Medical Waste Processing Agreement: A Mandatory MoH Requirement from 2026

Starting January 8, 2026, the rules for the medical business are changing. The Ministry of Health (MOH) introduced a mandatory requirement that applies to every licensee, without exception: the presence of a medical waste processing agreement. Formally, it is just one document, but in practice, its absence has become a real reason for refusal of licensing or for issues with an existing license, which can threaten the suspension of your operations.

Many medical institutions and individual entrepreneurs (FOPs) are already operating legally, holding valid licenses, and do not expect radical changes. However, the new requirements mean that existing data must be updated, and this must be done within a specific deadline. For those planning to open a clinic or medical office, this condition must be included in the documentation package for obtaining a medical license from the outset.

In this article, we will examine what exactly is changing, who needs a medical waste processing agreement, and how to prepare for 2026 without risks to your business or license.

You  might also like: Updating Rehabilitation Facilities Under Resolution No. 309

Key Legislative Changes: Resolution No. 781 and the New Rules

As of January 8, 2026, the Ministry of Health has introduced updated licensing requirements for medical practice, one of which is the mandatory presence of an agreement for the collection, storage, decontamination, and disposal of medical waste. The agreement must be signed with a specialized, licensed organization.

This requirement is explicitly established by the Cabinet of Ministers of Ukraine Resolution No. 781, “On Amendments to the Licensing Conditions for Conducting Economic Activities in Medical Practice.” From this date, the rule applies to all entities in the healthcare sector without exception.

Who Does the New Requirement Affect?

• New licensees. For those submitting documents to obtain a medical license, the rule is direct and mandatory. From January 8 onward, the agreement must be included in the information submitted to the MOH. Applications submitted without a valid agreement will be automatically rejected by the Ministry.
• Existing businesses (legal entities and individual entrepreneurs). For current licensees, the legislation provides a transition period. Medical institutions and FOPs holding an existing license must update the information submitted to the MOH within six months of the law’s entry into force (i.e., by July 2026). This means signing an agreement for medical waste disposal and submitting notification of changes within the specified timeframe.

Thus, from 2026 onward, a medical waste processing agreement becomes a mandatory element of licensing compliance for both new applicants and those already operating in Ukraine’s medical market.

Categories of Medical Waste Subject to Mandatory Disposal

Under the MOH licensing requirements, medical waste that is inevitably generated during the provision of medical care must be mandatorily transferred for decontamination and disposal. Specifically, these categories include:

• Used syringes, needles, infusion sets, catheters, and other disposable medical items;
• Dressings, wipes, gloves, masks, and other materials contaminated with biological fluids;
• Infectious waste, including from patients with viral and bacterial diseases (HIV, viral hepatitis, tuberculosis, etc.);
• Mercury-containing thermometers, lamps, and other devices with mercury or hazardous chemicals;
• Pharmaceutical residues, including expired, damaged, or otherwise unusable drugs;
• Biological samples, laboratory research waste, and materials from analyses and tests.

All of these wastes require proper collection, labeling, temporary storage, and subsequent transfer to a specialized licensed company in accordance with established sanitary and environmental regulations. These are precisely the categories covered by the requirement for a mandatory medical waste processing agreement.

Risks of Not Having a Medical Waste Processing Agreement

From 2026 onward, the absence of a medical waste processing agreement constitutes a direct violation of licensing requirements. At the licensing stage, the consequences are clear: the MOH will refuse to issue a medical license in 100% of cases if the agreement is not listed in the submitted information. The law does not allow any alternatives or the possibility to submit the documents later.

For those who already hold a license, risks arise during inspections. Failure to have a medical waste disposal agreement or not updating the information submitted to the MOH results in remarks and mandatory orders to rectify the violations within a specified period. If the requirements are not met or updates are submitted late, the license may be suspended until all documentation complies with the law.

In practical terms, this can lead to lost time, financial losses, business downtime, and reputational damage. For this reason, the issue of a medical waste processing agreement should be addressed proactively, not just urgently after an inspection.

What Medical Institutions Need to Do Now

To comply with MOH requirements, medical institutions or individual entrepreneurs (FOPs) must act proactively.

1. Sign an agreement with a licensed company authorized to collect, transport, and process medical waste of the relevant category. Deadlines are important: the date of the agreement must be listed in the information submitted to the MOH, so the contract must be executed in advance, not retroactively.
2. Submit or update information with the MOH. For new license applicants, the agreement is included immediately in the application package. Existing licensees must update their data within six months from the date the changes come into force, as mentioned earlier, and this deadline is mandatory.
3. Check compliance of all documentation: internal orders, waste records, and actual working conditions. Alignment between documents and real practice minimizes the risk of remarks during inspections.

This approach not only ensures compliance with the law but also guarantees the stable operation of the medical institution without jeopardizing the license.

You might also like: Medical Facility Reorganization and Medical License: Apply for a New One or Update the Existing License

Legal Assistance: Obtaining a Medical License “From Scratch” and MOH Compliance Support

You entered the medical field to treat patients, not to navigate the complexities of environmental law. That’s why we offer a service that minimizes your involvement. Our legal team helps you adapt to changes by handling document preparation and communication with the MOH. We free your time from bureaucratic burdens, allowing you to focus entirely on patient care and the growth of your medical center without worrying about legal procedures.

We support medical businesses so that new regulatory requirements become a standard operational step, rather than a source of risk:

• For new licensees: We provide a full-cycle service: from reviewing your application package to correctly compiling the required information, ensuring your license is granted on the first submission.
• For existing businesses: We manage updates and changes, analyze your situation, and submit timely notifications to the MOH, eliminating the risk of errors or missed deadlines.
• Practical accuracy: Our work is based on current MOH practices. We thoroughly verify not only the existence of the agreement but also its correct documentation: from signing dates to compliance with your specific types of medical activity.
• Outcome and peace of mind: You gain assurance of full compliance with licensing requirements, which ensures uninterrupted and safe operation of your medical institution.

Don’t wait until deadlines start pressuring you; contact Pravova Dopomoga Law Firm now, and we will secure your license reliably.

You treat people, and we take care of your legal foundation. Learn more about our service here.