How to Amend a Medical License in Ukraine in 2025?
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Amending a medical license is a mandatory procedure that every license holder eventually faces. It ensures that the data in the licensing file remains current and that the medical institution's activities comply with legal requirements.
According to the Licensing Conditions for conducting economic activities in medical practice, the license holder must notify the Ministry of Health of Ukraine of any changes in data within one month from the date such changes occur.
The license must contain up-to-date information about the license holder, their material and technical base, staffing, business address, and other relevant details. Therefore, any changes, even minor ones, must be entered into the Ministry of Health’s licensing register.
Today, we will take a detailed look at how to amend a medical license from the perspective of our practicing lawyers, who have over 14 years of experience in licensing procedures and specialize in medical law.
Changes to a Medical License: What You Need to Know
The license holder is required to notify the Ministry of Health of any changes that affect the information listed in the license. For example:
- change of address for the business location where the medical practice is conducted;
- updates to the material and technical base (equipment, premises, etc.);
- changes in personnel, such as hiring of new medical staff or replacement of documents confirming their qualifications;
- expansion of activities, such as adding new specialties or types of medical care to be provided by the medical facility.
Related: Our Experience Amending a Medical License
Procedure for Amending a Medical License
The requirement to submit information about changes remains in effect. However, since April 2020, the licensing authority has stopped issuing separate decisions on the acceptance or rejection of such changes.
Now, after a correctly completed and submitted notification of changes to a medical practice license, the license holder must monitor the inclusion of the new information in the public registry of all medical practice licenses.
In practice, making changes has often taken longer than obtaining a new license, although it does not require additional fees. We are frequently approached by clients who previously attempted the process on their own and received several refusals, and only with our assistance were finally able to complete the amendments.
Let's take a close look at the step-by-step procedure for making amendments to a medical license:
1. Identifying the configurations that need to be updated in the licensing file.
Before initiating the procedure, it is necessary to determine which specific changes have occurred in the medical practice license and whether they require updates in the licensing file. As noted above, changes that require amendments to the licensing file may include: changes in the location of the practice, material and technical base, expansion of the list of specialties, etc.
2. Preparing the document package.
When submitting amendments to the Ministry of Health of Ukraine, only two documents are required:
- updated information on the state of the material and technical base;
- a notification of changes.
Important condition: only the information that has changed or been added should be included. For example, if you are adding a statement on the accessibility of non-residential premises for people with limited mobility, which is currently quite relevant, only that information should be indicated in the submission.
3. Submitting documents to the Ministry of Health.
Previously, during martial law, the Ministry of Health allowed documents to be submitted not only by postal mail (with an inventory of enclosures) or in person (through the Ministry’s Administrative Services Center "Single Window"), but also as scanned copies in "PDF" format via email to the official email address of the Ministry of Health. However, this option was granted on the condition that the documents would be resubmitted following the standard procedure within three months after the end or cancellation of martial law. Nevertheless, we decided to inquire with the Ministry of Health for more details: is the remote submission procedure for making amendments to a medical practice license still valid?
How to update a medical practice license?
After sending a request to the Ministry of Health, we received the following response: "Currently, the Ministry of Health is working on improving the Licensing Register of the Ministry of Health for medical practice (hereinafter – the Register). At this time, there is no technical capability to submit an application and the corresponding set of documents to the Ministry of Health in electronic format.
The deadline for submitting documents remains unchanged – within one month from the date the changes occur. There is no state fee for this process.
When applying in person, the applicant requesting changes to the licensing file must present an original identity document. If a representative is submitting the licensing documents on behalf of the applicant, they must also provide the original (or a certified copy) of a power of attorney. The power of attorney must include the name of the authority to which the documents are being submitted, the date of issuance, the validity period, and a list of the authorized representative’s powers.”
4. Review of documents by the Ministry of Health and updating the licensing register.
The Ministry of Health has 30 calendar days to review the submitted documents. However, in practice, updating the information in the Licensing Register may take significantly longer.
So, how can you find the register on the Ministry of Health's website and check whether the changes have been made:
- Go to the Ministry of Health’s website using a search engine
- Navigate to the “About the Ministry” section, then to “Administrative Services” and select “Licensing”
- Click on the “Licensing Register” tab
Here you can enter all the necessary information for your identification and check whether the Ministry of Health has approved the Notification of changes submitted by you.
If the notification is rejected, the license holder receives an email at the address specified in the Unified State Register or in the previously submitted License Application. In this email, the Ministry of Health states the reason for the refusal to make the changes and requests that the document package be resubmitted correctly. However, in practice, such an email is not always sent, so sometimes it is necessary to submit a request for confirmation of the changes.
It is also important to note that certain changes, such as expanding the license holder’s material and technical base, hiring new medical staff, updating medical documentation, or changing a medical worker’s last name, cannot be verified through the public register.
To ensure that these changes have been processed, it is necessary to submit a formal request to the Ministry of Health asking for confirmation of whether the updates have been made.
You might also like: How to Amend a Medical License Without Errors
Consequences of Failing to Report Changes in the License
The licensing authority has the power to conduct scheduled or unscheduled inspections of medical institutions (the license holder) to verify compliance with licensing requirements. Grounds for such inspections may include, in particular, a patient complaint regarding substandard medical services. The importance of properly documenting patient relations in your clinic was discussed in this article.
If, during the inspection, it is found that your institution submitted changes late or failed to submit them at all, this may lead to serious consequences:
- revocation of the license;
- fines ranging from 250 to 500 non-taxable minimum incomes of citizens.
Risks of Cooperation with the National Health Service of Ukraine (NHSU)
It is equally important to note that if your medical institution operates under the Medical Guarantees Program, failure to make timely updates may cause complications in cooperation with the NHSU.
Please note! When working with the NHSU, it is also necessary to upload through the medical information system a scanned copy of the letter you submitted to the Ministry of Health requesting changes to your license.
What to Do If the Ministry of Health Does Not Accept the Changes?
Sometimes the Ministry of Health refuses to accept changes if the submitted documents do not meet legal requirements. This raises a rather contentious question: what should be done in such cases, and can the license holder face fines during an inspection? To avoid such issues and ensure that the Ministry of Health accepts the changes on the first attempt, contact our specialists.
Amending a Medical License: Why It Is Important to Act Correctly
After analyzing the new submission procedure and completing several amendments under it, we have reached an important conclusion: the new procedure does not facilitate independent document submission, as the amendment process turns out to be lengthy.
The wait for amendments to be processed can take months, which may negatively affect your business plans and the operations of your medical facility. Any inaccuracies in the documents may result in a refusal to amend the license, leading to lost time and money and potentially damaging your institution’s reputation. Therefore, the accuracy of the submitted documents directly affects both the registration timeline and the final decision.
Our team has many years of experience in successfully obtaining medical licenses and has already tested the new amendment procedure in practice with medical institutions of various profiles. We have worked with clinics of all sizes, from small private practices to large medical centers, and have successfully handled tasks of any complexity.
What do we offer?
1. A thorough analysis of your situation.
- Determining exactly which changes need to be made to your medical license.
2. Guidance on preparing a complete set of documents.
- Updating the information about the condition of your material and technical base.
- Drafting a clear, legally sound notice of amendments.
3. Full support in submitting documents to the Ministry of Health and managing all communication with the licensing authority.
4. Obtaining official confirmation of the amendments.
We guarantee transparency, a well-structured process, and official verification of changes in the licensing register.
If you want to avoid negative consequences, delays, and risks, and ensure your medical business remains secure, contact us. We will handle the entire procedure from start to finish, providing reliable and high-quality legal support.
