Clinic AI in Hong Kong, what private clinics and health systems should know in 2026

The private care market in Hong Kong

Hong Kong had 16,459 doctors at 31 March 2024, 2.16 for every 1,000 people.¹ The public and private sectors each employ around half of them, while the public system provides 90% of in-patient services, so private doctors see their patients mainly in outpatient clinics.¹

As of August 2025, more than 4,100 private healthcare providers had registered with eHealth, covering over 6,700 service locations, up 18% in a year.³ Private providers mostly view records there and only a minority deposit them, and the government is adding technical help, subsidies and incentives to change that.³

The rules a Hong Kong clinic works under

The Private Healthcare Facilities Ordinance, Cap. 633, requires a licence to operate a clinic where registered medical practitioners or dentists practise, and licensees follow the Code of Practice for Clinics issued by the Director of Health.² The Department of Health began accepting applications on 13 October 2025. Clinics operating since before 30 November 2018 could apply under transitional arrangements until 13 April 2026, and small practice clinics of no more than five doctors or dentists obtain a letter of exemption instead.²

The Personal Data (Privacy) Ordinance applies to every patient record. The PCPD's Model Personal Data Protection Framework for AI, published in June 2024, recommends that higher-risk AI keep a human in the loop who retains control of decisions, and lists AI-assisted medical imaging analytics or therapies among its higher-risk examples.⁴

Recording a consult collects personal data, so under Data Protection Principle 1 the clinic tells patients the purpose and the classes of people who may receive the data, including any AI supplier, on or before collection.⁴ Where an AI provider processes data for the clinic, Principle 4(2) calls for contractual safeguards against unauthorised access or loss.⁴ wai names every subprocessor, with what it does and the agreement in place, and gives thirty days notice before any change.⁷

For personal data moving between Hong Kong and the mainland Greater Bay Area cities, the CAC and the Innovation, Technology and Industry Bureau published a standard contract in December 2023, filed with the Office of the Government Chief Information Officer within 10 working days of taking effect.⁸

The Electronic Health Record Sharing System (Amendment) Ordinance 2025 took effect on 1 December 2025, so once a citizen consents to join eHealth, their healthcare providers may deposit health data to their account.³ wai is built to connect to eHealth. We set up your clinic's connection with you.

wai hosts each clinic's records in its own country, under that country's rules. We set this up with your clinic. wai is compliant with these rules and built for clinics in Hong Kong. The guide to data residency lists the contract questions.

The languages Hong Kong patients write in

In the 2021 Population Census, 88.2% of residents aged five and over spoke Cantonese at home, 58.7% could speak English and 54.2% Putonghua.⁵ For written messages, 90.1% could read Chinese and 70.6% could read English.⁵

wai works in any language.⁶ A member of the team reads and approves each reply before it goes.

What a demo shows in Hong Kong

The demo opens on a message in Chinese sent through the clinic's website at 11.30pm to a family clinic in Central, asking whether the doctor can see a child before school on Saturday. wai reads it in the patient's thread, checks the doctor's busy times in Google Calendar or Outlook, finds an open slot and drafts the reply. The clinic assistant approves it at 8am.

A missed call during the morning session becomes a drafted text the team approves in the same thread. After the consult, the doctor reviews and signs the drafted note and referral letter, and every draft and signature is logged. Bring a real week of enquiries, in the languages they arrived in.

For hospital groups and insurers in Hong Kong

A private hospital group or insurer can have wai built around one pathway, such as outpatient follow-up with eHealth deposits, under its own brand and with data rights agreed in the contract. The organisations page describes how a build begins.

Where to start

First, confirm whether the practice holds a clinic licence or a small practice clinic exemption under Cap. 633.² Second, update the Personal Information Collection Statement so patients know about AI note-taking and which suppliers receive their data, as the PCPD framework recommends.⁴

Third, name who approves messages and who signs notes, keeping a person in the loop for every AI output.⁴ Fourth, count last month's enquiries by language and by hour, and bring the count to the demo.

Frequently asked questions