Licensing a clinic or a pharmacy in Oman — two different answers

A private clinic in Oman can in principle be 100% foreign-owned. A retail pharmacy cannot — its owner, or at least one of its partners, must be an Omani pharmacist. That single split decides your shareholding, your partner search and your timeline, and it does not come from the foreign-investment negative list.

The split that decides your structure

Take the clinic first. Ministerial Decision 231/2024, the executive regulation of the medical practice law, sets out in Article 5 who may apply for a private health establishment licence: a company incorporated under the commercial law and entered in the commercial register, whose owners, partners and shareholders are of good character with no felony or dishonour convictions, who do not hold a stake in an establishment with unresolved violations, and who have not owned an establishment whose licence was revoked in the previous two years. There is no requirement that any owner be a physician, and no Omani-nationality condition at all.

Nor does the foreign-investment side close the door. Ministerial Decision 209/2020 lists 70 activities closed to foreign investment and Ministerial Decision 435/2024 added 28 more; no healthcare, clinic, hospital or medical activity appears on either list. Royal Decree 50/2019, the Foreign Capital Investment Law, permits a foreign investor to own an investment project wholly in permitted activities, and neither it nor its regulation sets a general minimum capital. One caveat from the gov.om service page itself: it states that GCC nationals must be residents of the Sultanate to invest fully without an Omani partner.

Article 13 adds a second constraint that catches investors planning a chain: a licensed pharmacist must manage the pharmaceutical establishment, and one pharmacist may not manage more than one facility. Existing establishments at the time the law came into force had five years to comply, extendable to ten by Cabinet decision, and heirs of a deceased owner get five years to regularise. The pharmaceutical establishment licence itself runs for two years under Article 15 and must be displayed prominently.

Who licenses what

Readers are routinely sent to the wrong body. The map, as the decrees actually set it out:

• The Ministry of Health licenses both the establishment and the individual practitioner. Article 7 of Royal Decree 75/2019 is explicit: no person may practise medicine or an allied health profession without an MOH licence. Royal Decree 10/2024 sets the Ministry's competences.
• Within MOH, the Directorate General of Private Health Establishments (DGPHE) handles clinic licensing and assessment; the Drug Safety Center handles pharmacies, pharmacists, pharmacy assistants and medical representatives.
• MOCIIP issues the commercial registration and reserves the trade name — the CR is submitted un-activated at the start and activated before final inspection.
• The municipality and civil defence issue the premises certificates, and you need a medical waste disposal contract with Be'ah and a cleaning contract before final inspection.
• The Oman Medical Specialty Board (OMSB) runs the examinations. It does not issue the licence.

That last line is where almost every consultancy article goes wrong. Royal Decree 31/2006 established OMSB with objectives that are about preparing and qualifying physicians, developing training programmes and securing international recognition of them; Article 12 lets it approve specialty training plans and Article 15 lets it recommend award of training-completion and examination certificates. The decree gives OMSB no power to license a practitioner. Licensing sits with MOH under RD 75/2019 Article 7.

Ministerial Decision 231/2024 — the regulation now in force

MD 231/2024 was issued on 4 September 2024 and published in Official Gazette No. 1561 on 8 September 2024. It is the executive regulation of RD 75/2019 and it repealed five earlier decisions — MD 52/98, MD 53/98, MD 54/98, MD 25/2009 and MD 124/2015. It runs to six chapters: definitions, licensing of private health establishments, practitioner qualifications, institutional obligations, sterilisation, and DNA fingerprinting. Its appendix lists more than 40 categories of private health establishment — general hospitals, specialist clinics, dialysis centres, day-surgery units, physiotherapy centres, traditional and complementary medicine centres and so on. Under Article 11 the establishment licence is valid for three years, renewable for like periods, with the renewal application filed 60 days before expiry.

Licensing a clinic, step by step

1. Submit an application letter with an un-activated commercial registration and the owner's ID to DGPHE Licensing and Assessment.
2. Pay the application fee — RO 100 in the Ministry's manual.
3. Receive an Initial Approval Letter, valid between six months and one year.
4. Submit an architectural sketch stamped by an approved engineering office.
5. Get the sketch approved — the SOP allows two to three weeks at this stage.
6. License your health professionals. The SOP is explicit that staff must be licensed before the establishment licence is printed.
7. Request the final inspection with the activated CR, the approved sketch, municipal and civil defence certificates, the Be'ah medical waste contract, the cleaning contract and the reserved trade name from MOCIIP. A medical director must be appointed before final inspection.
8. Receive the licence, valid three years.

The SOP sets an initial compliance review of the application within 10 days, and routes specialised departments — IVF, endoscopy, radiology — for additional review by the Department of Medical Technologies. Against those internal timings, the gov.om service page states a processing time of 180 days across an eight-step process. Treat 180 days as the number to plan a lease and a payroll around; the 10-day and two-to-three-week figures describe individual stages, not the whole file.

The bank guarantee nobody publishes

Article 8(5) of MD 231/2024 requires an unconditional bank guarantee in favour of the Ministry, issued by a bank licensed in Oman, of a value and duration determined by the Ministry. Small and medium enterprises are exempt. The regulation itself states no figure — and no Ministry of Health page publishes the amount. We looked. If a consultancy blog gives you a specific number for the clinic bank guarantee in Oman, that number is not traceable to any government source, and you should treat it as unverifiable rather than as a budget line. The same applies to the "OMR 150,000 minimum capital for foreign investors" figure that still circulates: it derives from Royal Decree 102/94, which RD 50/2019 repealed.

What it costs

These come from Ministerial Decision 71/2024, effective 17 March 2024, which repealed MD 239/2018. Each figure is per three-year licence. The gov.om service page independently confirms the headline numbers — hospital OMR 3,000, medical complex OMR 2,000 in Muscat and OMR 1,000 outside, centre OMR 1,000 and OMR 500, clinic OMR 500 in Muscat — which is unusual and welcome; most Omani fee schedules are published in only one place.

One thing the sources do not reconcile: the Ministry's manual states an RO 100 application fee while MD 71/2024 and gov.om state OMR 500 for a Muscat clinic. The most consistent reading is that the RO 100 is the fee for the initial approval letter and the schedule fee falls due at licence issue — but no official page says so, and we are not going to present an inference as a rule. Budget for both and ask DGPHE which applies at which stage. Practitioner fees are separate, also set by MD 71/2024, and run per two years:

• Medicine — OMR 20 for an Omani, OMR 100 for a non-Omani. Pharmacy — the same, OMR 20 and OMR 100.
• Allied health — OMR 20 and OMR 50. Pharmacy assistant — OMR 20 and OMR 50.
• Professional examination or interview fees — medical OMR 100, allied health OMR 50, pharmacy OMR 30, pharmacy assistant OMR 20.
• Visiting physician — OMR 150 per visit.
• A government doctor working part-time in the private sector — OMR 100 a year; a private institution using government doctors — OMR 300 a year. Those arrangements are governed by Ministerial Decision 29/2018.

There is a second exam fee, and no official page reconciles the two. gov.om prices the OMSB Occupational Classification examination at OMR 84.70 for medical specialists and OMR 77.00 for medical allied health, while MD 71/2024 sets the MOH exam or interview fee separately. MOH's SOPs describe both a Pearson VUE test and an MOH viva for doctors, with two to three re-take attempts, and a VIVA-only route for pharmacists — which suggests the fees are sequential rather than alternative. No government page states that.

Premises: the distance rules and the minimum areas

Article 8(1) of MD 231/2024 requires a minimum of 100 metres between a new facility and the nearest public pharmacy, or the nearest private health facility of the same specialty, measured from the centre of the main entrance. Facilities inside commercial complexes are exempt. This is the rule most likely to kill a lease you have already signed, and it is checkable before you sign.

A retail pharmacy is governed separately, by Article 29 of Ministerial Decision 113/2020: minimum 24 m² of internal area, at least 100 metres from the nearest health facility, at least 200 metres from another public pharmacy, measured from the midpoint of the main entrance, on the ground floor on the main façade of the building — again with an exception for commercial complexes. Separate dispensing and pharmaceutical-counselling zones are required, and the storefront glass must be UV-protected. A pharmacy authorised to open 24 hours needs a front-façade window and an external electric bell for night duty. Note that the two decisions are both in force and do different work: the 200-metre rule is pharmacy-to-pharmacy only, and the Ministry's establishment manual states no distance rule at all.

Those areas come from the Ministry's licensing manual, which also sets a minimum ceiling height of 2.70 m, a minimum patient door opening of 86.35 cm, public corridors at least 1.50 m wide, and mandatory wheelchair accessibility. On staffing, the same manual requires a full- or part-time specialist or consultant pathologist plus at least one DGPHE-licensed laboratory technician for a laboratory, and a specialist or consultant radiologist plus a DGPHE-licensed radiographer for radiology. All clinical staff must hold valid basic CPR certification. A facility must have enough DGPHE-licensed doctors, nurses and allied staff, and cannot operate with part-time specialists and consultants only.

Licensing the practitioner

Registration comes first. The MOH Directorate General of Human Resources runs practitioner registration through the eHealth portal for medical, nursing, pharmacy and allied health staff in both the government and private sectors. It is free of charge, takes five business days, and allows a maximum of three rounds of feedback before rejection. Documents not in Arabic or English need certified translation.

Licensing then follows under Article 17 of MD 231/2024: passing the prescribed professional assessment, entry in the register, good character with no dishonour convictions, medical fitness, mandatory training courses, vaccinations, and professional liability insurance in the private sector or a compensation-fund contribution in the public sector. The practitioner licence runs two years in the private sector and three in the public sector.

Experience thresholds in the MOH standard operating procedure

• General practitioner — bachelor degree, Pearson VUE test, internship and four years' experience.
• Specialist Level 2 — no mandatory post-specialty experience.
• Specialist Level 3 — three years post-specialty.
• Consultant Level 2 — six years post-specialty. Consultant Level 3 — twelve years.
• Alternative medicine — a three-year certificate, though the same source elsewhere states a bachelor degree plus two years.

Allied health professionals need a bachelor degree plus two years' recent experience, or a diploma plus three years'. The document set includes a CV, transcript, passport, DataFlow primary-source verification of qualifications, a sponsor letter, labour card, medical insurance and photographs. DataFlow takes real time and is the step foreign hires most often underestimate.

Opening a pharmacy

Article 10 of RD 35/2015 is the base rule: no pharmaceutical establishment may open without an MOH licence. On the personnel side, Article 16 of MD 113/2020 requires a pharmacist to have three or more years of practical experience, registration in the national registry, a pass in the professional examination, and no continuous absence from practice exceeding one year. Article 11 permits registration of foreign-trained pharmacists — the qualification is not the barrier to foreign involvement; the ownership rule is.

Article 28 of MD 113/2020 sets the general premises conditions for any pharmaceutical establishment:

• Reinforced concrete construction, sealed tile or marble flooring, washable interior paint.
• Air conditioning maintaining a maximum of 24 °C.
• Refrigeration at 2–8 °C and below 0 °C, with temperature logs — recorded twice daily under Article 34.
• A locked cabinet for controlled drugs (Article 28(9)) and closed waste containers.
• Veterinary products and pesticides segregated; expired medicines stored in labelled, sealed boxes; a numbered, officially stamped register of controlled-substance prescriptions under Article 35(4).

A private in-hospital pharmacy is a different category under Article 32: it may be located only inside a private hospital and needs a minimum of 20 m². And a practical point for staffing cover — under Article 36 a pharmacy assistant may run the pharmacy in the responsible pharmacist's absence for a maximum of 60 days a year, consecutive or not, with prior notice to the Directorate, and may not dispense narcotics or psychotropics in that period.

Beyond the OMR 300 general pharmacy fee in MD 71/2024, the Drug Safety Center publishes fees for the other pharmaceutical establishments: a factory at OMR 1,500, a warehouse at OMR 450, an analysis laboratory and studies centre at OMR 600, and a consulting office at OMR 300. Licensing a pharmacist, pharmacy assistant or medical representative takes 14 working days and requires a pass in the VIVA oral test at the Directorate, plus an ID or resident card, a valid visa for non-Omanis, a two-year professional liability insurance policy and a photograph.

Medicines held outside a pharmacy

Clinics often assume they can keep a dispensary. Ministerial Decision 185/2020, issued 14 December 2020, says otherwise. Under Article 4 a private health establishment may stock medicines only if it is licensed, located in an area with no pharmaceutical establishment, and at least 1 km from the nearest licensed pharmacy. All three conditions, not one of them.

The decision carries three schedules: Schedule I essential clinic drugs, Schedule II emergency drugs for facilities without operating theatres, and Schedule III emergency drugs for facilities with theatres. Diazepam in Schedule I and midazolam in Schedule III carry an express note to obtain the required licence. Article 9 puts storage and dispensing in the hands of the pharmacist or pharmacy assistant, or the facility's medical director if neither is present; Article 8(7) requires a prescription register; Article 12 penalises violations under the pharmacy and narcotics laws. The Ministry has never published a list of the "areas without pharmaceutical facilities" in which the exemption applies, which makes the first condition impossible to verify from the outside before you apply.

Controlled drugs

If you will handle narcotics or psychotropics at all — and a clinic with an operating theatre will — Royal Decree 17/99 is the instrument that governs your day-to-day record-keeping, and it is the one with the harshest consequences for sloppiness.

• Article 15 — trade in controlled substances is restricted to licensed pharmaceutical establishments meeting ministerially-set criteria.
• Article 18 — permits are issued by the Minister or a delegate, valid one year, renewable, and void if unused within 90 days.
• Article 25 — storage in original containers in a locked, dedicated store.
• Article 26 — dispensing only against a prescription written in indelible ink on an authorised form, within maximum quantities, issued within three days. Article 27 — the pharmacist annotates the licence card with quantity and date and takes the patient's signed receipt.
• Article 31 — numbered, sequentially paged special registers of all receipts and disbursements. Article 32 — quarterly returns to the administrative authority in the first week of every three months.

What no official source publishes

• The bank guarantee amount. MD 231/2024 leaves it to Ministry determination and no MOH page states a figure.
• Any minimum capital for a clinic or hospital. RD 50/2019 and MD 72/2020 set none.
• The pass mark, syllabus or blueprint for the OMSB examinations. OMSB directs enquiries to its Occupational Classification examinations office rather than publishing them.
• The list of "areas without pharmaceutical facilities" where a clinic may stock medicines under MD 185/2020, and the list of "underserved regions" where the Omani-pharmacist ownership rule may be waived.
• Any Omanisation percentage for the private health sector. RD 53/2023 delegates the percentages to ministerial decision; we could not locate a decision publishing health-sector ratios. Separately, no medical, nursing, pharmacy or laboratory profession appears on the lists of professions closed to non-Omanis in MD 235/2022 or MD 501/2024.
• What happened to the RD 35/2015 Article 13 deadline requiring MOH to Omanise the pharmacy sector within ten years of the law entering into force — a period that would have run out around 2025 or 2026. No follow-up decision was found.
• Qualification criteria for the medical director. MD 231/2024 names the role; the requirement to appoint one before final inspection appears in the Ministry's manual; neither publishes what the post-holder must hold.

Penalties

The pharmacy law is where the criminal exposure sits. Article 36 of RD 35/2015 punishes unlicensed practice and document fraud with six months to three years' imprisonment and a fine of OMR 500 to OMR 2,000, and trafficking counterfeit or expired drugs with three to seven years and OMR 2,000 to OMR 5,000, with possible licence revocation and closure. Under RD 17/99, failure to keep the controlled-substance registers carries imprisonment of not less than one year, a fine of OMR 300 to OMR 500 and licence suspension — and Article 63 requires mandatory closure of a pharmacy where a controlled-substance offence occurs, with permanent closure on repeat. On the clinic side, remember MD 231/2024 Article 5 bars anyone who owned an establishment whose licence was revoked in the past two years from applying again.

If you are at the stage of assembling the file rather than deciding whether to proceed, our office in Al Ghubra handles the commercial registration, the trade name reservation and the municipality and civil defence side of the paperwork, and can tell you which counter each MOH step goes to. The clinical licensing decisions themselves stay with DGPHE and the Drug Safety Center.