By – Sarthak Katewa 

Abstract

On the 11th of August 2026, the National Medical Commission notified a draft regulation which proposed a single national licensing framework for doctors. Once a doctor has registered with a state medical council and has been assigned a Unique Identification number in the National Medical Register, such a doctor would be free to practice anywhere in India without seeking a fresh registration in another state. A reform which has claimed to ease the shortage of doctors and reduce bureaucratic duplication, the proposal opens the much older question of, where does the state authority over public health end and central regulatory power begin? States often use their registration powers as a check of quality, disciplinary accountability and local health oversights. Centralizing this function through a single UID risks diluting exactly the kind of localized scrutiny which catches malpractice and fraud, or even worse creating a kind of jurisdiction shopping abuse that a truly national register could enable if enforcement architecture at the centre is not equally robust. This piece asks whether India’s federal health governance is ready to trade the friction of state level checks for the promise of a borderless medical workforce. 

Introduction

On the 11th of August 2026 the National Medical Commission (NMC) notified draft amendments to the Registration of Medical Practitioners and License to Practice Medicine Regulations, proposing a Centrally generated Unique Identification number for every registered medical practitioner in India. Under the proposal, once a Doctor or foreign medical graduate is registered with any State Medical Council and allotted a UID in the National Medical Register (NMR) they would be eligible to practice medicine in any state or Union Territory without obtaining fresh registration or a separate state level license. The UID would embed the state or Union Territory along with the Doctor’s State Medical Register number creating a single portable identifier maintained by the NMC’s Ethics and Medical Registration Board under section 31 of the NMC Act, 2019. A mobility enhancing reform, the draft regulation has been described as moving India closer to a one nation, one licence model for medical practice. Yet the administrative simplicity of the proposal masks a deeper constitutional and regulatory question: does centralizing the right to practice through a national register strengthen oversight and patient security? or does it erode the state level accountability mechanisms that have historically acted as a check on malpractice, credential fraud and jurisdictional abuse? 

The Promise of Mobility

The NMC’s reasoning for the UID linked NMR is straightforward: reducing administrative friction thereby enabling doctors to move across states without it re-registering and creating a single, real time view of credentials and disciplinary records. In a country where doctor density varies sharply across states and where rural urban disparities in access to care are acute, the argument that a national register will improve the distribution of medical professionals is intuitively compelling. The draft explicitly notes that once a state medical council grants registration and the Ethics and Medical registration Board (EMRB) allots a UID, the doctor would not require fresh registration or a separate license to practise in another state or union territory. The proposal also promises better accountability. The NMR would serve as a central repository of registration particulars and disciplinary proceedings, including suspensions, removals and restorations, with automatic electronic synchronisation between the national and state registers. Under the current system a doctor facing disciplinary action in one state could in theory relocate and register elsewhere without that history being easily visible, the UID framework is designed to close that loophole. 

The Federalism Question 

But the proposal, for all its administrative neatness, does not quite fit India’s constitutional setup. The Seventh Schedule, specifically Entry 6 of the State List, puts “public health and sanitation; hospitals and dispensaries” directly under the state governments. On the other hand, the Union government gets its authority over medical education and p⁠rofessional standa͏rds mostly from the Concurrent List, alongside specific laws su‍ch as the NMC Act, 2019. Historically, State Medical Councils have done more t͏han just keep records; they have actually served as important guardians of public health standards locally. This includes checking applications, mak‍ing sure renewal conditions are met, and taking disciplinary action against doctors within their particular areas. The new draft regulation tries to maintain this existing balance by keeping disciplinary jurisdiction with the State Medical Council in whose territory the misconduct is said to have happened, that is important. However, the practical effect of having a national Unique Identification Number, or UID, would be separating the right to practice a profession from the actual state that initially provided the registration. For instance, a doctor who is registered in State A co‌uld theoretically continue to practice for an unlimited time in State B. They would not need to ask for new permission from State B’s council. This is true even though State B is the one that wou͏ld deal with the political and administrative problems that come from any medical malpractice or public he‍alth failures. This brings up an accountability issue that the current draft does not entirely address. If a doctor’s UID came from S͏tate A, but they work, and perhaps cause harm in State B, which council really has the main responsibility for overseeing things, for inspection, and for making sure rules are fol‌lowed? The draft tr⁠ies to answer this by s‌aying the state where any incident happened keeps jurisdiction, which makes sense legally. But this is not very clear in terms of how it would work in practice. Especially since the National Medical Register’s centralized database is managed by the Ethics and Medical Registration Board (EMRB) and the National M⁠edical Commission (NMC), not by the individual sta͏tes. 

The Implementation Risk 

In addition to the question of whether the NMC will be able to fulfill the technical and institutional commitments made under the UID framework, there is the question of whether the NMC will be able to fulfill its commitment to launch the NMR. The NMR was launched in August 2024 with great fanfare; however, in December 2025, only about 1,800 out of India’s estimated 14 lakh registered medical practitioners were enrolled in the NMR. There were also approximately 30,000 applications for enrollment that were waiting to be verified. In August 2025, the Union Health Ministry informed Parliament that enrollment in the NMR is voluntary. However, the NMC has recently appeared to reverse this stance via the draft regulations. The Indian Medical Association (IMA) has stated that the previous portal used by the NMC did not function properly, resulting in many doctors experiencing difficulties in enrolling. Additionally, if the NMC attempts to use the same central system again without resolving the functional issues associated with using that system, then the NMC runs the risk of experiencing the same failures as it did previously. Although the draft regulations provide for a single-time update for all currently practicing doctors who do not have a UID, the regulations do not establish a time frame or an enforcement process for non-compliance. Thus, there remains the potential for a split register where some doctors are UID-linked while others are not.

A deeper question of trust

At its heart the UID plan is more about trust than about technology. It believes that a single database, run by the NMC and its EMRB will be more trustworthy, more open and more responsible than the mix of State Medical Registers it wants to take the place of. But trust in groups doesn’t come just from having a database; it comes from steady rules being followed, ways for people to complain that are easy to use and a clear path of responsibility that everyone can understand and depend on. If the NMR ends up being another system that doesn’t have users and has technical problems, like the first version almost did, the outcome might be worse than before. A list that looks complete on paper but doesn’t work well in life gives people the  wrong idea about control while leaving real problems with responsibility not fixed. 

Conclusion

The National Medical Register’s UID proposal is a classic example of a reform that is administratively elegant but constitutionally and operationally fraught. It promises mobility and accountability, yet it risks diluting state-level oversight without guaranteeing that the Centre can fill the gap. The draft regulation’s success will depend not on the sophistication of its database architecture, but on whether the NMC can demonstrate that a centralized register will improve patient safety, reduce malpractice, and strengthen rather than weaken the chain of accountability between doctors, states, and citizens.

About the Author 

Sarthak Katewa is a 5th-year B.A. LL.B student at O.P. Jindal Global University and a columnist of the Centre of New Economic Studies with a focus on Public Policy & Governance. 

Image Source : https://www.nmc.org.in/