Medical Licence for a Plastic Surgery Clinic

A step-by-step guide: from premises to Ministry of Health approval | Dextralaw

Why Plastic Surgery Is Not Simply “Surgery” on a Licence

Opening a plastic surgery clinic in Ukraine means navigating one of the most complex licensing paths in medicine. Unlike a standard outpatient practice, a plastic surgery clinic requires an operating theatre, anaesthesia support, resuscitation equipment and a staff of at least 5–7 specialists across multiple disciplines.

Medical practice licensing in Ukraine is governed by Cabinet of Ministers Resolution No. 285 of 02.03.2016 (“Licensing Conditions”), as amended by Resolutions No. 1393 (27.12.2023), No. 536 (10.05.2024) and No. 781 (02.07.2025). The most recent amendments introduced differentiated licensing by medical speciality — a violation in one speciality no longer results in suspension of the entire licence.

If you are looking for an overview of the general medical licensing procedure, we have prepared a dedicated guide: Medical Practice Licence in Ukraine: Application Procedure. This article focuses on the specifics of licensing for plastic surgery clinics.

A licence is only the starting point. Plastic surgery requires a complete set of internal documents — from informed consent forms to operating theatre SOPs. For an in-depth look at the contractual framework for such clinics, see our dedicated article on contracts in plastic surgery clinics. This material is about the licensing process itself.

“A Ministry of Health licence is not the final destination — it is the entry point. Without a proper set of documents, SOPs and informed consent forms, the licence becomes a piece of paper that protects no one: not the clinic, not the surgeon, not the patient. We accompany you the entire way — from the premises audit to the first patient.” — Medical Licensing Attorney, Dextralaw

Legal Framework

• Law of Ukraine “On Licensing of Business Activities” — Art. 7(1)(15): medical practice is subject to mandatory licensing
• CMU Resolution No. 285 of 02.03.2016 — Licensing Conditions for medical practice (primary document)
• CMU Resolution No. 781 of 02.07.2025 — new amendments: differentiated licensing by speciality
• MoH Order No. 210 of 02.04.2009 — “On Improvement of Plastic and Reconstructive Surgical Care”: personnel training, list of procedures
• Law of Ukraine “Fundamentals of Health Care Legislation” — Art. 16 (healthcare institutions), Art. 17 (business activities), Art. 43 (informed consent)
• Criminal Code of Ukraine — Art. 138 (unlicensed medical activity), Art. 140 (negligent performance of duties by a healthcare worker)
• Law of Ukraine “On Personal Data Protection” — Art. 7 (health data as a special category)

Important: the licence is issued to the clinic (a legal entity or sole trader — FOP/TOV), not to the individual physician. The concept of a “plastic surgeon’s licence” does not exist in Ukrainian law. However, each surgeon’s qualifications must be confirmed by a specialist certificate and form part of the licensing file.

Which Specialities Must Be Listed on the Licence

A full-service plastic surgery clinic must hold a licence covering at least the following specialities:

Speciality on the licence	What it authorises	Staffing requirements
Surgery (plastic surgery)	All types of plastic operations: rhinoplasty, mammoplasty, blepharoplasty, abdominoplasty, liposuction, facelift, etc.	Physician specialised in surgery + plastic surgery training cycles as required by MoH Order No. 210.
Anaesthesiology	General anaesthesia, sedation, regional anaesthesia. Mandatory for any operating theatre.	Anaesthesiologist with a valid specialist certificate. Anaesthetist nurse.
Healthcare organisation and management	Mandatory for every institution. The head of the healthcare establishment must hold this specialisation.	Director with the relevant specialist certificate or attestation.
Nursing (operating theatre)	Scrub nurse duties: surgical instrument management, sterilisation.	Mid-level healthcare professionals qualified in Operating Theatre Nursing.
General nursing	Dressings, injections, pre- and post-operative ward care.	Mid-level healthcare professionals with a nursing qualification.
Radiology / Ultrasound diagnostics	Diagnostics: X-ray, CT, ultrasound (where required).	Qualified physicians or specialists with licensed equipment.

⚖ MoH Order No. 210 of 02.04.2009: Defines the training pathway for plastic surgeons through specialised training cycles within the “Surgery” speciality.

Premises and Equipment Requirements

The Licensing Conditions set strict requirements for the material and technical base. For plastic surgery, these are significantly more demanding than for outpatient practice.

Operating Theatre Block

• Operating room: minimum floor area of 36 m² per theatre
• Scrub room: surgeon and staff preparation zone
• Sterilisation room: autoclave, disinfection agents, sterile storage
• Anaesthesia and ventilation equipment: mechanical ventilator, patient monitor, defibrillator
• Emergency resuscitation equipment: intubation kit, emergency medications
• Backup power supply: UPS or generator for the operating theatre

Ward Facilities

• Wards for pre- and post-operative patient care
• High-dependency observation room (for complications)
• Nurse call system, oxygen outlets (as required)

Additional Requirements from 2024–2025

• Accessibility for people with reduced mobility (Resolution No. 781)
• Compliance with fire safety and sanitary regulations
• Separate entrance (if located in a residential building)

Full Document Package for Submission to the Ministry of Health

Document	Content / requirements
Licence application	Standard form. Must state: entity name, USREOU code, activity addresses, list of specialities.
Material and technical base details (Annex 2)	List of premises and equipment with compliance confirmation. For plastic surgery: operating theatre, scrub room, sterilisation room, wards, resuscitation equipment.
Personnel details (Annex 2)	Full name, speciality, diploma number, specialist certificate / attestation, and work experience for each physician. For plastic surgeons: proof of plastic surgery training cycles.
Document inventory (Annex 3)	Certified copies of all documents confirming compliance with the Licensing Conditions.
Director’s education documents	Diploma + specialist certificate in “Healthcare Organisation and Management”.
Premises documents	Lease agreement or title deed. Technical passport. SES conclusion (where required). Accessibility for people with reduced mobility.
Internal institutional documents	Articles of association, divisional regulations, job descriptions, SOPs, informed consent forms, internal rules of procedure.
Licensing fee receipt	Amount = 1 subsistence minimum for able-bodied persons (UAH 3,028 in 2025). Payable within 10 days of the Ministry of Health decision.

“The most common mistake is incorrectly completing the Annex 2 Details. If the equipment does not match the declared specialities, or a physician’s qualifications are not properly documented, the Ministry will refuse. We check every line to make sure the application is approved first time.” — Licensing Attorney, Dextralaw

The Licensing Process: 6 Stages with Dextralaw

Stage	What happens	What Dextralaw does
1	Audit: assessment of current premises, equipment and personnel against licensing requirements.	On-site visit. Compliance checklist. Remediation roadmap.
2	Document preparation: completing the application, details forms and full set of annexes.	We prepare 100% of the documentation. You only sign.
3	Internal document development: articles of association, regulations, SOPs, informed consent forms, patient contracts.	Complete internal document package tailored to plastic surgery. See also our article on contracts.
4	Submission to the Ministry of Health: Single Window or e-cabinet. Monitoring of review timelines.	We manage the submission and communicate with the Ministry on your behalf.
5	Decision: the Ministry issues its decision within 10 working days. Licensing fee is paid.	We monitor timelines. If refused — we appeal and resubmit.
6	Post-licensing support: notifying the Ministry of changes, preparing for inspections, adding specialities.	Legal retainer: document updates, consultations, representation during inspections.

⚖ Art. 7(1)(15), Law of Ukraine “On Licensing of Business Activities”: Medical practice is included in the list of activities subject to mandatory licensing.

Internal Documents: What You Need Before the First Patient

A licence permits you to operate. But to operate safely and with legal protection, the clinic needs a complete set of internal documents. Dextralaw develops these in parallel with the licensing package:

• Public service contract (tailored to plastic surgery)
• Extended informed consent forms for each procedure type: rhinoplasty, mammoplasty, blepharoplasty, liposuction, etc.
• Warranty policy with defined terms and conditions for each type of service
• Operating theatre SOPs: sterilisation, anaesthesia, pre-operative preparation, emergency response
• Personal data processing SOPs: before/after photographs, medical records, staff access
• Personal data protection policy (Law No. 2297-VI)
• NDA with staff: confidentiality obligations, non-solicitation of patients
• Job descriptions for surgeons, anaesthesiologists, nurses and administrators
• Internal rules of procedure for patients and staff

For more on the contractual framework for plastic surgery clinics, see our dedicated article on contracts in plastic surgery clinics. For the general medical licensing procedure, refer to our guide: “Medical Practice Licence in Ukraine: Application Procedure”.

Risks: What Happens Without a Licence or in Breach of Licensing Conditions

Case 1. Performing procedures without a licence — criminal liability

⚠ Situation: A cosmetic surgeon was performing filler injections and liposuction in a rented room without a medical licence. After a complication (tissue necrosis following lipofilling), the patient filed a report with the police.

⚖ Legal basis: Art. 138 of the Criminal Code of Ukraine — unlicensed medical activity (without a licence or the required qualifications): a fine of up to 1,000 NMSI or restriction/imprisonment of up to 3 years. If serious harm is caused — up to 5 years’ imprisonment.

❌ Outcome: Criminal proceedings. Equipment confiscated. Patient’s claim for UAH 450,000. Ban on medical activity. Holding a valid licence is the first and most fundamental condition for lawful practice.

Case 2. Licence held, but anaesthesiology not included

⚠ Situation: A clinic held a licence for “surgery” but had not included anaesthesiology in its list of specialities. An anaesthesiologist was engaged under a civil law contract. During a mammoplasty, an anaesthesia complication arose and the patient was transferred to intensive care.

⚖ Legal basis: Breach of the Licensing Conditions (CMU Resolution No. 285): providing services in a speciality not covered by the licence. Grounds for Art. 140 CCU + licence suspension by the Ministry of Health.

❌ Outcome: Licence suspended pending remediation (3 months of downtime). Fine. Criminal proceedings against the surgeon and clinic director. Claim for UAH 680,000. Anaesthesiology is a mandatory speciality for any surgical clinic.

Case 3. Ministry of Health inspection: missing internal documents

⚠ Situation: A routine Ministry of Health inspection found: no SOPs for sterilisation; informed consent forms were the generic template without plastic surgery specifics; medical records were partially completed; patient personal data was stored without adequate protection.

⚖ Legal basis: Breach of licensing conditions. Non-compliance with Art. 43 of the Law “Fundamentals of Health Care” (informed consent) and the Law “On Personal Data Protection”. Grounds for licence annulment (repeat violation).

❌ Outcome: Enforcement notice requiring remediation within 30 days. Warning of possible annulment. The clinic urgently engaged Dextralaw to develop the full document package. The licence was saved — but the cost of emergency assistance was three times higher than a planned preparation would have been.

Case 4. Ministry of Health refusal due to errors in the application

⚠ Situation: A clinic submitted a licence application independently. The Annex 2 Details listed equipment that had not yet been delivered (it was planned for future delivery). One physician’s qualifications were not supported by a valid certificate — the attestation had expired 2 months earlier.

⚖ Legal basis: Providing false information in the application is grounds for refusal and a prohibition on resubmission for a defined period. Under the Law “On Licensing of Business Activities”, the Ministry of Health may annul a licence if false data is discovered after issuance.

❌ Outcome: Application refused. Clinic opening delayed by 4 months. Additional costs for resubmission and remediation. Legal support from day one prevents such situations entirely.

“We have accompanied the licensing of more than a dozen medical institutions. The key lesson is always the same: a licence is not a one-time procedure — it is the beginning of the clinic’s legal life. We do not simply obtain a permit; we build a document system that protects the clinic for years to come.” — Senior Partner, Dextralaw

Dextralaw: Plastic Surgery Licensing — Full-Service Support

Law firm Dextralaw offers a complete cycle of services:

• Premises and personnel audit before licensing begins
• Preparation of the complete licensing package — you only sign
• Development of internal documents: contracts, informed consent forms, SOPs, NDAs, warranty policies
• Submission and representation before the Ministry of Health — we communicate with the licensing authority on your behalf
• Licence expansion — adding new specialities, addresses, equipment
• Protection during Ministry of Health inspections — preparation, attendance, appeal of enforcement notices
• Post-licensing retainer — document updates as legislation changes

We do not simply obtain a licence — we ensure your clinic is fully legally prepared. From the first day of the audit to the first patient, and beyond.

For more on the general procedure for obtaining a medical licence, see our guide: “Medical Practice Licence in Ukraine: Application Procedure”.

Frequently Asked Questions