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HR news: what changes from October to December 2026
Five changes affect French employers before the end of the year. Two hit cash flow: the end of OPCO subrogation and the cut in AT-MP daily allowances. The others call for updated processes and HRIS settings. Two more texts are worth following until December: pay transparency and the 2027 budget. A month-by-month review.
October: already in force
Training: the end of OPCO subrogation
Since 1 October 2026, the OPCO (the sector training fund) no longer pays the training provider directly in most cases. The company settles the invoice, then claims reimbursement. The change follows the end of the OPCOs' special VAT regime, after two tax rulings (November 2025 and February 2026). Reimbursement is generally based on the amount excluding VAT: the VAT stays with the company, which deducts it if it is VAT-registered.
There are exceptions: the skills development plan of companies under 50 employees (under conditions) and apprenticeship contracts. Some OPCOs, such as Uniformation or OPCO Santé, are not affected. The reference date (funding agreement issued before or after 1 October) and reimbursement timelines vary from one OPCO to another.
To do: plan for the cash advance, check reimbursement timelines with your OPCO and factor the impact into the 2027 training budget.
The career-path interview
The professional interview becomes the career-path interview under law no. 2025-989 of 24 October 2025, already in force. The first takes place in the year following hiring, then every 4 years. A summary review takes place every 8 years.
Company or industry agreements based on the previous rhythm had to be brought into line before 1 October 2026. Otherwise they lapse.
The penalty remains: in companies with at least 50 employees, if the 8-year review finds that the interviews did not take place and that no non-mandatory training was followed, the employer tops up the employee's training account (CPF) by €3,000.
To do: update interview templates, train managers and set the HRIS to the 1, 4 and 8-year cycle.
Labour court: a simplified procedure
For proceedings started since 1 October 2026, the claim no longer has to include every exhibit. A schedule of documents is enough, with the latest payslip in dispute. Exhibits are handed directly to the other party, at the latest at the conciliation hearing or the trial hearing. Decree no. 2026-683 of 27 July 2026 also changes the procedure for contesting Urssaf enforcement orders: the judgment on the challenge now replaces the enforcement order and is provisionally enforceable.
AI: the "Impulsion IA 2027" plan
The Ministry of Labour presented the plan on 22 September 2026. It has 12 measures and a budget of over 80 million euros. It aims to train employees and support companies as jobs evolve.
November: two changes on 1 November
AT-MP: a sharp cut in the daily allowance ceiling
Decree no. 2026-909 of 30 September 2026, published in the Journal officiel on 1 October, lowers the salary ceiling used to calculate daily allowances for workplace accidents and occupational diseases (AT-MP). It goes from 0.834% to 0.226% of the annual social security ceiling, the equivalent of 1.8 times the minimum wage.
AT-MP daily allowances: before and after 1 November 2026
| Amount | Before 1 November | From 1 November |
|---|---|---|
| Maximum daily salary taken into account | €400.82 | €108.62 |
| Maximum daily allowance, days 1 to 28 | €240.49 | €65.17 |
| Maximum daily allowance, from day 29 | €320.66 | €86.90 |
The rule applies to accidents and occupational diseases occurring from 1 November 2026. Absences linked to an earlier event stay on the previous ceiling.
Consequence: the salary top-up paid by the employer rises for employees above the ceiling. Employees without salary continuation are the most affected (temporary workers, seasonal staff, less than one year of service).
To do: check the AT-MP allowance settings in payroll, subrogation and income-protection cover.
Qualiopi: a 33-indicator framework
Decree no. 2026-728 of 1 August 2026 updates the national quality framework. The 7 criteria remain. The number of indicators goes from 32 to 33. The new indicator 33 concerns apprenticeship only: apprentices must be able to assess course content and teaching, separately from the satisfaction survey.
About a dozen existing indicators are clarified or strengthened, notably on public information, follow-up of remote learners (indicator 19), prevention of violence and harassment (12, 14 and 15) and control of subcontracting (27). Any audit carried out from 1 November 2026 uses the new framework, with no transition period. Two implementing orders and the updated reading guide are still awaited.
Year end: what to watch
Pay transparency
The bill transposing the EU directive was presented to the Council of Ministers on 10 September 2026. The Government aims for a vote by the end of the year.
The text provides in particular for:
- a pay range in every job advert, or given in writing before the interview: "depending on profile" will no longer do;
- a ban on asking candidates about their pay history, including in application questionnaires;
- a right to information: every employee will be able to compare their pay with the average of their job category, and the works council (CSE) and union representatives will be able to question the employer on the indicators;
- the replacement of the gender equality index by seven indicators, including the gender gap by category of jobs of equal value; six of them would be calculated by the Ministry of Labour from payroll declarations (DSN);
- a strengthened penalty regime.
Thresholds, timeline and the format of the indicators will depend on the text as passed and its decrees, and adoption before the presidential election is not guaranteed. The data to prepare is already known: we detail it in our article on pay transparency.
To do: map payroll items and define categories of workers, without waiting for the decrees.
2027 budget: the payroll measures to watch
The 2027 finance and social security financing bills were presented on 1 October 2026. Nothing is voted yet, but four measures directly concern payroll:
- Value-sharing bonus (PPV): in companies under 50 employees, the income tax exemption for employees paid under 3 times the minimum wage would not be renewed after 31 December 2026; the CSG and CRDS exemption would be extended by one year. A bonus decided for 2026 is therefore better paid before year end.
- General contribution relief: profit-sharing, incentive schemes and employer top-ups would enter the base of the general reduction in contributions from 1 January 2027.
- Daily allowances: allowances paid for long-term illness would become 50% taxable, and AT-MP allowances fully taxable.
- Severance pay: the exemption regime would be reviewed, with a single ceiling.
To do: quantify the impact on the 2027 budget, without changing payroll settings before the vote.
The calendar at a glance
The seven deadlines and the teams concerned
| Date | Change | Impact |
|---|---|---|
| 1 October 2026 | End of OPCO subrogation | Cash flow, training budget |
| 1 October 2026 | Career-path interview (1, 4 and 8-year cycle) | HRIS, interview templates, managers |
| 1 October 2026 | Simplified labour court procedure | Legal, payslip archiving |
| 1 November 2026 | Lower AT-MP daily allowance ceiling | Payroll, subrogation, income protection |
| 1 November 2026 | Qualiopi with 33 indicators | Training providers, CFA |
| By end of 2026 | Pay transparency bill | HR data, payroll, HRIS |
| By end of 2026 | 2027 budget (PPV, relief, allowances) | Payroll, 2027 budget |
Frequently asked questions
Who pays the training provider since 1 October 2026?
The company settles the invoice and then claims reimbursement from its OPCO, with exceptions: the skills development plan of companies under 50 employees under conditions, apprenticeship contracts, and some OPCOs such as Uniformation or OPCO Santé. Reimbursement is generally based on the amount excluding VAT; terms and timelines vary from one OPCO to another.
Do we have to redo professional interviews that are already scheduled?
No, but the cycle changes: a career-path interview in the year following hiring, then every 4 years, with a summary review every 8 years. Company or industry agreements based on the previous rhythm had to be brought into line before 1 October 2026; otherwise they lapse.
Which absences are affected by the new AT-MP daily allowance ceiling?
Workplace accidents and occupational diseases occurring from 1 November 2026. Absences linked to an earlier event remain calculated on the previous ceiling, even if they continue after that date.
Does pay transparency already apply?
Not yet: the transposition bill was presented on 10 September 2026 and the Government aims for a vote by the end of the year. The substantive obligations are those of the EU directive; the timeline and format will depend on the text as passed. The HR data, however, can be prepared now.
What to remember
Two cash-flow items to anticipate now, three settings to update, and two texts to follow until December. If you want to check what these changes alter in your payroll or HRIS, let's talk.
Sources: Légifrance (law no. 2025-989, decrees no. 2026-683, 2026-728 and 2026-909), Ministry of Labour, case-law news from the Paris Île-de-France Chamber of Commerce (in French), Centre Inffo and the specialist legal press. This article is an information summary, not legal advice: refer to the texts published in the Journal officiel.
Further reading
- Pay transparency: prepare your HR data before the law.
- Mandatory training: keep the register without spreadsheets.
- Payroll Cockpit: check payroll before paying it.
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