Practising in another state: what 'transferring' your medical registration actually means

Indian medical registration is granted by a state medical council, which makes an obvious question surprisingly hard to answer: what happens when you move to a different state?

The short version: there is a defined transfer procedure, it is a transfer rather than a fresh registration, and your registration number is meant to survive it. The National Medical Commission's Registration of Medical Practitioners and Licence to Practice Medicine Regulations, 2023 — notified on 10 May 2023 and published in the Gazette of India on 12 May 2023 — set it out in Clause 9.

The longer version, which is the part that actually affects you: that framework is being rolled out, the regulations themselves say the prevailing system continues until they are in force, and councils differ in how far along they are. This guide covers both — what the gazette says, and where you still have to ask.

What the regulations say the transfer procedure is

Clause 9 of the 2023 regulations, Transfer of Licence to Practice, describes four steps.

You apply to the destination state, through the national portal. "If any medical practitioner registered with the State Medical Council, desirous to practice medicine in another State may apply to the concerned State through the web portal of the Ethics & Medical Registration Board."

Your current council is notified and has 30 days. "On submission of an application for transfer of Licence to Practice, an intimation shall be received by the State Medical Council where the medical practitioner is registered for practice and the State Medical Council within a period of 30 days shall approve the application for transfer of Licence to Practice, if it has no objection thereon."

Silence counts as approval. "If no decision is taken within 30 days of receipt of the transfer of registration the same shall be deemed to have been approved."

The destination council issues the licence for that state, and — the provision most worth knowing — "the unique number of the registration shall remain the same and the prefixed Code of the concerned State/Union Territory shall be substitute with the Code of the new State/Union Territory."

Finally, "the changes made in respect of the State, shall automatically reflected in the National Register."

One inconsistency in the text, stated rather than smoothed over

Clause 6, on the first grant of a licence, says the registration number is formed such that "a Unique Identification Number shall be suffixed with a Code of the concerned State/Union Territory". Clause 9, on transfer, refers to "the prefixed Code".

Suffixed in one clause, prefixed in the other. This is in the published gazette text, not a transcription error here. The substantive point — your unique number persists and only the state code changes — is consistent across both. The formatting is not, so do not build an expectation about what your certificate will look like on either wording.

What "deemed approved" is actually worth

The 30-day deemed-approval clause is the most useful thing in Clause 9, and it is worth understanding precisely what it does and does not do.

It removes inaction as a way for your current council to stall a move. It does not remove a considered objection — the clause approves on no decision, not on a refusal. And it is a rule in a regulation, which is not the same as a button in a portal. If your transfer is sitting unmoved past 30 days, the clause gives you something specific and citable to escalate with, which is more than most administrative processes offer.

Note also what the clause is silent on: it gives no timeline for the destination council to issue the certificate once the transfer is approved.

Transfer is not the same as holding licences in two states

These get conflated, and they are different transactions.

Transfer moves your licence to practise from one state to another. That is Clause 9.

Multiple states is contemplated separately, in Clause 6 on the procedure for obtaining a licence: "The eligible person may opt any State/States to practice medicine and the application so made through the web portal shall be referred to the concerned State/ States Medical Council." Each council then "shall satisfy themselves and consider the application for grant of licence to practice medicine in that state after charging appropriate fee within a period of 30 days."

If you consult across a state border, or hold posts in two states, this is the distinction to raise with both councils — because asking for a transfer when you meant to keep both is an expensive misunderstanding.

Where practice still lags the text

Three caveats, all of them in or around the regulations themselves rather than editorialising.

The regulations preserve the existing system in the interim. Clause 4 ends: "Until such time that these Regulations and appropriate sections are in force, licence to practice and prevailing system of Registration shall continue." Parts of the framework — including registration in the National Medical Register being tied to qualifying the National Exit Test — depend on provisions that have not all commenced.

The one-time update was framed as a three-month exercise. Clause 11, the transitory provision, requires practitioners already enrolled on the Indian Medical Register or a state register without a registration number under these regulations to update on the EMRB web portal "within a period of three months of publishing of these Regulation", obtaining the registration number as a one-time measure, with no fee charged by EMRB. Many practitioners' entries were not updated on that timetable, and the National Medical Register onboarding has continued well past it.

Councils differ in what they actually ask for. This is the ordinary reality of a system with a national framework and state-level administration, and it is the same reason renewal rules differ by state. A guide can tell you what the regulation provides. Only your council can tell you what its counter will accept this month.

What to do before you move

Check your National Medical Register entry first. A transfer propagates whatever is already recorded. If your postgraduate qualification was never registered against your number, or your name does not match across documents, moving states does not fix it — it carries the problem to a new council that has less history with your file. The checklist for correcting your register entry covers what to compare.

Separate the council question from the employer question. If you are leaving a government post, a departmental release is a different document from anything the council issues — see the guide to NOCs — and neither authority can substitute for the other.

Ask the destination council directly, in writing. Specifically: does it accept the EMRB portal transfer route today, or does it still require its own application; what documents it wants; and what it charges.

If a council refuses

The regulations provide an appeal route. Under Clause 12, an applicant whose application for grant or renewal of a licence is rejected by a state medical council "may file an appeal to the Ethics and Medical Registration Board against the decision of the State medical Council, within thirty days of receipt of such decision." EMRB is to examine and decide within thirty days, and an order allowing the appeal is binding on the council, which must then grant the licence within fifteen days. A second appeal lies to the NMC within sixty days, and "the decision of the NMC shall be final."

Whether that machinery is quick in practice is a separate question. That it exists, with dates attached, is worth knowing before you accept a refusal as the end of the matter.

Primary sources

• Registration of Medical Practitioners and Licence to Practice Medicine Regulations, 2023, dated 10.05.2023 (EMRB–Registration) — National Medical Commission
• Rules and Regulations — National Medical Commission
• Indian Medical Register — National Medical Commission
• State Medical Councils — National Medical Commission