New public registry for Health Care Institutions

The Business Registers Agency (“BRA”) announced the establishment of a new public registry for healthcare institutions that starts operating as of October 11th this year. This represents a massive improvement compared to the system currently in use. Up until now, commercial courts have been in charge of registering healthcare institutions and maintenance of the related registers. This implies that there was no such thing as a single register to round up all the records. These were in fact all kept separately. Each commercial court in Serbia kept the records of data pertaining to their territory. One could not access any information without personally going to the corresponding court keeping the records in question.

The new Healthcare Law (Law on Healthcare Protection), which came into force on April 11th 2019, introduced changes by prescribing that the BRA takes over the registers and establishes a new public registry within 18 months as of the day the Law enters into force.

The new registry will represent an electronic, public and unified database of all registered healthcare institutions, as stipulated by the Law. The integrated records of healthcare entities will consist of consolidated data on healthcare institutions and private practice at the territory of the Republic of Serbia.

Harmonization procedure

Healthcare institutions, both public and private, registered with the relevant commercial courts, are now under obligation to harmonize/synchronize (their records?) with the new healthcare register. The harmonization procedure is initiated by submitting an application for registration to BRA, together with all the required documents. This harmonization procedure will last for three months, starting on October 11th 2020 until January 11th 2021, during which time the BRA will not charge any fees for submitting the applications in question. On expiration of the harmonization period, i.e. after January 11th 2021, all entities will be charged a fee in the amount of 4.900,00 RSD and required to submit a proof of payment together with their application.

Documentation required

Aside from the application form, the following must be submitted to BRA (either as original or certified copies):
• Valid Incorporation act;
• New statute;
• Approval obtained from the relevant body for the new statute of the publicly owned healthcare institution;
• Decision or the extract from the institution’s act determining the weekly working schedule, as well as the start and end of working hours at a healthcare institution.

Please note that the new Healthcare Law, Article 264, prescribes the obligation for healthcare institutions of amending their general acts and working schedule under the provisions of the Law, within 12 months as of entering into force, that is until April 11th 2020. The Law also stipulates the mandatory elements to be comprised by an incorporation act and statute in Articles 32 and 124 respectively.