In short: a signed and then scanned attendance PDF has, in practice, no enforceable legal value in the event of an OPCO audit. The Qualiopi framework, indicator 28, requires actual traceability of attendance. The proper path is through a timestamped electronic signature, kept in a controlled environment for the five-year regulatory period.
You are an independent trainer or a training organization. You arrive at your Qualiopi surveillance audit with your binder of scanned attendance sheets, proud to have digitized everything. The auditor looks at them, nods, and asks how you prove that a specific trainee was actually present at the session on Thursday, March 17, 2026, at 2:12 PM. And there, your signed and then scanned PDF suddenly becomes very silent.
Why a signed and scanned PDF is not enough
A PDF of an attendance sheet that is manually signed and then scanned consists of three objects that occurred at different times. The blank form, which was printed. The handwritten signature, applied at time T. The scan, made at time T+1, T+2, or T+10. None of these objects carry enforceable information regarding the exact moment the signature was applied. The date appearing on the sheet was filled in by hand — by you or by the trainee. The scan itself carries a file date that could have been modified.
As long as no party challenges it, the system holds up. The day an OPCO demands a refund because they suspect a fictitious attendance, or a trainee disputes having attended a certain session, your scanned PDF reveals itself for what it is: an object that is credited by habit, not by legal structure.
What Qualiopi framework indicator 28 requires
The Qualiopi national reference framework, applicable since January 1, 2022, to providers of actions contributing to skills development, requires in its indicator 28 that the provider be able to prove “the implementation of means, methods, and evaluation techniques, as well as the traceability of attendance.” The keyword is traceability: it is not enough to assert presence; it must be documented in a verifiable manner.
The Qualiopi audit is a system audit: you are asked how you operate, how you track, and how you archive. A scanned attendance sheet is not, in itself, rejected — it may suffice for an audit that does not delve deep. But when an auditor digs deeper, or when an OPCO challenges it after the fact, the quality of the evidence becomes decisive.
Five-year retention: what the Labor Code says
Article L. 6362-7-2 of the Labor Code requires training organizations to keep supporting documents related to training actions for five years. This period runs from the end of the action, and it is regularly checked by the regional control services of the DREETS, as well as by the OPCOs in case of funding.
“The organizations mentioned in Article L. 6351-1 shall retain, for a period of five years, the documents relating to the implementation of actions contributing to skills development for which they have received funds.”
Article L. 6362-7-2 of the Labor Code
Five years is longer than the lifespan of most training SaaS platforms. If your provider shuts down, changes its model, or limits access to your history, you remain responsible for record-keeping. The actual portability of your attendance records and assessments becomes an issue, and dependence on a single provider becomes a concrete operational risk.
The legal value of an electronic signature under eIDAS
The European eIDAS regulation distinguishes three levels of electronic signature: simple, advanced, and qualified. The simple signature is the most accessible: a click in an email, entering an SMS code. Its probative value is not zero—Article 1367 of the Civil Code recognizes the value of an electronic signature—but it is lower than that of the qualified signature, which relies on a certificate issued by a qualified trust service provider.
For training attendance records, a simple signature is generally sufficient, provided it is accompanied by a reliable server-side timestamp and a record of the signatory’s identification. It is precisely this combination that makes the attendance record enforceable, and it is what a scanned PDF lacks.
Criteria for a sustainable attendance record chain
Here is the framework to apply to any attendance solution, regardless of the provider. Identification of the trainee at the time of signing—not just via a handwritten signature. Server-side timestamping independent of the user’s workstation. Encrypted retention for at least five years. Data retrieval in a usable and auditable format. Compartmentalization by session and by OPCO. Independence from a single provider: if the tool disappears, your records remain retrievable.
With this grid, you can evaluate Digiforma, Dendreo, or any other solution. Digiforma is the French benchmark for the training organization (OF) segment, with very comprehensive Qualiopi coverage. Dendreo is positioned for mid-sized structures. Both are hosted SaaS solutions: editorial sovereignty is French, and hosting is too, but you remain in a subcontracting arrangement. For an OF that wants to fully own its stack, a WordPress path with a sovereign vault offers a complementary alternative.
How Client Vault responds — regarding the learner portal segment
Client Vault does not claim to replace Digiforma or Dendreo for OF back-office operations — such as managing training agreements, BPF declarations, or OPCO financial monitoring. It is positioned for the learner portal and the collection of trainee documents: signed agreements, employer certificates, funding proof, pre-training assessments, and hot and cold evaluations.
For attendance tracking specifically, Client Vault integrates with a simple electronic signature provider — Yousign or Universign — which handles timestamping and evidentiary value. The vault itself stores the signed sheets and makes them available for audit or dispute. This separation of roles — signature via a qualified provider, storage with you — is more robust than a monolithic system where everything depends on the same vendor.
For WordPress agencies equipping training organizations: the typical deployment combines WordPress + Tutor LMS for pedagogical delivery + Client Vault for document collection and the learner portal + Yousign for signing agreements and attendance records. This set is coherent, sovereign, and each building block remains independent.
Honest limits
Client Vault does not handle electronic signatures: for that, you should stick with Yousign, Universign, or any other qualified provider. Client Vault also does not handle LMS pedagogical tracking — for course distribution, interactive assessments, or grade tracking, you should continue using Tutor LMS, LearnDash, or equivalents. The promise is focused: a learner portal, document collection, and auditable storage.
For a very large training organization already set up on Digiforma with complex OPCO integrations, the switching cost may not be justified. Client Vault is better suited for independent trainers and medium-sized training organizations that want to start their Qualiopi process on a sovereign stack or reduce their dependency on a single vendor.
Let’s get to know each other
If you are an independent trainer, a training organization, or a WordPress agency serving training organizations, and you are concerned about the robustness of your attendance tracking chain as a Qualiopi audit approaches, let’s have a video call. Twenty to thirty minutes to understand your setup and see if a sovereign path can complement or replace your current solution.
Frequently asked questions
Is a scanned PDF legally enforceable for Qualiopi?
It is accepted in practice as long as no one challenges it, but its probative value is weak. No date of signature is proven by design. In the event of an OPCO dispute or an in-depth audit, only non-repudiable chains will hold up.
What does indicator 28 of the Qualiopi framework require?
Indicator 28 requires the implementation of evaluation means, methods, and techniques, as well as the traceability of attendance. The keyword is traceability: it is not enough to make a claim; it must be documented in a verifiable manner.
What is the legal value of a simple electronic signature?
Article 1367 of the Civil Code recognizes electronic signatures. The eIDAS regulation distinguishes three levels: simple, advanced, and qualified. A simple signature is sufficient for most attendance records, provided it is server-side timestamped and associated with a reliable identification of the signatory.
How long should attendance records be kept?
Article L. 6362-7-2 of the Labor Code mandates a retention period of five years from the end of the action. This duration applies to supporting documents, including attendance records and agreements.
Is Yousign sufficient for training provider attendance records?
Yousign covers the signature and timestamp with probative value. It must be supplemented with a retention chain that is auditable over five years, along with attendance tracking — this is precisely the complementary role of a sovereign digital vault.
How can a trainee’s attendance be proven in the event of an OPCO dispute?
By producing the complete chain: electronically signed attendance records with server timestamping, session event logs, and auditable retention. A scanned PDF alone is no longer sufficient when a dispute arises regarding contested attendance.
Is qualified timestamping mandatory?
Not for standard training attendance records. Qualified timestamping is required for acts with very high evidentiary value (qualified electronic signature, evidentiary archiving). For Qualiopi, a reliable, server-side timestamp with a clear audit trail is sufficient in most cases.
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