Questions particulières
Le présent chapitre aborde des questions particulières du droit de la fonction publique territoriale. Il a vocation à évoluer et présenter d’autres questions qui se posent souvent aux agents et collectivités. Deux questions y figurent à ce jour : le recrutement d’un agent contractuel et le cumul d’activités des fonctionnaires.
Le recrutement d’un agent contractuel
Depuis le décret n° 2015-1912 du 29 décembre 2015 portant diverses dispositions relatives aux agents contractuels de la fonction publique territoriale, les agents publics qui ne sont pas fonctionnaires ne sont plus désignés dans le Décret n°88-145 du 15 février 1988 relatif aux agents contractuels de la fonction publique territoriale, comme « non titulaires » mais comme des « agents contractuels ». Un premier pas vraisemblablement avant une substitution généralisée dans les autres textes…
Les agents des services publics des collectivités (et de l’Etat) sont en principe recrutés par concours qui leur confère après une nomination dans un grade et une période de stage la qualité de fonctionnaire.
Par exceptions, des agents contractuels, c’est-à-dire des agents non fonctionnaires et donc non titulaires, peuvent être recrutés dans certains cas.
Les conditions de recrutement d’un agent contractuel sont très encadrées par les articles 3 et suivants de la loi du 26 janvier 1984 modifiée par la loi du 12 mars 2012.
Voici les principaux cas où un contractuel peut être recruté.
- Besoins temporaires
Le recrutement d’un contractuel pour des besoins temporaires est possible dans des conditions précises tant sur un emploi temporaire que sur un emploi permanent.
Besoin temporaire sur emploi temporaire (art.3) :
Pour faire face à un accroissement temporaire (durée des contrats : 12 mois maximum sur une durée de 18 mois consécutifs) ou saisonnier d’activité (durée des contrats : 6 mois maximum sur 12 mois consécutifs)
Besoin temporaire sur emploi permanent (art. 3-1 et 3-2) :
– Pour remplacer momentanément un fonctionnaire ou un agent non titulaire (temps partiel, congé de maladie, congé de maternité, congé parental, congé de présence parentale, accomplissement du service civil ou national, participation à des activités de réserve, rappel ou maintien sous les drapeaux.) ;
– Pour faire face à une vacance temporaire d’emploi dans l’attente du recrutement d’un fonctionnaire.
Ce type de contrat est conclu pour une durée déterminée qui ne peut excéder un an. Cette durée peut être prolongée dans la limite d’une durée totale de deux ans lorsque, au terme de la 1èreannée, la procédure pour recruter un fonctionnaire n’a pas abouti.
- Emplois permanents occupés de façon permanente
En application de l’article 3-3 de la loi 1984 modifiée par la loi de 2012, il est possible de recruter des agents par contrat à durée déterminée d’une durée maximale de trois ans. Ces contrats sont renouvelables par reconduction expresse, dans la limite d’une durée maximale de six ans. Si, à l’issue de cette durée, ces contrats sont reconduits, ils ne peuvent l’être que par décision expresse et pour une durée indéterminée.
Petites collectivités
Dans les cas suivants prévus par l’article 3-3 3° et suivants :
-3° Pour les emplois de secrétaire de mairie des communes de moins de 1 000 habitants et de secrétaire des groupements composés de communes dont la population moyenne est inférieure à ce seuil ;
-4° Pour les emplois à temps non complet des communes de moins de 1 000 habitants et des groupements composés de communes dont la population moyenne est inférieure à ce seuil, lorsque la quotité de temps de travail est inférieure à 50 % ;
-5° Pour les emplois des communes de moins de 2 000 habitants et des groupements de communes de moins de 10 000 habitants dont la création ou la suppression dépend de la décision d’une autorité qui s’impose à la collectivité ou à l’établissement en matière de création, de changement de périmètre ou de suppression d’un service public.
Absence de fonctionnaires (art. 3-3)
1° Lorsqu’il n’existe pas de cadre d’emplois de fonctionnaires susceptibles d’assurer les fonctions correspondantes. Le recrutement en cas d’absence de corps de fonctionnaires pour assurer les fonctions recherchées s’applique aux emplois des catégories A, B et C.
2°Pour les emplois du niveau de la catégorie A lorsque les besoins des services ou la nature des fonctions le justifient et sous réserve qu’aucun fonctionnaire n’ait pu être recruté dans les conditions prévues par la présente loi.
- Les autres cas de recrutement prévus par la loi
- le recrutement des personnes reconnues travailleurs handicapés (article 38)
- le recrutement d’agents non titulaires sur certains emplois de direction des collectivités territoriales et des établissements publics locaux les plus importants (article 47)
- le recrutement de collaborateurs de cabinet des autorités territoriales (article 110)
- le recrutement de collaborateurs de groupes d’élus (article 110-1)
Comme le fonctionnaire, l’agent contractuel doit remplir un certain nombre de conditions générales pour pouvoir être recruté. Ces conditions sont prévues par l’article 2 du décret n° 88-145 du 15 février 1988 (aptitude physique, respect des règles relatives à l’entrée et au séjour des étrangers, droits civiques, casier judiciaire, limite d’âge).
Le cumul d’activités
En vertu de l’article 25 de la loi du 13 juillet un fonctionnaire ou un agent contractuel doit consacrer l’intégralité de son activité professionnelle à son emploi dans la fonction publique. Ce principe qui constitue l’une des obligations statutaires incombant à l’agent vise à le dissuader de négliger son service et à le protéger d’intérêts extérieurs qui pourraient nuire à son indépendance. Toutefois, il peut être autorisé, sous certaines conditions à exercer d’autres activités (lucratives ou non) à titre accessoire.
Textes de références :
– Loi n° 93-122 du 29 janvier 1993 modifiée relative à la prévention de la corruption et à la transparence de la vie économique et des procédures publiques
– Loi n° 2007-148 de modernisation de la fonction publique du 2 février 2007
– Décret n° 2007-658 du 2 mai 2007 relatif au cumul d’activités des fonctionnaires
– Décret n° 2007-611 du 26 avril 2007 relatif à l’exercice d’activités privées par des fonctionnaires ou des agents non titulaires ayant cessé temporairement ou définitivement leurs fonctions et à la Commission de Déontologie.
– Loi n° 2009-972 du 3 août 2009 relative à la mobilité et aux parcours professionnels dans la fonction publique
– Décret n° 2011-82 du 20 janvier 2011 modifiant le décret n° 2007-658 du 2 mai 2007 relatif au cumul d’activités des fonctionnaires.
Les modifications introduites par ce décret sont signalées en ROUGE dans la présente note.
– Circulaire ministérielle n°2157 du 11 mars 2008 relative au cumul d’activités.
– Article 432-13 du Code pénal sur la prise illégale d’intérêts commise par des personnes exerçant une fonction publique et applicable aux agents des établissements publics.
- Le principe d’interdiction
Les activités privées suivantes sont interdites, y compris si elles sont à but non lucratif :
« 1° La participation aux organes de direction de sociétés ou d’associations ne satisfaisant pas aux conditions fixées au b du 1° du 7 de l’article 261du code général des impôts ;
2° Le fait de donner des consultations, de procéder à des expertises et de plaider en justice dans les litiges intéressant toute personne publique, le cas échéant devant une juridiction étrangère ou internationale, sauf si cette prestation s’exerce au profit d’une personne publique ;
3° La prise, par eux-mêmes ou par personnes interposées, dans une entreprise soumise au contrôle de l’administration à laquelle ils appartiennent ou en relation avec cette dernière, d’intérêts de nature à compromettre leur indépendance. »
- Les dérogations possibles
Des dérogations sont toutefois possibles pour exercer certaines activités, soit après autorisation, soit librement.
2.1- Dérogations sur demande d’autorisation
Le dernier alinéa du I de l’article 25 de la loi précitée dispose que :
« les fonctionnaires et agents non titulaires de droit public peuvent toutefois être autorisés à exercer, dans des conditions fixées par décret en Conseil d’Etat, à titre accessoire, une activité, lucrative ou non, auprès d’une personne ou d’un organisme public ou privé, dès lors que cette activité est compatible avec les fonctions qui leur sont confiées et n’affecte pas leur exercice. »
L’article 1er du Décret 2011-82 du 20 janvier 2011 précise : « sous réserve que cette activité ne porte pas atteinte au fonctionnement normal, à l’indépendance ou à la neutralité du service… Un même agent peut être autorisé à exercer plusieurs activités accessoires. «
Les activités accessoires susceptibles d’être autorisées aux termes de l’article 2 du Décret précité sont les suivantes :
« I…1° Expertise et consultation, sans préjudice des dispositions du 2° du I de l’article 25 de la loi du 13 juillet 1983 susvisée et, le cas échéant, sans préjudice des dispositions des articles L. 413-8 et suivants du code de la recherche ;
« 2° Enseignement et formation ;
« 3° Activité à caractère sportif ou culturel, y compris encadrement et animation dans les domaines sportif, culturel, ou de l’éducation populaire ;
« 4° Activité agricole au sens du premier alinéa de l’article L. 311-1 du code rural dans des exploitations agricoles non constituées sous forme sociale, ainsi qu’une activité exercée dans des exploitations constituées sous forme de société civile ou commerciale ;
« 5° Activité de conjoint collaborateur au sein d’une entreprise artisanale, commerciale ou libérale mentionnée à l’article R. 121-1 du code de commerce ;
« 6° Aide à domicile à un ascendant, à un descendant, à son conjoint, à son partenaire lié par un pacte civil de solidarité ou à son concubin, permettant au fonctionnaire, à l’agent non titulaire de droit public ou à l’ouvrier d’un établissement industriel de l’Etat de percevoir, le cas échéant, les allocations afférentes à cette aide ;
« 7° Travaux de faible importance réalisés chez des particuliers.
« II. ― Dans les conditions prévues à l’article 1er du présent décret et à l’article L. 133-6-8 du code de la sécurité sociale, outre les activités mentionnées au 1°, au 2°, au 3° et au 7° du I, et sans préjudice des dispositions de la loi du 13 juillet 1983 susvisée :
« 1° Services à la personne ;
« 2° Vente de biens fabriqués personnellement par l’agent. »
Ces deux dernières activités sont obligatoirement exercées sous le régime « auto-entrepreneur », tandis que les 1°, 2°, 3° et 7° du I le sont éventuellement. Les autres ne peuvent pas être exercées sous ce régime.
La demande doit être formulée auprès de l’administration dont dépend l’agent. Elle doit préciser :
- l’identité de l’employeur ou la nature de l’organisme pour le compte duquel l’activité sera exercée,
- la nature, la durée, la périodicité et les conditions de rémunération de cette activité,
- si nécessaire, toute autre information.
L’administration dispose d’un mois pour répondre (2 mois en cas de demande d’information complémentaire) après avis préalable de la Commission administrative paritaire. Si l’administration n’a pas répondu dans le délai d’un mois (ou 2 mois), la demande est acceptée. L’autorisation est sans limite de temps.
Toutefois, L’administration peut s’opposer à tout moment à la poursuite d’une activité qu’elle a autorisée :
- si l’intérêt du service le justifie,
- ou si les informations sur la base desquelles l’autorisation a été accordée sont erronées,
- ou si l’activité ne revêt plus un caractère accessoire.
A noter que tout changement substantiel dans les conditions d’exercice ou de rémunération de l’activité est assimilé à l’exercice d’une nouvelle activité. L’agent doit alors demander une nouvelle autorisation. Naturellement l’activité accessoire doit être exercée en dehors des heures de service de l’intéressé.
Cas particuliers
La création ou reprise d’entreprise
En application du II 1° de l’article 25 de la loi de 1983, un agent qui crée ou reprend une entreprise peut être autorisé à cumuler sa nouvelle activité privée lucrative avec son emploi public pendant 2 ans, renouvelable 1 an.
Pendant la période de cumul, l’agent peut aussi bénéficier d’une autorisation de travail à temps partiel au moins égale à un mi-temps.
L’agent doit déclarer son projet à son administration qui soumet la déclaration à la commission de déontologie l’article 87 de la loi n° 93-122 du 29 janvier 1993 relative à la prévention de la corruption et à la transparence de la vie économique et des procédures publiques
Le dirigeant d’entreprise ou d’association
Qu’il soit lauréat d’un concours ou recruté en tant qu’agent public, il peut, après déclaration à l’autorité dont il relève pour l’exercice de ses fonctions, continuer à exercer son activité privée. Cette dérogation est ouverte pendant une durée maximale d’un an à compter du recrutement de l’intéressé et peut être prolongée pour une durée maximale d’un an. Sa déclaration est au préalable soumise à l’examen de la commission de déontologie précitée.
2.2 Dérogations sans demande d’autorisation
Les activités suivantes peuvent être exercées librement sans demande préalable d’autorisation (III &IV de l’art 25 loi 1983)
– Toute activité (conditions et limites fixées part décret en Conseil d’Etat) lorsque l’agent occupe un emploi à temps non complet, inférieur ou égale à 70% de la durée légale
– Détenir des parts sociales, et percevoir les bénéfices qui s’y rapportent
– Gérer son patrimoine
– Produire des œuvres de l’esprit (livres, articles….) dans le respect du devoir de discrétion.
– Exercer une profession libérale du personnel enseignant, technique ou scientifique des établissements d’enseignement exerçant des activités à caractère artistique
- Sanctions
Toute violation de l’article 25 donne lieu au reversement des sommes indûment perçues, par voie de retenue sur le traitement sans préjudice de l’application de l’article 432-12 du code pénal relatif à la prise illégale d’intérêts.
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