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 articleIt is five in the afternoon, the day before a Qualiopi surveillance audit, the French quality certification for training providers. A provider's quality manager is looking for proof that Imran, a learner on the March session, really followed his remote module. She finds an email from the trainer, a blurry screenshot and a half-completed spreadsheet. Nothing false, nothing solid either.
This scenario is not inevitable. An online course leaves records by design: you just need to know which ones to keep.
What evidence does an online course produce?
Five families of records come up almost everywhere. The table links them to what they demonstrate.
| Record | What it shows | Example on a platform |
|---|---|---|
| Progress | The learner moved forward in the path | Modules completed, date of last activity |
| Assessment | The objectives were met | Quiz results, marking of a case study |
| Work submitted | The learner produced something | Assignment submitted, with date and mark |
| Support | The trainer replied and followed up | Forum messages, drop-out alerts dealt with |
| Feedback | Learners' views were gathered | End-of-path questionnaire, complaints |
Note the last line: feedback gathered proves nothing until it has led to a decision recorded somewhere in writing. The auditor looks for what follows.
Why a simple login is not enough
A login says that a door was opened. It does not say who worked, for how long, or with what result. The French decree of 20 August 2014 on open or distance training relies, moreover, on three elements to establish attendance: evidence of the work requested, tracking and assistance data, and specific assessments. We detail them in our article on proof of attendance in distance learning.
What changes on 1 November 2026
The framework moves from 32 to 33 indicators, and indicator 19, the one on distance training, is clarified: as soon as an action includes e-learning, the provider must be able to demonstrate that learners actually followed it. Until 31 October, the framework stays at 32 indicators. The detail is in our article Qualiopi at 33 indicators.
How to keep it without getting lost
Three habits are worth more than a grand filing system.
- One place. Evidence lives in the platform and in your quality file, not in five mailboxes.
- An export on a fixed date. At the end of each session, pull each learner's record and file it with the session's name.
- A retention period decided in writing. It depends on your funders and your certification body: ask them, note the answer, apply it.
A point of caution on personal data: a record with a name on it is personal data. Limit access to the people who need it.
The pre-audit checklist
- Every path has written objectives and an assessment tied to those objectives.
- For each learner: progress, results, work submitted, in the same place.
- Drop-out alerts have a follow-up: a message, a call, a note.
- Learners' feedback has an associated decision, however small.
- You can explain in two minutes how the platform serves the training.
- You have reread the detail of the indicators with your certification body.
What Kognisia does, and what it does not do
Kognisia is compatible with the Qualiopi approach: it produces the records we have just discussed. Learning paths, quizzes, assignments, case studies with automatic marking, progress dashboard, drop-out alerts and forum each keep their own history. The detail is on the Qualiopi page and on the progress tracking page.
However, no software certifies an organisation. The audit looks at how you operate, your decisions and your continuous improvement. A platform saves you from chasing documents, nothing more.
And outside France?
Qualiopi and the 2014 decree are specific to France; only the data protection framework is European. Elsewhere you find neighbouring mechanisms, never identical ones. If you are in the UK, the EU GDPR does not apply to you as such, but the UK GDPR gives you the same logic for records that carry a name.
| Country | Equivalent or rule | Reference | Key point |
|---|---|---|---|
| United Kingdom (England for apprenticeships) | No single equivalent: Ofsted for apprenticeships and further education, Ofqual for qualifications, Office for Students for higher education. Records with a name on them are personal data under the UK GDPR. For mandatory health and safety training: training at recruitment and when risks change, repeated periodically where appropriate | gov.uk pages of the three regulators; UK GDPR art. 28; Management of Health and Safety at Work Regulations 1999, reg. 13 | Three regulators depending on the type of offer, to whom you may need to produce evidence of attendance and assessment. The platform supplier is generally your processor: the contract must refer to the UK GDPR. For mandatory training, a dated completion record is a sensible way to show you did it (our interpretation). Apprenticeship rules verified for England only. |
| European Union | No single quality certification for training providers; GDPR for records that carry a name | Regulation (EU) 2016/679, art. 28 | The platform publisher is generally the organisation's processor: a processing contract is required |
| Germany | AZAV: approval of the provider and of the measure, for training funded by the Bundesagentur für Arbeit | §§ 176 to 180 SGB III | Functional equivalent of Qualiopi for access to public funds, but not identical. In-company training needs no approval |
| Germany | Paid distance course with a check of learning outcomes, mostly asynchronous: ZFU approval (FernUSG) | § 7 FernUSG; BGH, 12 June 2025 | Without approval, the contract is void, including between businesses. Draft repeal on 1 July 2027, not adopted: the current rule applies. A course that is entirely or mostly live is in principle not concerned |
| Spain | Distance training: platform with continuous, real-time tracking; at most 20% classroom-based | Real Decreto 694/2017, art. 4; Orden TMS/369/2019, annexes II and IV | The detailed requirements concern catalogue-based vocational training for employment, not all e-learning. |
| Italy | Health and safety e-learning: an LMS that records each activity and its duration, SCORM or equivalent | Accordo Stato-Regioni of 17 April 2025, part IV | Course file kept for ten years. Applies to safety only. The 24-month deadline for the employers' course falls in May 2027 (the 19th or the 24th, depending on the entry-into-force date used) |
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
Is an LMS enough to pass a Qualiopi audit?
No. It supplies records, but the audit examines your organisation: needs analysis, continuous improvement, handling of complaints. The LMS feeds the file, it does not replace it.
How long should evidence be kept?
It depends on your funders and your certification body. Ask them for the period in writing and apply it to all your paths.
Are screenshots accepted?
They help to illustrate, but a dated record with a name on it, produced by the platform, is stronger. Keep the screenshot as a complement, not as the main item.
What if a learner has submitted nothing?
Keep the trace of your follow-ups: alert, message, call. It shows that support took place even if the learner did not respond.
Summary
An online course leaves five families of records: progress, assessments, work, support, feedback. File them in the same place, dated and named, and never rely on logins alone. Next step: take one path and check that you can pull out its complete file in one minute.
Sources
- 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.
- Centre Inffo: open and distance training, first decree published in the Official Journal (2014), accessed on 13 October 2026.
- Regulation (EU) 2016/679 (GDPR), Official Journal text, accessed on 13 October 2026.
- SGB III, § 176 (Germany, AZAV approval), accessed on 13 October 2026.
- SGB III, § 179 (Germany, approval of the measure), accessed on 13 October 2026.
- FernUSG, § 7 (Germany, nullity of the contract without approval), accessed on 13 October 2026.
- BGH, judgment of 12 June 2025, III ZR 109/24, accessed on 13 October 2026.
- BGH, judgments of 5 and 12 February 2026 (synchronous or asynchronous criterion), accessed on 13 October 2026.
- German federal ministry, draft repeal of the FernUSG, accessed on 13 October 2026.
- Real Decreto 694/2017 (Spain, programmed training and distance training), accessed on 13 October 2026.
- Orden TMS/369/2019 (Spain, register of entities and platforms), 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.
- Ofsted, about the regulator (United Kingdom), accessed on 13 October 2026.
- Ofqual, about the regulator (United Kingdom), accessed on 13 October 2026.
- Office for Students, about the regulator (United Kingdom), accessed on 13 October 2026.
- United Kingdom: UK GDPR, Article 28, 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.