If the conseil départemental (departmental council) of the Ordre des médecins, France's medical council, refuses to enter you on its register, or has not answered three months after receiving your complete application, you have 30 days to appeal to the conseil régional or interrégional of the Ordre (its regional council), by registered letter with acknowledgement of receipt. In France, silence here counts as a refusal and opens the same appeal as a written one. The conseil régional has two months to decide. Its decision can then go to the Conseil national (the Ordre's national council) and finally to the Conseil d'État. None of these steps lets you practise while you wait, and none of them goes through an ordinary administrative court.
Who this guide is for
You are a doctor, a national of an EU or EEA country, with a medical qualification obtained in the EU, and you have already applied for registration ("inscription au tableau") with the conseil départemental of the Ordre des médecins in the French département where you plan to work. If you have not applied yet, start with our guide for EU-qualified doctors registering in France, which covers documents, steps and deadlines. This article picks up once the file is in and something has gone wrong: an unexpected summons, a refusal letter, or no news at all.
Two situations are covered at the end: a refusal by the Centre national de gestion (CNG) of an individual authorisation to practise, which follows different rules, and the recognition of your specialist qualification.
Has the Ordre refused your registration, or gone silent? Suxens helps EU doctors read the decision, work out their deadlines and prepare their appeal. Join the waiting list for doctors →
Before any decision: how the Ordre examines your file, and the only grounds for refusal
When your application arrives, the president of the conseil départemental appoints a rapporteur from among the council members, who examines the file and writes a report. The council checks your qualifications and requests bulletin no. 2 of your criminal record (casier judiciaire) (Article R4112-2 of the French Public Health Code).
What matters most: the council can refuse registration on three grounds only:
- you do not meet the requirements of good character (moralité) and independence;
- a lack of professional competence has been established after an expert assessment;
- a disability or medical condition incompatible with practice has been found after an expert assessment.
No refusal can be issued unless you have been invited, by registered letter sent at least fifteen days in advance, to appear before the council and explain yourself. If that letter arrives, treat it as a warning sign that a refusal is being considered, and prepare your answers and any documents that address the issue raised. Any refusal must also state its reasons.
On timing: if the council orders an expert assessment of your competence or health, its deadline can be extended by two months at most. It cannot be extended just to check your qualifications.
No answer: when does silence become a refusal?
The conseil départemental must decide within three months of receiving your complete application (Article L4112-3). Once that period has passed, its silence is treated as an implied refusal, which you can challenge exactly like a written one (Article L4112-4).
Everything therefore hinges on the date your file became complete. To pin it down:
- find the acknowledgement slip of your registered letter, or the date you handed the file in;
- the council president must acknowledge receipt within one month and, where relevant, list any missing documents;
- if documents were requested (see the list of documents for Ordre des médecins registration), note when you sent them: the three months run from the complete file;
- if an expert assessment was ordered, add up to two months.
Your 30 days to appeal start on the day the implied refusal takes effect. This is the classic trap: waiting for a letter that never comes while the appeal deadline runs out. If you are unsure of the date, write to the conseil départemental to ask about your file, and do not wait until the last day to act.
Refusal received: what the letter must tell you
A written refusal is sent to you by registered letter within a week of the decision, with its reasons. The letter must also state that an appeal lies to the conseil régional or interrégional covering the conseil départemental, within thirty days, and that the appeal does not suspend the decision (Article R4112-4). Because you are an EU or EEA national, the refusal is also notified to the competent authority of your home country.
Before writing anything, read the decision with three questions in mind. Is the ground one of the three allowed by the Code? Were you summoned at least fifteen days before the refusal? Do the stated reasons actually explain the decision? Your answers are the backbone of your appeal.
Appealing to the conseil régional (regional council): step by step
Step 1 — Find the right council
The appeal goes to the conseil régional or interrégional of the Ordre des médecins that oversees the conseil départemental which refused you. Its name should appear in the refusal letter. In the case of silence, ask the conseil départemental.
Step 2 — Write your appeal letter
What the rules say, and what they leave open. The articles we have read set no template for the letter and no list of documents to enclose. As a precaution, we suggest you state your full name and address, identify the decision you are challenging (its date, or for a silence the date your file was complete), explain why you dispute it, and enclose a copy of the decision with any documents that answer the ground for refusal.
Step 3 — Send it by registered post within 30 days
On its registration page, the Conseil national of the Ordre states that the appeal must be lodged by registered letter with acknowledgement of receipt within thirty days of notification. For an implied refusal, the period runs from the day it takes effect. Keep your proof of posting and the acknowledgement slip.
Step 4 — The hearing before the conseil régional
The conseil régional appoints a rapporteur. You are summoned by registered letter, which must reach you at least fifteen days before the hearing, and you may be assisted or represented by any person of your choice (Article R4112-5).
Step 5 — The conseil régional's decision
The conseil régional rules within two months of receiving your appeal. Its decision letter tells you that any further appeal goes to the Conseil national, within thirty days.
The appeal chain at a glance
| Body | What it reviews | Time limit to apply | Time limit to decide | Suspends the refusal? |
|---|---|---|---|---|
| Conseil départemental of the Ordre | Your application for registration | — | 3 months from the complete file, plus up to 2 months if an expert assessment is ordered; silence = refusal | — |
| Conseil régional or interrégional | The written or implied refusal | 30 days, by registered letter with acknowledgement of receipt | 2 months from receipt of the appeal | No |
| Conseil national of the Ordre | The conseil régional's decision | 30 days | 2 months from receipt of the appeal (Article R4112-5, applied by Article R4112-5-1) | No |
| Conseil d'État | The Conseil national's decision | 2 months | Not set by the articles we read | No, unless the court orders otherwise (Code de justice administrative, Article L4) |
While your appeal is pending: why you cannot practise yet
Neither the appeal to the conseil régional nor the appeal to the Conseil national suspends the refusal. Registration with the Ordre is a condition for practising medicine in France (Article L4111-1). So until a decision registers you, you cannot settle and practise medicine in France on the strength of this application, even while the appeal runs. If an employer is expecting you, tell them early and share the time limits above.
An emergency procedure has, however, been allowed in another profession registered with an Ordre. In 2017, in the case of a dental surgeon whose appeal was pending before the Conseil national of her Ordre, the Conseil d'État's urgent-applications judge (juge des référés) suspended the refusal to register her (CE, order of 20 June 2017, no. 411060). In that case, the judge checked that the appeal had already been lodged, that the matter was urgent and that there was serious doubt about the lawfulness of the refusal, and did not order her registration. If your situation is urgent, talk to a lawyer as soon as you receive the refusal.
A refusal can freeze a whole move, often with a job waiting. Suxens works with EU doctors so that no deadline slips and the next step is ready. Join the waiting list for doctors →
After the conseil régional: Conseil national, then Conseil d'État
If the conseil régional upholds the refusal, you can take the case to the Conseil national de l'Ordre des médecins within thirty days; this appeal does not suspend the decision either. The Conseil national rules within two months of receiving the appeal, following the same procedure as the conseil régional (rapporteur, summons at least fifteen days before the hearing, assistance or representation). The Conseil national's decision can in turn be challenged before the Conseil d'État within two months (Article R4112-5-1).
Two mistakes to avoid: going to the tribunal administratif (the first-tier administrative court), which is not the route for a refused registration; and trying to go straight to the Conseil d'État against the conseil départemental's decision, skipping the conseil régional and the Conseil national.
In a case decided in 2023, the Conseil d'État upheld the cancellation of a doctor's registration as a general practitioner; the qualification she relied on was the Italian basic medical degree (CE, 13 April 2023, no. 455187). More on this in our article on EU specialist doctors in France.
What this article does not cover
A refusal by the Centre national de gestion (CNG). If your EU qualification does not meet the conditions for automatic recognition and you applied to the CNG for an individual authorisation to practise, a refusal is not appealed to the conseil régional of the Ordre: the challenge goes to the administrative courts, within two months.
Your specialist qualification. This article does not deal with the recognition of your specialist qualification, whose rules depend on your situation: ask the conseil départemental, and see our article on EU specialist doctors in France.
Once registered. Registration lets you practise anywhere in France. The Ordre's membership fee then becomes compulsory; its amount is set by the Conseil national and it is paid during the first quarter of the year.
Frequently asked questions
Does silence from the Ordre des médecins mean my registration is accepted?
No. If the conseil départemental has not decided within three months of receiving your complete application (five months at most if an expert assessment was ordered), its silence counts as a refusal. You can then appeal to the conseil régional or interrégional within thirty days.
How long do I have to appeal against a refused registration?
Thirty days from notification of the written refusal, or from the day the implied refusal takes effect. The Conseil national of the Ordre states that the appeal is lodged by registered letter with acknowledgement of receipt.
Can I practise while my appeal is pending?
Not on the strength of your appeal alone: appeals to the conseil régional and to the Conseil national do not suspend the refusal, and registration with the Ordre is a condition for practising medicine in France. If your situation is urgent, talk to a lawyer: in a case involving a dental surgeon, the Conseil d'État's juge des référés suspended a refusal to register while the appeal was pending.
Should I go to the administrative court?
No. A refused registration is challenged first before the conseil régional or interrégional of the Ordre, then before the Conseil national, and only then before the Conseil d'État.
Can someone come with me to the conseil régional hearing?
Yes. You may be assisted or represented by any person of your choice. The summons must reach you at least fifteen days before the hearing.
On what grounds can the Ordre refuse to register me?
Only three: you do not meet the requirements of good character and independence; a lack of competence has been established after an expert assessment; or a disability or medical condition incompatible with practice has been found after an expert assessment. No refusal without a summons at least fifteen days beforehand, and every refusal must give reasons.
The Ordre has summoned me to explain myself: does that mean a refusal?
Not yet. No refusal can be issued unless you have been invited, by registered letter sent at least fifteen days in advance, to appear before the council and explain yourself. Treat the summons as a sign that a refusal is being considered, and prepare your answers and any documents that address the issue raised.
Official sources
- French Public Health Code, Article L4112-4 — implied refusal and appeal
- French Public Health Code, Article L4112-3 — time limit for the decision
- French Public Health Code, Article R4112-2 — examination and grounds for refusal
- French Public Health Code, Article R4112-4 — notification of a refusal
- French Public Health Code, Article R4112-5 — procedure before the conseil régional
- French Public Health Code, Article R4112-5-1 — Conseil national and Conseil d'État
- Conseil d'État, urgent-applications judge, order of 20 June 2017, no. 411060 (in French)
- Conseil national de l'Ordre des médecins — Registering with the Ordre (in French)