The Regulation on Medical Reports Has Been Published.
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The Regulation on Medical Reports (“Regulation”) entered into force upon its publication in the Official Gazette dated 19 May 2026 and numbered 33258. The Regulation comprehensively revises the rules concerning which healthcare service providers may issue medical reports, and under which procedures and formats such reports may be issued, as well as the application, examination, electronic system, objection and supervision processes. The purpose of the Regulation is stated as determining the procedures and principles regarding the issuance of medical reports, report formats, objection processes, and the duties, powers and responsibilities of the relevant personnel.
The Regulation has a broad scope of application, as it covers not only public healthcare institutions but also all official and private healthcare service providers, private law legal entities and natural persons. In this respect, the Regulation will have direct consequences for a wide range of stakeholders, from family physicians and private hospitals to employers, institutions requesting medical reports and individuals.
This article summarizes the main changes introduced by the Regulation.
Digitalization of Medical Report Processes
One of the most notable aspects of the new Regulation is the emphasis placed on conducting medical report processes through electronic systems. As a rule, persons requesting a medical report must first complete or update the personal health information form via e-Government. For persons under the age of 18, this process must be carried out by their parent or guardian.
As also reflected in the statements of the Ministry of Health, the Regulation aims to make the e-Nabız and e-Government infrastructure more central in application processes. Accordingly, where there is no diagnosis, medication use or declared health condition preventing the issuance of a medical report, a Health Status Certificate may be issued via e-Nabız. Where the declaration is inconsistent with the health information available in the system, the person will be referred to a physician.
The Regulation further provides that reports integrated into the e-Report system shall be issued through this system. Except for reports that cannot be transferred to the e-Report system, wet-signed reports will not be deemed valid. This constitutes an important step in terms of ensuring the verifiability and traceability of reports and preventing forgery.
Standardization of Report Formats
Pursuant to the Regulation, report formats will be determined by the Ministry of Health and published on the Ministry’s website. Hospitals affiliated with the Ministry, university hospitals, other public healthcare institutions, private hospitals licensed by the Ministry, private medical centers and primary healthcare service providers will be required to comply with these formats.
This provision is important in terms of reducing practical issues frequently encountered in practice, such as the issuance of reports in different formats, different interpretations of report content by institutions, and uncertainties regarding the validity of reports.
Restructuring of Medical Boards
With the Regulation, two main board structures come to the fore in relation to medical board reports: the fully equipped medical board and the three-physician medical board. The fully equipped medical board consists of specialists in internal medicine, general surgery, ophthalmology, otorhinolaryngology, neurology, psychiatry, and physical medicine and rehabilitation or orthopedics and traumatology, under the chairmanship of the chief physician or another physician appointed by the chief physician. The three-physician medical board, on the other hand, is formed with the participation of three specialists from the relevant branch or, where necessary, physicians from specialties closest to the relevant branch.
Through this structure, except for the cases determined by the Ministry, it is aimed to facilitate the process of obtaining medical board reports by allowing certain medical board reports to be issued by three physicians.
Time Limits for Sick Leave Reports
The Regulation introduces significant limits regarding sick leave reports. Accordingly, a single-physician report may grant sick leave for a maximum of 10 days at once. If a follow-up examination is prescribed in the report, the physician may issue an additional sick leave report for a maximum of 10 days following the follow-up examination. If the illness continues after the follow-up examination and the sick leave report to be issued exceeds 10 days, the report must be issued by a medical board. In addition, the total duration of sick leave reports issued by a single physician to the same person within a calendar year may not exceed 40 days.
The Regulation also provides that sick leave reports are part of the medical examination and that no separate fee may be charged to individuals under the name of a “sick leave report fee”.
Limitation on Special Statements in Health Status Reports
One of the provisions of the Regulation that may have significant practical implications is that medical reports must, as a rule, only reflect the person’s health status. According to the Regulation, the purpose for which the report is obtained may not be included in the report unless the relevant legislation sets out a specific health criterion for that purpose or the Ministry of Health approves the inclusion of such special statement in the report.
This approach aims to ensure that reports remain within the boundaries of medical assessment and to prevent physicians from using expressions that may give rise to legal or administrative consequences, such as “fit to work”, “unfit to work” or “fit to perform this duty”, in cases where such expressions are not expressly provided for under the relevant legislation.
Limited Authorization Regime for Private Healthcare Service Providers
The Regulation separately addresses the authority of private healthcare service providers to issue medical reports. Accordingly, private healthcare service providers may issue sick leave/incapacity reports for the patients they treat, as well as medical reports concerning the use of medicines, medical devices and materials used in their treatment. However, except for cases permitted by the Ministry, private healthcare service providers will not be allowed to issue other health status reports.
In order for private healthcare service providers to be authorized to issue health status reports, certain conditions must be met, such as the relevant specialties being registered in the hospital license and the physician serving as a board member working full-time at the hospital.
Special Rules on Marriage, Athlete Licenses, Firearm Licenses and Disability Reports
In addition to the general procedure for medical reports, the Regulation also includes specific provisions for certain types of reports.
For pre-marital medical reports, prospective spouses are required to complete the application and informed consent forms, as well as the pre-marital examination information form, through electronic systems. Where no issue is detected in the test results, the report may be approved electronically, and the individuals may access the report through electronic health systems.
In terms of sports activities, it is stated that, except for athlete licenses, no medical report is required for school sports licenses or sports activities for social purposes, and participation in sports may be ensured with a Health Status Certificate. This is also one of the issues particularly emphasized in family medicine practice.
The content of reports, examination criteria and statements that may be included in reports are regulated in detail in areas such as firearm licenses, smoothbore hunting rifle licenses, private security officer candidacy, engagement in explosive substance-related activities, disability medical board reports and special consumption tax exemption. In particular, with respect to disability medical board reports, the provisions requiring the type, side and rates of disability to be separately specified in assessments concerning vehicle purchases within the scope of the special consumption tax exemption are noteworthy.
Limitations on Reports Issued within the Scope of Remote Healthcare Services
The Regulation also introduces specific provisions regarding the issuance of medical reports within the scope of remote healthcare services. Accordingly, to the extent permitted by remote healthcare services, a medical report may be issued based on examination, observation and monitoring. However, the identity of the person for whom the report will be issued must be verified through official documents via video call. In addition, health status reports may not be issued through remote assessment, except for patients receiving home healthcare services. Medical reports to be issued for the first time also cannot be issued through remote assessment.
This framework allows for the issuance of reports within telehealth practices, while imposing significant limitations depending on the nature of the report and whether the person is being assessed for the first time.
Validity Period of Reports, Existing Reports and Transition Process
Health status reports other than those bearing a permanent statement will be valid for one year, unless otherwise specified by the physicians. Reports issued before the entry into force of the Regulation in accordance with the procedures, principles and formats determined by the Ministry will remain valid until the expiry of their validity period. In addition, the system integration for the Health Status Certificate is required to be completed within one year from the publication date of the Regulation.
Sanctions for Reports Contrary to Truth, Medical Science and Procedure
The Regulation provides that medical reports found to have been issued contrary to truth, medical science and procedure shall be deemed invalid and cancelled. In such cases, a criminal complaint may be filed against the relevant persons under the applicable provisions of the Turkish Criminal Code; disciplinary proceedings may also be initiated, and notifications may be made to the relevant professional organizations. For private healthcare service providers, consequences such as cancellation of the authorization to issue reports may arise in cases where reports are issued contrary to truth or where the applicable fee policy is violated.
The Regulation also explicitly provides that, in the event of non-compliance with the Law on the Protection of Personal Data (“LPPD”) and the relevant secondary legislation in the processing of personal health data, action will be taken under the LPPD.
Conclusion
The Regulation introduces significant changes to medical report processes on the axes of digitalization, standardization, determination of authorization limits and auditability. Through the Regulation, it is aimed to ensure more effective use of the e-Report and e-Government infrastructure, determine report formats by the Ministry, limit the authority of private healthcare service providers to issue reports, clarify time limits for sick leave reports and explicitly set out sanctions for reports issued contrary to truth.
In this respect, the new Regulation is closely relevant not only to individuals’ processes for obtaining medical reports, but also to the internal operations of healthcare service providers, the responsibilities of physicians, the scope of authority of private healthcare institutions, employers’ processes for evaluating medical reports and compliance obligations regarding the processing of personal health data. In particular, private healthcare service providers, family physicians, employers and institutions requesting medical reports should review their processes under the new Regulation.
AUTHORS
Nuri Melih İnce
