KUALA LUMPUR, Jan 2 — The Malaysian Medical Council’s (MMC) delay in approving annual practising certificates (APC) for 2026 has rendered many doctors in government service and private practice unable to legally practise medicine.
An undated notice on MMC’s website stated that the MMC was receiving a “very high” number of APC applications, requesting patience from medical practitioners for their APC approvals.
“The present situation raises concern because failure to issue APCs in a timely manner may inadvertently expose compliant practitioners to the risk of being deemed to practise without a valid APC — an outcome that is neither intended by the statute nor justifiable in law when the practitioner has fulfilled all statutory obligations,” Federation of Private Medical Practitioners’ Associations Malaysia (FPMPAM) president Dr G. Shanmuganathan told CodeBlue in a statement.
“Pursuant to Section 20 of the Medical Act 1971, a registered medical practitioner is required to apply for an APC within the prescribed period and to fulfil the stipulated conditions, including continuing professional development requirements and payment of the prescribed fee.
“Where such requirements have been met in full and on time, the Act places a corresponding obligation on the Registrar to process and issue the APC.
“It is a well established principle of administrative law that where a statutory duty is imposed on an authority, that duty must be exercised reasonably, fairly, and within a reasonable time. A delay in administrative processing, particularly where no fault lies with the applicant, should not result in prejudicial consequences to the affected party.”
Section 20(7) of the Medical Act 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.
A private general practitioner (GP) told CodeBlue that as of December 30, 2025, the doctors who just obtained their APC 2026 showed a serial number of 58xxx series. CodeBlue’s checks yesterday on the APC status of MMC council members showed one with a 70xxx APC 2026 serial number. If that is among the most recent APC approvals, this suggests that potentially thousands of doctors may have been left unlicensed to practise medicine since yesterday.
According to the MMC’s 2024 annual report, the number of APCs issued has increased every year from 44,802 in 2017 to 71,374 in 2023 and 74,333 in 2024. The number of APC approvals for the year 2025 isn’t available publicly.
Ironically, CodeBlue’s check as at 9.30am today of MMC’s Merits portal – which enables the general public to search for registered doctors – showed that 10 of 33 MMC council members themselves did not have a 2026 APC; their 2025 APC was displayed as the most recent.
These 10 doctors without a 2026 APC, comprising nearly a third of the regulator’s council members, include a Health deputy director-general and two state health directors in the Ministry of Health (MOH), two surgeons, and two O&G specialists.
The president of the MMC, which regulates Malaysia’s medical profession, is Dr Mahathar Abd Wahab, who is also the Health director-general in the MOH (he has a 2026 APC).
Following a brouhaha over newly appointed Youth and Sports Minister Dr Taufiq Johari’s medical qualifications, Dr Mahathar said in a statement last December 23 that all individuals who wish to practise medicine in Malaysia must be registered with the MMC and hold a valid APC, as he encouraged the public to check the Merits portal.
In an earlier statement on June 17, 2025, the MMC emphasised that it was an offence under Section 20 of the Medical Act for any registered medical practitioner to practise medicine without holding a valid and current APC, as it granted a grace period until December 31, 2025, for APC renewal applications.
“Effective 1st January 2026, any practitioner found to be practicing without a valid APC may be subject to disciplinary action by the Council in accordance with the provisions of the Medical Act 1971,” said the MMC.
“The Council further emphasises that it is the responsibility of employers to ensure that any practitioner without a valid APC is not permitted to practise medicine or be assigned to any clinical functions.”
In a December 17, 2024 statement, the MMC stressed that practising medicine without a valid and current APC was “illegal” under the Medical Act. “Both the practitioner and the employer, if convicted, may face penalties under the Act.”
CodeBlue has requested Dr Mahathar for comment, including the number of APC 2026 applications pending approval, as well as whether he (as MMC president) would instruct university hospitals, private hospitals, and GP clinics to halt doctors from practising medicine without their APC.
CodeBlue also asked Dr Mahathar if he (as Health DG) would issue a circular to all MOH hospitals and clinics to pull clinicians out of duty rosters pending their 2026 APC issuance.
Hartal Doktor Kontrak (HDK) spokesman Dr Muhammad Yassin, who is practising at a university hospital in Kuantan, Pahang, said his 2026 APC still hasn’t been issued since he submitted an application last November 20, some six weeks ago.
“MMC has not approved thousands of applications for APC renewals for 2026; many have been under review since middle November,” Dr Yassin told CodeBlue yesterday. “In a Facebook group consisting of GPs, hundreds of them said they haven’t got their APC.”
He added that APC renewal typically took one to two weeks at the most. The APC renewal process is completed entirely online via the MMC’s Merits portal.
Dr Shanmuganathan said a doctor told him that his APC application was denied because the words “Petaling Jaya” in the address column were repeated.
A private GP based in Johor said the APC 2026 delays were under discussion in a doctors’ Telegram group with some 3,000 members.
“MMC has blamed doctors for late applications close to the November 30 deadline. However, MMC with automation and computerisation, should be able to handle this or change their system,” the GP, who requested anonymity, told CodeBlue.
“If JPJ (Road Transport Department), which handles two million vehicle licensing renewals per month (23 million annually) that require third-party insurance verification, surely MMC should be able to handle it even if all 80,000 doctors apply on November 30, giving MMC one month to handle all applications during December?”
MMC’s new chief executive officer, Dr Zakiah Mohd Said, was appointed last December 22.
FPMPAM told the MMC to assure medical practitioners that those who have duly applied and paid for their APC within the prescribed timeframe would not be deemed non-compliant, besides calling for “interim administrative measures to ensure continuity of lawful medical practice pending issuance of APCs”.
In its statement last month, the MMC expressed its commitment to “protecting patient safety” and ensuring that the public receives health care services only from “medical practitioners who are truly qualified and registered”.
It’s unclear if any doctor without a 2026 APC illegally practised medicine yesterday. Dr Yassin said New Year’s Day tends to see more trauma cases. Dr Shanmuganathan highlighted other medicolegal issues, including potential lawsuits or insurance denials of treatment by doctors without their APC.
