Your learners log in at 6 a.m., on a Sunday, in twenty-minute chunks. And your Qualiopi auditor is asking you for “attendance sheets.” The two seem incompatible, and plenty of training providers end up cobbling together unverifiable spreadsheets or getting backdated PDFs signed. That's exactly what triggers a non-conformity.
Good news: for asynchronous distance learning, the French Labor Code does not ask for a signature every half-day. It asks for an individualized training protocol and evidence that the training actually happened. That difference completely changes how you organize your day-to-day.
Here you'll find the four methods actually used to produce digital attendance records that hold up in front of an auditor, from the most automated to the most manual. For each one: what it really proves, what it costs you in time, and where it falls short. And at the end, the precise list of documents to keep in your evidence pack, session by session.
What Qualiopi really requires in e-learning (and what it doesn't)
In open and distance learning, the expected evidence isn't a signature at a fixed time: it's a body of traces showing that the learner followed and completed the training.
The framework comes down to two texts. First, article D6313-3-1 of the French Labor Code on Légifrance, which states that a distance learning action follows an individualized protocol covering three elements: the technical and educational support made available to the learner, information about the learning activities and their average duration, and the assessments that punctuate or conclude the training.
Then the national quality framework, set by decree no. 2019-564 of 6 June 2019: 7 criteria, 32 indicators, mandatory since 1 January 2022 for any provider that wants access to public and pooled funding (OPCOs, CPF, France Travail, regions, local authorities).
In practice, the auditor is trying to answer three questions:
- Did the learner actually access the content, and over what period?
- Did they produce something (work, quizzes, assessments) that proves they were active?
- Did they have access to support, and did that support leave a trace?
What the auditor doesn't ask for: a handwritten signature every half-day for asynchronous sequences. That would be a fiction, and a well-documented fiction is still a fiction.
Two nuances to watch. As soon as a sequence is synchronous (virtual classroom, video call, in-person session), timed attendance becomes the norm again, and it's almost always required. And above all, your funder can be stricter than the law: an OPCO's terms and conditions or a regional agreement override your convenience. Read them again before choosing your method. If you want the details indicator by indicator, the article on what auditors really expect when it comes to Qualiopi evidence is a good complement to what follows.
Method 1: a platform that produces the evidence for you
The shortest path is to use an e-learning platform that natively timestamps every login, every completed module and every assessment, then exports it all as one document per learner.
That's the idea behind Skilzy, a French platform for learning and using AI: more than 15 programs (image creation, UGC videos, ads, faceless channels, avatars and voiceovers, music, automation with n8n, prompt writing, AI-assisted development). A built-in “AI Lab” lets learners use the real tools directly inside the platform, with credits included, so they don't have to stack subscriptions on their own side.
For a training provider, there's a double benefit. The catalog is ready to offer, and two certifications registered in the French Répertoire spécifique are state-recognized and eligible for funding: the RS7439 certification in AI content marketing and RS6792 in AI and sales. On the compliance side, learner activity is tracked by design: login dates and durations, modules opened and completed, quiz and assessment results, work produced in the Lab, support exchanges.
Those elements feed directly into the file an auditor expects. The compliance offer for training providers details the available exports and how to tie them back to your training agreements.
Two honest caveats. The platform supplies the raw material: building the file, and keeping it consistent with the quote, the agreement and the certificate of completion, is still your responsibility — nobody can carry that for you. And if you're running several tools in parallel, you'll have to consolidate the exports.
As for testing, the discovery demo gives you 7 days of access with no credit card, including 1 image, 1 video, 1 music track and 10 messages — enough to check out the learner experience before committing to anything. The consumer plan starts at €29.90 per month with no commitment, and there's a dedicated offer for training providers. If you're still weighing up your technical foundation, start by comparing the options in the guide to choosing an e-learning platform for your training organization.
Method 2: your current LMS plus an attendance module
If you already host your content on an LMS like Moodle, Chamilo, LearnDash or 360Learning, the evidence often already exists in the activity logs: the work is making it readable.
An LMS records logins, time spent per module and assessment results. Content in SCORM or xAPI format (also called Tin Can) additionally reports completion status and score. Many tools offer an attendance module or plugin that turns those logs into a dated, electronically signed record.
Two settings you shouldn't overlook. Connection time isn't training time: a tab left open for three hours creates false data, and a sharp auditor will spot it. Set up an automatic logout after inactivity — 15 or 30 minutes, for example. Then export as a timestamped PDF rather than an editable CSV: a raw spreadsheet file can be tweaked in two clicks, which weakens its evidentiary value.
Main limitation: raw logs are unreadable for someone discovering your tool. Plan a formatting template, one page per learner, with your organization's name, the title of the training and the session dates.
Method 3: a dedicated electronic attendance tool
Specialized solutions (Edusign, Digiforma, Dendreo, Ypareo and the like) bring what an LMS does badly: a named, timestamped signature, especially for synchronous sequences.
The principle is simple: the learner receives a link or a code by email or text, signs from their phone, and the tool generates a consolidated sheet per session. The signature relies on the European eIDAS regulation, which distinguishes three levels (simple, advanced, qualified). For attendance purposes, a simple electronic signature is accepted in practice as long as you can demonstrate the signer's identity, the exact date and the integrity of the document. The qualified level, which is far more expensive, isn't expected here.
This is the best option for virtual classrooms, group sessions and blended formats. Pricing varies by vendor (per user, per session or as an annual package): check the current rate card, it changes often.
Limitation: this tool proves presence at a given moment, not asynchronous engagement. If your programs are mostly self-paced, it doesn't replace your platform's activity records — it complements them. And without a connector to your LMS, you'll be re-entering sessions by hand.
Method 4: the hand-signed PDF, the minimum viable option
Sending an attendance sheet as a PDF, having it printed, signed, scanned and returned is still possible, but it's the most fragile and most time-consuming method.
It makes sense in one case: low volume, a few sessions a month, with clearly dated synchronous sequences. Beyond that, you'll spend a huge amount of time chasing learners, and the return rate drops fast.
The risks are real. A scanned signature is worth no more than a piece of paper: nothing indicates the actual date of signing, which opens the door to suspicions of backdating. Sheets signed after the fact all at once, all in the same ink and on the same day, are a classic red flag in an audit. And an unprotected PDF is easy to modify.
If you stick with this method, lock down at least three things: one sheet per session and per date, not a monthly summary sheet; a saved email trail for both sending and return (the message timestamp becomes your proof of date); and systematic, consistently named archiving.
Quick comparison of the four methods
| Method | What it proves | Effort per session | Best suited to |
|---|---|---|---|
| Integrated platform (Skilzy) | Logins, progress, assessments, work produced | Almost none, automatic export | Asynchronous programs and high volumes |
| LMS plus attendance module | Logins and completion, signature depending on plugin | Low once configured | Organizations already running an LMS |
| Dedicated attendance tool | Named, timestamped presence | Low, automated sending | Virtual classrooms and synchronous sessions |
| Hand-signed PDF | Declared presence, uncertain date | High, manual chasing | Low volume, occasional stopgap |
The evidence pack: the checklist to build for each learner
A solid file contains seven items per learner, all dated, consistent with each other and unambiguously linked to the same person and the same training action.
- The individualized training protocol, handed over before the start, with the activities, their average duration, the support arrangements and the planned assessments.
- The timestamped activity record: login dates, durations, modules opened and completed.
- Assessment results: initial positioning, intermediate quizzes, final assessment.
- The learner's output: work, deliverables, exercises, screenshots of what they created in a lab or an integrated tool.
- Support traces: emails, in-platform messages, tickets, meeting notes. This is the item most often forgotten, and one of the most closely examined.
- Signed attendance sheets for every synchronous sequence, one sheet per date.
- The certificate of completion sent to the funder, plus the end-of-training attestation given to the learner.
A few rules that save you trouble. Name your files according to a single scheme, for example 2026-03-12_LASTNAME_Firstname_activity-record.pdf: an auditor who can find a document on their own in ten seconds is a reassured auditor. Check that dates line up across the agreement, the activity record and the certificate of completion, because date inconsistencies are the most common cause of non-conformity. Keep everything for at least three years, the length of the certification cycle, bearing in mind that an administrative check can cover earlier periods; many organizations keep five years, with the retention period written into their GDPR records.
The three mistakes that cost you dearly: records generated en masse the day before the audit, connection times that match the advertised durations exactly (nobody completes a 45-minute module in exactly 45 minutes), and an individualized protocol sent after the training has started. On that last point, if you're building your offer from external content, check that the ready-made AI training catalog you're using actually provides average durations per activity: without them, your protocol is incomplete.
Where to start this week
Take a session you finished recently and try to reconstruct the seven items. Whatever you can't find in under ten minutes is exactly what will be missing on audit day. Then choose your method based on how much of your programs are asynchronous: an integrated platform if everything happens self-paced, plus a signature tool as soon as you schedule virtual classrooms. The rest is a matter of habit, not technology.
