Revised Code of Practice for Medical Laboratory Technologists: What You Need to Know About the 2025 Update

Author: Rendy Ng

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Executive Summary: The 2025 MLT Code of Practice Update

In December 2025, the Medical Laboratory Technologists Board of Hong Kong (the "Board") issued a revised Code of Practice (the "2025 Code"), replacing the version that had been in effect since April 2012. This comprehensive revision was prompted by the enactment of the Supplementary Medical Professions (Amendment) Ordinance 2025 (Ordinance 33 of 2025), which took effect on 25 July 2025. The update introduces targeted amendments that every registered medical laboratory technologist ("MLT") and every person operating a medical laboratory must understand to ensure ongoing regulatory compliance.

While the 2025 Code does not represent a wholesale rewrite of fundamental professional obligations, it introduces consequential changes to statutory frameworks and cross-disciplinary referral pathways. This article provides an in-depth analysis of the key changes, their legal and policy context, and the practical steps that laboratory operators and technicians should implement immediately.

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1. Statutory Renaming: The Allied Health Professions Ordinance

The most pervasive structural change in the 2025 Code is the update to all statutory references. The Supplementary Medical Professions Ordinance (Cap. 359) has been officially renamed the Allied Health Professions Ordinance (Cap. 359). This renaming reflects a clear policy shift by the Hong Kong government to elevate the professional status of allied health professionals and formally recognise their increasingly specialised roles in the healthcare system, particularly in the context of primary healthcare development.

The Foreword and all appendices of the Code have been updated accordingly. Appendix I now reproduces the statutory provisions as amended by Ordinance 33 of 2025. This includes the updated text of Section 16(1) of the Allied Health Professions Ordinance, which strictly provides that a registered person must not practise a profession in Hong Kong unless the person is the holder of a practising certificate that is in force.

Actionable Insight for Compliance

All internal compliance documents, employment contracts, patient consent forms, and public-facing materials (including signboards and websites) should be systematically reviewed and updated to replace references to the "Supplementary Medical ProfessionsOrdinance" with the "Allied Health Professions Ordinance". Maintaining accurate statutory references in operational documents demonstrates a robust compliance culture to regulators.

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2. The New Referral Pathway: Chinese Medicine Practitioners

The most significant operational change in the 2025 Code is the formal recognition of referrals from Registered Chinese Medicine Practitioners ("RCMPs"). Under the previous 2012 framework, MLTs were strictly prohibited from performing diagnostic tests in the absence of a referral from a registered medical, dental, or veterinary practitioner. Chinese medicine practitioners were historically excluded from this referral network.

The 2025 Code amends Paragraphs 6.3 and 6.4 to permit MLTs to perform tests and accept specimens on referral from an RCMP. However, this is not a blanket authorization. The Code establishes a highly structured pilot framework governed by three strict, cumulative conditions set out in the newly added Note (i) to Section 6. First, the medical laboratory technologist must be authorized by The Chinese Medicine Hospital of Hong Kong ("CMHHK") to provide services to its patient. Second, the registered Chinese medicine practitioner must also be authorized by CMHHK to provide services to its patient. Third, the medical laboratory technologist must be providing services that are specifically authorized by CMHHK to that patient.

The policy rationale for this amendment is rooted in legislative reform aimed at integrating Chinese medicine into Hong Kong's mainstream healthcare system. It acknowledges the practical clinical need for RCMPs to utilize modern diagnostic technologies. The CMHHK, which commenced operations in late 2025, serves as the designated, controlled pilot site for this cross-disciplinary referral arrangement.

Actionable Insight for Compliance

Laboratory operators must understand that these three conditions are cumulative and strictly construed. Currently, this referral pathway applies exclusively within the CMHHK framework. A private medical laboratory cannot accept a direct referral from a Chinese medicine practitioner operating in a private clinic unless the specific CMHHK authorization requirements are met. Operators who accept RCMP referrals outside this defined framework face significant risk of disciplinary action for professional misconduct.

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3. Updated Disciplinary Procedures and Strategic Legal Defence

Appendices I and II of the Code have been substantially updated to reflect the amended disciplinary and inquiry procedures introduced by Ordinance 33 of 2025. These appendices reproduce the relevant statutory provisions of the Allied Health Professions Ordinance and the Medical Laboratory Technologists (Registration and Disciplinary Procedure) Regulations. Notable procedural updates include the revised composition of the Preliminary Investigation Committee (PIC) and amendments to the Board's powers when making orders or declining applications for registration.

Why Early Legal Advice is Critical

MLTs and laboratory operators who face a complaint or disciplinary inquiry must be aware that the procedural framework has been updated. We strongly recommend seeking specialized legal advice at the earliest opportunity upon receiving a complaint from the Board. Engaging legal counsel immediately is crucial for several strategic reasons. First, early intervention allows legal professionals to build a strong, cohesive defence strategy in light of the updated regulations and statutory law. Second, it prevents respondents from inadvertently placing wrong emphasis on evidence that is legally unimportant to the specific charges. Third, unrepresented respondents often attempt to explain or justify actions using reasoning that does not align with what the PIC is actually looking for, which can inadvertently damage their case. Professional legal guidance ensures that responses to the PIC are focused, legally sound, and strategically aligned with the regulatory framework, thereby maximizing the chances of a favourable outcome before the matter escalates.

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4. Modernized Language and Patient Data Privacy

The 2025 Code adopts modern, gender-neutral language in several provisions. Most notably, Paragraph 6.5 now refers to information obtained through "his or her professional work" on patient samples, aligning the Code with contemporary legislative drafting practices in Hong Kong.

Despite the language update, the substantive obligation regarding patient confidentiality remains rigorous. MLTs must not, except as required by law, knowingly disclose to any unauthorized person information obtained through their professional work. The Code expressly mandates that requests for disclosure of specimen test results must be handled with strict adherence to the Personal Data (Privacy) Ordinance (Cap. 486).

Actionable Insight for Compliance

Given the rapid digitization of laboratory information systems, the integration of electronic health records, and the reliance on cloud-based platforms for report delivery, laboratory operators must conduct comprehensive audits of their data governance frameworks. Ensuring robust cybersecurity measures are in place is no longer optional; it is a critical component of professional compliance.

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5. Continuity of Core Obligations: Advertising, Rebates, and Supervision

While the 2025 revision introduces important updates, the substantive core of the Code remains intact. Several obligations, which historically form the basis of most disciplinary proceedings, continue to be fully enforced.

Regarding laboratory management (Section 3), professionally qualified directors and Part I MLTs must continue to take overall responsibility for laboratory operations. This includes ensuring adequate supervision of junior staff and the rigorous implementation of quality control practices.

Advertising restrictions (Paragraph 6.6) remain rigid. Technologists may only advertise specific, permitted details, such as name, contact information, approved qualifications, services, charges, and turnaround times. Any advertising that is untrue, dishonest, or damaging to the profession's reputation is strictly forbidden.

Finally, the prohibition on fee-sharing and rebates (Paragraph 6.8) remains a high-risk compliance area. Giving or accepting rebates is strictly prohibited. Discounts are only permissible if they are genuinely intended for the patient and are clearly documented on the bill. Laboratory owners must carefully structure all business development, marketing, and partnership agreements to ensure they do not violate these anti-rebate regulations.

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Conclusion and Next Steps

The 2025 Code of Practice represents a critical legal alignment and modernization of the regulatory framework for medical laboratory technologists in Hong Kong. The carefully circumscribed recognition of Chinese medicine referrals within the CMHHK pilot framework marks a significant operational development, while the renaming of the governing Ordinance underscores the elevated status of allied health professionals.

To ensure full compliance, laboratory operators should immediately update all internal documentation to reflect the Allied Health Professions Ordinance. It is also imperative to establish written intake protocols specifying the exact conditions under which Chinese medicine referrals may be accepted. Furthermore, operators should conduct a comprehensive compliance audit of all marketing materials, billing structures, and data privacy protocols to align with both the updated and unchanged provisions of the Code.

If you have any questions about the 2025 Code of Practice or require strategic legal assistance with a compliance review or disciplinary inquiry, please do not hesitate to contact our Healthcare Regulatory Practice team.

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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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