When Kognisia is not the right choice: cases to know
Control of the code, selling courses to the public, very small numbers: where another solution serves you better, and where Kognisia is a good fit.
Read the articleSix months after an online course ended, a funder asks you to prove that Priya really followed it. You produce a printout: forty logins. The funder replies: "And what did she do during those forty logins?" At that point, the printout says nothing.
What the reference text says
The French decree of 20 August 2014, the first text published in France on open or distance training, states that attendance is established by three elements. It makes a list of them, not an à la carte choice.
| Element in the decree | In plain terms | What the platform can keep |
|---|---|---|
| Evidence that the requested work was completed | The person submitted what was asked | Assignments submitted, marked case studies, with dates |
| Data on tracking, support and assistance | Someone followed, helped, replied | Progress dashboard, drop-out alerts, forum exchanges |
| Specific assessments organised by the provider | Learning was verified | Quiz results, marks, corrections |
The text also refers to response times of assistance staff and the means of reaching them: these are things to plan in your organisation, not only in the tool.
Why it matters more from 1 November 2026
The Qualiopi framework, the French quality certification for training providers, moves from 32 to 33 indicators on that day, and indicator 19 is clarified: as soon as an action includes e-learning, the provider must be able to demonstrate that learners actually followed it. Before that date, the framework stays at 32 indicators. The detail is in our article Qualiopi at 33 indicators.
In other words, what was good practice becomes a control point.
The most frequent mistakes
Here are the others, in the order in which we meet them.
- Dating nothing. A mark with no date, or an assignment whose submission date is unknown, loses half its value.
- Forgetting the support. You chased Priya by email, but the email sleeps in a personal inbox. For the auditor, it does not exist.
- Assessing without tying to objectives. A pleasant quiz that measures nothing the course promised proves very little.
- Exporting too late. A printout requested three years later, on a platform whose subscription has ended, is an empty file.
- Keeping everything, without sorting. Ten thousand log lines cannot be read. One printout per learner, readable on one page, can.
What a solid file looks like
The logic is simple. Work submitted answers the question "what did she do?", tracking answers "who supported her?", assessment answers "what did she retain?". You need all three.
What Kognisia does, and what it does not do
The platform keeps learning paths, quizzes, assignments, case studies with automatic marking, a progress tracking dashboard, drop-out alerts and a forum. It is compatible with the Qualiopi approach: it produces the records. You will find them described on the progress tracking page and on the Qualiopi page.
It does not decide for you what counts as sufficient evidence for your funder, and it does not replace your organisation: it is up to you to define who follows up, when, and what you keep. For the items in the file, our article on the evidence to keep gives a checklist.
And outside France?
The three attendance elements of the 2014 decree are a French rule, and European law sets no common equivalent. If you work in the UK, we have not identified a UK text to cite as the equivalent; what you owe depends on who regulates your offer and who funds it. Each country has its own requirements, more or less detailed.
| Country | Equivalent or rule | Reference | Key point |
|---|---|---|---|
| United Kingdom (England for apprenticeships) | No equivalent text to the French decree identified. Ofsted inspects further education and apprenticeship training providers, Ofqual oversees regulated qualifications, the Office for Students regulates higher education. Mandatory health and safety training: training repeated periodically where appropriate and delivered during working hours | Regulators' official pages; Management of Health and Safety at Work Regulations 1999, reg. 13 | Depending on your offer, one of the three regulators may ask for evidence of attendance, assessment and quality: the framework is not single. For mandatory training, a dated completion record is a sensible way to show it (our interpretation). Apprenticeship rules verified for England only; Northern Ireland has its own health and safety regime (not verified). |
| Germany | Paid distance course with a check of learning success, mostly asynchronous: ZFU approval (FernUSG) | § 1 and § 7 FernUSG; BGH, 5 and 12 February 2026 | Without approval, the contract is void. A course that is entirely or mostly live is in principle not concerned; mixed formats remain a grey area. Draft repeal on 1 July 2027, not adopted |
| Germany | Monitoring of employees: co-determination of the works council (Betriebsrat) | § 87 Abs. 1 Nr. 6 BetrVG | Technical devices designed to monitor behaviour or performance are subject to it. Individual LMS tracking falls within it on the usual reading, to be confirmed |
| Spain | Distance training: platform with continuous, real-time tracking, assessment, tutoring; at most 20% classroom-based | Real Decreto 694/2017, art. 4; Orden TMS/369/2019, annex IV | Annex IV provides for tracking of participation and recording of entry, duration and frequency of presence. This applies to catalogue-based vocational training for employment, not to all e-learning |
| Italy | Health and safety e-learning: an LMS that records each activity, its duration and the assessments | Accordo Stato-Regioni of 17 April 2025, parts III and IV | Attendance of at least 90% of the hours to reach the final check, paper or electronic attendance register, course file kept for ten years. Applies to safety only, and not to every course |
| Italy | Remote monitoring of employees: trade union agreement or authorisation from the Ispettorato nazionale del lavoro | Statuto dei lavoratori (Law 300/1970), art. 4 | Exception for work tools and time-recording tools, but adequate information is always compulsory. Classification of an LMS to be validated |
These rules change, sometimes within a few months: have the framework that applies to your situation checked by a local adviser before acting.
Frequently asked questions
Does time spent online prove attendance?
Not by itself. It can complement the file, but the decree asks for work submitted, tracking and assistance data, and assessments. Connection time is not one of them.
Do I need a trainer available live?
The text speaks of support and assistance, with response times and means of contact to be planned. It does not ask for permanent presence: what matters is that the learner knows whom to approach and gets a reply within a stated time.
What should I do about a learner who submits nothing?
Keep the trace of your follow-ups: alert, message, call. It shows that support took place. The file will honestly say that the training was not followed to the end.
Do these rules apply to e-learning in a company?
In France, they apply to distance training actions, whatever the audience. If you train your own employees, your funder or your OPCO (skills operator) may ask you for the same elements.
Summary
Remote attendance is proved by three elements: work submitted, tracking and assistance, assessments. A login replaces none of the three. Next step: take a recent learner, try to rebuild their file in five minutes, and note what is missing.
Sources
- Centre Inffo: open and distance training, first decree published in the Official Journal (2014), accessed on 13 October 2026.
- CNFCE: Qualiopi, what changes on 1 November 2026, accessed on 13 October 2026.
- Certiforma: Qualiopi decree 2026-728 and 33 indicators, accessed on 13 October 2026.
- FernUSG, § 1 (Germany, definition of distance teaching), accessed on 13 October 2026.
- FernUSG, § 7 (Germany, nullity of the contract without approval), accessed on 13 October 2026.
- BGH, judgment of 5 February 2026, III ZR 137/25, accessed on 13 October 2026.
- BGH, judgment of 12 February 2026, III ZR 73/25, accessed on 13 October 2026.
- German federal ministry, draft repeal of the FernUSG, accessed on 13 October 2026.
- BetrVG, § 87 (Germany, co-determination), accessed on 13 October 2026.
- Real Decreto 694/2017 (Spain, distance training), accessed on 13 October 2026.
- Orden TMS/369/2019 (Spain, platform annexes), accessed on 13 October 2026.
- Italian Ministry of Labour, Accordo Stato-Regioni of 17 April 2025, accessed on 13 October 2026.
- Italian Ministry of Labour, FAQ of 27 March 2026, accessed on 13 October 2026.
- Normattiva, Statuto dei lavoratori, art. 4 (Italy), accessed on 13 October 2026.
- United Kingdom: Ofsted, about the regulator, accessed on 13 October 2026.
- United Kingdom: Ofqual, about the regulator, accessed on 13 October 2026.
- United Kingdom: Office for Students, about the regulator, accessed on 13 October 2026.
- United Kingdom: Management of Health and Safety at Work Regulations 1999, regulation 13, accessed on 13 October 2026.
The Kognisia team
Kognisia designs a SaaS learning platform, with a training catalogue and white label as options.
Kognisia designs a SaaS learning platform, with a training catalogue and white label as options.