NMC draft proposes mandatory NMR registration, doctors raise implementation concerns

New Delhi: After the earlier announcement from the Union Health Ministry stating that registration in the National Medical Register (NMR) was voluntary, the National Medical Commission (NMC), in its recent Draft Registration of Medical Practitioners and License to Practice Medicine (Amendment) Regulations, 2026, has proposed making it a mandatory requirement for doctors across the country.

NMR is a dynamic database and will be a central repository of all registered doctors, in which their authenticity is verified by Aadhaar IDs. All the MBBS doctors who are registered on the Indian Medical Register (IMR) were asked to register again on the NMR.

√ The Commission has also proposed in the Draft that once any person/FMG has registered in the concerned State Medical Register; An UID shall be generated centrally by the Ethics & Medical Registration Board (EMRB), National Medical Commission (NMC); thereby granting the practitioner, Registration in NMR and Eligibility to practice medicine anywhere in India.

√ Further, NMC said that "The EMRB shall ensure electronic synchronization of the National Register and the State Register in such a manner that any change in one register is automatically reflected in the other register."

√ NMR will also include the Active/Inactive status of licence to practice medicine and details of disciplinary action against the RMP.

√ The National Medical Register shall serve as the central repository of the registration particulars of Registered Medical Practitioners and of any disciplinary proceedings, orders of suspension, removal, restoration, or any such order issued by a State Medical Council, the Ethics and Medical Registration Board, or the National Medical Commission

√ Transitory Provisions

The Commission has proposed in the Draft that "All the existing medical practitioner enrolled in the Indian Medical Register or the State Medical Register, not having the Unique Identification (UID) number of NMR as per these Regulation shall update in the web portal of the Ethics & Medical Registration Board within stipulated period, as decided by the Ethics & Medical Registration Board and obtain the Unique Identification (UID) Number as a onetime measure. For the purpose of updating of Unique Identification (UID) number of such medical practitioner, no fee shall be charged by EMRB, NMC."

Therefore, if this new Draft is implemented, NMR registration will no longer remain voluntary, as all the medical practitioners shall have to obtain a UID as a one-time measure by updating it in the web portal of the NMC Ethics Board.

Commenting on this, Kerala-based Health Activist Dr KV Babu told Medical Dialogues, "It is a failed experiment. Without much effort, this is going to fail again."

He pointed out that as per the minutes of the 17th meeting of NMC, which was availed by him through an RTI application, only 1800 doctors made entry into the NMR till December 2025 and 30,000 applications were pending. He added that he himself had applied in August 2024 and it is still pending even after two years.

Dr. Babu questioned the requirement of NMR registration again when the doctors are already registered with the State Medical Councils (SMCs) and opined that the data should be updated from the SMC to the NMR portal. 

While Dr Aviral Mathur, Past President of Federation of Resident Doctors Association (FORDA), and currently a consultant at Sir Gangaram Hospital, called NMC's proposed amendment "a step in the right direction", he expressed his concerns regarding the implementation process.

"The NMC’s proposed amendment to make NMR registration mandatory, with a centrally generated UID linked to each doctor’s State Medical Register entry, is a step in the right direction. A unified national register that tracks credentials, licence status, and disciplinary history across states was long overdue. The fragmented state-wise system meant a doctor could face action in one state and continue practising elsewhere without any check - that was a clear patient safety gap. What’s particularly welcome is that the UID will now allow doctors to practise anywhere in India without having to obtain fresh registration in every state. That’s a genuine administrative relief for the medical community, especially for doctors who move or work across state borders," he said.

"However, the devil will be in the implementation. Doctors already registered on state rolls and the old Indian Medical Register are being asked to update their records on the EMRB portal. If the process is cumbersome or unclear, it will create unnecessary anxiety among thousands of practitioners. The NMC has rightly waived the fee for this one-time updation - now they must ensure the portal is functional, the helpdesk is responsive, and the deadline is realistic," he added.

Demanding fairness and implementation of the Draft only after proper discussion with the stakeholders, Dr. Mathur added, "Systemic accountability is not something the medical community opposes. What we ask for is fair, transparent processes. This draft moves towards that, and we hope the final regulation reflects the feedback from stakeholders before it comes into force."

Further, referring to the proposed change in policy by making NMR registration mandatory, Dr Meet Ghonia, General Secretary of FORDA, said, "Such a significant policy shift needs clear justification, transparent communication and proper consultation with the medical fraternity. Existing doctors should also be given a clear transition mechanism without disruption to their practice. Policy changes must be consistent and transparent."

While the Healthcare Reforms Doctors Association (HRDA), Telangana, has supported the objective of a credible, unified and interoperable NMR that can improve verification of doctors’ qualifications, transparency and facilitate legitimate interstate practice, it has expressed that the new Draft raises an important concern regarding the apparent change in the Government’s position.

Commenting on the matter, HRDA State President, Dr. N. Karthik, referred to the Health Ministry's announcement on August 8, 2025 that NMR registration was voluntary and also referred to the new Draft that proposes a much more integrated NMR/UID framework, linking registration and the licence to practise across India with the national system.

"If the Government is now proposing to make NMR/UID effectively mandatory, there should be clear transparency on the reasons for this change in policy, particularly when the earlier position was officially communicated to Parliament. HRDA Telangana is not opposed to NMR or a Unique Identification system. Our concern is that mandatory registration should not create another layer of bureaucracy for doctors who already hold valid registration with a State Medical Council," he said.

He opined that before making it compulsory, the authorities should ensure seamless integration and automatic synchronisation between State Medical Councils and the NMR, without requiring doctors to repeatedly submit existing registration details. He also said that there should be no loss or interruption of the right to practise due to portal failures, technical issues, data mismatches or delays in verification that are beyond the doctor's control.

Further, he called for a reasonable transition period and effective grievance-redressal mechanism before taking any adverse action against a registered doctor, protection of the statutory role of State Medical Councils, with NMR functioning as an integrated national system rather than a parallel registration bureaucracy, and strong data-protection, correction and due-process safeguards, particularly if licence status and disciplinary information are to be reflected in the NMR.

"HRDA Telangana welcomes the objective of “One Nation, One Licence” if it genuinely simplifies registration and enables doctors to practise across India. However, this should be achieved through automatic digital integration of existing State registrations, rather than imposing unnecessary additional compliance on doctors. When the Government had informed Parliament in 2025 that NMR ID application was voluntary, any subsequent move towards mandatory NMR registration deserves a clear public explanation and meaningful consultation with State Medical Councils, medical associations and practising doctors. We urge the NMC and the Union Ministry of Health & Family Welfare to ensure that the final framework is transparent, technically robust, legally sound and doctor-friendly, while protecting patient safety and professional accountability," Dr Karthik added.

Dr Lakshya Kumar Jha, the National Vice President of FAIMA Doctors Association, agreed that a unified and updated database can improve verification of doctors' credentials, strengthen professional regulation and make the system more transparent.

"However, the shift from the earlier position that NMR registration was voluntary to now proposing it as a mandatory requirement raises legitimate concerns about policy consistency and implementation. Doctors who already possess valid registration with their respective State Medical Councils should not be made to bear the burden of repeatedly submitting and verifying information that is already available with statutory regulatory bodies. Ideally, the NMR should be integrated seamlessly with State Medical Registers, so that a doctor's existing registration is automatically reflected in the national database," he added.

"If NMC believes mandatory NMR registration is now necessary, there should be a clear explanation for the change in policy, adequate transition time, a technically reliable portal, robust data-privacy safeguards and, importantly, no adverse consequences for doctors arising from administrative or verification delays beyond their control. The objective of strengthening regulation is commendable, but the implementation should be designed around ease of compliance for doctors rather than creating another layer of bureaucracy," he further mentioned.