The successful operation of a private medical clinic or an individual medical practitioner depends not only on the professionalism of healthcare personnel, modern equipment, and patients’ trust. Proper legal support for healthcare businesses is equally important, as it helps identify legal risks, ensure regulatory compliance, and protect business interests.

Relocating a clinic to new premises, expanding the range of medical services, changing personnel, or adapting to new regulatory requirements are common aspects of healthcare business development. However, each of these changes may require appropriate legal procedures and documentation.

Relations with patients also require particular attention. Even when medical care has been provided properly, complaints concerning treatment outcomes may lead to disputes in which properly maintained medical records, informed patient consent, and compliance with established procedures can be decisive.

Therefore, legal support for healthcare businesses should not be limited to obtaining a medical license or preparing documents for inspections. Its primary purpose is to ensure compliance with applicable legislation and minimize risks that may affect the stability of a medical practice.

Medical Practice Licensing: Does Your Business Comply with Current Legal Requirements?

Obtaining a license to conduct medical practice is only the initial stage of establishing a legally compliant healthcare business.

Under the Licensing Conditions for Conducting Economic Activities in Medical Practice, approved by Resolution No. 285 of the Cabinet of Ministers of Ukraine dated March 2, 2016 (hereinafter referred to as the Licensing Conditions), license applicants must meet the established requirements, while license holders must comply with them throughout their operations.

In practice, changes in the organization of a medical facility’s activities often require updates to licensing documentation or notification of the Ministry of Health of Ukraine (MOH).

Changes to the location of medical practice. Opening a new medical office or relocating a clinic requires verification that the premises comply with licensing requirements. Medical practice must be conducted at locations declared to the licensing authority. Relevant changes must be reported to the MOH within the prescribed period, including submission of updated information on facilities, equipment, and personnel. The business must also have a valid legal basis for using the premises.

Expansion of medical services. Introducing a new medical specialty or type of medical care may require an extension of the licensed scope of medical practice. The availability of equipment or additional professional training alone does not replace the relevant licensing procedures.

Changes in medical personnel. Engaging new specialists requires proper employment documentation and verification of their professional qualifications. An appropriately qualified specialist must be available for each declared medical specialty. When preparing staffing schedules, healthcare facilities must take into account the List of Healthcare Professions and Positions approved by MOH Order No. 1065 dated July 5, 2025.

Updating licensing documentation. Healthcare legislation is regularly amended. In particular, during 2025–2026, the Licensing Conditions were amended by Cabinet of Ministers Resolutions No. 781 dated July 2, 2025, No. 148 dated February 5, 2026, and No. 813 dated June 24, 2026.

An updated version of the Licensing Conditions has applied since September 1, 2026, introducing changes concerning medical specialties, staffing requirements, and electronic communication with the licensing authority.

Consequently, holding a valid medical license does not necessarily mean that a clinic’s actual operations fully comply with current legislation.

A timely legal audit of a healthcare facility helps verify the accuracy of licensing documentation, identify discrepancies, and determine the measures required to address them.

Legal Protection of Doctors and Clinics in Patient Disputes

Patient complaints concerning treatment outcomes represent one of the most sensitive legal risks in medical practice.

However, the existence of a complaint does not automatically indicate wrongdoing by a doctor. An objective assessment requires consideration of the medical personnel’s actions, compliance with applicable standards of medical care, and proper documentation of treatment.

Particular attention should be paid to:

  • Providing patients with appropriate information about their health condition, treatment objectives, prognosis, and potential risks;
  • Obtaining and properly documenting informed consent for medical interventions;
  • Maintaining medical records in accordance with applicable requirements;
  • Entering the necessary information into Ukraine’s electronic healthcare system;
  • Maintaining medical confidentiality;
  • Protecting patients’ personal data, including when communicating via email and messaging applications.

Incomplete medical documentation may significantly complicate the legal defense of a doctor or healthcare facility, even when medical care has been provided appropriately.

Therefore, legal protection begins long before a dispute arises — with properly organized recordkeeping and internal procedures.

Documents required under the Licensing Conditions play an important role in this process. These include the facility’s charter or regulations, staffing schedule, job descriptions, internal rules, patient clinical pathways, and standard operating procedures.

Proper employment documentation is also important in disputes with employees. Job descriptions, internal labor regulations, and records confirming employees’ acknowledgment of relevant documents help establish individual duties and responsibilities.

At the same time, using generic document templates without considering the specific characteristics of a clinic may not provide adequate legal protection.

Internal documentation should reflect the actual organization of medical practice, staffing structure, range of services, and operational processes.

Several Doctors Operating in the Same Premises: Legal Considerations

A common business model in private healthcare involves several doctors registered as individual entrepreneurs operating from the same premises, or a legal entity sharing premises with self-employed medical practitioners.

Such arrangements can help optimize rental, equipment, and administrative costs. However, they require proper legal structuring.

Each business entity independently providing medical services is a separate license holder and must comply with applicable legal requirements.

In particular, it is necessary to ensure:

  • That medical practice is conducted within the declared specialties and approved locations;
  • Proper documentation of rights to use premises and medical equipment;
  • Display of the required information about each business entity;
  • Preparation and approval of internal documentation by each license holder;
  • Clear procedures for cooperation between doctors and administrative personnel;
  • Proper contractual arrangements with patients;
  • Clear allocation of responsibility for specific medical services.

Special attention should be paid to the shared use of medical equipment, medical waste management, infection prevention and control, and the organization of medical services during air raid alerts.

Sharing premises, equipment, or a commercial brand does not exempt individual license holders from their own legal obligations.

Without proper contractual arrangements, difficulties may arise in determining responsibility in the event of patient complaints, regulatory inspections, or disputes between the parties.

Therefore, cooperation between several independent medical practitioners should be legally structured before joint operations begin.

New Regulatory Requirements for Healthcare Facilities in Ukraine in 2026

Healthcare legislation is subject to regular changes, and compliance with new requirements may necessitate updates to internal documentation and operational procedures.

In 2026, owners of private medical clinics and individual medical practitioners should pay particular attention to the following matters.

Accessibility Requirements for Healthcare Facilities

The Licensing Conditions require medical practice locations to be accessible to persons with disabilities and other persons with reduced mobility.

Compliance with applicable state building standards must be properly documented.

In particular, the relevant confirmation may be issued by a certified specialist authorized to conduct technical inspections of buildings and structures or by an authorized institution.

Therefore, the presence of a ramp or other individual accessibility features does not necessarily demonstrate compliance with all applicable requirements.

Priority Services for War Veterans and Families of Fallen Defenders of Ukraine

The updated Licensing Conditions establish obligations concerning care and priority services for certain legally protected categories of individuals, including war veterans and family members of deceased veterans and fallen Defenders of Ukraine.

To ensure compliance, healthcare facilities should establish appropriate internal procedures and familiarize their personnel with the relevant requirements.

Medical Waste Management

Since April 1, 2025, the State Sanitary Norms and Rules governing medical waste management, including safety requirements for waste generation, collection, storage, transportation, and treatment, approved by MOH Order No. 1827 dated October 31, 2024, have been in effect.

Compliance with these requirements involves, in particular:

  • Appointing a person responsible for medical waste management;
  • Approving a medical waste management scheme;
  • Developing standard operating procedures for the relevant stages of waste handling;
  • Providing personnel training;
  • Organizing proper waste collection, storage, and transfer;
  • Concluding agreements with authorized waste management service providers;
  • Fulfilling applicable waste accounting and reporting obligations.

Individual medical practitioners must also organize the relevant procedures, taking into account the specific nature of their activities.

The exact documentation and procedural requirements depend on the categories of waste generated during medical services.

Operation of Healthcare Facilities During Air Raid Alerts

Cabinet of Ministers Resolutions No. 1092 dated September 4, 2026, and No. 1158 dated September 21, 2026, regulate certain aspects of healthcare operations during threats associated with military hostilities.

In particular, they establish a differentiated approach to organizing medical activities depending on the applicable threat level.

Healthcare facilities and individual medical practitioners must establish appropriate internal response procedures, designate responsible personnel, determine patient notification arrangements, and identify medical processes that cannot be immediately interrupted without endangering patients’ health.

Special attention must also be paid to identifying available protected premises and nearby shelters.

The legislation also takes into account the specific circumstances of providing medical care in shelters during air raid alerts.

The relevant internal documents must be approved within the deadlines established by law. Their absence requires prompt assessment and, where necessary, corrective action.

Adapting Medical Care Standards to Clinic Operations

MOH Order No. 845 dated June 19, 2026, “Certain Issues Concerning the Development of Sectoral Standards in Healthcare,” regulates the development and application of healthcare standards.

Healthcare facilities must ensure that applicable standards are properly reflected in their internal documentation.

In particular, they should establish procedures for organizing medical care, patient pathways, staff responsibilities, required equipment, and the use of medicinal products.

When new standards are approved, the relevant internal documents must be reviewed and updated within the prescribed periods.

Infection Prevention and Control in Healthcare Facilities

Compliance with infection prevention and control requirements is an essential component of medical practice.

Healthcare facilities must ensure compliance with applicable requirements concerning infection prevention, hand hygiene, personal protective equipment, and staff training.

Relevant requirements are established, in particular, by MOH Order No. 1614 dated August 3, 2021.

Proper infection prevention and control requires not only the availability of necessary supplies but also the approval of internal procedures and their effective implementation by personnel.

Legislative Changes to Consider in 2027

Certain regulatory changes in the healthcare sector are scheduled to enter into force on January 1, 2027.

In particular, MOH Order No. 274 dated March 2, 2026, introduces amendments to several regulations concerning accessibility and infection prevention and control.

The repeal of certain regulatory acts governing equipment requirements for healthcare facilities is also envisaged.

Accordingly, clinic owners should assess in advance whether their operations will require updates to internal documentation, organizational procedures, or equipment.

Legal Audit of a Healthcare Facility: What Should Be Checked?

A legal audit of a medical clinic or individual medical practice helps assess compliance with applicable legislation and identify matters requiring further attention.

For an initial self-assessment, healthcare business owners should review the following areas.

Medical Licensing and Organization of Practice

  • Do the actual practice locations, medical specialties, and types of medical care correspond to the information submitted to the MOH?
  • Has the licensing authority been notified of relevant changes within the prescribed deadlines?
  • Do employees’ qualifications and employment arrangements comply with applicable requirements?
  • Are documents confirming the right to use the premises available?
  • Do the facilities and equipment meet regulatory requirements?

Mandatory Internal Documentation

  • Has compliance with accessibility requirements been properly documented?
  • Have procedures for serving war veterans and other legally protected categories been established?
  • Have medical waste management documents been approved?
  • Have procedures for operating during air raid alerts been developed?
  • Have standard operating procedures for infection prevention and control been approved?
  • Do internal documents comply with current medical care standards?

Patient Relations and Medical Documentation

  • Is informed patient consent properly obtained and documented?
  • Are medical records maintained in accordance with applicable requirements?
  • Is the protection of personal data and medical confidentiality ensured?
  • Are procedures for handling patient complaints and claims established?
  • Is the required information about the healthcare facility, doctors, services, and prices publicly available?

Personnel and Internal Operations

  • Are job descriptions and internal labor regulations up to date?
  • Have employees been properly familiarized with the relevant documents?
  • Are contractual relations with other individual medical practitioners and businesses operating on the same premises properly regulated?
  • Are procedures established for responding to inspections and requests from regulatory authorities?
  • Are legislative changes monitored systematically?

A negative answer to an individual question does not necessarily indicate a legal violation. However, it may justify further legal assessment.

Timely identification of deficiencies allows them to be addressed in a planned manner, rather than during a regulatory inspection or legal dispute.

Why Is Ongoing Legal Support Important for Healthcare Businesses?

Legal risks in medical practice may arise in relations with patients, employees, business partners, and public authorities.

When a complaint is received, an inspection begins, or an employment dispute arises, opportunities to correct previously overlooked deficiencies may be limited.

Therefore, ongoing legal support should be considered an important element of healthcare business management.

A preventive legal audit allows a healthcare business to:

  • Verify compliance with medical licensing requirements;
  • Identify deficiencies in internal documentation;
  • Assess risks in relations with patients and employees;
  • Review contractual arrangements with business partners;
  • Determine whether documentation needs updating due to legislative changes;
  • Prepare for potential inspections and disputes.

Legal support cannot eliminate the possibility of complaints or inspections. However, it can reduce legal risks and help ensure that the business is properly prepared to address them.

Legal Services for Private Medical Clinics and Individual Practitioners

Law Firm “Kavchuk & Partners” provides comprehensive legal support for healthcare businesses, including private medical clinics, dental practices, and doctors operating as individual entrepreneurs.

We provide legal assistance both during the establishment of a healthcare business and throughout its ongoing operations.

Our principal areas of legal support include:

Establishment of medical and pharmaceutical facilities. Advising on the appropriate legal structure, assessing premises for regulatory compliance, preparing documentation, and assisting with licensing procedures.

Legal audits of medical practices. Conducting comprehensive reviews of clinics and individual medical practices, identifying legal risks, and preparing recommendations to address identified deficiencies.

Medical licensing support. Preparing documents for obtaining medical licenses, expanding the scope of licensed specialties, changing practice locations, and updating information submitted to the MOH.

Preparation of internal documentation. Drafting internal regulations, orders, job descriptions, standard operating procedures, medical waste management documents, infection prevention and control procedures, air raid response protocols, and documents adapting medical care standards.

Contractual legal services. Drafting and reviewing agreements with patients, employees, individual medical practitioners, suppliers, and other counterparties.

Healthcare business structuring. Legally organizing cooperation between several business entities operating on shared premises, allocating responsibilities, and regulating the use of shared medical equipment.

Protection of healthcare business interests. Providing legal representation during regulatory inspections, resolving patient complaints, employment disputes, and other legal conflicts.

 

Protect the Legal Security of Your Medical Practice

Proper legal support is an important prerequisite for the stable operation and further development of a healthcare business.

Timely reviews of licensing documentation, internal procedures, contracts, and patient-related processes help identify legal risks before they result in disputes or regulatory inspections.

Law Firm “Kavchuk & Partners” can help assess whether your clinic or medical practice complies with applicable legislation, identify the necessary measures, and ensure their proper legal implementation.

Contact Law Firm “Kavchuk & Partners” for professional legal advice and comprehensive legal support for your healthcare business.