Following a public consultation that ran from July 1 to August 12, 2024, the BOSS (Bulletin officiel de la sécurité sociale) was updated on September 25, 2024 to include a new chapter on headcount, devoted to the specific methods for counting headcount in terms of contributions to the financing of vocational training and apprenticeships.
Our expert, Asuncion ROXAN SALMERON, deciphers these new features.
What are the implications of these changes?
These changes have an impact on the various workforce thresholds involved in the liability and/or calculation of the vocational training contribution, the apprenticeship tax (TA) and the supplementary apprenticeship contribution (CSA).
What to include in the workforce
The calculation of the average annual number of contracts promoting professional integration (EMA CSA CFIP) is thus detailed and completed as follows: "The EMA CSA CFIP also includes, for a current one-year period from the first day following At the end of the apprenticeship or professionalization period, alternating employees who have signed an apprenticeship or professionalization contract for an indefinite period which continues with the company after this period".
By way of illustration, BOSS provides the following example (BOSS, Effectif, § 1750):
"Following his apprenticeship contract which ends on September 30, 2022, an individual is hired on an open-ended contract in the same company as of October 5, 2022 (i.e. after the day following the last day of his apprenticeship contract, but within the 7-calendar-day period starting on October 1, 2022).
This individual is included in the CSA CFIP workforce for the period from October 5, 2022 (effective date of his permanent contract) to October 4, 2023 (or 1 year later). "
What to exclude from the workforce
As mentioned above, employees hired on permanent contracts by the company at the end of their professionalization or apprenticeship contract are taken into account in the CSA CFIP EMA, for a period of one year from the first day of the permanent contract.
However, to be taken into account, the open-ended contract must take effect the day after the end of the apprenticeship or professionalization contract. or at the latest within 7 calendar days of the end of the contract.
By way of illustration, BOSS provides the following example (BOSS, Effectif, § 1740):
"Following his apprenticeship contract, which ends on September 30, 2022, an individual is hired on an open-ended contract in the same company on October 15, 2022 (i.e. after the 7-calendar-day period starting on October 1, 2022). This individual is not included in the company's CSA CFIP workforce.