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How do notaries in France and Italy differ from lawyers in common-law countries?

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Wood-paneled courtroom with judge's bench, American and Nevada flags, wooden chairs and tables, and a mounted animal head above the bench in the Esmeralda County courthouse, Goldfield, Nevada. — Court Judge's bench in a courtroom in Nevada, U.S.

In France and Italy, which follow the civil-law tradition, the role of a notary differs significantly from that of a lawyer in common-law countries. While common-law notaries are often limited to authenticating signatures, civil-law notaries are highly trained legal professionals with educational requirements comparable to those of lawyers.1

Key distinctions include:

Legal Practice: Civil-law notaries specialize in areas such as real estate, mortgages, sales, and the settlement of estates. Unlike lawyers in common-law jurisdictions, they are generally prohibited from appearing in court.1
Document Authority: Documents prepared or authenticated by a civil-law notary are admissible in court without further proof of authenticity, as the notary guarantees the identity of the parties and the validity of the facts. In contrast, common-law courts typically do not accept facts certified by a notary as inherently true, and common-law notaries are restricted from drafting legal documents like wills or deeds for a fee, as that is considered the unauthorized practice of law.1
Professional Status: Civil-law notaries act as public officials who preserve evidence, a role distinct from the adversarial responsibilities of lawyers in common-law systems.12