The PHFO mainly regulates premises where registered medical practitioners and/or registered dentists practise.  Under the PHFO, four types of PHFs are subject to regulation, namely hospitals, DPCs, clinics, and health services establishments.  Operators of the above four types of PHFs need to obtain a relevant licence or a letter of exemption in order to continue their operation.  Please refer to Part 1 of the PHFO for definitions of the four types of PHFs.

Hospital licences under the PHFO are required for operating private hospitals.  For premises where registered medical practitioners and/or registered dentists practise and provide medical services without lodging, the premises will either need a DPC licence if scheduled medical procedures defined under the PHFO are provided, or a clinic licence if such procedures are not provided.  Please refer to section 2 and Schedule 3 to the PHFO for the definition of scheduled medical procedures.

Under the PHFO, a clinic that falls under the meaning of an SPC may request for a letter of exemption.  For details, please refer to Question A2.

Health services establishments encompass new modes of operation or delivery of healthcare services that entails a significant level of risk.  Facilities for conducting clinical trials as described in Schedule 9 to the PHFO are to be regulated as health services establishments.

The definition of an SPC is stipulated in section 41 of the PHFO. An SPC must be operated only by registered medical practitioner(s) and/or registered dentist(s). The operation may be in the form of a sole proprietorship, a partnership or a company. Moreover, the following three conditions must also be met.

1. Number of medical practitioners or dentists:
1. If the SPC is operated under a sole proprietorship, the sole proprietor must be a registered medical practitioner or a registered dentist;
2. If the SPC is operated under a partnership or a company, there can only be a maximum of five partners or company directors, and all partners or company directors must be registered medical practitioners or registered dentists.
2. The right to use the premises:
1. The sole proprietor of the sole proprietorship; at least one partner of the partnership; or at least one director of the company shall have exclusive rights to use the premises forming the SPC; in other words, except for the operator(s) and locum arrangements, other doctors or dentists are not allowed to practise in the clinic; and
2. No matter whether the SPC is operated as sole proprietorship, partnership or a company, the operators of the SPC cannot employ other registered medical practitioners or registered dentists (except for locum arrangements).
3. Locum arrangement:
1. For every registered medical practitioner or registered dentist operating the SPC, the total number of locum days for which another registered medical practitioner or registered dentist takes up the duties of the individual must not exceed 60 days in a calendar year;
2. In addition, the aggregate number of locum days for all the partners or directors operating the clinic must not exceed 180 days in a calendar year.

Each registered medical practitioner or registered dentist may operate up to three SPCs with valid exemption at the same time. Please refer to Part 4 of the PHFO for details.

The PHFO was gazetted on 30 November 2018.

The Government has been implementing the PHFO in phases based on the risk level of various types of PHFs.  Applications for hospital and DPC licences have commenced on 2 July 2019 and 2 January 2020 respectively.  Applications for exemption of scheduled nursing homes commenced on 2 January 2020 and ended on 30 April 2020.

Penalty provision pertaining to the operation of a hospital and a DPC without a licence has commenced on 1 January 2021 and 30 June 2022 respectively.  Any person operating a hospital without a licence commits an offence and is liable on conviction to a fine of HK$5,000,000 and to imprisonment for five years; any person operating a DPC without a licence commits an offence and is liable on conviction to a fine of HK$100,000 and to imprisonment for three years.

The Notices related to commencement of clinic regulatory regime have been gazetted on 23 May 2025.  The Secretary for Health has appointed 13 October 2025 as the date starting to accept applications for clinic licences and letter of exemption.  The Department of Health will announce the application arrangements in due course.  The commencement of penalty provision pertaining to the operation of a clinic without a licence will be announced in due course.  Please check out the latest announcements on our website.

Before the Secretary for Health announces the commencement of the penalty clauses by notice published in the Gazette, you may continue to operate the clinic. Once the penalty provision pertaining to the operation of a clinic without a licence commences, all clinics and SPCs must be covered by a licence or a letter of exemption to continue to operate legally.

Premises where registered medical practitioners and/or dentists practise are subject to regulation and licensing under the PHFO.  If the services provided by Chinese medicine practitioners and allied health professionals are provided in the same premises where registered medical practitioners and/or registered dentists practise, such services will also be covered by the licences issued under the PHFO.  The PHFO, however, does not cover premises where only Chinese medicine practitioners and allied health professionals practise.  These Chinese medicine practitioners and allied health professionals are continued to be regulated under the applicable legislations and codes of practice.

Under the PHFO, any PHF where registered medical practitioners and/or registered dentists practise must be covered by a licence or a letter of exemption, regardless of whether they work part-time or full time.

Moreover, the licensee of a PHF must appoint a CME to take charge of the day to day administration of the facility.  Please also refer to FAQ Section B for more information on the requirements on governance of PHFs.

Under the PHFO, any PHF that is covered by a licence or an exemption shall:

• be a distinct and exclusive unit that is able to perform its functions independently, and is physically separated from any premises that serve a purpose not reasonably incidental to the type of facility for which the licence is issued or specified in the letter of exemption; and
• has a direct and separate entrance.

Except during the transitional phase in clinics where a provisional licence is issued, all operators must ensure that the facility they operate has a direct and separate entrance not shared with any other premises.

For further details, please refer to Question B9 and Question B11.

Under the PHFO, any PHF where registered medical practitioners and/or registered dentists practise must be covered by a licence or a letter of exemption.  Any premises (including premises claiming to be providing "beauty services") that provide medical services (e.g. carrying out medical procedures) require a licence or a letter of exemption depending on the nature of medical services or procedures they provide. Licensed PHFs are subject to licensing conditions imposed by the Department of Health and the relevant codes of practice.  The operator has the responsibility to justify the reasonableness of any incidental service to be provided in the facility and observe the relevant requirements on distinct premises and direct and separate entrance as set out in the PHFO.  Please also refer to Question B9 and Question B12 for more information on requirements on entrance and differentiating medical procedures from beauty services respectively.

The Department of Health conducts inspection to licensed PHFs to ensure compliance with the PHFO and the relevant codes of practice.

The licensing periods for different types of PHF licences are as follows:

• Hospital licence: not more than two years
• DPC licence: not more than three years
• Clinic licence: not more than five years
• Licence of scheduled clinics listed in Schedule 6 to the PHFO: not more than one year

The Department of Health has been announcing the details of the new licensing regime in phases according to the implementation schedule and organising briefings for respective stakeholders.  Please check out the latest announcements on our website.

To address public concern about the use of titles or descriptions by illegal practitioners which may mislead the public into believing that medical services are provided therein, the Government plans to further implement section 92 of the Ordinance after the clinic licences and letters of exemption for SPCs have come into force to prohibit premises other than a permitted facility (i.e. neither a licensed hospital/day procedure centre/clinic, nor an SPC holding a letter of exemption) from bearing titles or descriptions specified in Schedule 8 to the PHFO (such as "medical", "dental" or "treatment", or a similar expression) in order to enhance regulation.

Under the PHFO, the licensee of a hospital must be a legal person, i.e. a company, or other body corporate, operated by a board of directors, which must include a person who is not a registered medical practitioner, a registered dentist, nor an employee of the hospital.  Apart from the scheduled clinics listed in Schedule 6 to the PHFO, the licensee of other PHF may be a legal or natural person, i.e. an individual, a partnership, a company, a body corporate other than a company, or a society.

The CME of a DPC shall be a registered medical practitioner or a registered dentist who has been registered in Hong Kong for not less than six years, and the CME of a clinic shall be a registered medical practitioner or a registered dentist who has been registered in Hong Kong for at least four years.  If a DPC or clinic provides medical services, the CME must be a registered medical practitioner; if only dental services are provided, the CME must be a registered dentist; if a DPC or clinic provides both medical and dental services, the CME must be a registered medical practitioner, and the licensee must also appoint a registered dentist to assist the CME in carrying out the day to day administration of the dental practice.

If a licensee who operates a group of four or more clinics has established for this group of clinics a Medical Advisory Committee (MAC) (refer to Question B6) and appointed for each clinic in the group, according to the type of practice, a registered medical practitioner or a registered dentist who is serving at the clinic, to assist the CME in carrying out the day to day administration of the clinic, the licensee may appoint a single CME for this group of clinics.  This appointed CME for the group of clinics will have to be a medical practitioner or dentist who has been registered in Hong Kong for not less than eight years, and is not serving at the same time as the CME of another PHF.

It is the duty of the licensee to appoint a CME and it is an offence if he/she fails to do so.  Please refer to section 49 of the PHFO for more details.

Please also refer to the Guidance Notes for Assessing Fitness and Properness of Applicants / Chief Medical Executives for Licence Application (PHF(E) 81A).

Under the PHFO, the licensee of a PHF is wholly responsible for the operation of the facility.  The licensee's responsibilities include ensuring the facility's compliance with the PHFO, conditions of licence, codes of practice, etc.; appointing a CME for the PHF; setting up and enforcing rules, policies and procedures relating to the quality of care for, and the safety of, patients in the PHF; making available to the public information about the prices of chargeable items and services provided in the PHF; and putting in place complaints handling procedures.

The appointed CME is to take charge of the day to day administration of the facility.  The CME's responsibilities also include adoption and implementation of rules, policies and procedures concerning healthcare services provided in the facility.

The licensee of a hospital must be a legal person, while the licensee of other PHFs can be a legal person or a natural person.  As such, the licensee of PHFs other than hospitals may be appointed as the CME for the same PHF.

The above requirements for licensees and CMEs do not apply to SPCs with exemption in force.

Under the PHFO, the CME of a PHF is responsible for the day to day administration of the facility, and the adoption and implementation of rules, policies and procedures concerning the healthcare services provided in the facility.  The CME of a hospital (registered medical practitioner only) must not serve at the same time as a CME of another PHF.  Furthermore, a registered medical practitioner or a registered dentist must not serve at the same time as the CME of:

• more than two DPCs;
• more than three clinics; or
• more than one DPC and one clinic.

However, if four or more clinics are operated at the same time by the same licensee, the licensee may appoint a single CME for that group of clinics provided that the licensee:

• has established a Medical Advisory Committee for that group of clinics; and
• has appointed for each of the clinics under that group a medical practitioner, or a dentist, who is serving the clinic to assist the CME in carrying out the day to day administration of the clinic.

For requirements on qualification of a CME in different types of PHFs, please refer to Part 5 of the PHFO.

A registered medical practitioner or a registered dentist who operates, or intends to operate, an SPC may ask the Director of Health for a letter of exemption for the clinic, regardless of whether he or she is serving as a CME of other PHF(s).  However, each registered medical practitioner or registered dentist may only operate up to three exempted clinics at the same time.  Please refer to Part 4 of the PHFO for details.

The operator of a PHF refers to the licensee of any licensed PHF.  The PHFO does not require the licensee to be doctors or dentists.  For SPC, the operators of an exempted clinic must be registered medical practitioners or registered dentists.

The licensee of a hospital is required, in addition to appointing a CME, to establish and maintain an MAC.

For a group of four or more clinics operate at the same time by the same licensee who appoints a single CME for this group of clinics, MAC has to be established.  Moreover, the licensee has to appoint for each of the clinics a registered medical practitioner and/or a registered dentist, who is serving the clinic, to assist the CME in carrying out the day to day administration of the clinic.

If the PHF is a medical practice or a combined medical and dental practice, the chairperson of the MAC must be a registered medical practitioner.  If the PHF is a dental practice, the chairperson of the MAC must be a registered dentist.  The number of members of the MAC is to be decided by the licensee, but at least half of the members must be registered medical practitioners or registered dentists, including at least one registered medical practitioner who is not employed by, or practising in, the concerned PHF.

If there is a change of the CME, the licensee must, before the expiry of 14 days after the change has occurred, notify the Director of Health in writing of the change.  It is the duty of the licensee to notify such change and it is an offence if he/she fails to do so.  Please refer to section 49 of the PHFO for more details.

Under the PHFO, the premises of licensed PHFs and exempted clinics must

1. be a distinct and exclusive premises, physically separated from any premises that serves a purpose not reasonably incidental to the facility, and
2. have a direct and separate entrance.

The transitional arrangement for clinics with a provisional licence on the above requirements is provided under the PHFO.  During the validity period of a provisional clinic licence, shared entrance is acceptable in some cases.  Please refer to section 138 of the PHFO for details.  This transitional arrangement is not applicable to SPCs.

Moreover, operators of SPCs are required to have the exclusive rights to use the premises forming the SPC.

Under the PHFO, premises in relation to a PHF are interpreted as places if they are:

• physically connected by internal access among themselves; or
• physically attached or in close proximity to, or adjoining one another; and
• forming a distinct whole for the facility to function as a single entity.

If a PHF has several units in the same building, and these units have internal access among themselves, or adjoining to each other, such that they operate as a single entity, these units will be considered as part of the premises of the PHF.

Following are some scenarios for a DPC or clinic premises to be covered by one licence:

• a DPC/clinic occupying two or more units connected with internal access
• a DPC/clinic occupying two or more adjoining units
• a DPC/clinic occupying two or more units within the same building

In a PHF, services such as those provided by dietitians and physiotherapists may in principle fall within the scope of being reasonably incidental to the services of a medical clinic, subject to any specific circumstances pertaining to those practices in individual cases.  Services such as beauty services (e.g. haircut, manicure) are considered not reasonably incidental to the intended practice.  The operator of any PHF must ensure that the premises of the facility are physically separated from any premises that serve a purpose not reasonably incidental to the type of facility/practice as specified on any licence/letter of exemption.  The operator has the responsibility to justify the reasonableness of any incidental service to be provided in the facility.  In general, conducting sales promotion of medical insurance, providing catering services and selling daily necessities, including but not limited to health supplements, skin care products, proprietary Chinese medicines and herbs without prescription, are not considered as being reasonably incidental to the medical or dental practices in a DPC, clinic or SPC.

In 2013, the Steering Committee on Review of Regulation of Private Healthcare Facilities published the "Report of the Working Group on Differentiation between Medical Procedures and Beauty Services".  The report has made recommendations that the following four categories of procedures should be performed by registered medical practitioners or registered dentists:

• cosmetic procedures that involve injections;
• procedures that involve the mechanical/chemical exfoliation of the skin below the epidermis;
• hyperbaric oxygen therapy; and
• dental bleaching.

Please refer to the "Report of the Working Group on Differentiation between Medical Procedures and Beauty Services" for details.

According to the PHFO, private hospital, each DPC or clinic operated by a group practice is required to have a separate licence as a private hospital, day procedure centre or clinic.

According to the Pharmacy and Poisons Ordinance (Cap. 138) and its Regulations (Cap. 138A), private hospital, DPC or clinic can supply medicines only to its own patients for the purposes of medical treatment.

Meanwhile, private hospital, DPC or clinic cannot supply controlled medicines to any person or party outside the private hospital, DPC or clinic, unless it is holding a relevant licence (for example an Authorized Sellers of Poisons/Wholesale Dealer Licence) issued under the Pharmacy and Poisons Ordinance.

Operators of DPCs should observe the relevant requirements of the PHFO, the "Code of Practice for Day Procedure Centres", and the "Guidance notes for application for Day Procedure Centre licence".  Operators should also ensure that premises are distinct and separate with separate entrance for the DPC, and a CME with relevant qualifications is appointed.

The various codes of practice for PHFs are standards and specifications issued by the Director of Health under the PHFO.

The "Code of Practice for Day Procedure Centres" is available here.

Operators of PHFs are advised to make reference to the relevant codes of practice to ensure compliance.

The PHFO is a premises-based legislation.  Hence, if both scheduled medical procedures and minor medical procedures are performed in the premises, the operator of that PHF would only need to apply for a DPC licence.

Minor medical procedures are medical procedures carried out in ambulatory settings not belonging to scheduled medical procedures.  Minor medical procedures may be performed in clinics.  Column 3 of Schedule 3 to the PHFO has indicated certain medical procedures that are exceptions to the scheduled medical procedures.  Examples include core biopsy of superficial and peripheral muscle, diagnostic pleural tapping, removal of foreign body with endoscope.  Please refer to Schedule 3 to the PHFO for details.

The PHFO provides transitional arrangements for clinics.

Under the transitional arrangements, operators of clinics which were in operation on 30 November 2018 are eligible for a provisional licence.  Provisional licences may be issued for applications submitted from 13 October 2025 to 13 April 2026 (both dates inclusive).  After considering the circumstances, the DH may issue a provisional licence, which allows the clinics to continue their operations before a full licence is issued.  Please refer to section 136 under Part 9 of the PHFO for details.  Operators with clinics eligible for provisional licence are advised to lodge an application as soon as practicable to allow sufficient time for licence processing.

The Secretary for Health will appoint by notice published in the Gazette the date on which the transitional arrangements expire.  A provisional licence issued to a licensee will expire on the appointed date, or when the licensee's application for the full licence is approved, withdrawn or rejected.  In order to provide sufficient preparation time for the trade, the expiry date of the transitional arrangements will be at least one year after the date on which the notice is published.

Operators of clinics which came into operation or were moved to another premises after 30 November 2018 are not eligible for provisional licence and need to apply for a full licence.

The above transitional arrangements do not apply to SPC.  As stipulated in section 41 of the PHFO, operator(s) of the SPC may submit request for a letter of exemption starting from 13 October 2025 irrespective of when the SPC started operation or whether the SPC is an existing clinic or a new clinic.

All PHFs must hold a licence or a letter of exemption in order to legally operate.  The provisional licence of clinics allows those which were already in operation on 30 November 2018 to continue to operate during the transitional period under the new regulatory regime before they are qualified for a full licence.  The clinic will be issued a full licence only when it conforms to all licensing requirements and standards.  When the transitional period comes to an end, clinics with provisional licence must all be covered by a full licence.

In line with the development of digital government, the Department of Health has made the application procedures for clinic licence fully electronic.  Operators can complete the application form online via e-Licensing and sign the application form using iAM Smart+.  By registering a user account and completing the application form at e-Licensing, applicants could track their application status online.

Please quote your reference number on all documents and subsequent submissions related to the application.  After submission of the application form and all required documents, you will be notified by email to obtain a general demand note at e-Licensing for payment of application fee.

Please refer to the Guidance Notes for Application for Clinic Licence for the detailed procedures of applying clinic licence.

The amount of application fee is based on the scale of services of the clinic.  Please refer to the Schedule 4 to the PHFO for details.  Pursuant to section 110 of PHFO, any fee paid under this Ordinance is not refundable.

Pursuant to section 99 of the PHFO, the Advisory Committee for Regulatory Standards for Private Healthcare Facilities (Advisory Committee) was established in 2020 to devise, review and update the standards of regulation for PHFs.  The Code of Practice (CoP) for Clinics was published in the Gazette in 23 May 2025 and will take effect on 13 October 2025.  Operators are required to comply with all the requirements under the PHFO and the CoP for Clinics in order to obtain a clinic licence.  The CoP is developed by the Advisory Committee in consultation with relevant stakeholders and are intended to apply to all medical and dental clinics to be licensed under the PHFO when the relevant provisions are in force.  The CoP comprises standards in respect of governance, physical conditions, service delivery and care process, infection control, risk management and contingency, and other matters related to the operation of a clinic.

The "Code of Practice for Clinics" is available here.

Yes.  Mobile clinics where registered medical practitioners and/or registered dentists practise need to obtain clinic licence or can request for exemptions.

In section 2 of the PHFO, "premises" includes any place and, in particular, includes the following:

1. any land or building;
2. any vehicle or vessel (other than a sea-going ship as defined in the Merchant Shipping (Seafarers) Ordinance (Cap. 478);
3. any part of any land or building or of any vehicle or vessel mentioned in paragraph (a) or (b).

Only one clinic licence (or one letter for exemption for an SPC) would be issued for medical and dental clinic occupying the same premises that share the same entrance.  Operators of the clinic can apply for a clinic licence as a combined practice, such that there is only one licensee (which can be a legal or natural person, i.e. an individual, a partnership, a company, a body corporate other than a company, or a society).  The licensee must appoint a CME - who is a medical practitioner responsible for the clinical management of the facility, and a registered dentist serving this clinic to assist the CME in carrying out the day to day administration of the dental practice.  If you are considering a request for a letter of exemption for SPC, please ensure fulfillment of the requirements as stated in E1.

Yes.  After relevant clinic licences come into force, the existing Medical Clinics Ordinance (Cap. 343) will be repealed and replaced by the regime established under the PHFO.  Existing operators of medical clinics registered under Cap. 343 should apply for a clinic licence under PHFO as soon as practicable.

The PHFO is a premises-based legislation.  According to the PHFO, a clinic is any premises that do not form part of the premises of an outreach facility (section 6 of the PHFO).  Section 9 of the PHFO has set out the meaning of outreach medical services.

When providing outreach medical services, registered medical practitioners or registered dentists must comply with the relevant provisions of their professional codes (including protection of patient safety and privacy, medical record keeping, drug management, etc.).  Relevant operators should seek independent legal advice and ensure that the services provided comply with Hong Kong laws.

The Ordinance is a premises-based legislation.  Section 3.10 in the CoP for Clinics outlines the requirements for telemedicine service for licensed clinics.

Registered doctors practising telemedicine should also refer to the "Ethical Guidelines on Practice of Telemedicine" issued by The Medical Council of Hong Kong.  If a doctor violates the Guidelines, they may violate the "Code of Professional Conduct".  Relevant operators should seek independent legal advice and ensure that the services provided comply with Hong Kong laws.

Vaccines are prescription-only medicines in Hong Kong and are regulated under the Pharmacy and Poisons Ordinance (Cap. 138). Vaccines must be prescribed by a registered medical practitioner.  Therefore, the provision of vaccination services in a centre should be under the supervision of a registered medical practitioner.  PHFs providing vaccination services would require relevant licence or letter of exemption in order to operate.

Relevant operators should seek independent legal advice and ensure that the services provided comply with Hong Kong laws.

The PHFO regulates premises where registered medical practitioners practise.  If a registered medical practitioner working in an imaging centre recommends examination items to patients, prescribes medications (such as contrast medium and steroids to prevent contrast allergy), drafting reports, or explains reports to patients, the centre must apply for a licence or request a letter of exemption.

Other medical professionals such as radiographers working in the centre are continued to be regulated under the applicable legislations and codes of practice.

Relevant operators should seek independent legal advice and ensure that the services provided comply with Hong Kong laws.

The PHFO aims to regulate premises where registered medical practitioners and / or registered dentists practise.  If you provide direct patient services such as medical consultation, blood taking, performing medical procedures, prescribing laboratory tests, explaining laboratory reports to patients, etc., or delegate your medical duties to other persons in the laboratory, the premises would fall under the definition of private healthcare facility under the PHFO.  If your laboratory meets the definition of a small practice clinic, regarding number of doctors and dentists, exclusive right to use the premises, locum arrangement, you may request for a letter of exemption.  Please refer to Section E of the FAQ for more details on SPC requirement.  If your laboratory does not meet the definition of a small practice clinic, then you need to apply for a clinic licence.

Premises where a pathologist solely reports laboratory investigations and issues reports to referring doctors do not fall into the definition of a private healthcare facility.  You do not need to apply for a clinic licence or request a letter of exemption for the premises where you solely report laboratory investigations and issue reports to the referring doctors.

Premises where a pathologist solely reports laboratory investigations and issues reports to the referring doctors do not fall into the definition of a private healthcare facility.

If the registered medical practitioner provides direct patient services such as medical consultation, blood taking, performing medical procedures, prescribing laboratory tests, explaining laboratory reports to patients, etc. or delegates of his/her medical duties to other persons at your premises, the premises would fall under the definition of a private healthcare facility.  You will be required to obtain the relevant licence/letter of exemption under PHFO.

Medical practitioners should observe requirements of practice in association with non-qualified persons and delegation of medical duties to non-qualified persons as stipulated in the Code of Professional Conduct issued by the Medical Council of Hong Kong.

Other healthcare professionals such as medical laboratory technologists, registered nurses and enrolled nurses who may perform procedures like blood taking should also observe relevant requirements of their respective Ordinances and requirements on training, prescription/referral and delegation as stipulated in their respective codes of practice.

If a clinic fulfills the requirements of an SPC, operator(s) of the SPC may ask the Director of Health for a letter of exemption for the clinic to be exempted from applying for a licence.

The definition of an SPC is stipulated in section 41 of the PHFO.

• An SPC must be operated only by registered medical practitioner(s) and/or registered dentist(s).
• The operation may be in the form of a sole proprietorship, a partnership, or a company.
• No registered medical practitioners or dentists other than the operator(s) can serve the clinic (except for locum arrangement).

Moreover, the following three conditions must also be met:

1. Number of medical practitioners or dentists:
1. If the SPC is operated under a sole proprietorship, the sole proprietor must be a registered medical practitioner or a registered dentist;
2. If the SPC is operated under a partnership or a company, there can only be a maximum of five partners or company directors, and all partners or company directors must be registered medical practitioners or registered dentists.
2. The right to use the premises:
1. The sole proprietor of the sole proprietorship; at least one partner of the partnership; the company or at least one director of the company shall have the exclusive right to use the premises forming the SPC.  Sub-lease is not allowed.
3. Locum arrangement:
1. For every registered medical practitioner or registered dentist operating the SPC, the total number of locum days for which another registered medical practitioner or registered dentist takes up the duties of the individual must not exceed 60 days in a calendar year;
2. In addition, the aggregate number of locum days for all the partners or directors operating the clinic must not exceed 180 days in a calendar year.

Each registered medical practitioner or registered dentist may operate up to three SPCs with valid exemption at the same time.

In addition, the clinic must comply with sections 66 and 67 and:

• Be a distinct and exclusive unit that is able to perform its function independently;
• Be physically separated from any premises that serve a purpose not reasonably incidental to the facility; and
• Have a direct and separate entrance.

The Government is now actively taking forward the regulatory work on clinics.  The Secretary for Health has appointed 13 October 2025 as the date starting to accept applications for clinic licences and requests for letter of exemption.  Operators of an SPC may make request for a letter of exemption from then on.  We shall announce the arrangements in due course.

An SPC can only be operated by registered medical practitioner(s) and/or registered dentist(s).  As stipulated in section 42 of the PHFO, any individual, a partnership or a company that operates or intends to operate an SPC may ask the Director of Health for a letter of exemption for the clinic.

As stipulated in section 41 of the PHFO, a registered medical practitioner who is qualified to operate an SPC is a person whose name is included in Part I of the General Register kept under section 6(1) of the Medical Registration Ordinance (Cap. 161).

The PHFO stipulates that an SPC is a clinic operated only by registered medical practitioner(s) and/or registered dentist(s).  No medical practitioners or dentists other than the operators can serve the clinic.  There is no requirement on the period the operator is required to practise at the clinic.

Please note: section 19(1)(b) of the Medical Registration Ordinance provides that the Medical Council may order the removal from the General Register of the name of any person who has not, before 30 June of a year, obtained his / her practising / retention certificate for that year.  If a person's name is removed from the General Register, he / she will cease to be a registered medical practitioner and will not be qualified to operate an SPC.  The operator must ensure that his/her name is included in Part 1 of the General Register in order to be qualified to operate an SPC.

In general, any registered medical practitioner or registered dentist who operates or intends to operate an SPC may request a letter of exemption for an SPC from the Director of Health.  However, each registered medical practitioner or registered dentist may only operate up to 3 SPCs at the same time.  Whether or not the registered medical practitioner is serving as a CME is not a criterion in the definition of SPC under the PHFO.

No.  All the directors of a company operating an SPC must be registered medical practitioner(s) and/or registered dentist(s).  Your clinic does not fulfil the conditions of an SPC and must apply for a clinic licence.

No.  All the directors of a company operating an SPC must be registered medical practitioner(s) and/or registered dentist(s), irrespective of how long the clinic has been operated or the personal relationship between the directors.  Your clinic does not fulfil the conditions of an SPC and must apply for a clinic licence.

If the SPC is operated in the form of a partnership, operators are required to make relevant declaration in the request for a letter of exemption.  Under the PHFO, all operators of an SPC are equally liable to the legal responsibilities of operating the SPC.

All operator(s) of an SPC are required to sign the request form.

Yes.  According to section 44 of the PHFO, if there are any intended changes of the clinic (including change of partner(s)/ director(s) in the partnership/ company, change in address), intended cessation of the clinic's operation, or intended cessation of the clinic's operating as an SPC, the operator(s) must give the Director of Health not less than 14 days' advance notice in writing.  The operator(s) may have to make another request for exemption or apply for a licence because of the changes.

Subject to the operation, having an "exclusive right to use the premises" means the sole proprietor, or at least one partner/director of the partnership/company, or the company of the SPC, but not anyone else must have control on the access to and use the premises at any time.  

In general, if a person / company is the owner or tenant of the premises forming the clinic, they are regarded as having the exclusive right to use the premises.   Sublease, where another operator not clarified under the PHFO has rented part of the premises without separate entrance, would be regarded as contravention of the PHFO.

For specific premises, please seek your own legal advice to ensure the premises complies with the PHFO.  Please note that under section 93 of the PHFO, persons making a false or misleading statement or representation commit an offence.

Under sections 66 and 67 of the PHFO, the premises of licensed PHFs and exempted clinics must –

1. be distinct and exclusive premises, physically separated from any premises that serves a purpose not reasonably incidental to the facility, and
2. have a direct and separate entrance.

Moreover, operators of exempted clinics are required to have the exclusive rights to use the premises forming the SPC.  In other words, operator(s) of an exempted clinic must ensure that the SPC he or she operates has a direct and separate entrance that is not shared with any other premises.

For your case, as you and the dentist share the same entrance, you are regarded as using the same single premises.  Please note that only one letter of exemption or clinic licence can be applied for a premises.  Please discuss among yourselves to ensure fulfillment of the requirements as stated in E1 for requesting a letter of exemption.  Alternatively, you may consider to apply for a clinic licence if the clinic cannot fulfill the requirements for a letter of exemption.

According to sections 66 and 67 of the PHFO, the premises of licensed PHFs and exempted clinics must –

1. be distinct and exclusive premises, physically separated from any premises that serves a purpose not reasonably incidental to the facility, and
2. have a direct and separate entrance.

Moreover, operators of exempted clinics are required to have the exclusive rights to use the premises forming the SPC.

In other words, operator(s) of an exempted clinic must ensure that the SPC he or she operates has a direct and separate entrance that is not shared with any other premises.

Please make sure that only services with a purpose reasonably incidental to the clinic are allowed to be conducted in the premises.

Services considered as "reasonably incidental" are subject to any specific circumstances pertaining to those practices in individual cases.  The operator has the responsibility to justify the reasonableness of any incidental service to be provided in the clinic.

In general, for a clinic where registered medical practitioners practise, supporting services such as physiotherapy, occupational therapy, optometry, radiology, pharmacy, medical laboratory, chiropractor, Chinese medicine are considered as reasonably incidental.

However, beauty service (e.g. haircut, manicure), sales of medical insurance, selling of products (e.g. daily necessities, proprietary Chinese medicine, skin products, etc.) are not considered to be reasonably incidental to the clinic, and should not be conducted inside the premises of the clinic.

Yes, you can provide radiology diagnostic service in an SPC.

However, you should make sure that all the related regulations are complied with.  For example, you need to obtain a licence for the X-ray apparatus under the Radiation Ordinance (Cap. 303), and make sure that diagnostic radiographers registered under Allied Health Professions Ordinance (Cap. 359) are responsible for operating the imaging machines.  All the equipment should be serviced according to the recommendations of the manufacturers.

Please be reminded that in an SPC, only the sole proprietor, the partners or the company directors can provide medical service in the clinic.  Therefore, the clinic should not allow a radiologist who is not the operator of the clinic to provide imaging service.

According to section 70 of the PHFO, if any of the room, unit, or section of the clinic bears a name or description that includes the expression "operating room", "operation room", "operating theatre", "operation theatre" or a similar expression, you must apply for a prior approval in writing of the Director of Health for using the above names or descriptions.  You need to submit a layout plan and other relevant documents.  Please contact us for further details.

No.  Please note that each SPC can only be operated by registered medical practitioner(s) and/or registered dentist(s) in the one of the following forms:

• a sole proprietor;
• a partnership having no more than 5 partners; or
• a single company having no more than 5 directors.

Please discuss among yourselves to ensure fulfillment of the requirements as stated in E1 for requesting a letter of exemption.

No.  Please note that sub-lease is not allowed in SPCs as it does not fulfill the requirement of exclusive right to use the premises.  Moreover, each SPC can only be operated by either a sole proprietor, a partnership having not more than 5 partners, or a single company having not more than 5 directors.  Each premises can only request a letter of exemption or apply for a clinic licence.

Please discuss among yourselves to ensure fulfillment of the requirements as stated in E1 for requesting a letter of exemption.

No.  Under PHFO, only the sole proprietor, the partners of a partnership or the directors of a company can serve in the SPC.  Doctors D and E are not directors of your company.  They are not allowed to serve the clinic if you would like to request a letter of exemption.

Please discuss among yourselves to ensure fulfillment of the requirements as stated in E1 for requesting a letter of exemption.  Alternatively, please consider to seek legal advice on whether applying for a clinic licence is suitable in your case.

As far as the operation of an SPC is concerned, locum arrangement refers to the situation where another registered medical practitioner or registered dentist takes up the duties of a registered medical practitioner or registered dentist who is entitled to the relevant letter of exemption at the SPC during the latter's absence.  The two persons would not provide medical services at the SPC concerned at the same time.  Any locum period within a calendar day will be taken as one locum day.

For every registered medical practitioner or registered dentist operating the SPC, the total number of locum days for which another registered medical practitioner or registered dentist takes up the duties of the individual, must not exceed 60 days in a calendar year.  In addition, the aggregate number of locum days for all the partners or directors operating the clinic must not exceed 180 days in a calendar year.

Part-time employment of any registered medical practitioner(s) or registered dentist(s) to provide medical services in the presence of the registered medical practitioner(s) or registered dentist(s) who is/are issued with the relevant letter of exemption at the SPC concerned is not allowed.

Any period within a calendar day that a locum doctor works to take up the duties of the absent operators will be taken as one locum day, regardless of the number of absent operators on that day.   For example, if two doctors take leave on the same day but only one locum doctor comes to serve at clinic on that day, only one calendar day will be counted.

On the other hand, the duty of each operator of the exempted clinic can only be taken up by one locum registered medical practitioner/registered dentist for a particular day.  For example, if only one doctor takes leave but two locum doctors (Doctor A and Doctor B) come to serve the clinic on that day, only Doctor A will be considered as locum doctor and "one locum day" will be counted.  However, Doctor B will be regarded as visiting doctor, which is NOT allowed in SPC and deemed as violation of the PHFO.

Any locum period within a calendar day will be taken as one locum day.  The operator must ensure that the total number of locum days for which another registered medical practitioner or registered dentist takes up the duties of the individual does not exceed 60 days in a calendar year and, if the SPC is operated by a partnership or a company, the aggregate number of locum days for all the partners or directors operating the clinic does not exceed 180 days in a calendar year.

Operator(s) of an SPC should remain responsible for all services provided or activities carried out on that premises.

The calculation of locum days is based on each individual SPC.  The number of locum days will not be added across different clinics.

Please note that for every registered medical practitioner or registered dentist operating an SPC, the total number of locum days for which another registered medical practitioner or registered dentist takes up the duties of the individual, must not exceed 60 days in a calendar year for each SPC and, if the SPC is operated by a partnership or a company, the aggregate number of locum days for all the partners or directors operating the clinic does not exceed 180 days in a calendar year.

Operators do not need to inform DH of the information of individual locum doctor.  However, any breach of the requirement concerning locum arrangement for SPC would result in regulatory actions.

Please be reminded that the locum registered medical practitioner/registered dentist can only take up the duties of the operator of the exempted clinic at time of his/her absence, and they cannot practise at the clinic at the same time.

According to section 43(1) of the PHFO, each registered medical practitioner or registered dentist may operate up to three SPCs with valid exemption at the same time.  If you are already operating three exempted clinics at the same time, you will have to apply for a clinic licence for the fourth or subsequent clinics.

No.  Each exemption is specific to an SPC at one specified location.  You are required to make a separate request for each SPC.  Please note each registered medical practitioner or registered dentist may operate up to three SPCs with valid exemption at the same time.

The PHFO provides for the regulatory regime of PHFs on a risk-based basis and focuses on regulation of clinics of larger scales and under the management of incorporated bodies.  SPCs are typically of smaller scale and are exclusively operated by doctors and/or dentists registered under The Medical Council of Hong Kong and The Dental Council of Hong Kong respectively.

A licensed clinic is required to:

• appoint a CME, comply with requirements under the Code of Practice and be subject to regular inspection;
• pay a fee for application for a clinic licence; and
• renew the licence.

The above requirements are not applicable to SPCs.

The operator(s) must make a request for a letter of exemption to the Director of Health in order to obtain a letter of exemption.  You will not be granted an exemption automatically without making a request.

Operator(s) of a clinic that falls under the meaning of an SPC can choose to apply for a clinic licence or request a letter of exemption.  For details on applying for a clinic licence, please refer to the relevant webpage.

The operator(s) of any clinic that does not fall under the meaning of an SPC must apply for a clinic licence in order to operate.  Please refer to the relevant webpage for the requirement on clinic licence.

In line with the development of digital government, the Department of Health has made the procedures for requesting letter of exemption for SPC fully electronic. Operator(s) of SPC can register for an "e-Licensing" account in preparation at https://apps.orphf.gov.hk/Submission. Operators can submit the request and relevant document(s), check the request progress and receive the letter of exemption through the e-Licensing system from 13 October 2025 onwards. Digital signatures can be submitted via the "iAM Smart" app, offering the most efficient and expedited route for obtaining the letter of exemption.

If operators are not able to submit the request electronically, they may submit the request and relevant document(s) by post. Alternatively, operators or their delegate may contact our office to make an appointment for in-person submission.

Operator of an SPC is required to submit a Request for Letter of Exemption for Small Practice Clinic ("Request Form") to request a letter of exemption. In the Request Form, you are required to provide information regarding particulars of the SPC, particulars of the operator and declarations of the SPC and operator(s). Please note that the following information will be available on PHF Register for public inspection: clinic name, clinic address, contact information of the clinic, type of practice of the clinic and operators' names.

The supporting documents required depend on the submission method:

• Those request by means of e-Licensing using digital signature in the form of "iAM Smart+" are only required to provide a proof of clinic address in electronic format as supporting document.
• If you cannot use "iAM Smart+" for digital signature, please complete the Form on e-Licensing and print the Form. All operators will have to sign manually on the Form. You may then submit by post or contact our staff to make an appointment to submit the following documents:
1. Completed and signed Request Form;
2. Copies of Hong Kong Identity Cards of all operators;
3. Copies of valid practising certificates of all operators; and
4. Address proof of the clinic.

In addition, if any of the room, unit, or section of the clinic bears a name or description that includes the expression "operating room", "operation room", "operating theatre", "operation theatre" or a similar expression, you must apply for a prior approval in writing to the Director of Health for using the above names or descriptions. You will need to submit an application form, a layout plan and other relevant documents. Further details will be announced on the Office for Regulation of Private Healthcare Facilities website in due course.

Only after making sure that the clinic has fulfilled all the requirements as explained in E1, and the clinic is ready to provide medical service (e.g. the facility, equipment and manpower are in good condition), then you can submit your request for letter of exemption.

To minimize the risk of delaying service commencement, if you have any questions, we suggest you to call our staff early to clarify the eligibility for letter of exemption and the information required.

It depends on several factors, including whether you can complete the request through electronic platform, whether the information submitted is complete and correct, etc.

In general, the exemption can be granted within a week (or even earlier) if all the required information is submitted through electronic platform.

Yes.  According to section 43(4) of the PHFO, the Director of Health must refuse to issue a letter of exemption if the Director considers it inappropriate for the person making the request to carry on the practice in the clinic without a licence (i.e. request a letter of exemption).  Assessment criteria include, but not limited to, history of contravention of or conviction of offences under the PHFO, other conditions related to professional competence, business arrangement or financial status.

If your SPC is operated by a partnership or a company, operators are required to appoint an authorized partner / authorized director for (i) holding an e-Licensing account if the request form will be filled on e-Licensing; and (ii) representing the partnership / company to communicate with DH on matters related to the SPC.  Their means of contact should be provided as the correspondence of the partnership / company on the request form.  All partners / directors should maintain good communication among themselves and will share responsibilities on operating the exempted clinic.

The requirement of appointing a CME is not applicable to SPC. However, operator(s) of an SPC should remain responsible for all services provided or activities carried out on that premises.

No.  Instead, you will be asked to declare that the premises of your clinic comply with the requirements stipulated under sections 66 and 67 of the PHFO when you submit your request form.

However, operators who plan to operate an "operation room" or "operation theatre" as defined in section 70 of the PHFO in an SPC would be required to produce a layout plan for such room.  Pursuant to the PHFO, clinic /SPC operators cannot operate the room under the name of "operation room" or "operation theatre" without prior approval from the Director of Health.

Normally, DH will not conduct site inspection to SPC requesting a letter of exemption.  In most cases, DH will make use of the information provided in your request form and relevant supporting documents to process your request.

Please note that all the information you provide in your request should be true and correct to the best of your knowledge.  According to section 93 of the PHFO, any person who furnishes in such request any statement or information that is false or misleading in a material particular commits an offence and could result in revocation of the letter of exemption issued.

In addition, pursuant to sections 114 and 115 of the PHFO, the Director of Health reserves the authority to enter any premises under specific conditions.  These include circumstances where a premises is reasonably suspected of being in contravention of regulations, or where such entry is deemed necessary for the protection of public health during emergency situations.

There is no transitional arrangement for SPCs.  The operator of a clinic either apply for a licence or request a letter of exemption to operate the clinic provided that relevant licensing/exemption requirements are met.

Requesting a letter of exemption for an SPC is free of charge.

Operators of exempted clinics must comply with all relevant requirements for an SPC and its operation under the PHFO.  If there are any intended changes of the clinic, or intended cessation of the clinic's operation, the operator(s) must give the Director of Health not less than 14 days' advance notice in writing.  The operator(s) may have to request another exemption or apply for a licence.

Unless the clinic is relocated, no longer falls under the meaning of an SPC, or the exemption is revoked by the Director of Health, the letter of exemption for an exempted clinic does not need to be renewed.

While there is no requirement under the PHFO for the operators of an exempted clinic to display the letter of exemption in their clinics, exempted clinic are provided with a QR code and operators are recommended to display the QR code to facilitate the public to obtain the information of the SPC in the Private Healthcare Facilities Register on our website.

The letter of exemption is available in the e-Licensing account of the SPC, operator can log on e-Licensing to access the letter of exemption whenever necessary.  Operators are recommended to create an e-Licensing account to manage the profile of the exempted clinic.

The letter of exemption will be issued in electronic format.  The letter of exemption is available in the e-Licensing account of the SPC, operator can log on e-Licensing to access the letter of exemption as and when necessary.  The letter of exemption will be sent to the email addresses of operators who do not have an e-Licensing account.  Operators are recommended to create an e-Licensing account to manage the profile of the exempted clinic.

In order to facilitate the public to identify whether the premises providing medical services have been issued with a valid licence or an exemption, the Department of Health has established the Private Healthcare Facilities Register (the Register) to record all exempted clinics and PHFs with valid licence.  Relevant information of exempted clinics will be uploaded to the Register.  The Register will be uploaded to the website of ORPHF and will be available in ORPHF office for public inspection.  Furthermore, exempted clinics are provided with letter of exemption as well as a QR code to facilitate the public to obtain the information of the SPC on our website.  The innovative Licence Scanner in "@DH" mobile apps allows users to verify licences and certificates recognised by DH.

The Ordinance has different requirements and arrangements for clinics applying for a "Letter of Exemption for Small Practice Clinic" and a "Provisional Clinic Licence".  In general, the differences can be summarised in the following areas:

The operator(s) of a small practice clinic is/are the only person(s) eligible for making a request for letter of exemption.  Small Practice Clinic should not employ or sublet any part of the clinic to doctors or dentists who are not the operators.

If you do not operate a clinic, and the clinic you currently work in is not operated by you, you do not need to apply for a letter of exemption.  However, since the clinic you currently work in has been sublet to you, the clinic must apply for a provisional or full clinic licence and cannot apply for a letter of exemption.

For an SPC, the operators must be the only registered medical practitioner(s) or registered dentist(s) who serve the clinic.
Employment of any other registered medical practitioner(s) or registered dentist(s) is not allowed.  However, if needed, an operator can arrange a locum to take up the duties of any operator during their absence.  Please refer to section 41 of the Ordinance on locum arrangements.

If your clinic employs any other registered medical practitioner(s) or registered dentist(s) other than the above situations, you must apply for a clinic licence.

Under the PHFO, transitional arrangements are provided for existing clinics to transit to the new licensing regime.  If clinics were already in operation on 30 November 2018, operators can apply for provisional licences.  Applications for clinic provisional licences would be accepted from 13 October 2025 to 13 April 2026 (both dates inclusive).  After considering the circumstances, the DH may issue a provisional licence, which allows the clinics to continue their operations before a full licence is issued.

The above transitional arrangements do not apply to SPC.  As stipulated in section 41 of the PHFO, operator(s) of the SPC may submit request for a Letter of Exemption starting from 13 Oct 2025 irrespective of when the SPC started operation or whether the SPC is an existing clinic or a new clinic.

After registering for an e-Licensing account, operators are strongly encouraged to fill and use "iAM Smart+" to digitally sign the Request Form. This is the most convenient way of submission and has the shortest processing time. Those signing with "iAM Smart+" are only required to provide a proof of clinic address in electronic format as supporting document.

If you cannot use the "iAM Smart+" for digital signature, please complete the Form on e-Licensing and print the form. All operators will have to sign on the printed Form. You may then submit by post or contact our staff to make an appointment to submit the following documents:

"Scheduled medical procedures" (SMPs) are medical procedures specified in Column 2 of Schedule 3 to the Ordinance (excluding Column 3) which are carried out in ambulatory settings.  As SMPs entail a higher level of risk, they can only be performed in hospitals or DPCs but are not allowed in clinics / SPC setting.  SMPs include eight classes of specialized services: (i) Surgical procedure, (ii) Endoscopic procedure, (iii) Dental procedure, (iv) Chemotherapy, (v) Haemodialysis, (vi) Inter-ventional radiology and lithotripsy, (vii) Anaesthetic procedure, (viii) Radiotherapy.  Please refer to Section 2 of the Ordinance for the interpretation of "SMPs" and Column 2 of Schedule 3 to the Ordinance for the particular medical procedures under the abovementioned classes of specialized services.

In contrast, minor medical procedures are medical procedures carried out in ambulatory settings not belonging to SMPs.  They may be performed in clinics.  Please note Column 3 of Schedule 3 to the Ordinance has excluded certain specific examples of medical procedures from the particular medical procedures of the above specialized services.  Examples include core biopsy of superficial and peripheral muscle biopsy, diagnostic pleural tapping, removal of foreign body with endoscope.  These procedures are therefore not SMPs and may be performed in clinics. Other examples of minor medical procedures include excision of sebaceous cyst, wound dressing, and simple suture under local anaesthesia.

The Ordinance does not impose any requirements on the size of small practice clinics, but the clinics must comply with the requirements of sections 41, 66 and 67 of the Ordinance. Furthermore, clinics should have an appropriate physical design, size, layout and environment to provide safe and effective services that meet the needs of patients.

The definition of an SPC is stipulated in section 41 of the PHFO.

• An SPC must be operated only by registered medical practitioner(s) and/or registered dentist(s).
• The operation may be in the form of a sole proprietorship, a partnership, or a company.
• No registered medical practitioners or dentists other than the operator(s) can serve the clinic (except for locum arrangement).

In addition, the clinic must comply with sections 66 and 67 and:

• Be a distinct and exclusive unit that is able to perform its function independently;
• Be physically separated from any premises that serve a purpose not reasonably incidental to the facility; and
• Have a direct and separate entrance.

As far as the operation of an SPC is concerned, locum arrangement refers to the situation where another registered medical practitioner or registered dentist who located at the clinic takes up the duties of a medical practitioner or dentist who is entitled to the relevant letter of exemption at the SPC during the latter's absence.  If the online consultation is being conducted at the clinic as part of the duties taken up by another registered medical practitioner or registered dentist who is entitled to the relevant letter of exemption at the SPC, it will be considered as a locum arrangement.  Any locum period within a calendar day will be taken as one locum day.

Yes.  Each registered medical practitioner or registered dentist operating the SPC will use up one quota of operating exempted clinic, regardless of whether the clinics are operated by sole proprietorship, a partnership, or a company.  Please note each registered medical practitioner or registered dentist can only operate up to three SPCs with valid exemption at the same time.

The Code of Practice for Clinics is devised based on the recommendations from the Advisory Committee for Regulatory Standards for Private Healthcare Facilities (Advisory Committee).  The Advisory Committee includes doctors from various sectors, including Family Medicine doctors and Primary Care doctors.  The Advisory Committee has unanimously agreed after deliberation to establish the Code of Practice for Clinics as the minimum standards for the safe provision of medical services in a clinic setting in Hong Kong.

When a small practice clinic operator applies for an exemption certificate, they are not required to submit proof or a declaration that the clinic complies with the Code of Practice for Clinics. This is because the operating model of small practice clinics - being solely operated by registered medical practitioners and/or registered dentists, personally attending to patients, and having exclusive use of the premises - is already subject to professional regulation. The Code of Professional Conduct issued by the Medical Council of Hong Kong governs the conduct of doctors, including clinic management requirements such as medication handling, medical records, and patient privacy. Therefore, this professional code already plays a regulatory role in the operation of small practice clinics.

However, the Code of Practice for Clinics is more detailed and covers aspects such as staff training, equipment sterilization, sedation requirements, and the storage of medical gases. If the Department of Health finds that a small practice clinic fails to meet management standards or poses a risk to patient safety, it has the authority - under Sections 45 and 46 of the Ordinance - to revoke the exemption on the grounds that the clinic's operation is contrary to public interest.