What counts as a small practice clinic

A small practice clinic is operated by a sole proprietor, a partnership of not more than five partners, or a company of not more than five directors, each of whom is a registered medical practitioner or a registered dentist[1]. Apart from those owners, no other doctors or dentists practise in the clinic, and the owners have the exclusive right to use the premises[1].

Locum cover is capped: for each owner, locum days must not exceed 60 days in a calendar year, and across all partners or directors the total must not exceed 180 days[2]. Each doctor or dentist may operate up to three small practice clinics with valid exemption at the same time[2]. If any director is not a doctor or dentist, the clinic does not qualify and must apply for a clinic licence[2].

Exemption or licence: the differences

Letter of exemption compared with a clinic licence
ItemLetter of exemptionClinic licence
FeeFree of charge$8,840 for up to 5 consultation or procedure rooms, $9,860 for 6 to 10, $10,900 for more than 10
DurationNo renewal unless the clinic moves, stops qualifying or the exemption is revokedNot more than five years
Chief medical executiveNot requiredA doctor or dentist registered in Hong Kong for at least four years
Code of Practice for ClinicsNo proof of compliance needed when applyingMust comply to obtain the licence
When to applyFrom 13 October 2025, with no deadlineFrom 13 October 2025; provisional licences closed on 13 April 2026, so new applicants apply for a full licence

The Department of Health says an exemption can generally be granted within a week if all the information is submitted through its electronic platform[2].

When the penalty starts

The Ordinance was gazetted on 30 November 2018, and the Department of Health started accepting clinic licence applications and exemption requests on 13 October 2025[2]. The penalty for operating a clinic without a licence has not started: the government says it will announce the effective date in due course[4]. Until that notice is published a clinic may continue to operate; once it is, every clinic needs a licence or a letter of exemption[2].

The Ordinance itself provides that a person must not operate a private healthcare facility without a licence, with a fine at level 6 and imprisonment for 3 years on conviction on indictment for a facility that is not a hospital[3].

Keeping the exemption

Certain changes to an exempted clinic need not less than 14 days' advance notice in writing to the Director of Health[2], so read the FAQ before changing owners or premises. Ceasing to qualify as a small practice clinic without giving notice is an offence carrying a fine at level 4 and imprisonment for 3 months[3].

Who is outside the scheme

Premises where only Chinese medicine practitioners and allied health professionals, such as physiotherapists, practise are not covered by the Ordinance at all[2].

Rules, forms and figures can change, and the official pages listed below are the authority wherever this summary differs from them.