Setting up an X-ray room in Ukraine: SNRIU licence, room requirements and choosing a machine
2 November 2026
Before comparing models, a clinic setting up an X-ray room has to settle three things: whether it needs a licence from the State Nuclear Regulatory Inspectorate of Ukraine (Derzhatomrehuliuvannia, SNRIU), what the room must look like, and who will be responsible for radiation safety. The requirements for an X-ray room in Ukraine come from several documents at once: the Law «Про дозвільну діяльність у сфері використання ядерної енергії» (on permits in the field of nuclear energy), the General Radiation Safety Rules for the Use of Ionising Radiation Sources in Medicine, and Ministry of Health sanitary rules No. 294. Here they are, one by one, as of November 2026.
X-ray licence: which permits you need and in what order
You need a medical practice licence anyway, and we covered it separately: what equipment the licence conditions require. An X-ray unit adds a second licence. Under Article 7 of Law No. 1370-XIV of 11.01.2000, the use of ionising radiation sources is licensed by SNRIU. The law reads "use" broadly. Operation is only part of it; installation and maintenance count, and so do storing and buying a source. The sources themselves must be entered in the state register.
- Notice of intent (Article 7-1, added in 2022). You write to SNRIU in free form, stating the type of work and the type of source. Within 10 calendar days the regulator replies whether you may work without a licence or registration, without a licence but with registration, or only with a licence. Until it replies, no work with the source may start.
- Licence application, on paper or online, with founding documents, documents on the safety of the source and on the applicant's ability to meet the rules (Article 12). The full package is set by the licence conditions approved by State Nuclear Regulatory Committee order No. 125 of 02.12.2002, last amended in 2025.
- Timing: preliminary review takes up to 10 working days, and the decision comes no later than two months after filing. The licence is issued for at least three years.
- Adding a new unit to a licensed facility means amending the licence, and the amendment is reviewed the same way as a new application. Build those weeks into the procurement schedule.
Exemptions are set by Cabinet of Ministers resolution No. 1174 of 16.11.2011, including for some dental units. The criteria don't cover CT scanners, angiography systems or fluoroscopy units, and they don't cover installation or repair either.
Under martial law, Cabinet resolution No. 314 of 18.03.2022 lets state and municipal healthcare facilities acquire diagnostic X-ray generators on the basis of a declaration, and transfer or store them the same way. Charities and military units have this option too. Operating a unit on a declaration is allowed only for mobile units of the defence and security forces.
The Ministry of Health sanitary rules of 04.06.2007 No. 294 (version of 23.12.2025) require the room to be commissioned by an act of a facility committee, and clause 1.18 lists 15 documents, including the room's technical passport and the staff dose log. Prepare them alongside the licence package.
X-ray room requirements: what goes into the design
The room is placed according to a design project. It can't go in residential buildings or children's facilities, with an exception for diagnostic dental rooms, though a clinic built into a residential block may have one if the adjoining rooms aren't residential. The exam room can't sit under showers or toilets, or next to wards for pregnant women and children.
A design for licensed equipment in new or rebuilt rooms goes through a state nuclear and radiation safety review. Figures from rules No. 294:
- a gap of at least 1.5 m between the radiography table and the walls, 2 m between the tube and the viewing window (1 m for mammography and dental units), 0.8 m walkways next to stands, and a 1.5 × 2 m space for a trolley;
- a ceiling height of at least 3 m if the tube is ceiling-mounted;
- exam room doors at least 1.2 m wide and 2.0 m high, and a floor that carries the heaviest parts of the unit;
- a red-and-white "Do not enter" sign above the door that lights up automatically when the unit is switched on.
Shielding goes into the walls and floor and into the ceiling, and it covers doors and windows too. Behind it, the annual dose limit must not be exceeded. Shielding thickness is calculated from tube voltage and workload, the directions of the primary and scattered beam, and what the neighbouring rooms are used for. The primary beam points at a load-bearing wall with no one stationed permanently behind it.
Staff and dosimetry
Category A staff work with the sources directly; category B staff get additional exposure because of where they work. The effective dose limit for category A is 20 mSv a year averaged over any five consecutive years, and no more than 50 mSv in a single year. For category B it's 2 mSv, for the public 1 mSv.
The head of the facility appoints a person responsible for radiation safety and keeps individual dose records for staff and arranges training and medical checks for category A. Since 27 June 2025 the Regulation on the Radiation Protection Expert (Cabinet resolution No. 1493) has been in force. A clinic can contract an expert recognised by SNRIU for written recommendations, or hire one as the responsible person.
Acceptance testing and quality control
An acceptance committee of the facility checks the unit at commissioning, with a representative of the manufacturer or supplier taking part. After that, the General Rules require:
- a quality management system under SNRIU order No. 166 of 03.10.2008;
- checks of dose-related parameters at the intervals set by the rules and the manufacturer's documentation, with a ban on further use when deviations exceed the limits;
- a yearly comparison of patient doses against diagnostic reference levels;
- each patient's dose recorded in the medical file, with the data needed to estimate it kept for at least 50 years.
Equipment past its service life may not be used, so compare the service life in the manufacturer's documents as closely as the price.
How to choose an X-ray machine: DR, mobile, portable or C-arm
Preventive chest radiography for patients over 15 may only be done on digital equipment. New equipment being commissioned must have a device for automated exposure and dose control, and fluoroscopy units other than mobile and dental ones also need an image intensifier.
The compact PROTEC PRS 500 C digital system, with a fixed table, a wall bucky stand and a 50 kW generator, fits into a small room. Fluoroscopy and contrast studies call for a remote-controlled table such as the ANGELL Talent II. If the generator and stand still work well, the wireless 43 × 43 cm CELV-1717 detector replaces film.
A mobile X-ray unit comes to the bedside, and the exposure is taken with a remote switch. The ANGELL DP326 is 580 mm wide, has a 32 kW generator and takes up to 1,200 images on one charge.
A portable X-ray machine is held in the hand or mounted on a stand. The VSI VX-100 weighs 2.5 kg and, per its manual, is intended for chest radiography. The REMEX-KA6 weighs 2.4 kg and takes about 300 shots per charge, but it can't be used with a grid. Portable units without an adjustable collimator are banned, dental units excepted.
A C-arm gives live fluoroscopy during surgery, using either an image intensifier or a flat-panel detector. The Technix TCA 7 has a detector of up to 30 × 30 cm, and its 25 kW version plugs into a 16 A socket. A unit used for interventional procedures must show the doctor the patient's dose and run from an uninterruptible power supply.
Where to buy an X-ray machine for your room?
Before you talk to a supplier, put together a room plan showing ceiling height and the rooms next to it (above and below as well), plus the expected number of images per week and the list of exams: radiography, fluoroscopy, bedside imaging, the operating room. Note whether you already hold an SNRIU licence and for which sources. The specification should ask for automatic exposure control with dose measurement and DICOM output. Ask for the documentation in Ukrainian too.
Finer Ukraine LLC has worked with Ukrainian healthcare facilities since 2015, and our team includes doctors and engineers. We match units from our X-ray and C-arm range to your room, then deliver and install them and train the staff. Quotes and tender documents are part of the job too. If the room is part of a new department, turnkey equipping is usually simpler. Call 0 800 334 585 or write to us through contacts.
Frequently asked questions
1. Does dental X-ray need an SNRIU licence?
Not always. Under resolution No. 1174, an intraoral unit is exempt at up to 90 kV if it has its own room or takes 100 images a week or fewer. Panoramic units (up to 90 kV) and dental cone-beam CT (up to 120 kV) are exempt at 50 images a week or fewer.
2. Do you need a licence for a portable X-ray machine?
Resolution No. 1174 has no separate exemption for portable units. A diagnostic X-ray unit is exempt only if the ambient dose equivalent rate stays at or below 10 µSv per hour at 0.1 m from the focal spot in every direction except the target one. SNRIU gives the final answer to your notice of intent.
3. How much floor space does an X-ray room need?
The set of rooms and their areas are given in annex 4 to sanitary rules No. 294. The design may adjust the exam room area to the actual equipment if the clause 2.7 distances hold: 1.5 m or more between table and walls, 2 m between tube and viewing window.
4. Is a licence needed to service X-ray machines?
Yes. Law No. 1370-XIV treats maintenance and repair, as well as installation, as use of ionising radiation sources, which SNRIU licenses, and the exemption criteria in resolution No. 1174 don't apply to this work. Before signing a contract, ask the service company for a copy of its licence.
5. Does a radiographer need a personal dosimeter?
A radiographer works with the source directly, which puts them in category A, and rules No. 294 require individual dose monitoring and records for category A and B staff. Results are checked against the annual dose limits, and staff are told regularly about radiation levels at their workplaces and the doses they received.
