KUALA LUMPUR, Jan 3 — The Malaysian Medical Council (MMC) announced today that registered medical practitioners are allowed to practise while waiting for approval of their 2026 annual practising certificate (APC).
Doctors who have made payment and complied with requirements under Section 20 of the Medical Act 1971 and Regulation 28 of the 2017 Medical Regulations before or on December 31, 2025, will be permitted to practise medicine pending issuance of their APC for this year, provided that the medical practitioner isn’t subject to any restriction, suspension, or prohibition from practice under any other provision of the Medical Act.
“For applications that are complete and comply with the requirements under Section 20 of the Medical Act 1971 and Regulation 28 of the Medical Regulations 2017, submitted on or before December 31, 2025, the effective date of the APC shall commence on January 1, 2026, or in accordance with the date of professional indemnity coverage, and shall not depend on the date of approval or the date the certificate is issued,” said the MMC in a statement today that was not attributed to a specific official.
“The Malaysian Medical Council (MMC) apologises for the delay in the processing and issuance of the Annual Practising Certificate (APC) for the year 2026, following a sharp increase in the number of applications received at the end of 2025, particularly applications submitted with supporting documents that were received late,” it added.
“The MMC appreciates the patience and cooperation of all medical practitioners and wishes to assure that these measures are taken to ensure the continuity of health care services to the public.
“The MMC will also take appropriate improvement measures to ensure that this issue does not recur in the future.”
MMC’s statement did not specify the number of 2026 APC applications pending approval, after the Malaysian Medical Association (MMA) alleged yesterday that the backlog involved tens of thousands of doctors. Nor did the regulator commit to a timeline to processing the backlogged APC applications.
Although MMC said it would not take disciplinary action against doctors who practise medicine before issuance of their APC, medical practitioners are still open to criminal prosecution should patients file police reports against them for violation of Section 20(7) of the Medical Act.
Section 20(7) states that a fully registered medical practitioner who practises medicine, surgery, or obstetrics and gynaecology (O&G), and who does not have an APC in force, shall be guilty of an offence under the Act. These doctors are also prohibited from collecting any fee during the time without an APC.
The Medical Act does not provide for any sort of amnesty or exemption with regards to APC due to administrative delays by the Registrar.
MMC’s Merits portal, which the public relies on to search for registered doctors, doesn’t have details on whether a particular medical practitioner has made a complete application for their 2026 APC, complied with requirements, and is merely awaiting approval – only whether they are licensed to practise medicine with an APC for the year.
MMC permitting doctors to practise without a valid APC doesn’t guarantee continued coverage of medical indemnity during that period. Insurers and takaful operators (ITOs) and third-party administrators (TPAs) may also (lawfully) deny payment to doctors who provide treatment without a 2026 APC.
Neither does MMC refraining from disciplinary action protect medical practitioners (and their employers) from litigation in the event of malpractice suits filed over the practice of medicine without a valid APC.
In other words, MMC’s press statement today only serves to protect doctors from disciplinary action by the MMC, but not from other actors, including patients, police, professional indemnity insurance providers, payers, and the courts.
Several doctors have complained about waiting for more than two months for approval of their APC renewal applications.
Malpractice litigation has been on the rise in Malaysia against doctors in both public and private hospitals. The Federal Court’s 2024 landmark ruling holding a private hospital liable for medical negligence means that hospitals are now open to the risk of liability for negligence from doctors practising in their facilities.
