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
| Item | Letter of exemption | Clinic licence |
|---|---|---|
| Fee | Free of charge | $8,840 for up to 5 consultation or procedure rooms, $9,860 for 6 to 10, $10,900 for more than 10 |
| Duration | No renewal unless the clinic moves, stops qualifying or the exemption is revoked | Not more than five years |
| Chief medical executive | Not required | A doctor or dentist registered in Hong Kong for at least four years |
| Code of Practice for Clinics | No proof of compliance needed when applying | Must comply to obtain the licence |
| When to apply | From 13 October 2025, with no deadline | From 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.