"Health": New regulations to govern licenses and practice of psychological treatment in the public and private sectors

Abdul Karim Al-Abdullah

Minister of Health Dr. Ahmed Al-Awadi issued Decision No. 225 of 2026 concerning the General Regulations and Conditions for Licenses to Practice Psychotherapy and Psychological Counseling in the Public and Private Sectors, as well as the requirements and conditions that private health facilities must meet to be licensed as centers for providing psychotherapy and psychological counseling. This decision establishes a comprehensive regulatory framework for professional practice, licensing, qualifications, titles, specializations, and facilities providing these services.

The decision sets clear boundaries for professional practice in the field of psychotherapy and psychological counseling, specifying the academic qualifications, experience, and clinical training required for practitioners. It also regulates applied behavior analysis services, establishes controls for private health facilities operating in this sector, and governs supervision, documentation, patient privacy protection, and informed consent.

Furthermore, the decision includes detailed controls to prevent unlicensed, misleading, or non-evidence-based practices, and defines the professional responsibilities for each job title to prevent scope creep or the performance of tasks requiring a higher level of qualification and expertise.

**Broad Scope of Psychotherapy**

The decision defines psychotherapy and psychological counseling as non-pharmacological professional psychological services provided to individuals, families, groups, or public and private entities, either in person or remotely, within the framework of licensed and regulated professional practice.

The scope of these professional psychological services includes the assessment, diagnosis, interpretation, modification, or improvement of an individual’s psychological, behavioral, emotional, or cognitive state, whether directly or indirectly, and whether in person, remotely, or through other means, within the limits of licensed professional practice.

According to the decision, the scope of practice includes addressing psychological problems related to thoughts, feelings, and behaviors; psychological symptoms accompanying physical illnesses, injuries, or disabilities; and non-pharmacological psychotherapy associated with addiction, dependency disorders, and substance abuse issues, without encroaching upon the jurisdictions of regulated medical specialties.

It also includes the application of psychological measures and assessments, intelligence, personality, aptitude, and interest tests; education, training, supervision, and counseling related to assessment, treatment, and consultation; as well as neuropsychological rehabilitation programs and the use of biofeedback, neurofeedback, and electroencephalography devices, within the limits of rehabilitation and licensing.

**"Life Coaching"**

The decision brings within the scope of regulation any activity offered under titles such as "hypnosis," breathwork, "Life Coaching," personal training, life guidance, self-development, quality of life improvement, emotional intelligence, or cognitive or behavioral organization, whenever such activities are capable of influencing an individual’s psychological, behavioral, or emotional state.

It stipulates that the provision of such activities, when falling within the scope of psychotherapy, must be conducted by a licensed practitioner within the framework of a therapeutic or training program based on scientific evidence.

Professional Titles

The decision specified a set of regulated professional titles for the provision of services, including “Senior Psychotherapist,” “Psychotherapist,” and “Psychological Specialist.” It also included specialized titles in Applied Behavior Analysis, namely “Senior Applied Behavior Analyst,” “Applied Behavior Analyst,” and “Assistant Applied Behavior Analyst.” Furthermore, the decision organized several related health specialties, while emphasizing that clinical psychotherapy services may not be provided outside the scope of practice and licensing stipulated for each profession.

Academic Qualifications

The decision required that applicants seeking a license to practice meet all academic and professional requirements in a complete and integrated manner. This includes obtaining a scientific qualification issued by an accredited educational institution and providing a certificate equivalency in accordance with prevailing regulations. It further mandated that studies be conducted through actual on-campus attendance within the educational institution, ensuring regular student presence in the country of study. Some courses delivered in a hybrid or synchronous format are permitted under specified conditions, provided they form part of an accredited on-campus program and actual attendance requirements are fulfilled.

Additionally, the academic program must be integrated and organized within an accredited university or college, based on a credit-hour system, examinations, and assessments, with grades and evaluations officially recorded on the official transcript.

Special Requirements

The decision established different levels of qualifications and experience according to the professional title. It linked the title of “Senior Psychotherapist” to a higher academic level, practical experience, and clinical training, while setting independent requirements for the title of “Psychotherapist.” It also permitted, under specific conditions, the acceptance of certain programs related to psychology, psychotherapy, and psychological counseling, provided that the program description, curriculum, and practical training demonstrate that they include direct professional qualification in diagnosis and treatment or psychological counseling, in accordance with the standards outlined in the decision.

The decision also set requirements for core academic courses that must be completed, covering areas such as diseases and diagnosis, clinical or counseling psychology, clinical interviewing and case formulation, neurobiological foundations of psychotherapy or psychopharmacology, evidence-based psychotherapy or counseling approaches, ethics and professional practice, and other specified academic domains.

Practical Experience and Clinical Training

The decision did not rely solely on academic qualifications; it also required practical experience and clinical training supervised by direct professional oversight, in accordance with the required professional title. For certain titles, the decision specified years of practical experience after obtaining a bachelor’s degree. It also set a minimum number of therapeutic sessions that applicants must complete, requiring that these sessions be conducted face-to-face with clients under general professional supervision, with a portion subject to direct, actual supervision by the supervisor. Clinical training must take place in a licensed psychiatric or psychotherapy facility, or in an institution responsible for education and training in psychotherapy, with official documents and reports demonstrating the training provided.

“Psychological Specialist”

The decision defined the scope of practice for psychologists holding a bachelor’s degree, limiting their role to conducting initial or preliminary clinical interviews, gathering information and data, administering appropriate psychological assessments, and preparing summaries or preliminary reports necessary for presenting cases to a licensed psychologist or the relevant technical supervisor. It stipulated that all their work must be performed upon request and under the direct supervision of a “senior psychologist” who is licensed. The decision strictly prohibited them from providing any therapeutic interventions, conducting individual or group therapy sessions, developing or modifying treatment plans, or making any independent or final diagnostic or therapeutic decisions on their own. Furthermore, they were forbidden from presenting themselves to the public, clients, or individuals interacting with the facility as psychologists, or from performing duties beyond their preliminary scope of practice.

The decision granted senior psychologists the authority to provide clinical psychotherapy and psychological counseling services for cases within their professional scope, under the supervision specified according to their title and requirements. Their scope of practice includes conducting therapeutic interviews, performing clinical psychological assessments, formulating case conceptualizations, developing, implementing, and monitoring treatment or counseling plans, adjusting therapeutic interventions within their competence, and collaborating with psychologists and other members of the professional team.

In cases of clinical psychotherapy, the interview focuses on building a professional relationship, gathering clinical information, and administering appropriate assessments to formulate a diagnosis or differential diagnosis, followed by developing an appropriate treatment plan.

**Approved Scientific Systems**

The decision stipulated that psychological diagnoses must follow scientifically approved diagnostic systems such as “ICD-11” or “DSM-5-TR,” taking into account any newly issued approved scientific versions. It emphasized that the term “diagnosis” in this context refers to clinical diagnosis for the purpose of professional assessment and developing treatment or counseling plans within the facility. Such a diagnosis is not considered a medical diagnosis and does not carry any medical or pharmacological implications. Moreover, this diagnosis is not relied upon in the private medical sector to issue reports or opinions of a legal, judicial, or administrative nature outside the regulated boundaries.

**High-Risk Cases**

The decision mandated that senior psychologists refer cases requiring medical intervention or hospitalization to the appropriate physician or hospital. This specifically includes cases exhibiting acute symptoms that pose a risk to the patient or others, such as acute symptoms of psychoactive substance use, active suicidal ideation, or severe agitation. The decision also emphasized the necessity of maintaining a dedicated record documenting these referrals. Additionally, the decision required that when providing psychological services to children, practitioners—whether psychologists or senior psychologists—must possess adequate, documented, and appropriate training to work with this population, according to each professional’s scope of practice.

**Comprehensive Documentation**

The decision also obligated practitioners to fully and accurately document all diagnostic and therapeutic processes conducted within the unit or complex. They were required to prepare a comprehensive initial assessment for each client, keep it in their file, and document interviews, results of psychological tests and assessments, treatment plans, interventions, and the monitoring of case progress, storing all records in accordance with approved systems within the facility. In cases where a therapy session needs to be recorded for training or educational purposes, prior written consent from the client is required.

"Senior Psychotherapist" The decision designated "Senior Psychotherapist" as the highest professional level within the technical hierarchy of facilities providing psychotherapy and psychological counseling, assigning them the responsibility of supreme technical supervision. Their scope of work includes overseeing therapeutic services, reviewing the efficacy of therapeutic procedures and the integrity of professional practice, ensuring that staff adhere to professional and ethical guidelines, supervising sessions required to fulfill clinical experience requirements, conducting advanced clinical psychological assessments, developing treatment plans, and managing complex cases. The decision emphasized that technical supervision must be based on physical presence and genuine follow-up, and that the supervisor’s role should not be limited to direct therapeutic work.

Applied Behavior Analysis The decision established an independent framework for the practice of Applied Behavior Analysis (ABA), defining the titles "Senior Applied Behavior Analyst," "Applied Behavior Analyst," and "Assistant Applied Behavior Analyst," and linking each title to specific academic qualifications, practical experience, and clinical training. It also set academic requirements covering the theoretical foundations of ABA, intervention and treatment planning, measurement and assessment, professional ethics, and management and supervision. In specific cases, it allowed for the credit of certain related courses completed through distance learning, e-learning, or hybrid systems, in accordance with the conditions and accreditations specified in the decision.

The decision outlined the duties of the Applied Behavior Analyst, which include conducting initial case assessments and collecting and analyzing behavioral data using validated assessment tools, including those for assessing verbal behavior, foundational language and learning skills, early intervention models, and other scientifically recognized measurement instruments. It mandated defining therapeutic goals in collaboration with the family and the multidisciplinary team, and preparing an individual intervention program that includes short- and long-term goals and procedures based on the functional analysis of behavior. It required the daily collection and electronic documentation of case performance data, the preparation of periodic, traceable, and reviewable reports, and participation in supervisory meetings to discuss therapeutic progress.

Psychological Counseling Complexes The decision set detailed requirements for licensing a facility to provide psychotherapy and psychological counseling in the private medical sector. These include ensuring the facility’s location is suitable and easily accessible, and providing dedicated consultation rooms with an area of no less than 9 square meters per room, ensuring quietness, privacy, appropriate lighting, and ventilation. It required a minimum of two rooms dedicated to service provision, along with an information system and medical records management system compatible with the volume of work, enabling the management of appointments, forms, records, and files, as well as data storage, confidentiality, and access rights management.

It also mandated the provision of a suitable reception and waiting area, restrooms, and valid insurance covering risks related to buildings, devices, equipment, patients, staff, and visitors, in addition to professional liability insurance in accordance with applicable laws. The decision obliged facilities to install surveillance cameras only in waiting areas and corridors, adhering to privacy regulations, and retaining recordings for no less than three months. It further required each room to be equipped with an immediate assistance request device or an alarm system connected to a reception or supervision point within the facility, and designed to ensure easy exit for clients or therapists at all times.

Identification Cards for Staff

The decision mandated all personnel working in the facility to wear clear professional identification badges that include the full name, academic specialization, and official job title as per the professional license, thereby preventing any confusion among clients regarding the professional role of each practitioner. The decision also required obtaining informed and explicit consent from clients before initiating any psychological treatment or counseling services.

Remote service delivery was permitted in accordance with the regulations governing remotely provided health services, with the professional and the facility obligated to verify the beneficiary’s identity, document their data, and take appropriate professional measures to ensure their safety and establish a plan for handling emergency cases.

The decision stipulated the provision of at least one specialist holding the title of “Senior Psychologist” who meets the specified requirements, must be dedicated full-time to working at the Psychological Counseling Complex, and shall oversee the technical supervision of the services provided. It also authorized other job titles to work in the complex, including Psychologist, Psychological Specialist, Applied Behavior Analysis Specialist, Occupational Therapy Specialist, Speech and Hearing Specialist, and other related health specialties, in accordance with the governing conditions.

**Management Controls for the Complex**

The decision established specific requirements for the Director of the Psychological Counseling Complex. If the license holder does not wish to serve as the medical director, or if the license holder is a legal entity, a medical director must be appointed who is technically responsible and effectively oversees the management of its operations. Among the requirements is that the director must hold the rank of “Senior Psychologist” as outlined in the decision, be dedicated full-time, have no prior criminal conviction for offenses involving honor or integrity, have resided in the country for at least nine months of each year, not serve as a medical director for another health facility or any of its branches, possess experience in management or the complex’s field of activity, and obtain prior approval from the Ministry.

**Regulation of Job Titles**

The decision established an organized pathway for training and professional advancement, allowing certain qualified individuals who meet academic requirements to obtain training titles as a preliminary step toward fulfilling the practical experience, clinical training, and direct supervision requirements necessary for final licensing.

The decision specified the controls for transitioning licensed professionals from one title to another after meeting academic, experiential, and training requirements, while defining the duration of trainee licenses and their renewability in accordance with regulations and the approval of the competent technical authority. It also mandated that trainees clearly disclose their trainee status through identification badges, inform clients of this status before providing services, and obtain prior consent when using session data for the purpose of fulfilling training requirements.

The decision prohibited any person, including psychology trainees or students, from identifying or presenting themselves to others as a psychologist, psychological specialist, psychological counselor, or licensed practitioner unless they actually hold a professional license issued by the Health Licensing Department. It also banned the use of any description, title, designation, abbreviation, signature, identification badge, or communication method that implies the person is qualified to provide professional psychological services without a license.

**Prohibition of Misleading Advertising**

The decision prohibits any person or entity, including training centers, social, family, or educational counseling centers, individuals, and electronic platforms, from providing, advertising, or promoting services that fall within the scope of professional psychological services, directly or indirectly, except through a licensed practitioner and a licensed health facility. It also bans the use of titles or descriptors such as “psychological therapist,” “psychological counselor,” or “life coach,” among others, when their use is in the context of advertising or promoting services that imply the practice of licensed psychological therapy or counseling.

Furthermore, the decision prohibits psychological therapists and counselors from prescribing or dispensing any type of medication or therapeutic supplements, or from intervening in or modifying approved medication plans. Such activities are restricted to licensed practitioners according to their medical specialties. It also prohibits them from performing electroconvulsive therapy or using or applying neuromodulation techniques, whether electrical, magnetic, acoustic-frequency-based, or other similar technologies. These procedures are reserved exclusively for licensed physicians in accordance with established regulations.

Prohibition of Unapproved Methods

The decision firmly prohibits the provision of psychological services that are not based on recognized scientific or professional foundations, or that rely on false, illusory, or unscientific practices, or are presented in a manner suggesting their ability to treat mental disorders without approved professional backing. Examples cited in the decision include energy healing or “Reiki,” outer healing, stone and crystal healing, stage or fake hypnosis, neuro-linguistic programming (NLP), cognitive programming, mental and psychological engineering, positive affirmations, activation of psychological genetic expression, psychological, neurological, or spiritual preparation, activation of brainwaves or alpha waves, and healing by the law of attraction.

It also covers yoga-based psychological therapy, breath control therapy, prana therapy, meditation, emotional freedom techniques (EFT), line analysis therapy, body language analysis therapy, timeline therapy, color therapy, sound or wave therapy, tapping therapy, thought field therapy, vibrational therapy, spiritual healing, cosmic or star-seed healing, astral projection, chakra and aura techniques, energy field practices, and other similar practices.

Strict Confidentiality of Psychological Information

The decision obligates practitioners to maintain strict confidentiality regarding all information and data related to clients, including personal, health, and psychological data, as well as any information obtained during the provision of professional services. This duty of confidentiality extends to all forms of documentation, whether paper-based, electronic, audio-recorded, or video-recorded, and remains in effect even after the professional relationship has ended.

Disclosure of information is permitted only to the extent allowed by law, with valid and prior consent from the client, or in cases necessitating the protection of the client or others from real danger, in accordance with regulatory controls. The decision further requires every practitioner to operate within the boundaries of their licensed scientific and professional expertise, based on their accredited qualifications and experience, and prohibits engaging in any activities or practices that exceed this scope. This includes prohibiting diagnosis or the provision of therapeutic interventions in fields outside their qualifications or licensing, and forbidding interference in medical or pharmaceutical aspects or making medical-type treatment decisions without proper authorization.

Six Months to Regularize Status

The decree granted licensed psychotherapy offices and psychological counseling firms, which had initiated the licensing procedures with the Ministry of Health prior to the decree’s issuance, a six-month deadline from the date of its promulgation to regularize their status and comply with the new conditions and requirements.

For establishments that had not initiated the licensing procedures with the Ministry of Health before the decree’s issuance, the decree mandated an immediate halt to any activities related to providing psychological services. It further emphasized that any establishment continuing to offer services falling within the scope of psychological services without obtaining the necessary license from the Ministry of Health would be subject to accountability and legal action.

The decree obliged practitioners of psychotherapy in the private healthcare sector—psychologists or psychological specialists holding valid licenses prior to the decree’s issuance—to regularize their status upon license renewal, transfer, or change of title, in accordance with the new requirements. It also required practitioners in the public healthcare sector, who held valid licenses before the decree’s issuance, to regularize their status within 18 months from the date of its promulgation.

Academic Requirements

The decree included detailed appendices specifying the approved academic courses in the fields of psychological diagnosis and treatment, applied behavior analysis, and special education, serving as a reference for evaluating whether applicants meet the necessary academic qualifications.

These courses covered areas such as diagnosis and mental disorders, clinical and counseling psychology, clinical interviews and case formulation, neuropsychology, biological foundations of behavior and psychopharmacology, evidence-based psychological therapies, developmental and child psychology, and psychological measurement and testing.

In the field of applied behavior analysis, the courses included the theoretical foundations of behavior analysis, intervention design and treatment planning, measurement and evaluation, professional ethics, management and supervision, alongside areas of special education, early intervention, autism spectrum disorders, learning disabilities, and developmental disabilities.

Thus, the decree establishes a comprehensive regulatory framework for the practice of psychotherapy and psychological counseling in Kuwait, encompassing academic qualifications, experience, training, supervision, and licensing, extending to the definition of specializations and professional titles, regulation of facilities, records, privacy, and informed consent, and culminating in the combating of unscientific practices, misrepresentation of titles, and misleading advertising, thereby drawing clear boundaries between licensed professional psychological practice and activities lacking accredited qualifications or scientific evidence.