Setting up a medical practice company in Geneva: practising licence, OKP admission, needs clause, RCC number and TARDOC

The Geneva path: licence, OKP admission, RCC number

To open a medical practice in Geneva, a doctor first applies for a practising licence to the Cantonal Medical Officer’s Service. Federal law requires this licence from anyone practising under their own professional responsibility (Art. 34 of the Medical Professions Act, MedPA), together with the federal or a recognised diploma, the matching federal postgraduate title and command of an official language of the canton, which in Geneva means French (Art. 36 MedPA). Since 1 March 2025 the service no longer runs a walk-in desk and receives applicants by appointment requested by e-mail.

Next comes admission to OKP. The cantonal FAQ sets the order: a valid practising licence is a condition for admission, which is therefore issued after the licence, although both applications may be filed together. The third step is the creditor number, called RCC in French and ZSR in German, which lets an admitted doctor or institution issue prescriptions and invoices charged to OKP. Geneva is explicit that this number is not an admission, and that it is issued for independent activity to individuals and to institutions alike. It is managed by santéservices sa, the name under which the former SASIS SA has operated since 1 July 2026.

Geneva’s needs clause since 2021

Federal law obliges cantons to limit, by specialty or region, the number of doctors providing outpatient services charged to OKP (Art. 55a of the Federal Health Insurance Act, HIA). In Geneva the limitation has gone through three phases, as described by the canton.

• From 1 July 2021: the amendment to the HIA enters into force.
• From 1 October 2022 to 30 June 2025: Geneva applies the transitional provisions. The outpatient supply surveyed per specialty serves as the maximum number; new admissions are granted only below that figure, otherwise applications join a waiting list per specialty.
• Since 1 July 2025: a federal calculation method applies, dividing the reference supply by a care coverage rate calculated by the Federal Office of Public Health and, where relevant, applying a weighting factor.

Since 1 December 2023, Geneva has not applied the limitation to doctors licensed in certain primary care specialties. Any reduction in activity rate or cessation of outpatient activity must be reported in writing to the Cantonal Medical Officer’s Service, because the activity rate feeds the monitoring of supply. For a company, that means the partners’ agreement should say who reports what, and when.

Group practice or medical establishment: a distinction with consequences

The Geneva Health Act subjects the creation, extension, transformation and operation of any health institution to authorisation (Art. 101), but excludes individual and group practices from that chapter (Art. 100 para. 3). The Regulation on Health Professions defines what a group practice is: a grouping of individual practices that share premises and/or staff, each of which must have its own business identification number (Art. 1 para. 2). Such a group practice needs no operating authorisation.

A single GmbH or AG that employs the doctors and invoices in its own name does not match that definition. It may fall under private medical establishments, whose operating authorisation can be granted when, among other conditions, the establishment is medically directed by a responsible doctor holding a postgraduate title and admitted to bill OKP (Art. 20 of the Regulation on Health Institutions). The application is signed by the future operator and the responsible professional and comes with a commercial register extract for a legal entity and approved plans of the premises (Art. 4); one authorisation covers all the establishment’s sites, and the canton charges a CHF 1,650 fee. Whether a project is a group practice or an establishment is a question to settle with the Cantonal Medical Officer’s Service before the company is incorporated.

At federal level, the company that bills OKP is in any case a service provider under the HIA, an outpatient institution run by doctors (Art. 35 para. 2 let. n HIA), admitted if it works with licensed doctors holding a postgraduate title and meets the quality requirements (Art. 39 of the Health Insurance Ordinance). The cantonal notion of health institution and the federal notion of outpatient institution do not overlap.

A GmbH or an AG for the practice: what changes

The company holds neither the practising licence nor the doctors’ admission conditions. Doctors working in an outpatient institution must themselves have worked three years at a recognised Swiss postgraduate training institution and have the language skills of the region (Art. 37 para. 1 and 2 HIA). What the company changes is the economics of the practice.

• Invoicing: once admitted, the company obtains its own RCC number and bills in its own name.
• Doctors’ status: a partner doctor becomes an employee of the company, with old-age insurance contributions, accident insurance and an occupational pension on the salary.
• Tax: profit is taxed in the company; the doctor is taxed on salary and dividends. At federal level, dividends from a holding of at least 10% are taxable at 70% (Art. 20 para. 1bis of the Federal Act on Direct Federal Taxation). Our overview of taxation in Switzerland sets out the principles.
• Capital and form: CHF 20,000 for a GmbH, CHF 100,000 with at least CHF 50,000 paid up for an AG; the trade-offs are compared in our GmbH or AG in Geneva comparison.
• Succession: shares change hands instead of individual assets, but the value of the practice still depends on the successors’ admissions.

Doctors based in France or licensed in another canton

Geneva draws doctors from neighbouring France and from other French-speaking cantons, and the Regulation on Health Professions organises their temporary practice.

• Foreign nationals: those entitled under international treaties to practise independently in Switzerland without a licence for up to 90 days per calendar year must notify the competent authority, stating their activities, place of work and planned dates, with the certificates required by federal law (Art. 4 para. 1).
• Doctors licensed in another canton: they may practise independently for up to 90 days per calendar year, on notification and with a document from their licensing authority confirming that no disciplinary proceedings are pending (Art. 4 para. 2). The notification procedure is subject to a fee.
• Permanent practice: beyond that, a Geneva practising licence is required, and OKP billing requires the three years of practice in Switzerland.

For a doctor who lives in Haute-Savoie or the Pays de Gex and wants to join a Geneva practice company, the 90-day regime is a bridge, not a model: the company’s revenue plan cannot rest on it.

Geneva obligations: on-call duty, insurance, age limit, register

• On-call duty: doctors practising under their own responsibility take part in the on-call service organised by the professional associations and approved by the cantonal health office (Art. 6 of the Regulation on Health Professions).
• Insurance: health professionals practising under their own responsibility must hold professional liability insurance (Art. 78 para. 2 of the Health Act), a duty that also flows from federal law (Art. 40 MedPA).
• Age limit: the practising licence lapses at 70 and the doctor is removed from the register; to continue, the doctor applies with a medical certificate and the licence may be extended for three years, then every two years (Art. 75 of the Health Act).
• Register: licences, notifications and declarations are entered in a public register kept by profession, and registered professionals must report any fact that could change their entry (Art. 76 of the Health Act).

TARDOC, VAT and taxation of a Geneva practice

Since 1 January 2026, outpatient medical services are billed under the overall tariff system made of TARDOC and outpatient flat rates, which replaced TARMED. According to the Federal Office of Public Health, TARDOC has around 1,400 tariff items against more than 4,600 before, while the roughly 300 flat rates target services mainly provided in hospitals at first. For a practice company, the switch affects billing software, revenue tracking per doctor and, often, the pay formula between partners.

On VAT, medical treatment provided by licensed doctors is excluded from the tax (Art. 21 para. 2 no. 3 VAT Act). The practice charges no VAT on consultations, but cannot recover the VAT paid on fitting out the premises or on equipment used for that treatment, which belongs in the financing plan from the start.

Mistakes we see on these files

• Incorporating and signing the lease first, then discovering a waiting list in the specialty.
• Assuming a non-admitted doctor can bill OKP as an employee of the practice, which the canton expressly rules out.
• Calling a single company that employs all the doctors a “group practice”: under Geneva’s definition, a group practice brings together individual practices with their own identification numbers, and a different structure may need an operating authorisation.
• Confusing the 90-day notification with permanent practice for doctors based in France.
• Forgetting non-recoverable VAT on the fit-out in the financing plan.

FAQ: setting up a medical practice in Geneva

Does a group practice in Geneva need an operating authorisation?

Not a group practice within the meaning of Geneva law, that is a grouping of individual practices sharing premises or staff, each with its own business identification number. A single GmbH or AG that employs the doctors and invoices in its own name may instead be a private medical establishment requiring an operating authorisation and a CHF 1,650 fee; the Cantonal Medical Officer’s Service confirms the classification.

Can a doctor not admitted to OKP work in a Geneva practice company?

They can be employed, but they cannot provide care charged to OKP in the company’s name. Geneva states that being employed by an outpatient institution cannot be used to get around the needs clause.

How does the needs clause work in Geneva today?

Since 1 July 2025, maximum numbers are calculated with a federal method. When a specialty is at its maximum, new applications go on a waiting list. Since 1 December 2023, certain primary care specialties are not subject to the limitation.

Can a doctor living in France practise in Geneva?

Temporarily, yes: nationals entitled under international treaties may practise independently for up to 90 days per calendar year after notifying the authority. For permanent practice, a Geneva licence is needed, and billing OKP requires three years at a recognised Swiss postgraduate training institution.

What happens to a Geneva practising licence at 70?

It lapses and the doctor is removed from the register. A doctor who wishes to continue applies with a medical certificate; the licence may be extended for three years, then every two years.

Does a Geneva practice charge VAT?

No, for medical treatment by licensed doctors, which is excluded from VAT. The corollary is that VAT paid on the fit-out and on equipment used for that treatment cannot be recovered.

Sources

• Medical Professions Act (MedPA, SR 811.11), Art. 34, 36 and 40 (in French)
• Federal Health Insurance Act (HIA, SR 832.10), Art. 35, 36, 37 and 55a (in French)
• Health Insurance Ordinance (SR 832.102), Art. 39 (in French)
• Canton of Geneva, Practising licence for health professions (in French)
• Canton of Geneva, FAQ on OKP admission (in French)
• Canton of Geneva, Needs clause (in French)
• Canton of Geneva, Creating a health institution (in French)
• Geneva Health Act (K 1 03), Art. 75, 76, 78, 100 and 101 (in French)
• Geneva Regulation on Health Institutions (K 2 05.06), Art. 4 and 20 (in French)
• Geneva Regulation on Health Professions (K 3 02.01), Art. 1, 4 and 6 (in French)
• Federal Office of Public Health, TARDOC and outpatient flat rates (in French)
• Federal Act on Value Added Tax (VAT Act, SR 641.20), Art. 21
• Federal Act on Direct Federal Taxation (SR 642.11), Art. 20 (in French)