CNMC’s recommendations on the OMC’s articles of association

2026-06-01T09:15:00
Spain
Official digital medical certificates and improvements in private electronic prescriptions
CNMC’s recommendations on the OMC’s articles of association
June 1, 2026

The Draft Royal Decree approving the articles of association of the Collegiate Medical Organization (OMC) and those of the General Medical Council of Spain, proposed by the Ministry of Health, aims to unify and update both regulations in a single text. As a result of the request by the same Ministry, the CNMC has issued a report whose content addresses three main sections:

  • membership
  • official medical certificates
  • private electronic prescriptions.

Regarding membership, the CNMC recommends prioritizing less intrusive mechanisms than ex officio membership and expressly contemplating that the actions of the Official Colleges must comply with the limits of the defense of competition (Law 15/2007) and the principles of good regulation and proportionality (Royal Decree 472/2021).

Concerning the second section, the CNMC recommends the adaptation of official medical certificates to the digital environment by facilitating the use of electronic signatures and verification systems, among which it considers that public systems (i.e.  REPS) should be prioritized. It also indicates that, if the electronic format is introduced, criteria must be established to set the prices of the certificates following the type of format (physical or electronic).

Finally, it recommends that the procedure for the approval of private electronic prescription systems be governed by the principles of objectivity, transparency, celerity, procedural economy and non-discrimination. In addition, it recommends implementing safeguards that prevent the exchange of sensitive commercial information by guaranteeing compliance with regulations in defense of competition.

For more information, please contact our specialists through the Knowledge and Innovation Area.

June 1, 2026