The notary system is an important preventive judicial system. After the “de-administrativization” reform， China’s notary institutions have transformed from a single administrative system to a dual-track model where public institution system and cooperative system coexist. Due to the lack of regulation on the civil subject positioning of cooperative notary institutions in the legislation， there are controversies in the understanding of their civil subject attributes across all sectors， which hinders the full play of the functions of cooperative notary institutions and the deepening of mechanism reforms in the notary system. The Civil Code has broken through the traditional legislative model where civil subjects’ independent liability is attached to corporate personality. Under circumstances where laws provide otherwise， members of unincorporated organizations may also bear limited liability. The Notarization Law stipulates that notary institutions shall be established in accordance with the law， operate non-commercially， exercise notarization functions independently， and assume civil liabilities. From the perspective of The Civil Code， the property of cooperative notary institutions is jointly owned by the partners， which does not meet the conditions for the establishment of a legal person and thus lacks legal personality. However， based on the new concept in The Civil Code that separates group personality from members’ limited liability， when amending the Notarization Law， cooperative notary institutions can be regulated as unincorporated organizations in which partners bear responsibilities for the debts of the institutions within the limit of their capital contributions.