The National Council of the Order of Physicians reaffirmed its reservations regarding the application, in its current form, of electronic invoicing to the medical profession, and this until the completion of the legislative modification and the implementation of the necessary legal and technical safeguards.
The Council stressed that the modernization of the tax system must be gradual, clear, and in accordance with the law, without compromising the specificities of the medical profession, medical confidentiality, or patients’ rights.
It emphasized that medical activity operates in a regulated sector, subject to several mechanisms of declaration, control, and cross-referencing of data. According to it, electronic invoicing cannot be applied to the medical profession without taking into account its particularities, notably the fee note, medical confidentiality, as well as the protection of patients’ personal and medical data.
In a press release published yesterday on its website, the Order of Physicians also recalled that professional secrecy constitutes a fundamental obligation imposed on every physician.
It specified that, since the adoption of provisions extending electronic invoicing to service provisions, the National Council of the Order of Physicians had not considered that the medical profession was automatically affected by this measure, which is subject to a specific regime applicable to non-commercial professions, based mainly on the fee note. The Medical Code of Ethics further provides that the practice of medicine must not have a commercial character.
The Order added that the publication of General Note No. 02 of 2026, relating to the explanation of the provisions of Article 53 of the Finance Law for 2026 and the expansion of the scope of electronic invoicing, had altered the situation. The Council believes that this note went beyond its interpretative role by broadening the scope of the text, thereby subjecting non-commercial professions to this obligation even though they are not expressly mentioned in the article in question.
Following this development, the Council indicated that it had contacted executive and legislative authorities, held several meetings and consultations, and participated in the work on revising the legislative framework. These steps led to the presentation of a proposal to modify the text of the law, which the Council is still awaiting the completion of the process.
