Kuala Lumpur, 04 January 2026 — The Galen Centre for Health and Social Policy expresses serious concern that delays in the processing and issuance of the 2026 Annual Practising Certificate (APC) are creating avoidable medicolegal, patient-safety, and regulatory-compliance risks across both the public and private health sectors. The Malaysian Medical Association’s warning that this could possibly affect tens of thousands of doctors, in both the public and private sectors, is potentially describing a major crisis needing swift resolution.

The Galen Centre notes the Malaysian Medical Council’s (MMC) recent statement that no action will be taken against medical practitioners who submitted complete applications, made payment, and complied with requirements on or before 31 December 2025. Such practitioners are permitted to continue practising until the APC is issued and their effective dates will be backdated to 1 January 2026 or date of professional indemnity coverage, and does not depend on the actual date of the APC’s approval/issuance.

“While this assurance is important for continuity of services as well as preventing regulatory and enforcement actions from MMC and the Ministry of Health’s Private Medical Practice Control Section (CKAPS) which enforces compliance with the Private Healthcare Facilities and Services Act 1998, we remain concerned that frontline health providers and healthcare institutions may still face practical compliance, documentation and medicolegal challenges and vulnerable to legal action,” said Azrul Mohd Khalib, Chief Executive Officer of the Galen Centre for Health and Social Policy.

“Especially where third parties require proof of APC status such as insurance companies providing professional indemnity, processing health insurance claims, and even procurement of pharmaceutical products.”

“Delays in the issuing of APCs for healthcare professionals are not unique. Most countries which benefit from high quality healthcare systems such as Malaysia, have oversight and regulatory bodies which will require temporary suspension of affected healthcare personnel until the situation is regularised. It is intended to protect all parties concerned, particularly patients from harm,” said Azrul.

“While good intentioned and aimed to prevent thousands of affected doctors from being unable to do their work, does a MMC waiver or non-enforcement by CKAPS provide protection from lawsuits or a legal shield for potential offences under various legislation and regulation committed as a result of not having an APC? How will the safety of patients be affected?”

“The Medical Act 1971 makes it an offence for a fully registered practitioner to practise when they do not have an APC in force, and it also limits recovery of fees for work done during the period without a valid APC. In other words, affected healthcare professionals such as GPs and specialists will not be able to legally charge consultation or procedure fees,” Azrul pointed out.

“The requirement for an APC is also mandated under the Poisons Act 1952. A valid Annual Practicing Certificate is a fundamental legal requirement for a qualified medical practitioner in Malaysia to procure pharmaceutical products from manufacturers and wholesalers. Someone without a valid APC cannot legally purchase medicines from suppliers.”

“The MMC has recently reminded the Malaysian public to utilise the Medical Register Information and Technical System (MeRITS) to verify the validity and registration status of medical practitioners, particularly to prevent fraud and malpractice. It will not show that the doctor in question has submitted completed applications, made payment, complied with CPD requirements, and is under review. What the public will see are registered doctors without APCs. It could create mistrust and loss of confidence among the public.”

The Medical Act 1971 clearly states that the absence of a practitioner’s name from the published Gazette list is prima facie evidence that an APC has not been issued and that the person is not authorised to practise as a fully registered person.

“The MMC has also previously reminded practitioners and employers that practising without a valid APC engages regulatory consequences, and that employers should ensure practitioners without a valid APC are not assigned clinical functions. Any reversal of that position places healthcare professionals and their employers at legal risk, especially in a medical accident,” emphasised Azrul.

This situation should be a wake-up call for the MMC and other related healthcare regulatory bodies to adopt urgent reforms and for healthcare professionals to be responsible in ensuring that they keep their APCs up to date and not rush for the website at the last minute. The system should be resilient enough to prevent and adapt to end-of-year bottlenecks, including earlier processing windows and automated checks for completeness.

This situation should be a wake-up call for the MMC and other related healthcare regulatory bodies to adopt urgent reforms and for healthcare professionals to be responsible in ensuring that they keep their APCs up to date and not rush for the website at the last minute. 

Any widespread uncertainty around practising status risks unintended service disruption such as last-minute roster gaps, cancelled elective procedures, delayed referrals, and disruption to continuity of care. This situation was preventable but it requires cooperation and collaboration from all parties. Immediate risk-reduction measures need to be undertaken.

The Galen Centre emphasises that patient safety is best protected when regulatory processes are clear, timely, verifiable, and administratively efficient, and when employers have workable mechanisms to confirm staff compliance.