A doctor who is properly registered can still be running an unregistered clinic, and a great many are, usually without realising there were two separate things to do.
That is the single most common misunderstanding in this area. Your registration permits you to practise. It does not license the premises you practise in. Those are different registrations, with different authorities, different requirements and different consequences.
This article explains who registers what, what provincial inspectors generally look at, and the specific questions worth putting to your own commission.
An important caveat before anything else. Healthcare regulation in Pakistan is provincial, actively enforced in some provinces and less so in others, and the rules, fee schedules and categories are revised periodically. Nothing here is a substitute for the current requirements published by your own authority or for advice from someone who deals with them regularly. Use this to know what to ask.
The two registrations
The practitioner: PMDC
Registration with the Pakistan Medical and Dental Council is what allows a person to practise medicine or dentistry. It is individual, it attaches to you rather than to any clinic, and it has to be current — a registration obtained years ago and never renewed is not a valid registration.
This matters practically as well as legally. Your registration number belongs on your prescriptions and your signboard, and patients, insurers and corporate panels do check it.
The establishment: your provincial healthcare commission
The premises are licensed separately, by the province. Punjab has the Punjab Healthcare Commission, Sindh the Sindh Healthcare Commission, and Khyber Pakhtunkhwa and Balochistan have their own equivalents. They regulate healthcare establishments — clinics, hospitals, labs, dental setups — rather than individuals.
A clinic is an establishment even when it is one doctor in two rooms. Owners frequently assume the framework is aimed at hospitals and that a small practice falls outside it. That assumption is where most unregistered clinics come from.
Why the distinction matters
Because the consequences differ. A problem with your personal registration is a problem with your ability to practise anywhere. A problem with the establishment licence is a problem with that address, and it can mean notices, penalties, or an instruction to stop operating until it is resolved.
What provincial commissions generally care about
Specific standards differ by province and by the category your clinic falls into, but the themes are consistent, and they are worth understanding before you fit out premises rather than afterwards.
Who is providing the care
That every clinician holds valid registration for what they are doing, and that unqualified staff are not doing clinical work. This is the area inspectors treat most seriously, because it is the one where patients are most directly at risk.
The premises themselves
- Adequate space and separation — consultation, waiting, procedure and dispensing areas.
- Handwashing facilities and clean water.
- A usable, clean patient toilet.
- Lighting, ventilation and general cleanliness.
- Safe electrical installation and a plan for power failure.
Infection control and waste
Segregation of clinical waste, safe sharps disposal, a contract with an authorised disposal service, and sterilisation arrangements for anything reused. This is one of the most commonly failed areas and one of the easiest to fix. The practical side is in infection control and medical waste.
Records
That patient records exist, are legible, are kept securely, and are retained. An inspector asking to see how you record a consultation is asking a reasonable question, and "it is in a register somewhere" is a weak answer. What a defensible record looks like is in patient record management.
Emergency readiness
Appropriate for what you do — a clinic performing procedures is expected to be able to manage a reaction to them. Basic emergency drugs within date, oxygen where relevant, and staff who know where these are.
Display and transparency
Registration details and the practitioner's name and qualification displayed, fees visible, and no claims on your signage that your qualifications do not support.
Preparing properly, before anyone visits
Most clinics that struggle with an inspection are not badly run. They are run on knowledge that lives in people's heads and cannot be shown to a visitor.
Put the documents in one file
- PMDC registration certificates for every clinician, current.
- Qualification certificates.
- The establishment registration or the pending application.
- Lease or ownership documents for the premises.
- The clinical waste disposal contract and recent collection receipts.
- Equipment purchase and any calibration or service records.
- Staff records, including what each person is and is not permitted to do.
- Your written clinic procedures.
One physical file, in a known place, that somebody other than you can produce. A clinic that cannot find its own paperwork looks disorganised in a way that colours everything else in the visit.
Write the procedures down, even briefly
How waste is segregated, how instruments are sterilised, what happens in an emergency, who can access records, how a complaint is handled. Two pages beats nothing by a wide margin, and the act of writing it usually reveals a gap.
Walk your own clinic as a stranger
Look at the toilet. Look at the sharps container — is it the right kind, and is it overfull? Look at your emergency drugs and check the dates. Look at whether registration is actually displayed. These are the findings that come up repeatedly, and all of them are visible in ten minutes to anyone who looks deliberately.
Inspections rarely fail on clinical competence. They fail on an expired adrenaline ampoule, an overfull sharps box, and a file of paperwork that nobody except the owner can locate.
Questions to ask your own commission
These are worth asking directly, in writing where possible, because the answers determine what you need to do and vary more than people expect.
- Which category does a practice like mine fall into, and what standards apply to that category?
- What is the current fee, and what is the renewal cycle?
- What documents must accompany an application?
- Are there minimum requirements for room size, toilet or waiting area that would affect which premises I can use?
- What is required of a clinic that dispenses medicines?
- What is required if I perform minor procedures?
- How much notice is given before an inspection, if any?
- What is the process if a clinic is found non-compliant — is there a period to correct it?
- Does the licence transfer if I move premises, or is a fresh application needed?
The premises question is the one to ask first
Because it is the only one on that list that can make a lease you have already signed unusable. Ask it before you commit to a location, not after.
Registering staff who are not doctors
Clinics think of registration as a doctor question. Several other roles carry their own requirements, and this is an area where small practices are regularly caught out without any intention to cut corners.
Nurses and paramedics
Nursing and allied health roles have their own registration bodies, and what a given qualification permits a person to do is narrower than custom in many clinics assumes. The question to answer honestly is not who performs a task today but whether the person performing it is qualified and registered to.
The dispensing counter
Where a clinic dispenses, the requirements around who may dispense and under what supervision come from drug regulation rather than from the healthcare commission. These are separate frameworks, and satisfying one does not satisfy the other. Ask specifically what your province expects of a clinic pharmacy before you fit one out.
The person who does everything
Small clinics run on one or two people who gradually absorb whatever needs doing — registration, billing, dressings, injections, dispensing. It happens gradually and nobody decides it. Write down what each person is and is not permitted to do, and then check that it matches what actually happens on a busy evening.
Moving, expanding or adding a service
Licences attach to premises and to a declared scope, which makes three ordinary business decisions into regulatory events.
Changing premises
A licence granted for one address does not usually travel to another. Find out whether your province treats a move as a transfer or as a fresh application, because the answer affects how long you can afford the new premises to sit empty.
Adding a second branch
Generally a separate registration for a separate establishment, not an extension of the first. Owners planning a second location sometimes budget for rent and fit-out and forget this entirely.
Adding a service
Starting to dispense, adding a small lab, beginning day procedures, installing imaging — each may change your category and the standards that apply to you. The time to ask is while you are costing the new service, because a requirement discovered afterwards can make it uneconomic.
A partner joining or leaving
Most frameworks expect to be told who practises at an establishment. A consultant who started taking sessions last year and was never declared is a finding waiting to happen, and an easy one to avoid.
Keeping it current
Registration is not a one-off event, and lapses tend to happen quietly.
Diary the renewal dates
Your own registration, the establishment licence, the waste contract, equipment servicing. Put them in a calendar with a reminder a month ahead, because none of these authorities will chase you and all of them matter.
Tell the commission when things change
A new doctor joining, a doctor leaving, a change of premises, a new service. Most frameworks require notification, and the time to find out is not during an inspection that discovers a clinician you never declared.
Keep records of what you fixed
If an issue is raised and you correct it, keep the evidence — the new contract, the dated photograph, the receipt. Demonstrating that you act on findings is worth a great deal at the next visit.
Why this is worth doing beyond compliance
Clinics often treat registration as a cost to be deferred. It has three practical benefits that have nothing to do with avoiding penalties.
Corporate panels will ask
Companies and insurers empanelling a clinic routinely want to see establishment registration. An unregistered clinic is excluded from a revenue stream it may not even know it is being excluded from — the mechanics of that work are in corporate panel billing.
It is your position if something goes wrong
In a complaint or a medico-legal matter, a registered clinic with written procedures and retained records is in a fundamentally different position from one without. This is covered in patient complaints and medico-legal risk.
Patients increasingly check
Displayed registration, a real name and a real qualification are things patients look for, particularly in cities and particularly for a clinic they have not visited before. In a market with genuine quackery, being visibly legitimate is a competitive advantage rather than a formality.
If you are at the stage of setting the practice up, the sequence that puts this in the right order is in how to open a private clinic in Pakistan.
Frequently asked questions
- Do I need to register my clinic separately from my own PMDC registration?
- Yes, and this is the most common misunderstanding in the area. PMDC registration permits a person to practise; it does not license the premises. Healthcare establishments are registered separately at provincial level — the Punjab Healthcare Commission, the Sindh Healthcare Commission and their counterparts. A clinic counts as an establishment even when it is one doctor in two rooms.
- Who regulates private clinics in Pakistan?
- Practitioners are registered by the Pakistan Medical and Dental Council. Establishments are regulated province by province, so which authority applies depends on where your clinic is. Requirements, categories, fee schedules and how actively they are enforced all differ between provinces and are revised periodically, so confirm the current position with your own commission rather than relying on general guidance.
- What do healthcare commission inspectors check in a clinic?
- Themes are consistent even where standards differ: that clinicians hold valid registration for what they do, that premises have adequate space, handwashing, clean water and a usable toilet, that clinical waste is segregated with an authorised disposal contract, that patient records exist and are kept securely, that emergency drugs are in date, and that registration and fees are displayed.
- What should I ask my provincial healthcare commission before opening?
- Which category your practice falls into and what standards apply, the current fee and renewal cycle, required documents, and — most importantly before you sign a lease — whether there are minimum requirements for room size, toilet or waiting area that would make particular premises unusable. Also ask what is required if you dispense medicines or perform minor procedures.
- What happens if a clinic is not registered?
- Consequences differ by province and can include notices, penalties or an instruction to stop operating until resolved. There are also practical costs that owners overlook: corporate panels and insurers routinely require establishment registration before empanelling a clinic, and in any complaint or medico-legal matter a registered clinic with written procedures and retained records is in a markedly stronger position.
- Registration
- Licensing
- PMDC
- Compliance
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