KUALA LUMPUR, Jan 2 — The Malaysian Medical Association (MMA) claimed that delays in issuing Annual Practising Certificates (APC) for 2026 have left “tens of thousands of doctors” without their APCs, warning that the situation risks criminalising practitioners who complied with all renewal requirements on time.
MMA president Dr R. Arasu said many registered medical practitioners, particularly those in private practice, were left in legal and professional uncertainty from January 1 after their APCs were not issued despite timely applications.
“This issue is not a minor technical lapse. It is a regulatory failure with legal, professional, and public health consequences,” Dr Arasu said in a statement today. “Doctors who have complied with the law must not be exposed to criminal liability or loss of livelihood due to systemic inefficiencies beyond their control.”
The MMA said many affected doctors had fully complied with all statutory requirements well within the stipulated timeline.
Under Regulation 28 of the Medical Regulations 2017, a registered medical practitioner is required to submit proof of valid professional indemnity insurance, evidence of a minimum of 20 CPD points, and the prescribed renewal fee. Applications typically open from July to November, with penalties imposed only for late submissions in December.
“In the current situation, the delays are not due to non‑compliance by doctors, but arise from administrative backlog and processing inefficiencies,” Dr Arasu said.
CodeBlue earlier reported that delays in issuing APCs for 2026 had left many doctors technically unlicensed to practise medicine at the start of the year, raising medico-legal concerns for both practitioners and health care institutions.
Doctors told CodeBlue that APC approvals appeared significantly backlogged, while checks of the Malaysian Medical Council’s (MMC) public register showed that some council members themselves did not yet display 2026 certificates, highlighting the scale of the administrative delay.
While the immediate financial impact is greatest for doctors in private practice, the implications also extend to the public sector.
Although government doctors continue to receive salaries, Malaysia already faces a doctor shortage, and removing thousands from clinical duties due to APC delays would likely strain services and disrupt care delivery across the public health system.
The MMC is headed by its president, Dr Mahathar Abd Wahab, who is also the Health director-general at the Ministry of Health (MOH). He holds a 2026 APC.
Ironically, 10 of 33 MMC council members themselves do not have a 2026 APC. Their 2025 APC was displayed as the most recent.
The MMA said MMC’s delay carried serious legal implications under the Medical Act 1971, as practising medicine without a valid APC constituted an offence regardless of whether a doctor had met all renewal conditions.
“For private general practitioners, a valid APC is a legal prerequisite to consult, prescribe, and practise,” Dr Arasu said.
“For private specialists, hospitals and medical institutions are compelled to insist on a valid APC due to the high medico-legal exposure, including vicarious liability, where institutions may be held legally responsible if an unlicensed doctor practises within their facilities,” he added.
Dr Arasu said the impact extended beyond legal risk, as doctors in private practice were directly affected when they were unable to practise even for a short period, jeopardising their livelihoods, professional standing, and continuity of patient care.
“This situation is particularly untenable when compliant practitioners are rendered ‘unlicensed’ purely due to administrative delay. It undermines professional morale, disrupts health care delivery, and risks eroding public confidence in medical regulation,” he said.
The MMA said the MMC was statutorily responsible for the registration and regulation of medical practice in Malaysia under the Medical Act 1971, adding that while administrative functions might be carried out by the secretariat, oversight and accountability rested with the council itself.
“The council’s role is not only to enforce compliance, but also to guide the profession and safeguard patients by ensuring regulatory processes function efficiently and fairly.”
The association called for urgent enhancement of the MeRITS system, including a move towards a fully digital APC with real-time status tracking, automated verification of CPD and indemnity, and prompt electronic confirmation upon compliance.
It also urged stronger governance and oversight by the MMC council over its secretariat to prevent a recurrence of administrative failures that place doctors and patients at risk.
Dr Arasu urged the MMC to provide immediate formal assurance that doctors who had submitted all required documents on time could continue practising without penalty during the delay period and that all APCs would be issued by January 31.
“A clear public statement and interim letter from the council would protect compliant doctors, reassure health care institutions, and uphold patient safety,” he said.
Dr Arasu added that the MMA stood ready to engage constructively with the MMC and the Ministry of Health to resolve the backlog and ensure APC issuance processes were modernised and predictable.
“A regulatory system that safeguards patients must also be one that respects and protects compliant practitioners,” he said.