How the 2025 Code of Practice Changes Affect Physiotherapy Practice in Hong Kong

Date: 10 July 2026

Author: Rendy Ng / Amber Yung | Rendy Ng Law Firm

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Hong Kong's physiotherapy sector is entering a new phase of development. The Code of Practice of the Physiotherapists Board of Hong Kong (December 2025 Revised Edition) (hereinafter the "2025 Code") introduces several significant updates that not only elevate professional standards but also align the professional standing of physiotherapists more closely with that of medical doctors. This reflects a clear direction: to position allied health professions on par with the mainstream healthcare system in terms of professional responsibility and public trust.

Concurrently, the Supplementary Medical Professions (Amendment) Ordinance 2025 strengthens the regulatory framework, clearly defining the roles of physiotherapists and occupational therapists as professionals with direct patient access, thereby granting greater autonomy and responsibility. This article will guide you through the practical implications of these changes and share strategies for maintaining compliance under the new regulations while mitigating potential professional risks.

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Direct Access to Patients: Greater Flexibility, Higher Accountability

Under the 2025 Code, patients can now seek physiotherapy directly without a medical referral in three scenarios with conditions:

1. Emergency Cases - For example, acute injuries requiring immediate attention;
2. Community Services - As specified by projects designated by the Physiotherapists Board of Hong Kong ("PBHK"); and/or
3. Clinically Recognised Guidelines - For instance, common musculoskeletal complaints, provided that red flag symptoms are first ruled out, with referral to a medical practitioner when necessary.

This brings greater professional autonomy but simultaneously demands more rigorous clinical decision-making from physiotherapists.

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CPD Requirements: Raising Standards

Since July 2023, all registered physiotherapists are required to accumulate at least 45 CPD credits within a three-year cycle, with a minimum of 5 credits in each year. The Board anticipates that this requirement will soon become a condition for license renewal.

A few points deserve particular attention. Newly registered physiotherapists are required to fulfil CPD requirements on a pro rata basis. In addition, around 15 per cent to 30 per cent of the required credits must come from core activities, such as ethics related training and clinical education. Activities that are not formally accredited may still be recognised for CPD purposes, provided an appropriate application is made.

For clinic owners, group practices and managers, this is a useful time to consider whether CPD compliance is properly built into internal systems. This may include tracking mechanisms, staff supervision, employment terms and record keeping protocols. Taking these steps now may help avoid administrative difficulties and compliance concerns later.

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Digital Marketing and Professional Publicity: Accuracy, Consent and Professional Judgment

Section 6 of the 2025 Code, dealing with Professional Communication and Information Dissemination, reflects a clear regulatory focus on how physiotherapists present themselves online. This is particularly relevant given the widespread use of websites, social media, video content and digital advertising to promote services and engage with patients.

The central message is straightforward: publicity must be truthful, professional and not misleading. Physiotherapists should NEVER:

• guarantee of treatment outcomes or make exaggerated claims about the effectiveness of their services in any form;
• post before-and-after photos of patients and their testimonials without obtaining legal and informed consent (prior consent must be obtained from patients before taking photographs or videos, with due consideration of obligations and liabilities under the Personal Data (Privacy) Ordinance;  
• include unquotable qualifications other than those quotable qualifications listed on the PBHK's website.

Where AI generated images or videos are used, they should be clearly identified as such. Any content that may mislead members of the public, whether by implication, presentation or omission, should be avoided. The use of automated promotional notifications or links to commercial platforms is also prohibited.

That said, not all public facing content carries the same level of risk. Material prepared for general health education or public information purposes will usually be less problematic. Even so, where social media or AI tools are used as part of a clinic marketing strategy, content should still be reviewed carefully to ensure it remains objective, professional and consistent with the standards expected of a registered physiotherapist.

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Practical Highlights for Daily Operations

For physiotherapists and clinic operators, the latest regulatory changes are not just about formal compliance. They also affect day to day practice management, patient communication, record keeping, and internal risk control. In practical terms, clinics should consider whether their existing procedures are sufficient to meet current professional and legal expectations.

The areas below are especially important for daily operations. They highlight where physiotherapy practices may wish to review internal documents, staff procedures, and patient facing processes to reduce risk and support consistent professional standards.

Consent Management

• Develop terms and conditions that meet the legal requirements for informed consent, protecting the rights of both the clinic and patients.
• Clearly explain the scope of treatment, risks, and terms of image use to patients in advance; maintain written records to ensure transparent communication and prevent misunderstandings.

Medical Records

• Maintain clear, accurate, and timely records, avoiding vague descriptions; never alter medical records retrospectively (supplementary or clarifying information should be added as addenda).
• In the event of a complaint, these records serve as the most robust form of protection.

Internal Response Procedures

• Establish a complaint handling mechanism to address inquiries from the Consumer Council or professional investigations.
• A systematic and documented approach helps maintain professional trust.

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Professional Progress: Beyond Compliance, Moving Forward

The core philosophy behind the new code and legislative amendments is to make the physiotherapy profession more professional and autonomous, while further building public trust. This also presents an opportunity for the entire profession to demonstrate higher ethical and clinical standards. Our professional legal team can assist clinics and therapists in reviewing consent form clauses, digital/AI promotion strategies, and CPD systems, and provide training for staff on legal liability and risk awareness, helping teams proactively prevent potential legal risks, strengthen a culture of compliance, and ensure that professional image and operational practice are equally robust.

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Disclaimer: Nothing herein shall be interpreted as legal advice to any person. Readers are encouraged to consult their legal representatives for independent advice. The information provided is based on overall observations and the experience of the practitioners of the firm at the time of writing. The content may change without prior notification depending on changes in the law. If there are two versions of the article in different languages, the English version will prevail in case of discrepancies.

About Us:

Rendy Ng Law Firm is a law firm based in Hong Kong, providing a full range of commercial legal services for all sectors, with particular focus on supporting professionals and businesses in the medical and veterinary, consumer goods and retail and entertainment industries to achieve sustainable success. By combining legal guidance with understanding of business practicalities, we ensure that our clients receive support tailored to their business goals and individual needs. Please feel free to reach out to our team should you have any questions about our services.

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