New VSBHK Expectations for Veterinary Clinics: Governance, Complaints, Advertising and Clinical Independence

Author: Rendy Ng

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The Veterinary Surgeons Board of Hong Kong has issued new guidance on the management of veterinary clinics. While the Board recognises that it does not have statutory power to regulate clinic owning entities directly, the guidance clearly seeks to shape how clinics are governed and operated in practice.

The key message is that each clinic is expected to appoint a senior registered veterinary surgeon with overall responsibility for the provision of veterinary services. That role must be substantive, not merely nominal, and should be supported by appropriate authority, reporting lines and oversight arrangements.

For clinic owners, managers and registered veterinary surgeons, the guidance is a timely reminder that business structures do not reduce professional obligations. It also signals greater focus on clinical governance, operational controls and the protection of clinical independence.

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Why the guidance matters

Veterinary services in Hong Kong may be provided through sole practices, partnerships, companies or charities, including entities that are not owned or controlled by registered veterinary surgeons. However, the registered veterinary surgeons working within those structures remain personally bound by professional standards and the Code of Practice for the Guidance of Registered Veterinary Surgeons.

The guidance is aimed at that practical tension. Although the Board cannot directly regulate the clinic owner as such, it expects each clinic to appoint a senior registered veterinary surgeon to take overall responsibility for veterinary services. This places clinical governance at the centre of clinic management and makes clear that commercial ownership cannot dilute professional accountability.

Core expectation: a senior registered veterinary surgeon with real oversight

The clinic owning entity is expected to appoint a senior registered veterinary surgeon, such as a head of clinical services or equivalent, with overall responsibility for veterinary services at the clinic.

This appointment should be supported by real authority. In particular, the individual should be able to oversee and intervene in key areas such as complaints, supervision, records, medicines control, advertising, telemedicine and professional standards. An appointment in name only may not satisfy the Board’s expectations.

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Key areas clinics should review now

The guidance identifies eleven areas of responsibility. In practical terms, clinics should review whether they have appropriate systems, policies and accountability in place in the following areas:

• Complaints handling: written procedures for receiving, investigating, escalating and responding to client complaints.
• Supervision of inexperienced veterinary surgeons: clear support, mentoring and escalation arrangements for junior or less experienced clinicians.
• Supervision of lay staff and non registered personnel: appropriate controls over delegation and day to day oversight of students, nurses, assistants and other support staff.
• Client information and transparency: compliance with requirements on fee information, display of veterinary surgeons’ names and provision of medical records.
• Responses to the Board: proper document retention, retrieval and review processes to enable timely and orderly responses to regulatory requests.
• Professional premises: suitable conditions for treatment, hygiene, privacy, safety and equipment maintenance.
• Advertising: compliance with rules on inducements and restrictions on claims to specialist status.
• Medicines management: lawful dispensing, storage, record keeping and stock control.
• Telemedicine and teleconsulting: clear protocols for remote advice, record keeping and when in person consultation is required.
• Continuing professional development: monitoring and support for compliance with mandatory continuing professional development requirements.
• Clinical independence: safeguards to ensure that commercial pressures do not override clinical judgment.

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Main legal and operational implications

Although the guidance is not legislation, it should not be treated lightly. In practice, guidance often informs the standards against which professional conduct and clinic governance are assessed, particularly when complaints arise.

For many clinics, the main implications are likely to include:

• formalising a clinical governance structure
• defining the authority and reporting lines of the senior registered veterinary surgeon
• updating or introducing key policies and procedures
• reviewing advertising and client communication practices
• strengthening medicines management and record keeping
• revisiting supervision arrangements for clinicians and support staff
• implementing clearer telemedicine protocols
• assessing whether commercial controls may interfere with clinical autonomy

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A practical implementation approach

A full scale overhaul may not be necessary at once. A staged review is often the most efficient approach.

1. Governance and gap assessment

Identify the senior registered veterinary surgeon and assess whether that person has sufficient authority, support and access to information. Carry out a gap analysis against the areas covered by the guidance.

2. Policy review

Update or introduce the core policies needed to support compliance, including complaints handling, supervision, client communication, advertising, medicines management, telemedicine, document retention and clinical independence.

3. Contracts and reporting lines

Ensure that employment terms, job descriptions, incentive structures and internal reporting lines are aligned with the governance framework and do not undermine clinical autonomy.

4. Training and implementation

Train relevant staff and embed the revised procedures into day to day operations.

5. Monitoring and audit

Put in place periodic checks to confirm that the clinic’s procedures are being followed in practice and remain fit for purpose.

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Key risk points for stakeholders

• Clinic owners and investors should not assume that regulatory risk sits only with individual veterinary surgeons. Weak management systems may contribute directly to complaints and disputes.
• Senior registered veterinary surgeons should ensure that any responsibility assigned to them is matched by genuine authority, resources and management support.
• Practice managers and operations teams should recognise that these issues are not purely administrative. They affect professional compliance, evidence management and clinical quality.
• Multi branch clinic groups should pay particular attention to consistency of implementation across locations.

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How our firm can assist

This guidance presents an opportunity for veterinary clinics and groups to review their governance and compliance arrangements before issues arise. Legal support may be helpful not only in disciplinary or complaint situations, but also in preventive planning and implementation. We can assist with:

• advising on the VSBHK guidance and the Code of Practice
• reviewing governance structures and reporting arrangements
• drafting or updating clinic policies and standard operating procedures
• reviewing employment, contractor and management agreements
• assessing advertising and client communication materials
• advising on complaints handling and regulatory responses
• reviewing telemedicine and data management arrangements
• supporting internal investigations and regulatory defence
• conducting compliance reviews for veterinary practices

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Conclusion

The new VSBHK guidance makes clear that proper clinical governance is now an expected part of veterinary clinic management in Hong Kong. Clinics should not treat the appointment of a senior registered veterinary surgeon as a formality. The role must be supported by real oversight, appropriate systems and protection for clinical independence.

For many clinics, the sensible next step will be a focused legal and operational review to identify priority gaps and implement practical improvements.

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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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