Chamber's case numbers fluctuate yearly

Fifteen years after its creation in 2011, the National Disciplinary Chamber of the Nursing Order is now well established. Since 2016, when the first statistical data became available, its activity has continued to increase, with a growth since 2020 in the number of complaints filed. Counselor of State and president of the Chamber, Christophe Eoche-Duval, outlined the years: 178 cases recorded in 2021, 126 in 2022, 136 in 2023, 85 in 2024, but this is a false decrease since we are back to 134 in 2025. He noted that statistical elements for 2026 are not yet available but expects the figure to exceed that of 2025.

Chamber handles growing workload with new staff

Before the professional press on Wednesday, October 7, he defended the performance of the chamber, which is facing a rapid increase in its activity and had to deal with a temporary lack of staff. He explained that the dynamic goes hand in hand with the decisions rendered, which accelerated after 2023 and the arrival of a second president of the Chamber, Frédéric Dieu, and additional clerks. Thus, 106 judgments were rendered in 2024, and 104 in 2025, with an increase expected for 2026, reaching 120 according to his estimates. This trend is explained in part by the fact that the Nursing Order, although still young as it has only 20 years, covers the health profession with the largest number of staff, namely nearly 600,000 professionals registered on its roll.

Complainants are mostly nurses but their share is decreasing

The figures for the year 2025 show that the appellants are still mostly nurses, although their share tends to decrease between 2024 and 2025. They represented 59% of the appellants in 2024, against 37% in 2025. Next come patients and the Departmental Councils of the Order, at 14% respectively, then the joint complaints filed by nurses and the Departmental Councils (12%), and those filed by patients and the Councils (8%). Few other health professionals are bringing cases before the Nursing Order Chamber, with doctors, sometimes employees of clinics or EHPADs, filing complaints, though litigation does not necessarily develop.

Sanctions and rejections show a shift in the chamber's decisions

As for the sanctions pronounced, warnings come first (22%, against 11% in 2024), followed by the prohibitions to practice entirely or accompanied by a suspension (12%, against 6% in 2024), then the reprimands and prohibitions or partial practice accompanied by a suspension of less than or equal to 3 months (11% each, stable compared to the previous year). Rejections of appeals represent the largest part of the decisions rendered, even though they are decreasing; from 46% in 2024, they now weigh only 27% in 2025. In these cases, "we recognize the existence of a breach but we do not pronounce a sanction." The number of expulsions, although very minor, has increased, going from 1% in 2024 to 4% in 2025. This increase is explained by the arrival in appeal of cases related to the pandemic, notably to attempts to fraud the health passes, which result in much more severe sanctions.

Most appeals come from those who received initial sanctions

The complainants rarely appeal the decisions rendered in the first instance. Therefore, 95% of the appeals come from the accused condemned in the first instance, who sometimes have everything to gain by appealing to the national chamber for a simple reason: if it can reform the first instance judgment, "the appellate judge cannot aggravate the sanction of the appellant. It is an element of jurisdictional justice."

Self-employed nurses dominate complaints

The self-employed nurses are still massively represented. The complaints, whether they come from other professionals, the Order, or patients, concern in the vast majority of cases self-employed nurses. There are cases of patients who complain about a salaried nurse, who works in an EHPAD, for example. But it is extremely rare that patients file a complaint against hospital nurses. This is due to the nature of the practice. Because these nurses are part of the public service, patients cannot directly act on the Order, but must first go through the establishment, the Regional Health Agency (ARS) to which it belongs, the Ministry of Health... A path that discourages from the start.

Chamber sees rise in judicialization of disputes

In most cases, it is self-employed nurses who bring a professional ethical dispute against other self-employed nurses. "This imbalance is not desirable in the long term," warns Christophe Eoche-Duval. "Interprofessional conflicts should be better dealt with in advance, especially at the stage of mediation. It is a failure to go all the way to ordinary justice." And it is the other lesson - which is not so new, this one - from this 2025 balance. The Chamber thus witnesses a judicialization of cases, driven by the increasingly widespread knowledge that patients and nurses have of the existence of the jurisdiction and its role, which can also be prejudicial to professionals. "We do not rejoice at this judicialization phenomenon, but we cannot do anything about it. We have the duty to deal with these cases. We sometimes have patients who want to turn into an ordinary dispute what, in the past, was simply the desire to change practitioner."

Many cases involve conflicts between nurses

A third of the cases concern conflicts between nurses. In June 2025, the president of the National Disciplinary Chamber was already worried about this judicialization, which particularly affects the contractual relationships between professionals. "We cannot consider that a supposed contractual fault, simply alleged," he reminded at the time, "necessarily entails a professional misconduct. However, if the disciplinary chamber deals with the latter, it is not competent for the former, which is the subject of the civil judge."

2025 marks notable disciplinary cases

"We counted 39% of requests concerning contracts in 2024, and we are down to 13% in 2025. Those concerning brotherhood represent 23% of the requests. If we add the two, we arrive at a third of the cases that concern conflicts between nurses. My wish is to see it decrease." These 2025 cases that set a precedent. "Rare case," a hospital nurse was expelled in March 2025 for diverting opioid medications for her personal use. The sanction is indeed radical, but "the National Nursing Order fights against the use of narcotics in the professional environment. And on this issue, we will not tolerate that the National Disciplinary Chamber show tolerance," justifies Christophe Eoche-Duval. The nurse had filed a petition with the Court of Cassation, which rejected it. In July 2025, the jurisdiction condemned a nurse to a temporary ban on practicing for 3 years for having provided 94 fake health passes during the pandemic of Covid-19. The year 2025 is marked by the arrival before the Chamber of several cases related to the management of the pandemic. The nurse had been condemned in the first instance to expulsion, but the Chamber reformed the decision. The National Chamber can now judge nurses who were not registered with the Order at the time of the facts for which they are accused. In October 2025, it judged a hospital nurse for misconduct, although this nurse was not registered on the Order's roll and should therefore have been outside its jurisdiction. Most of the unregistered professionals are indeed either employees or work in hospitals. "There was therefore a form of injustice for the complainants, who could not go through with their complaint," explains Christophe Eoche-Duval. "With this decision, we have recognized our competence. And we will maintain the jurisprudence as long as it is not overturned by the Council of State." However, it does not apply retroactively.