Your Code Has Changed: What Every Occupational Therapist and OT Practice Owner in Hong Kong Needs to Know

Author: Rendy Ng

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If you are a registered occupational therapist (OT) or you operate an occupational therapy practice in Hong Kong, your professional rulebook has just been updated. The Occupational Therapists Board has issued a revised Code of Practice effective December 2025, replacing the previous July 2023 version. The changes carry real legal weight, some expand your obligations in ways that could affect how you run your practice, how you communicate with clients, and how you respond if a complaint is ever made against you.

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1.  The Law Itself Has a New Name

The statute that governs your registration and discipline, previously known as the Supplementary Medical Professions Ordinance (Cap. 359), has been officially renamed the Allied Health Professions Ordinance, effective July 2025 pursuant to the Supplementary Medical Professions (Amendment) Ordinance 2025. The December 2025 Code of Practice updates all references to reflect this new name.

Any document in your clinic that still cites the old Ordinance name, consent forms, employment contracts, practice policies, signage, is technically referring to an outdated title and worth updating. More importantly, the rename signals the Government’s broader push to establish allied health as a distinct, more tightly regulated profession.  

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2.  Who Is a 'Client'? The Definition Has Been Expanded

The Code's definition of 'clients' has been broadened. In the July 2023 version, the definition focused on people who were already receiving OT services. It has now expanded to cover people referred to, or consulting, and OT, not just those already receiving treatment.  

Your duties around communication, confidentiality, and conduct apply from the moment someone is in your professional orbit, not just after they become a paying patient.

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3.  Confidentiality: A Broader Circle of Professionals

The previous version permitted OTs to discuss patients’ affairs only with ‘other members of the medical team responsible for treatment’. Now, you may share patient information, with a need-to-know basis, with healthcare, education, and social welfare professions involved in the patient’s treatment or training, not just the ‘medical team.’ The 2025 Code formally recognises that sharing patient information with these professionals, when necessary for the patient's treatment or training, is permissible and appropriate. The ‘need-to-know’ qualifier remains; however, disclosure must always be proportionate and purposeful.

‘Therapeutic needs’ has also been added alongside ‘medical diagnosis’ as a basis for co-operating with other professionals. This reflects the reality that OT interventions are often driven by functional and therapeutic goals, not just a medical diagnosis.

4.  Electronic Media and Websites Are Now Formally Part of the Advertising Rules

In the 2025 Code, the dissemination of service information in publications, now expressly includes ‘electronic media’ alongside newspapers, magazines, journals and periodicals. The July 2023 version did not mention electronic media in this section. This means the same rules that apply to a print advertisement now apply to what you post online.  

Also, signboards may also now display your ‘electronic communication’ details in addition to telephone and fax numbers, which was not explicitly permitted before.  

5.  Treating Without Referral: The Legal Basis Is Now Explicit

Occupational therapists have always been permitted to treat patients without a referral in certain circumstances. What’s new is that the Code now expressly anchors this to a specific statutory provision (Cap. 359B, regulation 6), giving OTs a clear legal reference point when they exercise this discretion.  

Separately, referrals from a registered Chinese Medicine Practitioner are now formally accepted as basis for treatment. This was not present in the July 2023 version, which recognized only referrals from a registered medical practitioner or from a person registered in respect of an exempted medical clinic.  

6.  Disciplinary Procedures Overhauled Under the Supplementary Medical Professions (Amendment) Ordinance 2025

The most extensive changes in the December 2025 Code relate to the disciplinary process. The Supplementary Medical Professions (Amendment) Ordinance 2025 has significantly updated the procedural framework governing complaints, Preliminary Investigation Committee (“PIC”) proceedings, and Board inquiries. The key procedural changes include the following.

Breaching a condition attached to a condition or limited registration is now an explicit disciplinary ground. Respondents also have stronger rights: the Board must now notify the you of a complaint, its substance, the date of the Preliminary Investigation Committee meeting, and invite your explanation before the matter proceeds.  

7.  What Has Not Changed

The core ethical obligations, respecting patient rights and dignity, maintaining competence through CPD, avoiding conflicts of interest, not accepting improper financial arrangements such as fee-splitting or rebates, and maintaining professional integrity, remain unchanged, aside from the ‘therapeutic needs’ addition in principle 8 noted above. The fundamental structure of the Code, its advertising rules, and its approach to professional relationships remain the same.

Conclusion: Small Words, Real Consequences

The December 2025 revision of the OT Code of Practice is not a wholesale rewrite, but it is not trivial either.  

The best time to understand these changes is before any issue arises. We recommend that all OT practitioners and practice owners read the December 2025 Code in full, review their practice documents and digital presence for compliance, and seek legal advice if they have any doubt about how the updated rules apply to their specific circumstances.

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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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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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