MoH Inspections and License Changes: How to Protect Your Medical Business in 2026

You have obtained a medical license and launched your clinic. It may seem that the most difficult stage is behind you. However, the medical business is dynamic. You hire new doctors, purchase equipment, open additional treatment rooms, or change a laboratory responsible for waste disposal.

Many heads of medical institutions and self-employed physicians treat these changes as internal routine, forgetting that each such modification must be officially recorded with the Ministry of Health. This discrepancy between the “paper” status of the license and actual operations is the most common reason for fines or even license revocation during Ministry of Health inspections.

This means that a medical institution or self-employed physician loses the right to carry out medical activities. In practice, this is a business shutdown, while license restoration is a lengthy and costly process. In addition to financial losses, license revocation causes reputational damage and undermines the trust of patients and partners. That is why timely amendments to a medical license are essential. They protect your medical business from unpredictable consequences and ensure continuity of medical practice.

In this article, we explain how the control system works in 2026 and how to ensure that a Ministry of Health inspection of a medical institution is completed without risk.

You might also like: Liability for Illegal Medical Practice

What Is a Ministry of Health Licensing Inspection: Scheduled and Unscheduled Measures

A licensing inspection by the Ministry of Health of a medical institution is a form of state control over compliance with the licensing conditions for medical practice. Such inspections apply to healthcare institutions of all forms of ownership, as well as self-employed physicians who provide medical services under a valid license.

There are two types of inspections. Scheduled inspections are carried out according to an approved plan, while unscheduled inspections take place in response to a patient complaint or an inquiry from government authorities. Both types are aimed at verifying whether actual activities correspond to the information stated in the license. For medical practice, these inspections are of critical importance, as any discrepancy between licensing documents and real operations is treated as a violation of the law.

As a result of the inspection, an official report is prepared. It records whether the business entity complies with legislative requirements in the field of licensed medical practice. The form of this report is approved by the Ministry of Health.

Inspections During Martial Law: Is There a Moratorium in 2026

Many entrepreneurs mistakenly believe that inspections are currently not applicable. Indeed, under Resolution of the Cabinet of Ministers of Ukraine No. 303 dated March 13, 2022, scheduled and unscheduled state supervision measures were suspended for the duration of martial law. However, legislation provides for a number of exceptions to this general rule.

If there are threats that may negatively affect the rights and interests of citizens, their health, environmental safety, or the security of the state as a whole, as well as for the purpose of fulfilling Ukraine’s international obligations, unscheduled inspections are permitted during martial law based on decisions of the Ministry of Health of Ukraine. Such inspections are carried out exclusively to verify compliance with those licensing conditions that directly relate to the specific recorded violation and are supported by relevant documentation.

Thus, Ministry of Health inspections have effectively resumed, and any discrepancy between actual activities and the information stated in the license is treated as a violation of licensing conditions.

Which Changes Must Be Reported in a Medical License (Resolution No. 781)

According to Resolution of the Cabinet of Ministers of Ukraine No. 781, which enters into force on January 8, 2026, all medical institutions are required to promptly notify the Ministry of Health of any changes in the conditions under which their business activities are carried out. Such changes typically include:

1. Organizational changes: opening facilities at new addresses, changes to operating hours, change of location, expansion or reduction of structural units.
2. Staffing changes: updates to medical personnel, acquisition of additional specialties by employees, changes in the qualification profile of specialists.
3. Technical and contractual changes: entering into new contracts for medical waste disposal, updating contracts for equipment maintenance, changes in material and technical resources.

Tip: Any change must be submitted to the Ministry of Health within one month from the date it occurs. Failure to do so automatically places the institution in a risk zone.

More detailed information on the key amendments to the licensing conditions and the procedure for submitting such changes can be found in this article: Changes to the Licensing Conditions for Medical Practice 2025. What License Holders Need to Do.

How the Ministry of Health Selects Whom to Inspect: The Risk Scoring System

It is important to note that, under Resolution of the Cabinet of Ministers of Ukraine No. 1163 dated December 18, 2018, there is a defined set of criteria used by the Ministry of Health to determine whether it is appropriate to inspect a particular medical institution. These criteria include:

• the period and conditions under which medical activities are carried out;
• the types of medical care actually provided by the healthcare institution or by a physician operating as a self-employed practitioner;
• the compliance of the business entity’s activities with the norms and rules established by legislation governing medical practice;
• conclusions regarding the level and quality of medical services, formed based on the results of professional assessments conducted in previous years prior to the planned inspection period;
• the scope of medical specialties within which practical activities are carried out;
• the number of unscheduled supervisory measures applied by state oversight bodies to the business entity over several years preceding the planned inspection period.

Each medical institution receives its own assessment, meaning a specific number of points based on the established criteria, which determines the level of risk of its activities. Depending on the assigned risk level, scheduled state supervision measures are carried out with different frequency.

1. High risk: 41–100 points. Inspections are conducted no more than once every two years.
2. Medium risk: 21–40 points. Inspections are conducted no more than once every three years.
3. Low risk: 0–20 points. Inspections are conducted no more than once every five years.

This system makes it possible to optimize supervisory activities by focusing attention on institutions with a higher level of potential risk, while at the same time reducing the regulatory burden on medical institutions that comply with licensing conditions.

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

Consequences of Violations Identified During a Ministry of Health Inspection: Why a Fine Is the Least of Your Problems

Ministry of Health inspections can lead to very different consequences, ranging from fines to revocation of a medical practice license. As noted above, following an inspection the supervisory authority issues an official report detailing the identified violations and granting a specific period for their correction.

Once the deadline for remedying the deficiencies expires, sanctions may be applied to the business entity:

1. Fines may be imposed on medical institutions for failure to notify the Ministry of Health of changes within the установленный time frame and may reach up to UAH 17,000.
2. If more serious violations are identified, the Ministry of Health may suspend the license until the violations are eliminated or revoke it entirely.

In addition to these legal consequences, inspections often result in loss of patient trust and a decline in the clinic’s financial performance.

To prepare for a Ministry of Health inspection, it is essential to monitor whether your medical institution is included in the inspection schedule for the relevant year. For example, the Ministry of Health has already published the inspection plan for medical institutions for 2026 on its website, which you can review here.

Common Mistakes That Lead to Issues During Ministry of Health Inspections

Very often, situations arise where a medical institution has in fact made changes to its operations but has failed to reflect them in its medical license. This may include starting work with a new physician without updating the documentation, using additional equipment, opening a new treatment room, or relocating to a different address.

Another very common mistake is submitting notifications of changes to the Ministry of Health late or submitting an incomplete document package reflecting those changes. All of these actions create significant risks during an inspection and may lead to serious legal consequences.

Legal Audit of a Medical License and Preparation for a Ministry of Health Inspection

To enter 2026 without fear of inspections, we recommend starting with a professional audit. Our team specializes in supporting medical businesses and has many years of experience working with the Ministry of Health.

Your case will be handled by a medical law specialist who has an in-depth understanding of internal procedures of supervisory authorities and all the nuances of the updated Licensing Conditions. We do not simply “fill out paperwork.” We build legal protection for your clinic.

How we help protect your business:

• Compliance audit. We check whether your actual activities correspond to the information on file with the Ministry of Health.
• Turnkey submission of amendments. We prepare and submit document packages related to new doctors, equipment, or addresses.
• Inspection readiness. We simulate an inspector’s visit, identify weak points, and help eliminate them in advance.
• Dispute protection and appeals. If an inspection has already taken place, we assist with challenging unlawful decisions or support the process of correcting violations.
• Risk identification. We analyze potential risks, including what happens if changes are not reported in the medical license.

Your medical license is the foundation of your business. Take care of its accuracy in advance by ordering a legal audit and preparation for a Ministry of Health inspection.