Medical Practice Licence in Ukraine: Procedure, Requirements, Documentation

A licence from the Ministry of Health of Ukraine (MoH) is the foundational legal document without which no medical institution, doctor, or sole proprietor (FOP) in Ukraine has the right to provide medical services. We have been supporting the licensing process since 2015 — from a family doctor’s office of 18 square metres to reproductive medicine clinics with embryology laboratories and cryobanks.

The procedure itself looks simple: submit the application and Schedule of Information to the MoH, wait 10 working days for a decision. That is the formal side of the matter.

In practice, it is more complex. Most MoH refusals stem not from any malice on the regulator’s part, but from non-compliance of the material and technical base, staffing errors in the Schedule of Information, or incorrectly stated specialties. In 2025, an additional variable was added — Cabinet of Ministers Resolution No. 781, which requires all existing licensees to update their licensing files by 8 July 2026. Failure to comply results in licence suspension for up to 6 months.

This page contains a comprehensive practical resource: the legislative framework, requirements, list of documents, MoH procedure, typical grounds for refusal, cases from our practice, and answers to the most frequently asked questions.

“A medical practice licence is not a piece of paper to be filed away and forgotten. It is a living matter that needs to be kept current with every change of personnel, address, or specialty. Most of our clients come to us not for their first licence, but because they failed to update something on time.”

— From the practice of Dextra Law lawyers

Quick Summary of the Medical Licensing Process

• Medical practice is subject to mandatory licensing under clause 15, part 1, article 7 of the Law of Ukraine “On Licensing of Economic Activities”.
• The licensing authority is the Ministry of Health of Ukraine (MoH). A decision on issuance is made within 10 working days from the date of application submission.
• The state fee equals one subsistence minimum for able-bodied persons (UAH 3,028 as of 2025).
• An MoH licence is issued for an indefinite term, but requires updating with each change (personnel, premises, specialties, address).
• The licence may be obtained by either a legal entity (LLC, Private Enterprise, Joint-Stock Company, Communal Non-Profit Enterprise) or a sole proprietor (FOP) — even without personal medical education, provided that a qualified doctor is employed on staff.
• Conducting medical practice without a licence — an administrative fine of 1,000 to 2,000 tax-free minimum incomes plus criminal liability under article 138 of the Criminal Code of Ukraine (illegal medical activity).
• The status of any issued licence may be verified in the MoH Licence Register.

Important: Update of Licensing Files by 8 July 2026

This section concerns all existing medical institutions that already hold an MoH licence.

Pursuant to Cabinet of Ministers Resolution No. 781 of 02.07.2025, all healthcare establishments and sole proprietors that obtained their medical licence before 8 January 2026 are required to update their licensing files with the MoH no later than 8 July 2026.

What this means in practice. You must submit to the MoH an updated Schedule of Information (Appendix 2) on the material and technical base and personnel in the new wording introduced by Resolution No. 781. The form, the list of mandatory data, the requirements for confirming qualifications, and the registration of premises have all been amended. The old form is no longer accepted.

What happens if you miss the deadline. Failure to update the licensing file within the prescribed period constitutes grounds for suspension of the licence for up to 6 months. For a clinic, this means the inability to admit patients, to provide services under a contract with the NHSU, or to invoice insurance companies.

The second key change is the differentiation of licensing by specialty. Previously, a breach in any single specialty could lead to suspension of the entire licence. Now the MoH can suspend the licence only for the specific specialty at issue, while preserving the right to operate under the others. For clinics with 5–10 specialties, this is a fundamental shift.

We are already supporting the licensing file update process for existing clients. In most cases, the process is not limited to a simple “resubmission of documents”: in parallel, we must bring personnel data into line, reissue premises leases, and add specialties not previously covered by the licence.

What Is a Medical Practice Licence

A medical practice licence is an official state permit that establishes the right of a business entity to conduct economic activity in medical practice.

The term “economic activity in medical practice” means activity in the field of healthcare carried out by healthcare establishments and sole proprietors for the purpose of providing medical assistance and medical services on the basis of a licence.

Under the Licensing Conditions approved by Cabinet of Ministers Resolution No. 285 of 02.03.2016, medical practice may be conducted by a licensee in the following terms:

• By medical specialty — the full list includes over 130 positions: internal medicine, surgery, obstetrics and gynaecology, dentistry, cardiology, dermatovenereology, and others.
• By specialties of mid-level medical personnel — nurses, paramedics, midwives.
• By rehabilitation specialists — physiotherapy, occupational therapy, speech and language therapy, rehabilitation treatment.
• By pharmaceutical directions — pharmaceutical services within the scope of medical practice.
• By types of medical assistance — emergency, primary, specialised, palliative, medical rehabilitation.
• By place of activity — each premises where medical services are provided is listed in the licence separately.

Legislative Framework

• Law of Ukraine “On Licensing of Economic Activities” — clause 15, part 1, article 7: medical practice is subject to licensing.
• Cabinet of Ministers Resolution No. 285 of 02.03.2016 — Licensing Conditions for medical practice (as amended by Resolutions No. 1393, No. 536, No. 781 of 02.07.2025).
• Law of Ukraine “Fundamentals of Healthcare Legislation” — the framework law governing medical activity in Ukraine.
• Law of Ukraine “On Consumer Protection” — applies to the relationship between a medical institution and the patient as a consumer of services.
• Law of Ukraine “On Personal Data Protection” — article 7: medical data is classified as a special category with heightened processing requirements.
• State Building Codes (DBN) V.2.2-10:2022 — building regulations for healthcare facility premises (room areas, ceiling height, lighting, ventilation).
• Criminal Code of Ukraine — article 138 (illegal medical activity), article 140 (improper performance of duties by a medical worker), article 145 (medical confidentiality).

Which Types of Medical Activity Require Licensing

The Licensing Conditions provide that all types of activity covered by the term “medical practice” are subject to mandatory licensing. The licensing scope is classified as follows:

№	Category	Direction
1	Medical specialties	General practice — family medicine, obstetrics and gynaecology, gastroenterology, internal medicine, surgery, paediatrics, cardiology, dermatovenereology (cosmetology), psychiatry, dentistry, and others. Over 130 specialties in total.
2	Mid-level specialists with medical education	Nurses, paramedics, midwives.
3	Rehabilitation specialists	Physiotherapy, rehabilitation treatment, speech and language therapy, occupational therapy.
4	Pharmaceutical specialists	Pharmaceutical services within medical practice (within the scope of licensed activity).
5	Types of medical assistance	Emergency assistance, primary medical assistance, specialised assistance, palliative care, medical rehabilitation.
6	Place of activity	Healthcare establishments, medical centres, clinics, sole proprietor private practice offices, outpatient clinics, paramedic-midwife stations, dental clinics, medical offices in educational institutions and enterprises.

The most popular licensing directions our clients approach us about:

• Dentistry — paediatric, orthopaedic, surgical, therapeutic, orthodontic. Specialist material: Licence for a Dental Clinic.
• Plastic surgery and cosmetology — dedicated operating room, anaesthesiology, complications. Specialist material: Medical Licence for a Plastic Surgery Clinic.
• Reproductive medicine (ART) — embryology laboratory, cryobank, genetics, NHSU contract for free IVF. Specialist material: Medical Licence for a Reproductive Medicine Clinic.
• Family medicine — the most widespread direction for sole proprietor doctors.
• Internal medicine — including pre-trip/post-trip medical examination rooms for drivers.
• Dermatovenereology and cosmetology — the most fragmented segment due to the high number of private offices.
• Physical and rehabilitation medicine — rapidly expanding due to the wartime context.

Who Can Obtain a Medical Practice Licence

Under the Licensing Conditions, an MoH licence is issued to any business entity that meets the material, technical, and qualification requirements. The possible legal forms are:

Legal entities

• LLC (TOV in Ukrainian) — limited liability company. The most common form for clinics, medical centres, and outpatient facilities.
• Private Enterprise (PP) — suitable for small offices with a single founder.
• Joint-Stock Company (AT) — rarely encountered, mainly in large clinic networks.
• Communal Non-Profit Enterprise (KNP) — the form used by state and municipal medical institutions.

Sole proprietors (FOP)

A sole proprietor may obtain an MoH licence under two scenarios.

First — when the sole proprietor personally holds medical education, a specialist qualification certificate in the relevant specialty, and conducts private practice personally. This is the classic case: a family doctor, a dentist, a gynaecologist, a psychotherapist.

Second — when the sole proprietor does not personally hold medical education but employs a qualified doctor on staff. In practice, small offices are often set up this way, where the owner is the investor and the medical service is delivered by an employed specialist. This option is fully legal and is used, for example, for cosmetology offices or massage and rehabilitation rooms.

Among our clients, the typical split is roughly 60% LLC, 35% sole proprietor, with the remaining 5% in other forms. Sole proprietor is chosen when a simplified tax regime and a minimal staff are needed. LLC — when we are dealing with a multidisciplinary institution, several founders, or plans to attract investment.

Who Issues the Medical Practice Licence

The sole authority empowered to issue medical practice licences in Ukraine is the Ministry of Health of Ukraine (MoH). Applications are processed directly by the MoH Licensing Department.

The powers of the MoH licensing commission include:

• review of applications from individuals and legal entities concerning medical practice licensing;
• decisions on issuance or refusal to issue medical practice licences;
• external state oversight (control) over the quality of medical services;
• accreditation of healthcare establishments;
• review of patient complaints regarding the quality of medical services.

An MoH decision is formalised in an order published on the official website moz.gov.ua. Any third party (a patient, counterparty, insurance company) may verify the status of a licence in the MoH Licence Register.

Requirements for Obtaining a Medical Practice Licence

The Licensing Conditions impose two groups of requirements: those for premises and equipment (material and technical) and those for personnel (qualification requirements).

Material and technical requirements

• The premises must have appropriate intended and functional designation and belong to non-residential stock. The conversion of an apartment into a medical office is the most common error that leads to refusal.
• Right to use the premises: ownership or lease. The lease agreement must be registered.
• Accessibility certificate for persons with reduced mobility — a separate document obtained through a specialised expert.
• Premises area — in accordance with DBN V.2.2-10:2022. Individual minimum standards are prescribed for each specialty. For example: dentist’s office — from 16 m²; dermatovenereologist’s office — from 18 m²; anaesthesiologist’s office — from 24 m². The area cannot be reduced even by 1 m² — the MoH verifies this against the technical passport.
• Sanitary, fire safety, and construction requirements — additionally confirmed by the corresponding opinions of supervisory bodies.
• Medical equipment — only equipment entered in the State Register of Medical Devices of Ukraine, or holding a valid EU registration certificate.

Qualification requirements for personnel

• Higher education diploma in medicine and/or pharmacy — for doctors and pharmacists.
• Specialist physician (specialist provisor) certificate — confirms the right to work in a specific specialty.
• Qualification category certificate (assignment or confirmation) — for experienced doctors.
• Continuing professional development certificate — confirms ongoing professional development.
• Incomplete or basic higher medical education plus specialisation — for mid-level medical personnel.
• Confirmation of work experience — for category-rated doctors.

A separate block concerns the requirements for the head of a healthcare establishment. The head must hold a specialist certificate in “Healthcare Organisation and Management”. Without this certificate the MoH will not register any licence — even if the head is a practising doctor in another specialty.

List of Documents for Obtaining a Medical Practice Licence

The standard package submitted to the MoH for an initial licence application:

№	Document	Note
1	Application for a medical practice licence	Approved MoH form. Signed by the head of the legal entity or by the sole proprietor.
2	Schedule of Information on the material and technical base and personnel (Appendix 2)	Separately for each specialty, separately for each premises.
3	Inventory list of documents attached to the application (Appendix 3)	Inventory list, which the MoH verifies page by page.
4	Documents for the premises	Title deed or lease agreement. Technical passport. Accessibility certificate for persons with reduced mobility.
5	Qualification documents of personnel	Diplomas, specialist certificates, qualification category certificates, continuing professional development certificates — for each specialist.
6	Employment contracts	Confirm the employment of each specialist listed in the Schedule of Information.
7	Equipment documentation	Certificates of conformity, registration of medical devices in Ukraine, manufacturer’s warranty obligations.
8	Documents on the registration of the business entity	Extract from the State Register. For legal entities — articles of association. For sole proprietors — copy of passport and tax ID.
9	Criminal record clearance certificate	For the head of the legal entity or for the sole proprietor.
10	Photographs	For documents — where required by the MoH.

I want to highlight one thing that applies to all clients regardless of specialty. The MoH receives the base package. But the full-scale operation of a clinic requires a second, internal package: patient informed consents, service agreements, personal data protection policy, NDAs with staff, internal SOPs. These documents are not filed with the MoH. But without them, the clinic will lose any patient lawsuit and fail any unscheduled inspection. We prepare both packages simultaneously.

Download Current MoH Forms

Forms in the wording of Cabinet of Ministers Resolution No. 781 of 02.07.2025, in force from 08.01.2026:

• Application (Appendix 1) — DOCX
• Schedule of Information on the material and technical base and personnel (Appendix 2) — DOCX
• Inventory of documents (Appendix 3) — DOCX

Completed sample Schedules of Information by direction:

• Sole proprietor — family doctor (general practice) — PDF
• Sole proprietor — dentist — PDF
• School medical office (nursing) — PDF
• Pharmacy with pharmaceutical practice — PDF

All forms are official Ukrainian-language documents accepted by the Ministry of Health of Ukraine. They must be submitted in Ukrainian regardless of the applicant’s country of origin.

The MoH Licensing Procedure: 4 Steps

This is the sequence of actions the licensee goes through when interacting with the MoH.

Step	Content	Indicative timing
1. Preparation of the material and technical base and personnel	Premises lease or purchase, renovation, obtaining the accessibility opinion, equipment fit-out. Recruitment and employment of staff with confirmed qualifications.	From 2 weeks to 6 months (depending on the direction)
2. Compilation of the document package	Application, Schedule of Information (Appendix 2), Inventory of Documents (Appendix 3), qualification documents, premises and equipment documentation, employment contracts.	From 2–5 working days
3. Submission of the application to the MoH	Via the MoH “Single Window” or through the electronic cabinet of the licensee.	1 working day
4. Application review and licence issuance	The MoH verifies the completeness and accuracy of the documents. In case of a positive decision — an MoH order is issued and the licensee is added to the Licence Register. The state fee must be paid within 10 working days from the date of the order.	10 working days

In total, from the decision “we are getting a licence” to the start of operations, the process takes 2 to 6 months for standard directions (family medicine, dentistry, dermatovenereology). For complex ones — ART clinics, plastic surgery, multidisciplinary centres — it takes 4 to 9 months.

Grounds for MoH Refusal to Issue a Licence

The MoH may refuse to issue a licence or leave the application without consideration. The most common grounds we have encountered:

• Inaccurate information in the Schedule of Information. The most common error — discrepancy between a doctor’s employment record book and the position listed in the Schedule. The MoH cross-checks this with the Pension Fund of Ukraine database.
• Signing of documents by an unauthorised person. The application is submitted either by the head of the legal entity or by an authorised person under a notarised power of attorney. Signatures of an accountant or manager without a power of attorney are grounds for returning the documents.
• Non-compliance of the material and technical base. Areas smaller than the DBN minimum, missing accessibility certificate, absent dedicated rooms for specific specialties.
• Non-compliance of personnel composition. Missing certificate for a specific specialty, expired certificate, lack of a head with the “Healthcare Organisation and Management” specialty.
• Missing specialty declared for service provision. A clinic wants to provide IVF — but “medical genetics” is not listed. A clinic offers cosmetology services — but the doctor holds only a dermatology certificate, without cosmetology.
• Improperly executed equipment documentation. Equipment not entered in the Ukrainian Register of Medical Devices.
• Unregistered lease agreement. The MoH verifies the registration of the premises lease agreement.

In case of refusal, the licensee has the right to:

• Resubmit the application after correcting the deficiencies — with no limit on the number of attempts.
• Challenge the decision in court. We have handled such cases — in most instances, the MoH agrees to re-examine the case before a court ruling is issued.

Amendments to the Licence: When and How

An MoH licence is open-ended. But that does not mean “got it and forgot it”.

Under sub-clause 10 of clause 13 of the Licensing Conditions, the licensee is required to notify the licensing authority of all changes to the data specified in the documents submitted when the licence was obtained. If this is not done on time, the activity is in effect carried out in breach — which, upon inspection, can become grounds for licence suspension.

The most frequent changes requiring MoH notification:

• Dismissal or hiring of a new doctor. Particularly if this is the specialist whose qualifications were the basis for including a specialty in the licence. For example: the only oral surgeon resigns — the “oral surgery” specialty automatically loses its basis.
• Change of premises address. A clinic relocation is not an “internal matter” — it requires a separate document package for the MoH.
• Expansion of the list of specialties. For example, adding orthodontics to a dental licence.
• Opening of a branch or new office. Each address is added to the licence separately.
• Replacement of the head of the medical institution. Documents on the new head with a “Healthcare Organisation and Management” certificate.
• Replacement of equipment. If equipment used as the basis for providing a service in a particular specialty is replaced.

Separately — the update of licensing files under Cabinet of Ministers Resolution No. 781, as discussed above. This is not an “amendment” in the classical sense, but a mandatory migration of the entire file into the new form by 8 July 2026.

Liability for Operating Without a Medical Practice Licence

An often underestimated issue.

Administrative liability. For carrying out economic activity in medical practice without obtaining a licence — a fine of 1,000 to 2,000 tax-free minimum incomes (as of 2025, UAH 17,000 to 34,000), with confiscation of manufactured products, tools of production, raw materials, and money.

Criminal liability. Article 138 of the Criminal Code of Ukraine “Illegal Medical Activity” — for practising medicine without a special permit, if it has caused serious consequences for the patient, the penalty is restriction of liberty for up to three years or imprisonment for the same term.

Civil liability. Any patient who has received services from an unlicensed clinic has the right to recover the full cost of treatment and to claim damages for moral harm. Insurance companies do not cover such risks — liability falls personally on the owner of the establishment.

Reputational consequences. Information on fines and criminal proceedings is published in open registers (Unified State Register of Court Decisions, MoH Licence Register). This automatically closes off the possibility of contracting with the NHSU, insurance companies, or medical networks.

How Dextra Law Handles Medical Licensing: 4 Stages of Our Support

№	Stage	What Dextra Law does
1	Consultation and audit of the medical institution	Analysis of your case: legal form (sole proprietor or LLC), list of specialties, premises, personnel composition. Verification of the material and technical base and the qualification documents of personnel. A roadmap tailored 100% to your situation.
2	Preparation of documents	Application, Schedule of Information (Appendix 2), Inventory of Documents (Appendix 3), set of qualification and technical documents. We prepare everything in the format that the MoH accepts on the first attempt.
3	Submission of documents to the MoH and follow-up	We file through the “Single Window” on your behalf. Deadline control, responding to MoH queries, prompt correction of any remarks.
4	Licence issuance and post-licensing support	We obtain the MoH licence and the extract from the Licence Register. We hand over the internal documents package for the clinic. As needed — a legal subscription: licence amendments, MoH inspections, document updates upon legislative changes.

Cases from Our Practice

Case 1. Refusal due to personnel data inconsistencies

The situation. A dental clinic with three doctors submitted licence documents. The Schedule of Information listed an orthopaedic doctor as the principal specialist for the “orthopaedic dentistry” specialty. However, the doctor’s employment record listed his position as “general practice dentist”. On the face of it, a minor discrepancy.

Legal basis. The MoH cross-checks the data in the Schedule of Information with the Pension Fund register and the employment record book. Any discrepancy is grounds for refusal under clause 13 of the Licensing Conditions.

Outcome. MoH refusal. 10 working days lost. The doctor’s employment record had to be amended, and the documents resubmitted.

Takeaway from the case. A personnel audit before submission is not a formality. At the preparation stage, we verify not only the presence of the certificate, but also the correspondence between the employment record entry, the position in the staffing schedule, and the specialty name in the licence. Three points that must match down to the comma.

Case 2. A sole proprietor without medical education opened a cosmetology office

The situation. The client — an entrepreneur without medical education — wanted to open a cosmetology office. He hired two cosmetologist doctors. The question: “Can I even get a medical licence as a sole proprietor without a doctor’s diploma?”

Legal basis. The Licensing Conditions allow a sole proprietor to obtain a licence without medical education, provided that a profile specialist is employed on staff. Qualification is confirmed by the documents of the doctor who actually delivers the service.

Outcome. We registered the sole proprietorship, employed both cosmetologists under employment contracts, and submitted the documents to the MoH. The licence was issued on first submission within the standard 10 working days. The office has been operating for over two years.

Case 3. Licence expansion through addition of a new specialty

The situation. A gynaecological clinic operating as an LLC under two specialties (obstetrics and gynaecology + ultrasound diagnostics) decided to open an aesthetic gynaecology direction. This is a separate specialty that required a separate amendment to the licence.

I should add separately: the clinic initially planned “not to formalise it additionally”, believing that “it’s all gynaecology anyway”. A standard mistake.

Legal basis. Providing services in a specialty not included in the licence is a breach of the Licensing Conditions and potentially article 138 of the Criminal Code. Aesthetic gynaecology requires separate certification of the doctor and a separate listing in the Schedule of Information.

Outcome. We prepared the licence amendment package and obtained confirmation within 30 calendar days. The clinic now legally provides the service with transparent documentation, which removes the risks of inspections and patient lawsuits.

Case 4. Failure to update personnel data on time — MoH notice

The situation. A multidisciplinary medical centre (LLC, 8 specialties). Over one and a half years of operation, 4 doctors resigned and new ones joined. No notifications were filed with the MoH — management considered it an “internal clinic matter”.

Legal basis. Sub-clause 10 of clause 13 of the Licensing Conditions directly obliges the licensee to notify the MoH of all changes to the data. Failure to comply is a breach of the licensing conditions.

Outcome. During a scheduled MoH inspection, the discrepancy between the Schedule of Information and the actual staff was identified. A notice was issued requiring rectification of the breach within 30 days; otherwise, the licence would be suspended. We supported the full personnel data update procedure, prepared updated Schedules of Information, and defended the clinic’s interests.

I want to say separately: this is the most common scenario we encounter among clients who have been operating for more than 2 years. They obtained the licence, started with enthusiasm — and then “got caught up” in operations and forgot about the licensee’s obligations. A legal subscription at UAH 5,000–8,000 per month (illustrative figures, not an offer) saves you from risks worth hundreds of thousands.

“The most expensive mistakes do not happen at the moment the licence is obtained. The most expensive ones come a year or a year and a half later, when the clinic is already running, but the documents have not kept pace with reality. A patient who has filed a complaint, an insurance company that has refused to pay out, an MoH inspection — and everything that was not formalised on time surfaces at once.”

— From Dextra Law’s experience supporting medical clinics

Why Clients Choose Dextra Law for Medical Licensing

Dextra Law has been specialising in the licensing of economic activities in medical practice since 2015. What we guarantee to every client:

• Specialised expertise. Over 200 successfully obtained MoH licences — from family doctor offices to ART clinics.
• Individual approach. Each document package is tailored to the specific case. We do not work from templates — in medical licensing, templates simply do not work.
• Full turnkey cycle. From consultation to licence issuance and post-licensing support. Preparation of both packages — for the MoH and the internal one.
• Work across all directions. Dentistry, plastic surgery, reproductive medicine, family medicine, dermatology, psychiatry, rehabilitation, pharmaceuticals.
• Confidentiality. All client data is protected by an NDA and an internal information processing protocol.
• Post-licensing support. Legal subscription: licence amendments, MoH inspections, document updates upon legislative changes, appeals.
• Transparent timelines. No promises of “3 days” where 30 are objectively needed. No promises of “without the MoH” — we work within the legal framework.

Free consultation on medical practice licensing:

dextralaw.com  |  info@dextralaw.com

Related Dextra Law Resources for Medical Institutions

If you are planning to open a clinic in a specific direction, we have prepared specialised materials covering all sector-specific nuances:

• Licence for a Dental Clinic — licensing specifics for 6 dental specialties, office requirements.
• Medical Licence for a Plastic Surgery Clinic — operating block, anaesthesiology, professional liability insurance.
• Medical Licence for a Reproductive Medicine Clinic (ART) — embryology laboratory, cryobank, NHSU contract for free IVF.
• Contracts in Dental Clinics — informed consent, warranty provisions, treatment agreement.
• Contracts in Plastic Surgery Clinics — surgical consent, waiver of aesthetic outcome claims.
• Contracts in Reproductive Medicine Clinics — full contract package for ART and surrogacy.
• Legal Support of Surrogacy — a separate service for couples and agencies.
• Medical Device Registration — mandatory procedure for equipment used in a clinic.
• Pharmaceutical Registration — for clinics operating with their own pharmacy service.

Frequently Asked Questions