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Does my clinic qualify as a small practice clinic?

7 min readUpdated 15 October 2026, checked against orphf.gov.hk
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If the clinic is run by registered doctors or dentists, no more than 5 of them, who are the only doctors or dentists serving it apart from locums, with exclusive use of the premises, it can request a letter of exemption, 豁免書. The request carries no fee and the letter needs no renewal while the clinic qualifies.

Who qualifies, 小型執業診所

The operator is a sole proprietor, a partnership of no more than 5 partners, or a company with no more than 5 directors, all registered doctors or dentists. They are the only doctors or dentists serving the clinic, locums apart, and have exclusive use of the premises. Locums are limited to 60 days per operator per year, and 180 days in total. Each doctor or dentist may run up to three exempted clinics at once.1

The letter of exemption stays valid without renewal until the clinic relocates, stops qualifying, stops operating, or the exemption is revoked. Changes and closing need at least 14 days' notice.1 A small practice clinic does not need a Chief Medical Executive.2 By 30 March 2026, over 2,600 letters of exemption had been issued.3

  1. Check every condition. Operators, numbers, locums and exclusive use of the premises.
  2. Apply through e-Licensing. Signed with iAM Smart+, with no fee.
  3. Track locum days. 60 per operator per year, 180 in total.
  4. Notify changes. At least 14 days before a change or closing.
TemplateExemption eligibility check
  1. Operators and registration numbers ______
  2. Number of operators ______ No more than 5 ______
  3. Other doctors or dentists serving the clinic ______
  4. Locum days this year ______
  5. Exclusive use of premises ______

Questions

Is there a fee for the letter of exemption?

No, requesting a letter of exemption for a small practice clinic carries no charge.

Does it need renewing?

No, while the clinic still qualifies and stays at the same premises.

Must we display the letter?

ORPHF's guidance notes say a small practice clinic is not required to display it. Check the latest guidance, as a 2026 press release said otherwise.

Sources

  1. 1Department of Health, 2026Guidance notes for request for letter of exemption for small practice clinics, PHF(E) 51ARead source
  2. 2Legislative Council, 2025Legislative Council brief, commencement notices under Cap. 633Read source
  3. 3HKSAR Government, 2026Application for provisional clinic licences to close on April 13Read source

Written by the wai team from Office for Regulation of Private Healthcare Facilities, Department of Health, Hong Kong guidance, checked on 15 October 2026. This is guidance, not legal advice. ORPHF does not endorse wai or any software.

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