Opening a second physiotherapy practice location - documentation

Michał has been running a physiotherapy practice in Kraków for four years. He has a full patient roster, a three-week waiting list, and an idea to open a second practice in Wieliczka. He starts looking for premises -- and then a question he wasn't expecting comes up: is a second practice a new business? Is it enough to just add an address? What about the Register of Healthcare Entities (RPWDL), the Sanitary Inspectorate (Sanepid), and GDPR?

Expanding to a second location sounds simple, but it comes with concrete documentation obligations. In this article we show exactly what you need to do so your second practice can start legally, without risking trouble at the first inspection.

Is a second practice a new business

No -- as a rule, a second location is a new place of providing services within the same practice or healthcare entity, not a new business. You don't register a second sole proprietorship and you don't get a second NIP (Polish tax identification number).

The key distinction depends on your legal form:

• Physiotherapist's professional practice (individual/group) -- as a rule tied to a specific place; a second permanent location often requires an appropriate form of registration entry and reporting the additional address in the Register of Healthcare Entities (RPWDL).
• Healthcare entity -- in the register you list an additional place of providing services and the organizational units assigned to it.

This distinction determines the entire path ahead, so before you sign a lease, establish which regime you operate under.

Updating your RPWDL entry

RPWDL (the Register of Healthcare Entities) is a register kept in an IT system. A new location requires updating your entry:

1. Log in to the RPWDL system (using a trusted or qualified electronic signature).
2. Submit an application to amend the entry -- adding a new place of providing health services.
3. Specify the address, organizational units, and scope of services at the new location.
4. Attach the required declarations (including confirmation that premises and sanitary conditions are met).
5. Wait for the entry to be processed -- the registering authority has a statutory deadline for review.

The change should be reported before you start providing services at the new location. Starting operations at a location not reported to the RPWDL is a breach of a healthcare entity's obligations.

Premises requirements and the Sanitary Inspectorate for a second location

A second location means separate premises = separate requirements. It does not inherit approvals from the first practice. You must ensure:

• The premises comply with requirements for a physiotherapy practice (floor area, ventilation, access to water, sanitary facilities).
• A sanitary approval or opinion, if required for your scope of services.
• Sanitary-hygiene and disinfection procedures for the new location.
• Medical waste segregation and a collection agreement for that address.

Documentation you need to duplicate (or update)

Document	Needed at the second practice	Notes
RPWDL entry	Update (new location)	Before starting services
Internal organizational rules	Update	Must list both locations and units
GDPR documentation	Update	New data processing location
Sanitary procedures	Separate / adapted	For the new premises
Medical waste collection agreement	Separate	For the new address
Professional liability insurance	Scope verification	Must cover the whole business
Patient records	Shared system	If a patient uses both locations

Staff at the second location

If you hire additional physiotherapists at the new practice, each of them must have:

• PWZFz (Physiotherapist's Professional Practice Licence) -- active and confirmed.
• Confirmation of the right to practise the profession and membership in the Chamber of Physiotherapists (KIF).
• Current health and safety (BHP) training and, if applicable, medical checks.
• Authorization to process personal data (GDPR) for the new location.

It's also worth clarifying who is the manager / responsible person at each location, so that during an inspection it's clear who is accountable for the documentation.

Example -- Solo Practice [SP]: Michał works alone in Kraków and hires one physiotherapist in Wieliczka. He updates the RPWDL with the second location, creates separate sanitary procedures and a waste collection agreement for Wieliczka, and extends the internal organizational rules to cover both locations.

Example -- Group Practice [GR]: A limited liability company running a healthcare entity adds a second place of providing services in the register, assigns organizational units to it (e.g. "physiotherapy clinic -- Wieliczka"), and issues GDPR authorizations for the entire team at the new location.

Professional liability insurance and a second location

Mandatory professional liability insurance for physiotherapists is tied to practising the profession, but the scope and sum insured must genuinely cover the entire business. With a second location, check:

• Whether the policy covers services provided at both locations.
• Whether physiotherapists hired at the new practice have their own current liability cover (through KIF membership).
• Whether the sum insured is adequate for the increased number of patients and staff.

A coverage gap across two locations is one of the most commonly overlooked risks -- in the event of a claim at the second practice, the insurer may dispute the scope of cover.

Order of steps -- what to do first

It's best to expand your business in a set order, so you don't start providing services before completing the formalities:

1. Lease agreement / title to the premises -- with the condition that the premises meet practice requirements.
2. Adapting the premises and, if required, obtaining a sanitary opinion.
3. Updating the RPWDL entry with the new place of providing services.
4. Medical waste collection agreement and sanitary procedures for the new address.
5. Updating GDPR documentation -- the register of processing activities, authorizations, clauses.
6. Internal organizational rules extended to cover both locations.
7. Verifying liability insurance and staff credentials (PWZFz) for the new practice.
8. Only now -- start accepting patients.

Common mistakes with a second location

• Starting before the RPWDL entry is updated -- accepting patients at an unreported location.
• Copying the internal rules without changing the address -- the document no longer reflects reality.
• Forgetting to update GDPR documentation -- the new processing location isn't included in the register of activities.
• One waste collection agreement for two addresses -- collection must cover both premises.
• Not checking liability insurance -- the policy must cover the entire business, including the second location.

Frequently asked questions

Does a second practice require registering a new business?

No. A second location is a new place of providing services within the same practice or healthcare entity. You don't register a second business or get a new NIP (Polish tax identification number) -- you update your RPWDL entry with the additional address.

Do I need to report the second location before opening it?

Yes. The RPWDL entry update must be submitted before you start providing services at the new location. Accepting patients at a location not reported to the register is a breach of a healthcare entity's obligations.

Is the GDPR documentation from the first practice enough?

Not entirely. A new location is a new data processing location, which must be included in the register of processing activities, with an updated risk analysis and authorizations issued for that practice's staff.

Do I need a separate medical waste collection agreement?

Yes. A medical waste collection agreement is tied to a specific address, so for the second location you need a separate agreement or an extension of the existing one to include the new collection point.

CTA: Opening a second practice and don't want to guess what you need to prepare? The STANDARD package includes an opening checklist, an internal organizational rules template, and GDPR documentation ready to adapt for your next location. See FizjoReady packages →

Related articles:
- How to open a physiotherapy practice in 2026 -- a complete step-by-step guide
- RPWDL registration for physiotherapists -- instructions with examples
- Premises requirements for a physiotherapy practice -- what does your space need?