How Clinics and FOP Doctors Register in eHealth (ESOZ) and What to Enter Without an NHSU Contract

The Electronic Healthcare System of Ukraine (eHealth, ESOZ) is a government system for recording and managing medical data previously stored in paper patient records and doctors’ documents. It allows healthcare providers to keep electronic records of appointments, issue e-prescriptions and referrals, and interact with the National Health Service of Ukraine (NHSU).

The Licensing Conditions for Conducting Medical Practice as a Business Activity, approved by Cabinet of Ministers of Ukraine Resolution No. 285 of March 2, 2016, require everyone who holds a medical practice license to register in eHealth and use it to enter the information required by law (subparas. 30 and 31 of para. 13). Having an NHSU contract does not affect this obligation.

This article is for healthcare facilities and FOP doctors (doctors registered as sole proprietors). Patients access eHealth differently: through a personal patient account in the system itself, a medical information system (MIS), or Diia. That is a separate procedure, which we do not cover here.

Below, we explain the registration requirements and steps, what a facility without an NHSU contract must enter in the system, and the most common registration pitfalls.

Why You Must Register and Enter Data in eHealth

Both healthcare facilities and FOP doctors who provide services individually must register in the electronic healthcare system. This is a mandatory requirement for lawful medical practice, whether the facility participates in the state’s Medical Guarantees Program or provides only private services.

Registration in eHealth is necessary for:

• Lawful operation. The Licensing Conditions require all healthcare facilities and FOP doctors to use eHealth.

• Working with the NHSU. Facilities planning to participate in the Medical Guarantees Program and receive NHSU payments must register in eHealth. Without registration, they cannot enter into an NHSU contract or receive payment for services under state programs. Our step-by-step guide explains how to enter into an NHSU contract.

• Keeping electronic medical records. Medical records entered in eHealth constitute primary medical records in electronic form. This simplifies maintaining medical histories, prescribing treatment, and communication between doctors.

• Monitoring the quality of medical services. Data in the system is protected and accessible only to authorized users, preventing unauthorized changes.

• Sharing medical information between facilities. Doctors at different facilities can view patient information, which is important for comprehensive treatment, consultations, and coordinating treatment plans.

Related reading: eHealth Registration: Benefits of Connecting to the Electronic Healthcare System

How the Electronic Healthcare System Works

eHealth is a government IT system for healthcare that supports digital medical records and interaction between doctors, facilities, and patients. This shared medical data environment consists of two components:

• Central database (CDB)—stores electronic medical records and information about doctors, facilities, patients, prescriptions, referrals, and more.

• Medical information system (MIS)—software that healthcare professionals use to work with the central database by entering and updating data.

How Does eHealth Work in Practice?

• A healthcare facility or FOP doctor enters into a contract with the operator of an MIS connected to the central database and uses that MIS to access the system.

• Data about patients, services, prescriptions, and referrals is entered through the MIS.

• The information is transmitted to the central database and becomes available to other authorized users.

• Patients can view their medical records online.

How to Choose an MIS for eHealth

When choosing an MIS, focus first on what it enables your particular facility to do. Check whether it is connected to the central database and has passed testing for the functions you need: e-prescriptions, medical certificates of temporary incapacity for work, referrals, and equipment records. Testing statuses are published on the eHealth website.

Also find out how the operator trains and supports users and what terms apply to data exports if you ever decide to switch systems.

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eHealth Registration Requirements: Information, Documents, and Technical Requirements

The registration conditions are the same for healthcare facilities and FOP doctors: you must meet certain requirements and prepare the following information.

1. Facility Information

• Full facility name—the system retrieves it from the Unified State Register (USR), so it must match the registration details.

• EDRPOU code (for legal entities) or taxpayer identification number (RNOKPP, for sole proprietors).

• Registered address (also retrieved from the USR) and actual address, which must match the licensing information.

• Contact details: phone number and email address.

2. Valid Medical Practice License

• You cannot register in the system without a valid license.

• The facility head enters the license details (number, issue date, type of activity, and licensing authority), which the NHSU checks during verification.

3. Active Email Address

• Provide a working email address: confirmations and important notifications will be sent there.

4. Qualified Electronic Signature (QES)

• The facility head’s or FOP doctor’s QES is used to sign the registration request. An advanced electronic signature based on a qualified certificate is also acceptable.

Everyone who will enter records or sign prescriptions, referrals, and certificates also needs their own QES: doctors, nurses, and the authorized person who registers staff. One signature cannot serve the entire facility.

Information may be entered in eHealth only using a qualified signature (part 7 of Article 24-2 of the Fundamentals of the Legislation of Ukraine on Healthcare). Each record is linked to the employee who created it, and private keys must not be shared (Article 12 of the Law of Ukraine “On Electronic Identification and Electronic Trust Services”).

Employees obtain a qualified signature in their own name from any qualified electronic trust service provider. The central certification authority maintains the list of these providers (the Trusted List). Providers include the tax service and banks.

Registering a Private Healthcare Facility in eHealth

Connecting to eHealth and registering in it take place through your chosen MIS, rather than on a separate system website. The procedure consists of the following steps:

1. Review the list of available MIS platforms integrated with eHealth, choose the one that best suits your facility’s needs, and enter into a contract with its operator.

2. In the MIS registration section, enter information about the facility, its valid license, service locations, and current email address, then sign the request using the facility head’s QES (a FOP doctor uses their own).

3. After submission, the system automatically checks your information against the USR, and the NHSU then reviews it. If there are errors, you will receive guidance on what to correct.

4. An email with a link to confirm the facility head’s account will arrive at the address provided. Follow the link and set a password to access the system.

5. Register an authorized person (an administrator, HR officer, or other employee) who will enter staff information, then enter details of all the facility’s organizational units and each healthcare professional who will use eHealth.

While the NHSU checks the data (a process called verification in eHealth and MIS documentation), the facility’s record has “suspended” status. Registration is complete when its status becomes “active”: only then can facility employees use the system’s functions (para. 15 of the Procedure for Maintaining the Register of Healthcare Business Entities, approved by Ministry of Health of Ukraine (MOH) Order No. 2243 of October 18, 2021).

The regulations do not set a specific deadline for this verification: the time required depends on the NHSU’s review and whether corrections are needed. In our cases, NHSU verification took between two business days and a week, and longer when data needed correction. This is not a guaranteed timeframe.

How a FOP Doctor Can Register in eHealth

A doctor who works at a public facility and also runs a private practice must register separately in eHealth as a FOP doctor. Although they already have a profile through the public facility, their private practice requires a new record. This keeps work at different facilities separate and ensures that electronic documentation is maintained correctly.

Using eHealth in Ukraine for doctors registered as sole proprietors is mandatory even if they see patients alone, without employees. A sole proprietor’s eHealth registration begins with registration as a business entity, using their own QES to sign the request. For eHealth purposes, the sole proprietor acts as the facility head, so there is no need to appoint themselves separately as an authorized person.

The next step is registration as a doctor in eHealth: to keep records and issue prescriptions, the sole proprietor must also enter themselves in the system as a doctor. No license changes are needed for eHealth registration in Ukraine, but the service location address in the system must match the licensing information.

Related reading: Licensing for Dental Technicians and eHealth Registration: Legal Assistance

What to Enter in eHealth Without an NHSU Contract

Every licensee must use eHealth, regardless of whether they have an NHSU contract. Using eHealth without an NHSU contract means fewer mandatory records, but registration, up-to-date facility and staff information, e-prescriptions, and medical certificates are required for all providers that issue them.

Each row is explained in detail below.

Why an NHSU Contract Does Not Exempt You from Using eHealth

The obligation arises from the license, rather than the contract. The Licensing Conditions require every licensee to register in the Register of Healthcare Business Entities and use eHealth to the extent required by law (subparas. 30 and 31 of para. 13).

An NHSU contract adds its own data requirements. Without one, the basic requirements still apply. We explain what they cover below.

Facility, Service Location, and Staff Information: Who Enters It and When

This is the foundation: until the facility and its staff are entered in the system, none of its doctors can create any records. The following facility information must be entered:

• registration details and information about the facility head (the system retrieves the name and registered address from the USR);

• licenses and accreditation, if any;

• each medical service location, including its address, contact details, opening hours, and an indication of a valid license;

• medical services at each location: specialty, outpatient or inpatient setting, and schedule;

• authorized persons and every healthcare professional who will enter records.

The facility head handles the initial registration of the facility and authorized persons; a FOP doctor does this themselves (para. 32 of the Procedure for the Operation of the Electronic Healthcare System, approved by Cabinet of Ministers of Ukraine Resolution No. 411 of April 25, 2018). The facility’s authorized person enters healthcare professionals in the registers (para. 43).

There is no separate procedure for nurses: they are registered in the same way as doctors. A healthcare professional may also register themselves in the system (para. 44), but the authorized person must enter them as an employee of your particular facility.

Data must be current and accurate (para. 48 of Procedure No. 411). When an address, opening hours, or license changes, or a unit opens or closes, the facility head must update the register within 3 business days of the change (para. 16 of Procedure No. 2243).

If information submitted for licensing changes, such as the address, staff, or facilities and equipment, the MOH must be notified within one month (subpara. 10 of para. 13 of the Licensing Conditions). These obligations apply in parallel: the 3-business-day period for eHealth runs from the change itself, rather than from notification of the MOH. The facility head must revoke system access for an employee who leaves (subpara. 4 of para. 42 of Procedure No. 411); doing so on the employee’s last day is convenient.

After the facility’s registration details are updated, its record returns to “suspended” status until the NHSU verifies the data (para. 15 of Procedure No. 2243). During this period, facility employees can only view and correct the information specified in that paragraph: they cannot, for example, create an e-prescription. Changes should therefore be prepared in advance and entered accurately, but this does not justify delaying a mandatory update.

Which Medical Records, Prescriptions, Referrals, and Certificates to Enter Without a Contract

This is where the difference from facilities with a contract is greatest. MOH Order No. 587 of February 28, 2020 requires providers with an NHSU contract, as well as facilities and sole proprietors required to provide care free of charge under a law or contract, to enter medical records for all appointments, admissions, and discharges in eHealth (para. 4).

A private facility without a contract or such an obligation primarily needs the system for documents that, as a general rule, exist only electronically. If your doctors perform the relevant work, the following must be entered in eHealth:

• e-prescriptions for prescription medicines purchased by patients at their own expense and medicines under the reimbursement program (paras. 5–6 of Section I of the Rules for Issuing Prescriptions for Medicines, approved by MOH Order No. 360 of July 19, 2005);

• medical certificates of temporary incapacity for work, if the facility’s doctors assess temporary incapacity for work: these certificates are created in eHealth (MOH Order No. 1066 of June 1, 2021), while paper sick leave certificates are issued only in cases expressly specified in that Order;

• medical birth certificates, if the facility or sole proprietor holds a license in the specialty of obstetrics and gynecology and provides childbirth services (MOH Order No. 2136 of September 18, 2020);

• requests for medical devices reimbursed under the Medical Guarantees Program and for assistive rehabilitation devices on the MOH list (subpara. 5 of para. 4 of Order No. 587);

• medical records underlying these prescriptions, certificates, and requests: a prescription or certificate is created from a record of an examination, consultation, or treatment, so that record must also be in the system.

Paper prescriptions are allowed only in specified cases: during a technical outage, with the patient’s consent; and during martial law, at the patient’s choice, for medicines that are not reimbursed (except narcotic and psychotropic medicines).

Medical records, referrals, and prescriptions must be entered on the day the service is provided, or, if care was provided away from the practice location, no later than the next business day (para. 19 of the Procedure for Maintaining the Register of Medical Records, Referral Records, and Prescriptions, approved by Order No. 587).

Special rules for a particular service may also impose specific obligations, so you should check those relevant to your facility’s services. If a law or contract requires the facility to provide care free of charge, entering medical records in eHealth is mandatory (subpara. 2 of para. 4 of Order No. 587).

A facility without a contract that is not required to provide care free of charge may issue referrals on paper or electronically and, at the patient’s request, enter them in eHealth (para. 8 of Section II of the Procedure for Patient Referrals, approved by MOH Order No. 586 of February 28, 2020, as revised by MOH Order No. 968 of July 15, 2026).

If your MIS supports it, we recommend electronic referrals: the facility receiving the patient checks the referral in the system and immediately confirms whether it can provide the service under the Medical Guarantees Program (para. 1 of Section III).

A referral is not required, in particular, for primary care, outpatient appointments with an obstetrician-gynecologist, psychiatrist, addiction specialist, dentist, pediatrician, or tuberculosis specialist, or for HIV counseling and testing (para. 4 of Section I).

The facility may choose to enter other medical records in eHealth, and these also constitute primary medical records in electronic form (para. 11 of the Procedure for Maintaining the Register of Medical Records). Registration in eHealth does not in itself eliminate primary medical documentation requirements: the rules for each document determine whether a paper form is needed, and there is no general obligation to duplicate all electronic records on paper (MOH Order No. 110 of February 14, 2012).

Must Medical Equipment Be Entered Without an NHSU Contract?

Yes. Facilities without a contract must also enter equipment: this obligation is established in the Procedure for Maintaining the Register of Healthcare Business Entities, which covers all licensees. Existing equipment included in the list approved by MOH Order No. 697 of April 22, 2025 must be registered.

There is no separate date for facilities without a contract: the requirement applies from the date that Order took effect, and changes must likewise be entered within 3 business days. Our article “Registration and Recordkeeping for Medical Equipment in eHealth” explains which equipment and details must be entered.

What Is Optional Without an NHSU Contract?

Some eHealth functions support participation in the Medical Guarantees Program. Without a contract, you are not required to:

• enter into declarations with patients on the choice of a doctor providing primary care;

• enter medical records for every appointment unless a law or contract requires you to provide care free of charge (as discussed above);

• generate electronic reports for the NHSU or perform actions relating to a Medical Guarantees Program contract.

Whether to enter into an NHSU contract is a separate decision for the facility: registration in eHealth does not require it.

What Happens If Data Is Missing or Inaccurate?

The law does not establish a separate fine specifically for a facility’s failure to enter data in eHealth or for entering inaccurate data. This is a violation of the Licensing Conditions, and the consequences are governed by the Law of Ukraine “On Licensing of Types of Economic Activity”. They escalate in stages:

• if an inspection identifies a violation of the Licensing Conditions, the MOH issues an order to remedy it (part 7 of Article 19);

• if the order is not complied with and this is documented in an inspection report, the license may be suspended until the grounds for suspension are remedied, but for no longer than two months (para. 2 of part 2 and part 6 of Article 16);

• if the facility violates the same requirements again within a year after the order, this constitutes grounds for terminating the license (para. 6 of part 12 of Article 16).

These are not automatic consequences of every error in eHealth, but steps taken following an inspection.

A separate rule applies to false data: if a user systematically enters false information in the system, the NHSU or the technical administrator may temporarily suspend their access (para. 29 of Procedure No. 411). Without access, a doctor cannot create an e-prescription or a medical certificate of temporary incapacity for work, and paper documents are permitted only in the cases specified in the rules for each document.

Common Difficulties with eHealth Registration

Registration of a FOP doctor or healthcare facility in eHealth may be delayed or even denied. The most common reasons are:

• Errors in registration information: an incorrect license number or mistakes in a last name, first name, or address.

• Discrepancies between the data entered and the information in registers (the USR, the MOH register of licensees, and others).

• Missing required information, which may lead to registration being denied.

• No license for certain services, or a license that does not cover them.

• A need for additional confirmation of the FOP doctor’s or healthcare facility’s status.

• A service location address in the request that does not match the licensing information: for example, the facility has moved, but the changes have not yet been entered.

• A facility registration request signed by someone other than its head, or a FOP doctor’s request signed by someone other than the sole proprietor themselves.

To avoid these issues, carefully check the information before submission and make sure all documents meet the requirements.

From our practice. A FOP doctor’s private clinic operated without an NHSU contract and was already connected to an MIS. When the sole proprietor decided to enter into a contract, they could not submit a proposal: it turned out that the facility’s eHealth record had never passed NHSU verification after registration.

We contacted the NHSU, found that the facility’s address had been entered incorrectly in the MIS, and submitted the data for verification while the MIS address was corrected. The facility passed verification a week later.

How to Successfully Register a FOP Doctor or Healthcare Facility in eHealth

For many providers, data requirements, technical issues, and errors in the request make eHealth registration difficult. Yet registration is only the first step.

A facility without an NHSU contract must then determine which records, prescriptions, and certificates are mandatory for its services, which staff members will enter them and what signatures they need, how to meet the 3-business-day deadline for updating data, and how to avoid leaving the facility in “suspended” status. An error at any of these stages may not be immediately apparent: it surfaces when a doctor cannot issue a prescription or during an inspection.

Our healthcare lawyers can help register a healthcare facility or FOP doctor in eHealth and, after NHSU verification, set up the facility’s use of the system.

Our services include:

• Consultation and document preparation—reviewing your situation, explaining eHealth requirements, and preparing the registration request correctly.

• eHealth registration support—preparing the application and providing support while the facility head signs and submits it using their own QES, corresponding with the NHSU and MIS support team, and resolving technical and administrative issues.

• Error correction and resubmission—analyzing why the facility failed verification, correcting data, and resubmitting the request.

• Post-registration support—updating eHealth data, advising on electronic documentation, reviewing the MIS operator contract, and, if the facility chooses, separately supporting its NHSU contract.

• Setting up eHealth use without an NHSU contract—determining, based on the facility’s services, what you must enter and what is optional. We will prepare an internal order designating responsible persons and access rights, along with a staff guide to entry deadlines.

Registering a facility in eHealth or unsure what you must enter without an NHSU contract? Submit a request on our website or call us. We will identify the records your facility must maintain and support your registration through completion of NHSU verification.