NMR registration, licence renewal, appeals: Telangana doctors' body submits suggestions on NMC draft regulations amendment
National Medical Register
Telangana: Submitting its suggestions on the Draft Registration of Medical Practitioners and Licence to Practice Medicine (Amendment) Regulations, 2026, a doctors' body has asked the National Medical Commission (NMC) to simplify the registration, renewal, and appeal process for the National Medical Register (NMR).
Writing to the Ethics and Medical Registration Board (EMRB) of NMC, the association has requested an automated, completely online and simple renewal process. Further, they have also recommended the implementation of a transparent, time-bound, and easily accessible online process for appealing against rejection of registration/licence.
Medical Dialogues had earlier reported that, after publishing the Draft in the Gazette on 11.08.2026, the Commission had invited objections and suggestions from the stakeholders within 30 days from the date of the Gazette notification.
Healthcare Reforms Doctors Association (HRDA) has welcomed the Commission's efforts to streamline medical registration, strengthen transparency and establish an integrated National Medical Register.
While the association extended its support for the provision enabling a doctor with valid State registration and NMR UID to practise across India without obtaining fresh registration in every State, it also recommended that there should be a simple online mechanism for the State Medical Council to be informed when a doctor commences practice in its jurisdiction, without requiring fresh registration or additional licensing formalities.
Further, the association said that the final regulations should clearly define primary registration, NMR UID, licence to practise and State-wise practice details to avoid administrative and legal ambiguity. It also called for a simple, online, and automated renewal process wherever eligibility requirements are fulfilled.
"Adequate advance reminders and a reasonable grace period of at least six months should be provided before a doctor's status is changed to inactive," it suggested.
HRDA has further recommended that a doctor should not lose the right to practise merely due to an inadvertent administrative or technical delay. It opined that a simple restoration mechanism should be provided for genuine cases, including technical difficulties or unavoidable circumstances.
While the association has supported the jurisdiction being determined primarily by where the cause of action occurred, it added that the regulations should clearly address cases involving multiple States, telemedicine, doctors practising at multiple locations and hospital groups, while preventing parallel proceedings for the same cause of action.
Pointing out that the draft proposed including the details of disciplinary proceedings and orders in the NMR, HRDA suggested that no adverse entry should be treated as a final finding until due process is completed.
"The doctor must have adequate opportunity to respond, defend the case and avail the prescribed appeal process. The regulations should also provide for correction/removal of entries following exoneration or successful appeal," it said.
Regarding the appeal mechanism, HRDA recommended that the appeal process against rejection of registration/licence should be transparent, time-bound and easily accessible online. Processing fees should remain reasonable, and personal/virtual hearings should be available where substantive professional rights are involved, it said.
Although the association has welcomed the proposed electronic synchronisation, it opined that a clearly defined mechanism and time limit should be provided for correcting technical errors, duplicate entries or incorrect registration/disciplinary information so that doctors do not suffer due to portal or database errors.
"Adequate time, advance communication and technical support should be provided to existing registered doctors for migration to the NMR. Existing valid registration should not be interrupted merely because of difficulties in completing the online migration process. No fee for one-time UID generation is appropriate and should be retained," it said.
Further, the association has stressed the need for continued consultation with State Medical Councils and representative doctors' organisations during implementation, along with clear implementation guidelines and FAQs to ensure uniform application across States.
"HRDA Telangana supports the objective of creating a unified, transparent and digitally integrated medical registration system. At the same time, the final regulations should balance regulatory oversight with the practical realities of medical practice and ensure due process, protection of professional rights, minimal administrative burden and effective State-level coordination," HRDA said.
Also Read: No NMR registration fee for doctors, unified portal to generate IDs, NMC clarifies
