimburses EUR 5,000, net cost to the company EUR 3,000.

Recording the training invoice:

• Debit 6228 Continuing training: EUR 8,000
• Debit 44566 Deductible VAT: EUR 1,600 (if taxable)
• Credit 401 Creditors: EUR 9,600

Receipt of OPCO transfer:

• Debit 512 Bank: EUR 5,000
• Credit 791 Transfers of charges: EUR 5,000

Net training charge = EUR 8,000 - EUR 5,000 = EUR 3,000

Who qualifies and how to calculate it#

The director training tax credit belongs to the company (not to the director personally). It is available to companies subject to IS (SASU, SARL, SA, SAS) and to sole traders under BIC or BNC regimes. The calculation: number of training hours attended by the director(s) x gross SMIC hourly rate, capped at 40 hours per director per year.

In 2025: gross SMIC = EUR 11.88/hour -- 40h x EUR 11.88 = EUR 475.20 ceiling (2026 rate to be confirmed). For microenterprises (Finance Act 2022): doubled ceiling = approximately EUR 950 (to be verified in the 2026 BOFiP).

Journal entries for the director training tax credit#

The tax credit is recorded as a debit to account 695 (income tax and equivalent -- tax credits), with counterpart account 444 (State -- income tax) or 512 if immediately refundable. On the IS return it appears on form 2069-FC and is deducted from IS due on form 2572.

Year-end entry:

• Debit 695 Director training tax credit: EUR 475 (example)
• Credit 444 State IS: EUR 475

At IS settlement:

• Debit 444 State IS: offset against IS due
• Credit 512 Bank (if IS due is insufficient and credit is refundable)

Supporting documents to retain#

To secure the tax credit in a tax audit, retain: signed training agreements with dates and duration, attendance certificates from the provider, paid invoices, and an explicit calculation (hours x SMIC hourly rate) attached to form 2069-FC.

Scenario: a Paris-based SARL with five employees (fewer than 11, CFP rate 0.55 %) organises a two-day training course in March 2026 for four employees. The provider invoices EUR 10,000 excl. VAT + 20 % VAT. OPCO Atlas confirms a EUR 7,000 funding award. The director personally attended 12 hours of financial management training.

Step 1 - Training invoice received in March:

• Debit 6228 Continuing training: EUR 10,000
• Debit 44566 Deductible VAT: EUR 2,000
• Credit 401 Creditors: EUR 12,000

Step 2 - Payment to provider:

• Debit 401 Creditors: EUR 12,000
• Credit 512 Bank: EUR 12,000

Step 3 - OPCO Atlas reimbursement (EUR 7,000) received in May:

• Debit 512 Bank: EUR 7,000
• Credit 791 Transfers of charges: EUR 7,000

Net training charge for the year: EUR 10,000 - EUR 7,000 = EUR 3,000

Step 4 - Director training tax credit (at year-end): 12 hours x EUR 11.88 SMIC 2025 = EUR 142.56

• Debit 695 Director training tax credit: EUR 142.56
• Credit 444 State IS: EUR 142.56

CFP 2026 (annual levy, separate from training charge accounting): On gross payroll of EUR 120,000, CFP = 0.55 % x EUR 120,000 = EUR 660.

• Debit 6311 Contributions to training bodies: EUR 660
• Credit 437x OPCO payable: EUR 660 (paid via DSN, field 81-001)

The underestimated risk: confusing OPCO flows and the tax credit#

In the files we handle in Paris, the most common error is not the wrong account -- it is the confusion between three distinct mechanisms: (1) the OPCO reimbursement of a PDC training, (2) the CFP levy paid to the OPCO as a statutory contribution, and (3) the director training tax credit. Mixing incoming OPCO flows with outgoing CFP payments produces an inaccurate account 6311 and distorts the true cost of training.

The trade-off to make: funded PDC or not?#

A Paris-based SME director should systematically file a funding request with their OPCO before the training starts. Funding is not automatic and depends on the available budget in the branch fund, the type of action and the collective agreement. Cabinet Hayot Expertise observes that SMEs that do not file OPCO applications typically leave EUR 2,000 to EUR 8,000 in potential reimbursements unclaimed each year. The process is straightforward but must be anticipated -- the OPCO will not fund training that has already taken place outside its process.

What the tax authorities look for: the training agreement and the NDA#

During a tax or URSSAF inspection, auditors routinely check: the training agreement signed before the training started, the provider's NDA reference visible on the invoice, consistency between invoiced hours and attendance certificates, and the logical connection to the professional activity. An invoice without an NDA, or a "training" that resembles a team-building outing, is not deductible without risk. At Cabinet Hayot Expertise, we review these elements at every closing before validating charges in account 6228.

In practice: checklist for a well-accounted training expense#

• Training agreement signed before the start date
• Invoice stating the provider's NDA and the number of hours
• VAT invoiced or exempt: confirm the provider's QUALIOPI status
• OPCO funding request submitted in advance if PDC-funded
• Account 6228 for tuition fees, 6241 and 6258 for ancillary costs
• Director tax credit calculated at year-end and form 2069-FC completed
• CFP reported in 6311 via annual DSN, separate from training charges
• OPCO reimbursement in 791 (pre-agreed) or 7588 (late or uncertain)

To secure the accounting and tax treatment of your training expenses in Paris, contact the team at Cabinet Hayot Expertise or consult our payroll and social management service for the DSN and CFP dimension.