Le 15 novembre 2022, une proposition de loi a été déposée à l’Assemblée nationale demandant la suspension de la création de nouveaux offices notariaux jusqu’au 1er janvier 2024. Le motif évoqué est la crise la crise du coronavirus, qui a profondément marquée la profession en accélérant notamment la disparition d’offices dans certaines zones rurales. Nous décryptons ici ce qui semble être un retour sur le principe de libre installation des notaires.
Vers une révision de l’installation des notaires
Posé par la loi Macron en 2017, le principe de libre installation des notaires a profondément marqué la profession. Avec lui, l’arrivée des « notaires Macron » sur le marché du notariat, a provoqué une hausse significative du nombre d’offices notariaux. En effet, entre 2017 et 2019, la création d’offices a augmenté de 40 %.
Si les professions vivant un tel bouleversement sont rares, il faut avouer cependant, que les conséquences de cette réforme n’ont pas eu que des effets bénéfiques. Car force est de constater que :
- Seule une minorité des offices créés affiche une performance économique satisfaisante ;
- Et, une partie non négligeable des créations ont abouti à des suppressions.
Face à ce bilan plus que mitigé, il apparaît opportun pour le législateur de suspendre temporairement l’installation des nouveaux notaires et d’étaler les prochaines vagues de création d’offices. C’est en ce sens que la proposition de loi déposée mi-novembre à l’Assemblée nationale envisage :
- Une suspension de la création de nouveaux offices notariaux jusqu’au 1er janvier 2024, et ce du fait de la crise sanitaire ;
- La communication, par l’Autorité de la concurrence, de l’avis sur la liberté d’installation aux organisations professionnelles. Le but étant qu’elles puissent formuler des observations en amont de son adoption ;
- Une révision de la carte d’installation tous les 5 ans et non plus tous les 2 ans, comme initialement prévu par la loi Macron.
Les motifs de la proposition de loi sur les mesures d’adaptation de l’installation des notaires
Depuis la loi n° 2015‑990 du 6 août 2015 pour la croissance, l’activité et l’égalité des chances économiques, une partie significative de la réglementation relative au notariat a glissé dans le code de commerce. La profession se voyant, de ce fait, dirigée vers une mise en concurrence, le notariat a vécu un changement de caractère traduit par l’introduction de certains mécanismes. Le marché, l’offre et la demande d’offices, la liberté d’installation ou encore l’introduction d’un degré de flexibilité tarifaire, en sont les principaux rouages.
En gommant un certain nombre de particularismes hérités de longue date, l’objectif poursuivi par cette loi était d’inciter les offices à se rapprocher du droit commun des entreprises. Sans pour autant porter préjudice à la valeur de ses actes notariés et au statut des notaires, cette réforme a placé l’enjeu économique au cœur des offices. La conséquence : une disparition des offices moins efficaces, et bien souvent dans les territoires les plus reclus.
Plus concrètement, la réforme a conduit à une profusion d’offres entre juin 2017 et juin 2019 menant à une augmentation de 40 % du nombre d’offices. Mais également, à une évolution tarifaire plus flexible impliquant des transactions majoritairement moins élevées qu’auparavant.
En parallèle, la réforme a permis de réelles avancées :
- Une forte féminisation de la profession ;
- Un rajeunissement de l’ordre de deux ans en moins de trois ans ;
- L’apparition de nouveaux profils professionnels permettant à la profession de s’ouvrir plus.
Plus largement, la loi a permis de stimuler la capacité d’innovation et d’adaptation des offices notariaux avec une intensification de la démarche qualité, de la déontologie et de la communication. On a vu naître notamment des espaces d’échanges partagés, l’utilisation de la visioconférence et des sites internet dédiés à la profession.
Les effets de la crise sanitaire sur les offices notariaux
Cependant, cinq ans après l’entrée en vigueur de la loi, la crise du coronavirus a accéléré certains effets déjà perçus tels que la disparition d’offices dans certaines zones rurales.
En effet, d’un point de vue économique il est constaté que :
- 10 % des offices réussissant le mieux parviennent difficilement à la médiane des produits des offices ;
- Seuls un quart des offices créés affichent une performance économique satisfaisante ;
- Si un tiers des offices créés paraissent tout à fait viables pour le moment, 40 % ne parviennent pas à décoller ou se trouvent dans un état d’inactivité patente ;
- Une proportion significative de nouveaux offices n’a pas passé le cap des trois années.
Plus précisément, on comptabilise 294 suppressions d’offices sur les 2 161 créés et un nombre important d’offices invisibles, voire à l’état virtuel. Cela fait au total un tiers des créations et dans certaines zones, on atteint 40 % de « taux d’échec ».
Venue s’ajouter à cette conjoncture difficile, la crise sanitaire risque d’aggraver fortement la situation en cas de nouvelle vague d’extension. Son report permettra à l’ensemble des offices nouvellement créés de s’enraciner plus solidement dans leurs territoires respectifs et à la profession de se relever.
C’est pourquoi, l’article 1er de la proposition de loi vise à suspendre la création de nouveaux offices jusqu’au 1er janvier 2024 afin de laisser le temps aux offices récents d’absorber les effets de la crise.
Les mesures d’adaptation de l’installation des notaires visées par l’autorité de la concurrence
Ce faisant, au-delà de la quantité d’office notarial, les prochaines cartes pourront aussi mieux évaluer les zones où le besoin économique se fait le plus sentir. Et ce notamment, à travers l’étude des bassins de vie plutôt que d’emploi, trop incertains actuellement.
C’est dans cet objectif, qu’il est proposé au sein de l’article 2 de la proposition de loi que le prochain avis de l’Autorité de la concurrence puisse se faire avec l’implication des notaires et acteurs de la profession.
En effet, l’Autorité de la concurrence rend tous les deux ans un avis sur la liberté d’installation des notaires au ministre de la Justice. Sans pour autant pouvoir imposer la création d’office dans certains lieux, cet avis comprend une carte qui détermine les zones où l’implantation d’office apparaît utile.
Il apparaîtrait également utile que les notaires et intéressés puissent disposer en amont de cet avis. Le but étant qu’ils puissent y apporter, en toute transparence, des observations utiles pouvant conduire à des installations plus équitables sur le territoire. Dans le dans le respect bien évident de l’autonomie et du pouvoir d’enquête de l’Autorité.
Des vagues de création d’offices plus espacées
Enfin, S’il est vrai que trop peu d’offices ont été créés entre 1960 et 2015, la loi croissance de 2017 a conduit à l’excès contraire. Force est de constater que l’essor de créations d’offices sans précédent, incité par les deux vagues opérées en 2017 puis en 2019, étaient bien trop rapprochées.
Tel est l’objet des articles 3 et 4 de la proposition de loi : étaler les prochaines vagues de création de nouveaux offices tous les cinq ans au lieu de tous les deux ans.
Lancement de la consultation publique sur les modalités d’installation des notaires
Comme le rappelle l’Autorité, en l’état du droit positif, les cartes d’installation des notaires et des commissaires de justice doivent faire l’objet d’une révision dans les deux ans suivant leur adoption.
Comme prévu dans l’article 2 du projet de loi, l’Autorité de la concurrence annonce le lancement de deux consultations publiques en vue de préparer ses avis sur la liberté d’installation des notaires.
Le communiqué du 1er février 2023 précise que, pour mémoire :
Pour les périodes 2016-2018 et 2018-2020, les deux premières cartes relatives aux notaires avaient fixé respectivement, un objectif de nomination de 1 650 et 733 nouveaux notaires dans des offices créés ;
En 2021, l’Autorité avait tenu compte de l’impact, sur le court, moyen et long terme, de la pandémie de Covid-19 sur l’activité des professionnels. Et, c’est pourquoi elle avait décidé d’adopter une approche particulièrement prudente. Elle avait ainsi recommandé d’ici l’été 2023, l’installation libérale de 250 nouveaux notaires.
Les enjeux de la consultation publique
L’Autorité prend soin de rappeler que, comme pour les précédents exercices, l’objectif est de disposer d’un état des lieux le plus précis et objectif possible de la situation économique des notaires. Et tout particulièrement de ceux dont l’office a été récemment créé récemment, afin de formuler ses recommandations au gouvernement.
C’est pourquoi, les consultations porteront sur les thèmes récurrents des consultations publiques :
- l’évaluation de la procédure de nomination ;
- l’impact des créations d’offices sur les différentes parties prenantes ;
- la cohésion territoriale des prestations.
Mais également, d’autres enjeux importants sur lesquels les notaires intéressés sont invités à formuler des observations, notamment :
- les conséquences de la crise sanitaire sur le volume d’activité et l’organisation des offices ;
- les risques pesant sur l’activité des professionnels du fait de la dégradation de la conjoncture économique : ralentissement de la croissance, hausse de l’inflation, durcissement des conditions d’octroi de crédits immobiliers… ;
- l’impact de la réforme de la discipline et de la déontologie des professions du droit ;
- les implications du rapprochement des professions d’huissier de justice et de commissaire-priseur judiciaire.
Les notaires intéressés sont dès à présent invités à répondre aux différentes questions de l’Autorité, et ce, avant le 2 mars 2023. Le questionnaire est accessible sur le site de l’Autorité de la concurrence.
Conclusion
La loi pour la croissance, l’activité et l’égalité des chances économiques du 6 août 2015, appelée "loi Macron", a réformé la profession de notaire. Tout en renouvelant le profil des acteurs de la profession, ces nouvelles mesures ont permis l'installation de près de 700 nouveaux notaires sur la seule année 2019-2020.
Cependant, cinq ans après l’entrée en vigueur de la loi, le bilan est plus que mitigé et la crise du coronavirus a accéléré la disparition d’offices dans certaines zones rurales. Affaiblis d’un point de vue économique, les notaires nouvellement installés ont besoin de temps pour se relever et s’enraciner plus solidement dans leurs territoires respectifs.
C’est en ce sens que le député Pierre Morel a déposé,en novembre dernier, une proposition de loi demandant la suspension de la création de nouveaux offices notariaux jusqu’au 1er janvier 2024.
Ainsi, et pour faire suite à l’article 3 et 4 de la proposition, l’Autorité de la concurrence lance deux consultations publiques en vue d’élaborer deux nouveaux avis sur la liberté d’installation des notaires et des commissaires de justice.
Tous les notaires et acteurs de la profession sont donc invités, avant le 2 mars 2023, à prendre part à ce nouveau tournant dans la vie et l’avenir des offices notariaux.
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