Important Updates to the Code of Practice for Veterinarians in Hong Kong (Effective 29 September 2025)

Executive Summary

The Veterinary Surgeons Board of Hong Kong (“VSBHK”) has announced significant amendments to the Code of Practice (the "Code") for Hong Kong registered veterinary surgeons (“veterinarians”). These updates aim to address modern challenges, improve transparency, and enhance professional standards that will take effect from 29 September 2025. Key areas of change include:

• Telemedicine: Permitted only under strict conditions, including the existence of a veterinary-client-patient relationship (“VCPR”) and a physical examination of the animal within the last six months that reasonably suffices for the virtual consultation to take place without a further physical examination. Exceptional circumstances, such as emergencies or movement restrictions, waive this requirement if the animal’s life is at risk.
• Conventional Medicine: Prescriptions for controlled drugs require prior physical examination and treatment. Complementary treatments, such as Traditional Chinese Medicine, are allowed if they are safe, effective, and supported by proper consent and training, and are considered to render equal or better results.
• Consent & Medical Records: Consent is required for telemedicine. Medical records must clearly identify the treating veterinarian for every consultation.
• Administrative Matters: Updates include mandatory display of both permanent and locum veterinarians’ names in clinics and keeping practising addresses current with the VSBHK.

Veterinarians are ultimately responsible for ensuring complete compliance of the Code. The article below sums up our interpretation of some of these significant updates.

Key Updates to the Code

The VSBHK's amendments to the Code of Practice for Veterinarians aim to enhance professional standards, adapt to modern veterinary practices, and improve transparency in veterinary care. Below, we summarise the key changes and their implications, organised into four major sections:

1. Telemedicine

Telemedicine is only permitted under specific conditions:

• A veterinary-client-patient relationship (“VCPR”) must already exist, and a physical examination of the animal must have been conducted within the last six months;
• It is reasonably believed that, based on the aforementioned physical examination, a further physical examination is not necessary for the virtual consultation to take place in the best interest of the animal;
• The pet owner must give consent to receive telemedicine services; and
• In exceptional circumstances, such as extreme weather conditions or restrictions on movement (e.g., during a pandemic like COVID-19), the pre-condition of a prior physical examination and VCPR is waived if the animal's life is at risk.

Teleconsulting is different from telemedicine. Teleconsulting typically involves a veterinarian providing advice to another veterinarian, rather than directly diagnosing or treating a patient.

The attending veterinary surgeon remains ultimately responsible for the care and treatment of the animal, regardless of who the consulting veterinarian may be.

What This Means:

The current drafting of the rule allows veterinarians discretion to determine which conditions could be reasonably believed to justify virtual consultation for the animal without requiring an additional physical examination. Veterinarians should exercise their professional judgment and ensure that their analysis and decisions are documented with reasonable and well-founded rationale.

Our Recommendations:

• Develop and implement telemedicine protocols that comply with the new VCPR, physical examination, and consent requirements.
• Provide training to all staff on the new protocols, differences of telemedicine and teleconsulting in your practice to avoid regulatory misunderstandings.
• Document all circumstances where telemedicine is provided without a prior physical examination and VPCR, ensuring that the decisions are justifiable and in the animal's best interest.
• Regularly review updates and guidance on telemedicine and consult legal advisors for tailored advice on adapting these measures to your clinic's operations.

2. Treatment and Medication

A. Drug Prescription

Veterinarians must have (i) physically examined and (ii) treated an animal before prescribing controlled drugs under the relevant ordinances. It is noted that this particular applies only to the English version of the Code, while the Chinese text remains unchanged. The revised English text clarifies that the animal must have been physically examined by the veterinarian, not merely "seen".

B. Complementary and Alternative Treatments (E.g. Traditional Chinese Medicine (“TCM”))

Veterinarians may prescribe or use complementary or alternative treatments, such as TCM, only if:

• The treatment or substance used is beneficial and safe;
• The treatment or substance would yield equal or better results than conventional treatments or medication;
• Consent is obtained after discussing benefits, risks, and alternatives; and
• The veterinarian has undergone appropriate training to competently use or prescribe the treatment and medication.

Our Recommendations:

• Update client consent forms to reflect the regulatory requirements for complementary medicine.
• Display a clear policy on the use of complementary medicine in a prominent area within the clinic.
• Document the justification for using complementary treatments in medical records.

3. Consent & Medical Records

A. Medical Records

Medical records must clearly identify the treating veterinarian by name for every consultation or instance of providing care, regardless of whether the records are handwritten, printed, or electronic.

What This Means:

This requirement enhances accountability and transparency by ensuring the attending veterinarian's identity is always documented.

Our Firm's Recommendations:

• Ensure all medical records include the name of the attending veterinarian, regardless of format (handwritten, printed, or electronic).
• Veterinarian-in-charge or clinic managers should conduct regular audits of medical records to confirm proper documentation.
• For handwritten records, veterinarians must ensure their names are written legibly.

B. Extended Requirement for Consent

Consent is now explicitly required for telemedicine services and the use of complementary or alternative treatments.

Our Recommendations:

• Develop comprehensive consent forms tailored for telemedicine and alternative treatments, ensuring they align with regulatory requirements.
• Train staff to communicate consent requirements clearly to pet owners.

4. Administrative Matters

A. Keeping Address Updated

The register must now include the current regular or most regular practising address of each veterinarian, or a record if the veterinarian has no such address.

What This Means:

This ensures that all veterinarians remain contactable, even if they leave their clinic. It also prevents veterinarians from evading accountability by resigning without providing an address.

Our Recommendations:

Keep your address updated with VSBHK even if you are no longer in practice or residing in Hong Kong.

B. Being Known... and Displayed

Veterinarians must display their full names prominently at clinic entrances or waiting areas. Locum veterinarians must ensure their names are displayed during their periods of practice.

Our Recommendations:

• Ensure your name is prominently displayed within your clinic.
• Locum veterinarians should display their names in the waiting area using clear, legible signage.
• Provide locum veterinarians' business cards in the waiting area and encourage receptionists to inform pet owners of the attending veterinarian's name before consultations.

Conclusion

The updates to the Code of Practice for Veterinarians mark an important step towards modernizing veterinary practice in Hong Kong, ensuring higher standards of professionalism, accountability, and client confidence. However, this summary highlights only some of the key changes.

The Code of Practice contains other amendments and details that may affect your practice. The recommendations are non-exhaustive and provided solely as suggestions based on our firm's experience and understanding of the veterinary profession. Readers are strongly encouraged to seek independent legal advice and implement all the changes required under the updated Code based on your practice.

By addressing these updates proactively, you can safeguard your compliance, protect your professional reputation, and focus on delivering exceptional care to your clients and their animals.

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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.

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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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