Physiotherapist, chiropractor or doctor: who does what? Referral-free routes, the lines three ordinances draw, and what you can check before booking, 2026

TL;DR The biggest misconception is that "not a doctor" means "may not lawfully diagnose". Three professions in Hong Kong are regulated by three different ordinances: doctors by the Medical Registration Ordinance (Cap. 161), physiotherapists by the Allied Health Professions Ordinance (Cap. 359), and chiropractors by the Chiropractors Registration Ordinance (Cap. 428). Section 28(2) of Cap. 161 prohibits unregistered practice, but subsection (3) of the same section opens exemptions and subsection (5) states that "treatment" includes "the diagnosis required for the giving of treatment" — the line is not "who may diagnose" but "who is registered under which ordinance, doing which kind of treatment". But two things must be separated at once. Section 28 answers a question of criminal liability: which acts do not constitute unregistered practice. It does not, and cannot, answer the second question — whether your situation clinically already has an adequate medical diagnosis. "Not caught by section 28(2)" is not "equivalent to a medical diagnosis"; "listed on a register" is not "has diagnosed you". All three headcounts can be looked up, free and public. Registered chiropractors, 361; the physiotherapists register, Part Ia 3,955 and Part Ib 1,594, 5,549 in all; and the Medical Council's General Register and Specialist Register are both online and gazetted. An older formulation needs correcting: it is not "there is no public list". The Primary Healthcare Commission's Primary Care Directory carries a "first-contact physiotherapy service" filter; searching all eighteen districts on 3 August 2026 returned 1,293 physiotherapist records, and 58 with that filter added. The most commonly misstated division of labour: what the law says and what the guideline says are not the same things. Section 6(2) of the Physiotherapists (Registration and Disciplinary Procedure) Regulation (Cap. 359J) sets out four referral-free routes and nothing else; the restriction to particular conditions, the limit of 10 sessions or 30 days, and the duty to refer after a course of treatment are none of them in section 6 — they are all in an English clinical guideline of the Primary Healthcare Commission; and "which physiotherapist may do it" is likewise not in section 6 but in the Physiotherapists Board's training requirement. And the two-condition restriction binds only the route at section 6(2)(b) — if a doctor or registered Chinese medicine practitioner wrote down a diagnosis for you within the past 12 months, you are on section 6(2)(a) and are not confined to those two conditions. The 10 sessions or 30 days limit is not a ceiling you can renew for yourself, nor a promise that treatment may continue until you reach it. Paragraph 3.1.18 of the guideline requires regular review throughout treatment, and the moment the condition deteriorates or a red flag or atypical feature emerges the physiotherapist must stop treatment and refer to a doctor — without waiting for 10 sessions or 30 days. This article is about the division of roles and what you can check before booking. How each route actually works in a low back pain case is covered in full in the article on low back pain. This article also prints no red flag list (the reason is below). Decisions about diagnosis, imaging, drugs and surgery are for a doctor.

#Three titles, three ordinances: who is who

These are not three grades within one trade but three independent registration systems, each with its own ordinance, its own board, its own register and its own statutory title.

Most people are really asking one question: "my back hurts, who should I see?" To answer it you first have to know what each of them is in law.

The physiotherapist. Item 3 of Schedule 1 to the Allied Health Professions Ordinance (Cap. 359) defines one as a person trained in the assessment and treatment of physical disability by therapeutic exercise, manual therapy and the application of mechanical, thermal or electrical energy [Note 1]. That is, the statutory scope is the assessment and treatment of physical disability — not disease itself — and it names four means. The definition never uses the words "diagnosis of disease". Item 4 of the same Schedule, the occupational therapist, is likewise oriented to disability rather than to pathological diagnosis [Note 1].

The chiropractor. The long title of the Chiropractors Registration Ordinance (Cap. 428) states that a chiropractor is a person trained and qualified in the profession of chiropractic, which includes the prevention, diagnosis and treatment of disorders of human function by adjustment of joints, particularly the spine and surrounding joints and also the pelvis [Note 2]. In one sentence: the ordinance's opening words already say that chiropractors are in the business of prevention, diagnosis and treatment; the word "diagnosis" is written into the long title.

Set beside item 3 of Schedule 1 to Cap. 359, the two definitions are pitched quite differently — one speaks of assessing and treating physical disability, the other of preventing, diagnosing and treating. That is not this article's gloss but the words the two ordinances chose.

And the word "chiropractor" has a narrow legal definition in the ordinance: section 2 of Cap. 428 provides that a registered chiropractor means a person whose name is for the time being on the register [Note 3].

The doctor (registered medical practitioner). The Medical Council's registration requirements page states that anyone intending to practise medicine, surgery or midwifery in Hong Kong must apply to the Council under the Medical Registration Ordinance to become a registered medical practitioner [Note 4]. The same page lists five categories of registration under the General Register (full, provisional, limited, temporary and special registration, being Parts I to V), and states that a registered medical practitioner may further apply to have their name entered under a specialty in the Specialist Register.

⚠ For anyone who treats "physiotherapist", "chiropractor" and "orthopaedic surgeon" as three interchangeable options: the three start from different statutory places — one speaks of assessing and treating physical disability, one of preventing, diagnosing and treating disorders by adjusting joints, and one of practising medicine or surgery. Choosing between them is choosing which kind of handling you want.

#Why three different ordinances? Three years tell the whole story

The three were not planned in one legislative exercise but added one at a time, thirteen years apart and then thirty-two years apart, which is why the joints between them still have to be read through exempting provisions.

1980. The Allied Health Professions Ordinance (Cap. 359) came into operation on the first of October 1980 (Legal Notice No. 274 of 1980). Its scope is defined by Schedule 1, of which the physiotherapist is one item.

1993. The Chiropractors Registration Ordinance (Cap. 428) came into operation on the first of August 1993 (Legal Notice No. 297 of 1993). The "Chiropractic — a brief history" section of the Chiropractors Council's Code of Practice for Registered Chiropractors records that chiropractic in Hong Kong can be traced to before the Second World War, that the Hong Kong Chiropractors' Association was founded in 1967, and that at a meeting in 1981 it resolved on the Chinese names 「脊骨神經科」 and 「脊骨神經科醫生」 for "chiropractic" and "chiropractors" respectively; and that with the passage of the Chiropractors Registration Ordinance statutory registration of chiropractors began in Hong Kong in 1993, the first in Asia [Note 5].

⚠ The language status of that Code has to be stated. Its Chinese version prints a line on its own cover: 「(這是中文譯本，如文意與英文原文有差異，以英文本為準)」 — this is a Chinese translation, and where the meaning differs from the English original the English governs (our rendering). That is, the Council itself declares the Chinese to be a translation and the English to govern. This article quotes the Chinese version's own wording where the 繁 does, having checked it against the English; on one point of substance the two versions diverge, and that is set out below.

2025. The Allied Health Professions (Amendment) Ordinance 2025 (Ordinance No. 33 of 2025) came into operation on 25 July 2025. Section 1(1) of Cap. 359 now provides, in the authentic Chinese text, that the ordinance may be cited as 《專職醫療業條例》 [Note 6].

So: the ordinance's present name is the Allied Health Professions Ordinance and the board's present name is the Allied Health Professions Council. The older Chinese name 「輔助醫療業」 still appears in two places: in the name of the amending ordinance itself, which does not change when the principal ordinance is renamed; and in government documents that continued to use the old name after the renaming took effect, such as the press release of 11 December 2025.

The same amendment added a new provision, and it is the join this whole article turns on. Section 21A of Cap. 359 provides that a registered person must not practise a profession in Hong Kong unless the person complies with the supervision or referral requirements imposed by the Regulation, as the case requires [Note 7].

In one sentence: section 21A makes "the referral requirements in the regulation" a condition of lawful practice, not merely a professional code. For physiotherapists that regulation is the Physiotherapists (Registration and Disciplinary Procedure) Regulation (Cap. 359J).

⚠ For anyone who sees an older article writing 「輔助醫療業管理局」 and wonders whether they have the wrong thing: no, the name changed on 25 July 2025.

#The line is at section 28 of the Medical Registration Ordinance — and the key is subsection (5)

What actually draws the "who may do what" line is not the three definitions but section 28 of the Medical Registration Ordinance: first a fence, then several gates, and then in subsection (5) a statement of how wide the gates are.

This is the deepest layer of the article, and nothing on any government page sets it out in one place.

Step one, the fence. Section 28(2) creates two offences: practising medicine or surgery while not registered, provisionally registered or exempted from registration, punishable on conviction on indictment by 5 years' imprisonment; and making any medical diagnosis, prescribing any medical treatment or carrying out any medical treatment (including surgery) while not registered, thereby causing bodily injury, punishable on conviction on indictment by 7 years' imprisonment [Note 8].

Step two, the gates. Section 28(3) opens eight exemptions, (a) to (h), of which two bear directly on these three professions — and the following is not the whole of that subsection: (d) treatment given in the course of practising one of the professions listed in Schedule 1 to Cap. 359, by a person registered or otherwise permitted under that ordinance to practise it; and (f) treatment given by way of chiropody, chiropractic or osteopathy [Note 9].

The two gates are built quite differently, and the difference is substantive. Gate (d) hangs on the person — you must be registered or permitted under Cap. 359, and you must be in the course of practising that profession. Gate (f) hangs on the activity — chiropody, chiropractic, osteopathy, with the provision never mentioning registration at all.

Step three, how wide the gates are. This is the sentence you miss if you stop reading at the numbers. Section 28(5): in subsection (3), "treatment" includes the diagnosis and prescribed medical method required for the giving of treatment [Note 10].

In one sentence: the "treatment" of subsection (3) includes "the diagnosis needed in order to give that treatment". So what section 28(3)(f) exempts is not merely the hands-on adjustment but the diagnosis required in order to do it. That is why the long title of Cap. 428 can say "prevention, diagnosis and treatment" without colliding with Cap. 161 — the two ordinances are interlocked, and reading only one of them gives the opposite answer.

Step four, exemption under subsection (3) is not the absence of regulation. Section 24 of Cap. 428 lists eleven offences, (a) to (k), each punishable by a fine at level 5 and 1 year's imprisonment. The four bearing directly on unregistered practice are (g) using a name or title falsely implying that one is on the register, (h) practising chiropractic while not on the register, (i) practising chiropractic while not the holder of a valid practising certificate, and (k) advertising or holding oneself out as a registered chiropractor while not on the register [Note 11]. That is not the whole of the section.

That is: Cap. 161 lets go, and Cap. 428 catches. Practising chiropractic while unregistered is not an offence under Cap. 161; it is one under Cap. 428. Likewise section 21(1) of Cap. 359 provides that, subject to section 20(2), a person who practises a profession without being registered in respect of it commits an offence [Note 12].

Note the opening words of that sentence: "subject to section 20(2)". The section 20 it points to is Cap. 359's provision about companies rather than individuals: section 20(1) provides that a body corporate must not carry on the business of practising a profession, and section 20(2) then opens a condition — the company must have at least one director registered, fully or provisionally, in respect of that profession, and every person employed to practise it must be registered. Two further provisions in the same Part (Part IV, "Control of Professions") concern premises: section 18 requires a certificate of registration to be displayed conspicuously at the place of practice, non-compliance being an offence; and section 19 provides that a person must not practise at premises the relevant board considers unsuitable. Section 18 is the one closest to hand — you can check it standing in the clinic.

⚠ But Cap. 359 has a further gate beyond registration, and it governs how much "I found the name on the register" is worth. Section 16(1) provides that a registered person must not practise a profession in Hong Kong unless the person holds a valid practising certificate for that profession [Note 13].

That is: registration and a practising certificate are two things, and both are needed. Sections 13A(7)(b) and 13B(8)(b), added by the same amendment, likewise provide that a person with limited or temporary registration may practise "subject to section 16(1) and the Regulation" — the ordinance itself treats section 16(1) as an independent gate. The structure is identical on the chiropractic side: section 24(h) of Cap. 428 penalises practising while not on the register and section 24(i) separately penalises practising without a valid practising certificate, two provisions because they are two things. And what section 18(1) requires to be displayed at the premises is the certificate of registration, not the practising certificate, so the paper on the wall and "does he still hold a valid practising certificate" are two different questions.

A fifth line-drawing provision sits outside section 28: section 32 of Cap. 161, "Treatment of diseases of the eye". It provides that, apart from a registered or provisionally registered medical practitioner, no person may hold themselves out as qualified, competent or willing to give treatment for diseases of the human eye, to prescribe any medical remedy, or to give advice in connection with the treatment of eye diseases [Note 14]. Subsection (1A) opens only two gaps: a person who is not a registered medical practitioner may hold themselves out as qualified to test refraction, visual acuity and colour vision, or to make and supply spectacles and other optical appliances; and a Chinese medicine practitioner registered or listed under the Chinese Medicine Ordinance (Cap. 549). Contravening subsection (1) is punishable on summary conviction by a fine at level 6 and 3 years' imprisonment. This differs from section 28: the eight exemptions in section 28(3) disapply only section 28(2) and do not disapply section 32 — and the gaps in section 32(1A) contain no chiropractic, no osteopathy, and none of the professions under Cap. 359.

⚠ For anyone looking at a clinic signboard reading "spinal", "chiro" or "manual therapy" and unsure whether the person behind it is regulated: the line is not what the sign says but whether the name is on the corresponding register, together with whether they hold a valid practising certificate.

#How the three divide the work: what the ordinances themselves say

The three ordinances come at the same thing — your back pain — from different angles, so choosing one of them is choosing which set of rules will handle you.

One contrast: the two protected titles are protected to different widths. Section 28(1)(b) of Cap. 161 strikes at any name, title, addition or description implying that one is registered or on the Specialist Register — and the widest word in the provision is implying, meaning that a hint suffices and nothing need be said outright. Section 23(1) and section 24 of Cap. 428 are each drafted around the four characters of 「註冊脊醫」, the registered chiropractor, and around the register itself. This is not a question of which is stricter but of two different drafting techniques: one strikes at making people believe you are a doctor, the other at making people believe you are on the register.

The Chiropractors Council has dealt with the title question too. Paragraph 4 of Appendix A to the Code of Practice for Registered Chiropractors lists what a signboard may carry, including the statutory titles "registered chiropractor" or "chiropractor" and other titles approved by the Council — and 「脊骨神經科醫生」 carries a condition: it may be used only where it will not mislead anyone into thinking the chiropractor is a medical practitioner [Note 15].

#One Chinese-English divergence, and it lands squarely on this article's subject

In the last paragraph of Part II of the Code of Practice for Registered Chiropractors, "The scope of chiropractic", the Chinese version writes 「並會適當考慮為協助恢復和維持神經系統完整及體內平衡的急救、康復和物理治療程序」; the English original of the same paragraph reads "first aid, rehabilitation and physiological therapeutic procedures" [Note 16].

The English original says physiological; the Chinese version renders it as 物理治療, physiotherapy. In Hong Kong 「物理治療」 is the statutory name of a profession, item 3 of Schedule 1 to the Allied Health Professions Ordinance, and the two are not the same thing. The Council's Chinese cover already declares the English text to govern, so this article reads the paragraph on the English text and will not write that "the chiropractors' code says they perform physiotherapy procedures".

⚠ For anyone planning to judge whether two professions overlap from the Chinese version of a professional code: this is the counter-example.

#Do you need a doctor's note? Three professions, three answers — and your policy makes four documents

"Do I need a referral letter" is not one question. Each of the three professions has its own statutory answer, and your insurance policy is a fourth document — four different answers, settled by four different documents.

First, physiotherapy: referral by default, with four exception routes written into the regulation. Section 21A of Cap. 359 makes the referral requirements prescribed by the regulation a condition of lawful practice. That regulation is Cap. 359J. Section 6(1) provides that a physiotherapist must not provide services to a person unless the person is referred by a registered medical practitioner or a registered Chinese medicine practitioner (each a qualified referrer); section 6(2) sets out four exception routes, and the full authentic Chinese and English texts are at [Note 17].

The four routes are: (a) a certificate issued by a qualified referrer within the past 12 months stating a diagnosis, with the physiotherapist providing services only for that diagnosed condition; (b) the person's condition is of a type that any clinical guideline recognises as one for which services may be provided without referral; (c) the person is enrolled in a cross-disciplinary collaboration arrangement of the Primary Healthcare Commission; (d) the case falls within a specified situation that the code of practice treats as an emergency or as involving the provision of social services.

#Above the four routes sits a precondition about who may do it

The regulation says when a patient does not need a referral; it does not say which physiotherapist may take such cases. That is settled by the Physiotherapists Board, and it is a precondition, not a suggestion. The English original of the Board's "First-contact Physiotherapist" page states that before providing physiotherapy services under section 6(2)(a), 6(2)(b) and/or 6(2)(c), a physiotherapist must have completed a relevant course recognised by the Board [Note 18].

That precondition covers three of the routes, not just the clinical-guideline one. So even if you hold a diagnostic certificate less than 12 months old and are travelling by section 6(2)(a), the physiotherapist across the table still has to be someone who has completed the recognised training.

#What is not in section 6 is the part most often got wrong

Across the whole of Cap. 359J (authentic Chinese and English texts, consolidated version dated the first of January 2026): 「腰背」 appears 0 times, 「膝」 0 times, 「骨關節炎」 0 times, 「30日」 0 times. In the same document 「轉介」 appears 6 times and 「註冊」 75 times, and refer appears 30 times in the English text — that is, findable words are findable, and the ones above are genuinely absent. The provision says only "recognised by any clinical guideline"; which conditions, how many sessions, and what happens after a course of treatment are none of them fixed by the regulation but all by the clinical guideline; and "which physiotherapist may do it" is fixed by the Physiotherapists Board's training requirement.

The three subsections that follow are the couplings that fasten the guideline back into the regulation. Section 6(3) provides that a physiotherapist who provides services to a person in the situation described in subsection (2)(b) must comply with the requirements specified in the clinical guideline; section 6(4) provides that one who provides services in the situation described in subsection (2)(c) must comply with the requirements specified in the guidance published by the Primary Healthcare Commission for the cross-disciplinary collaboration arrangement concerned; and section 6(5) provides that a physiotherapist whose name is in Part II must practise under the supervision of a physiotherapist whose name is in Part Ia [Note 19].

Note that subsections (3) and (4) are two different routes and two different documents, but both say "must comply". So do not suppose that the Primary Healthcare Commission's cross-disciplinary collaboration arrangement is a route with no strings attached — the regulation says in terms that it has its own guidance to follow.

Section 6(6) then defines what a clinical guideline is: one published by a reference authority (the Department of Health, the Hospital Authority, the Primary Healthcare Commission or the Chinese Medicine Hospital of Hong Kong) on its website, intranet or similar electronic network, and stating that it is published for the purposes of subsection (2)(b). That is: the content of the guideline is the guideline's business, but the obligation to follow the guideline is imposed by the regulation. The distinction is not pedantry — the regulation takes the Legislative Council to change, the guideline can be updated by the reference authority itself, and section 6(3) makes the updated version bite automatically.

The one in force is the Primary Healthcare Commission's Clinical Guideline for First-contact Physiotherapists on Assessment and Cross-disciplinary Management Approach for Common Musculoskeletal Problems in Primary Care Setting (the document itself prints "First published: Dec 2025"; 55 pages in all). ⚠ There is no Chinese version of this guideline — not one Chinese character across the 55 pages — so this article quotes its English original, with any Chinese rendering placed outside the quotation marks and identified as this article's own.

#The two-condition restriction binds only the route at section 6(2)(b)

This is the most important sentence in the section, and the easiest to read past. Paragraphs 3.2.9 to 3.2.11 of the guideline sit under the heading "II. Clinical care pathway for patients with a condition stipulated by clinical guidelines" — that is, the section 6(2)(b) route.

Paragraph 3.2.10 means this: in the particular case of the direct-access arrangement, if the patient presents with a condition that is not consistent with knee osteoarthritis, low back pain, or such other conditions as are stipulated in clinical guidelines promulgated by a reference authority, the first-contact physiotherapist must refrain from providing direct-access physiotherapy services, even where the condition could be managed effectively and safely by physiotherapy. Paragraph 3.2.11 then deals with your having more than one problem at once: the first-contact physiotherapist may treat only the stipulated condition and must refrain from providing direct-access services for the others. The English originals of both paragraphs are at [Note 20].

That is: coming in by section 6(2)(b) is not "once I am in, he takes me on as a whole person". If your back and your shoulder both hurt and you have no diagnosis, on this route he can only work on the back.

What does that mean for you? If within the past 12 months a registered medical practitioner or registered Chinese medicine practitioner has written down a diagnosis for you, you are travelling by section 6(2)(a) — and that route carries no two-condition restriction; what it says is "services only for the diagnosed condition". Shoulder, neck, wrist: as long as it is the diagnosed condition, the route is open (and, equally, the physiotherapist must have completed the recognised training). Only when you have no diagnosis and want to come in on "recognised by a clinical guideline" do you run into today's boundary of knee osteoarthritis and low back pain. The back one of those two conditions is handled in full in the article on low back pain.

#That limit of 10 sessions or 30 days is in the guideline, and it does not bind only one route

But the limit is not a countdown from a full tank — before it reaches 10 sessions or 30 days, the guideline has a paragraph that can call a halt at any point during treatment. Paragraph 3.1.18 provides that the patient's clinical progress should be reviewed regularly throughout the course of physiotherapy to assess the response to treatment and any change in the condition; and that once the patient's condition deteriorates, or red flag symptoms, signs or atypical features emerge, the first-contact physiotherapist must stop treatment and refer the patient to a doctor (preferably the patient's own family doctor) or to an accident and emergency department as soon as the urgency of the condition requires [Note 21].

That is: this stopping condition does not wait for 10 sessions or 30 days — if the condition worsens or a red flag appears, stop and refer at once.

Paragraph 3.1.19 provides that direct-access physiotherapy services are subject to a time limit of at most 10 treatment sessions or 30 days, whichever is the earlier [Note 22]. Paragraph 3.1.20 provides that if the patient's condition has not improved on completion of the course, the first-contact physiotherapist must stop providing further physiotherapy and refer the patient to a doctor for diagnostic assessment and review [Note 23]. Paragraph 3.1.21 deals with the opposite outcome: on completion of the course, if the first-contact physiotherapist considers that the patient could benefit from further physiotherapy for the same condition, the patient must still be sent to a doctor for review, and it is for the doctor to decide whether to refer for further physiotherapy services [Note 24].

The three paragraphs have to be read together before the rule is complete: if during treatment the condition worsens or a red flag appears, stop and refer at once (3.1.18); if the course ends without improvement, hand back to a doctor (3.1.20); if the course ends with improvement and you want to carry on, hand back to a doctor for review and let the doctor decide (3.1.21). Reading 3.1.20 alone yields the opposite conclusion — that treatment which is working may simply continue; and even reading 3.1.21 alongside it still misses the 3.1.18 condition that stops treatment without waiting to reach 10 sessions or 30 days. So the limit of 10 sessions or 30 days is neither a ceiling you can renew for yourself nor a guarantee that treatment may continue until you get there.

Those three paragraphs sit in section 3.1 of the guideline, the section about direct access as a whole, not the section about the 6(2)(b) route — where the guideline deals with the section 6(2)(a) route (paragraphs 3.2.6 and 3.2.7), it likewise writes "within 30 days or 10 treatment sessions, whichever is earlier". So this limit should not be described as belonging to the clinical-guideline route alone.

Why keep them so far apart? Because they are changed in different ways. The regulation takes the Legislative Council; the guideline can be updated administratively by the Primary Healthcare Commission (that is exactly what section 6(6) provides). Describing the guideline's content as "written into section 6 of Cap. 359J" gives a document that can be amended administratively a statutory standing it does not have — and the most direct consequence is this: a reader who already holds a doctor's diagnosis, but whose problem is neither the back nor the knee, will think they have to queue for a doctor all over again. Section 6(2)(a) says they do not.

How each route actually works in a low back pain case, the guideline's red flag stratification and its various time limits are all handled in full in the article on low back pain, and are not repeated here.

Second, chiropractic: no referral requirement within the provisions examined. That sentence has a boundary, and the boundary needs stating: neither the section headings of the twenty-seven sections of the Chiropractors Registration Ordinance nor the full text of sections 23 to 25 (authentic Chinese and English texts, consolidated version dated the first of July 2022) contains any provision making a patient's holding a referral letter a condition. That is a statement about those provisions — not about every section of the whole ordinance, and not about Hong Kong law.

Third, doctors: Cap. 161 itself says nothing about patient referral. Again, put precisely: the Medical Registration Ordinance (consolidated version dated 18 June 2026) contains no provision requiring a patient to hold a referral letter before seeking care. That is a statement about that ordinance and cannot be widened into "no law requires a referral" — public specialist outpatient clinics have their own administrative requirements, insurance contracts have theirs, and neither is in Cap. 161.

Fourth, insurance is the fourth document, and it is in none of the above. Note (2) to the benefit schedule of the Standard Plan in the VHIS Certified Plan Policy Template provides that the company reserves the right to require proof of the written recommendation, such as a referral letter or a statement from the attending or registered medical practitioner in the claim form [Note 25]. Note (2) is attached to only three items of the benefit schedule: (d) specialist's fee, (i) prescribed diagnostic imaging tests, and (k) pre- and post-confinement or day case procedure outpatient care.

That is: the template does not make referral a condition of cover; it gives the insurer a right to ask for proof of the written recommendation, and a referral letter is one of the two forms of proof the document itself names. Individual policies, flexi plans and non-VHIS policies may impose other requirements, and this article has no information on which to make any statement about the practice of any particular insurer.

⚠ For anyone thinking "the law doesn't require a referral, so I'll just book": the law not requiring one does not mean your policy does not — the two are settled by two different documents, and the second one you have to look up yourself.

#If your problem is not their department, do they have a duty to refer you on?

The regulatory documents of all three professions write in a duty to pass the case on, but the three write it differently: one says "whether or not the patient holds a referral letter", one says "where it is in the patient's best interests", and one says "may refer, but is responsible for where the referral goes".

This is the widest sentence found anywhere in this article's sources, and it is worth setting out on its own: the Physiotherapists Board's sentence opens with "whether or not the patient holds a referral letter" — meaning that their duty to pass the case on does not exist only in referral-free cases. Go in with a doctor's note and the duty is the same: if your needs go beyond his professional scope he must tell you and help you find someone.

The same page also states how the first-contact physiotherapist-patient relationship comes into being: it is established when, without a referral letter from a registered medical practitioner or registered Chinese medicine practitioner, the patient receives assessment and subsequent treatment services from the physiotherapist under section 6(2)(a), (b) and/or (c) of Cap. 359J, having given informed consent [Note 26].

⚠ Note the two disclaimers the Code of Practice for Registered Chiropractors makes about itself. The preamble in Part I states that the Code offers guidance on the general areas of chiropractic professional conduct but is not a comprehensive code of professional ethics; and later in the same paragraph that the Code is not a legal document [Note 27]. It is a reference for disciplinary proceedings — which is stated on the Code's inside title page: a breach of the requirements of the Code constitutes conduct falling below the standard expected of a registered chiropractor and may lead the Chiropractors Council to institute disciplinary proceedings [Note 28].

#Why this article gives you no red flag checklist

Because no authority has published a complete, closed list of red flags, and printing a half-complete one in an article about who to see amounts to inviting readers to rule themselves out with it.

The article on low back pain handles this in full: it quotes three sources' own lists word for word (the six-row table in the two-page summary of the Health Bureau's Reference Framework on Common Musculoskeletal Problems in Primary Care, the urgency stratification in Table 3.1 of the Primary Healthcare Commission's clinical guideline above, and the National Health Service's three-tier public list), gives the provenance and date of each, and points out that the three lists disagree with one another — while Finucane and colleagues in 2020 (J Orthop Sports Phys Ther 2020;50(7):350-372) state that for most red flags there is no high-quality evidence of diagnostic accuracy.

This article covers only the part of that directly bearing on whom to see, and the direction has to be stated clearly.

This article will supply no feature or rule by which you could rule out serious disease yourself. A checklist fails when your symptom is not on it; a "distinguishing rule" fails when your symptom happens to fall on the reassuring side — which is worse, because the article has actively handed you a wrong conclusion.

The order runs one way only: the dangerous diagnoses are excluded first by a clinician, and only then is the benign one looked for. It cannot be reversed. "Not on the list" is not "not serious". The regulatory documents of all three professions write in a duty to pass the case on precisely because they expect cases outside their own scope to arrive. A government press release (19 March 2025) likewise states that physiotherapists and occupational therapists must at all times follow recognised clinical guidelines, including making a timely referral to a doctor for diagnosis and management on noticing that a patient has particular warning symptoms [Note 29].

⚠ For anyone planning to tick their way down an online checklist and, on finding nothing that matches, decide to go and have manual therapy: this approach has no support in any source seen in this article — not even the publishers of the lists say their lists are complete. For the lists and their respective time limits, see the article on low back pain.

#Before you book, how much can you actually check?

All three professions have public registers you can search name by name, all free and online; and the claim that "there is no public list of first-contact physiotherapists" needs correcting — the government has a public, district-searchable directory, and it is the Physiotherapists Board's own page that points to it.

#First, the three statutory registers

⚠ The register has five divisions, not three — and the Board's own page still carries the old formulation. Section 3 of Cap. 359J provides that the register is to be divided into 4 parts (Parts I, II, III and IV), with Part I to be further divided into Parts Ia and Ib [Note 30]. Section 5 then says who goes into which: Parts Ia and Ib are for persons registered under section 13 of Cap. 359; Part III is for persons with "limited registration" under section 13A and Part IV for persons with "temporary registration" under section 13B; Part II is for persons with provisional registration under section 15. Sections 13A and 13B were both added by section 18 of Ordinance No. 33 of 2025 — that is, by the same amendment that did the renaming.

⚠ But the Physiotherapists Board's "Registration Requirements" page still reads 「物理治療師註冊名冊分為兩個部分：第I部分及第II部分，其中第I部分再分為第Ia部及第Ib部」 — the physiotherapists register is divided into two parts, Part I and Part II, of which Part I is further divided into Parts Ia and Ib (our translation from the Chinese original). That is the position as it stood before 25 July 2025. The registration summary page on the same site likewise prints only Parts Ia and Ib and the total. This article quotes that page as it stands while pointing out the divisions the regulation now prescribes — the two disagree, and the regulation governs.

Do the arithmetic once (adding the figures already quoted in the table above): 3,955 plus 1,594 is 5,549, matching the total the Physiotherapists Board's registration summary prints itself (that summary counts these two parts only). Part Ia is 3,955 divided by 5,549, or 71.3%, and Part Ib 28.7%.

The proportion has a practical meaning. The Board's "Registration Requirements" page states that an applicant who has acquired not less than 1 year of "recognised experience" after qualifying may apply to be registered in Part Ia of the register, and one who does not hold such experience may apply to be registered in Part Ib. That is, the difference between Ia and Ib is recognised experience at the time of registration, not a difference in scope of practice (the "practice restriction" column of the registration summary prints "-" for both parts).

That also explains why the entry requirements for the first-contact training differ by part. The Board's "First-contact Physiotherapist" page provides that a Part Ia physiotherapist may enrol directly, while a Part Ib physiotherapist needs proof from an employer of having completed 2,000 hours of clinical experience (the source itself prints "2 000") and must make a statutory declaration before a person specified in section 12 of the Oaths and Declarations Ordinance (Cap. 11) [Note 31]. Note that the source itself prints "2 000", with a space in the middle, and does not write "at least". A bracketed note in the same paragraph adds that the Department of Health and the Home Affairs Department provide a free oath-taking service, so making that statutory declaration need not mean paying a solicitor.

#Then the "list of first-contact physiotherapists" — the old formulation needs correcting

The Board's "First-contact Physiotherapist" page does not itself print a register. But the same page points the way: physiotherapists should be responsible for keeping proof of completion of the training institution's course and using that proof where necessary, for example by submitting it directly to the Primary Healthcare Commission to update the Primary Care Directory so as to reflect their qualification as first-contact physiotherapists [Note 32].

Following that sentence through: the physiotherapist advanced search of the Primary Healthcare Commission's Primary Care Directory (apps.pcdirectory.gov.hk) carries a government primary healthcare programme filter called "First-contact Physiotherapy Service".

Do the arithmetic once (adding the figures already quoted in the table above): 1,002 plus 276 plus 15 plus 0 is 1,293, matching the total returned by the same eighteen-district search with no practice-category filter — that is, within the eighteen districts, the four practice categories cover every physiotherapist record. And 58 divided by 1,293 is 4.5%.

⚠ But that closure holds only within the eighteen districts. Searched with no district filter at all, the physiotherapist records number 1,301; searched with no district filter and one practice category at a time, the four categories return 1,002, 276, 15 and 4, totalling 1,297. That is: 8 records fall in none of the eighteen districts, and 4 of those fall in none of the four practice categories either. So the bounded statement this article makes is: within the scope of an eighteen-district search, the four practice categories add up to the total; whether the directory as a whole has a fifth category is something this article does not state.

How that 4.5% should be read, and how it must not be:

Numerator and denominator are both practice records, not people. A therapist with several practice addresses appears once for each, and this article has not de-duplicated. The figure 1,293 must not be divided by 5,549: the first is a count of records in a voluntarily-submitted directory, the second a headcount on a statutory register; they are not the same universe, and a percentage got by dividing them means nothing.

"Private, 0 records" is a statement about this directory, not about the private market. The same filter returns 0 in the private category, while the private category itself holds 1,002 records — meaning that both filter and category are working normally and the zero is a real zero. But the directory's information is submitted by service providers themselves, so all that can be said is: as at 3 August 2026, all 58 records in the Primary Care Directory carrying the "First-contact Physiotherapy Service" marking are in the "non-governmental organisation" category, and none is in "private".

"Hospital Authority, 0 records" is not a finding. That category returns 0 records on an eighteen-district search with no service filter in the first place, so its staying at 0 with the filter added says nothing at all. And searched with no district filter, the "Hospital Authority" category has 4 records — the category does pick things up; it is that those 4 fall in none of the eighteen districts. This cell is therefore about the eighteen-district search not capturing Hospital Authority physiotherapist practice records, not about first-contact services.

The directory does not prove completion of training either — on the sentence quoted above, keeping the proof of training is the physiotherapist's own responsibility, and submitting it to the Primary Healthcare Commission is likewise something they do themselves.

So the bounded statement is: the Physiotherapists Board's "First-contact Physiotherapist" page does not itself print a register, but the same page points to the Primary Care Directory, and that directory carries a public, free, district-searchable "First-contact Physiotherapy Service" filter. What has no list is that page, not the whole system.

#Beyond the three registers, one cell is empty

The Primary Care Directory has only five categories of service provider: Chinese medicine practitioners, dentists, doctors, occupational therapists and physiotherapists. There is no chiropractor category. So you cannot look a chiropractor up in the Primary Care Directory — for that you go to the Chiropractors Council's own "List of Registered Persons", where you can read registration numbers and Chinese and English names one by one.

⚠ For anyone who has already booked and is unsure whether the person is regulated at all: all three registers are free, public and searchable name by name, and once you have checked you at least know which register the person is on and whose disciplinary procedure they are subject to. But a register cannot answer the other half — the valid practising certificate of section 16(1) of Cap. 359 and section 24(i) of Cap. 428 — and that is dealt with below.

#A conflict worth noting: the government's own directory still prints a rule that has been superseded

One government website, one page carrying the old rule and another pointing to the new arrangement — and the footer date on the old page is three years earlier than the date the new rule took effect.

The physiotherapist search page and the search results page of the Primary Care Directory both print the same sentence: 「根據現行法例及職業治療師和物理治療師的專業守則，一般而言，患者須先獲得醫生轉介方可接受職業治療師和物理治療師的服務。」 — under the law in force and the professional codes of occupational therapists and physiotherapists, patients generally have to obtain a doctor's referral before they can receive occupational therapy and physiotherapy services (our translation from the Chinese original). The site's footer gives a last-updated date of the first of July 2022.

Two things do not square with that sentence, and each has a date of its own.

First, "a doctor's referral" leaves out registered Chinese medicine practitioners. The government press release "Arrangement for registered Chinese medicine practitioners to refer patients for allied health services takes effect" (11 December 2025) states that the Allied Health Professions (Amendment) Ordinance 2025 came into operation on 25 July 2025, renaming Cap. 359 and providing the legal basis for specified allied health professionals to accept referrals from registered Chinese medicine practitioners; and, later in the same release, that the Ordinance allows physiotherapists and occupational therapists to accept referrals from registered Chinese medicine practitioners, and that the Council has passed the relevant codes of practice, which took effect the same day [Note 33]. And the Physiotherapists Board's "First-contact Physiotherapist" page opens with the words "without a referral letter from a registered medical practitioner or registered Chinese medicine practitioner" — meaning that the Board itself treats a registered Chinese medicine practitioner's referral letter as a referral letter. ⚠ That press release still uses the old name 「輔助醫療業管理局」, even though its own first paragraph announces the renaming.

Second, the sentence makes no mention of the referral-free routes. The exception routes at section 6(2) of Cap. 359J exist just the same; the Physiotherapists Board's "First-contact Physiotherapist" page is itself written around sections 6(2)(a), (b) and/or (c).

How to handle the conflict: both are official documents, both carry their own dates, and the newer governs. The date in the Primary Care Directory footer is the first of July 2022; the amending ordinance took effect on 25 July 2025 and the press release is dated 11 December 2025. The latter are newer, so the latter govern. This article will not simply wipe the old sentence away and pretend it was never there — readers going to look up the list will see it with their own eyes, and if this article did not mention it they would think they had come to the wrong place.

⚠ The footer date on that directory page is only the website's last-updated date and is not necessarily the date the sentence was written; all this article can say is "the date given in the site footer is the first of July 2022", not "that sentence was written in 2022".

#What to do next

Each item below points back to a document already cited above; this article makes no assessment of the merits of any individual therapist or clinic.

1. Check which register the person is on. For a registered chiropractor, the Chiropractors Council's "List of Registered Persons"; for a physiotherapist, the Physiotherapists Board's "List of Registered Persons" (which also shows whether they are in Part Ia or Part Ib); for a doctor, the Medical Council's General Register and Specialist Register. All three are free and online.
2. ⚠ But being on the register is not the same as being entitled to practise now. Section 16(1) of Cap. 359 requires a registered person also to hold a valid practising certificate before practising the profession; section 24(i) of Cap. 428 likewise makes it an offence to practise chiropractic while not the holder of a valid practising certificate. The register pages do not necessarily show this, so ask directly.
3. If the person calls themselves 「脊骨神經科醫生」, first confirm they are on the register of chiropractors. What section 23(1) of Cap. 428 protects is "registered chiropractor"; 「脊骨神經科醫生」 is another title recognised by the Chiropractors Council, and the Council has attached its own condition — it may be used only where it will not mislead anyone into thinking the person is a medical practitioner.
4. If it is a chiropractic clinic, ask which registered chiropractor supervises that location. Sections 23(3) and (4) of Cap. 428 are requirements about the business, not only about individuals — a business that is not multidisciplinary must have a registered chiropractor supervising each place of business, and that registered chiropractor must not at the same time act in the same capacity for anyone else.
5. If you want physiotherapy without a referral, ask whether that therapist has completed the training recognised by the Board. This is not a bonus, it is a precondition. Proof of training is issued by the training institution and kept by the physiotherapist; the Board's page also states that the recognised training institutions were approved on a joint proposal submitted by the Hong Kong Physiotherapy Association and the Hong Kong Polytechnic University. You can also search the Primary Care Directory with the "First-contact Physiotherapy Service" filter — but remember that those 58 records are practice records from an eighteen-district search on 3 August 2026, submitted by service providers themselves, and are neither a statutory register nor proof that training was completed.
6. Look for the certificate of registration on the clinic wall. Section 18(1) of Cap. 359 requires a registered person to keep the certificate of registration, or a certified copy, displayed conspicuously at the place of practice, and section 18(2) makes non-compliance an offence. ⚠ Note that what section 18(1) requires to be displayed is the certificate of registration — the practising certificate of section 16 is a different document, and section 18 does not require it to be displayed, so the paper on the wall cannot prove the practising certificate is still valid.
7. Ask one question outright: if my situation turns out not to be your department, what will you do? All three professional codes and regulator pages write in a duty to pass the case on, and the physiotherapists' version begins "whether or not the patient holds a referral letter".
8. If your problem is low back pain, read that article first. Three sources' own red flag lists, their respective time limits, and how the four routes actually work in that condition are all handled in full in the article on low back pain and are not repeated here.
9. Read your policy once through. The VHIS Certified Plan Policy Template gives the insurer only a right to ask for proof of the written recommendation, attached to three items of the benefit schedule; individual policies may impose other requirements. This one depends on your own policy, and this article has no information with which to answer it for you.

#Frequently asked questions

Is a chiropractor a doctor?

A chiropractor is not a doctor registered under the Medical Registration Ordinance (Cap. 161) but a person registered under the Chiropractors Registration Ordinance (Cap. 428), whose statutory title is "registered chiropractor". Section 28(3)(f) of Cap. 161 takes treatment given by way of chiropody, chiropractic or osteopathy outside the offence in section 28(2), and subsection (5) of the same section states that "treatment" includes the diagnosis required for the giving of treatment; the long title of Cap. 428 likewise describes a chiropractor as someone trained in prevention, diagnosis and treatment. But that is an answer about criminal liability, not about clinical sufficiency — "does not offend section 28(2)" is not "your situation already has an adequate medical diagnosis". Section 32 of Cap. 161 draws a further line: apart from a registered or provisionally registered medical practitioner, no person may hold themselves out as competent to give treatment for diseases of the human eye, and the exceptions in section 32(1A) reach only refraction and optical appliances, and registered or listed Chinese medicine practitioners.

Can a physiotherapist diagnose me?

The statutory description at item 3 of Schedule 1 to the Allied Health Professions Ordinance is the assessment and treatment of physical disability, naming four means and not mentioning the diagnosis of disease. The Physiotherapists Board's own page states that whether or not the patient holds a referral letter, if the patient's needs go beyond the physiotherapist's professional scope the physiotherapist should inform the patient and assist in finding a suitable and qualified person.

Can I look up which physiotherapists have first-contact qualification?

The Physiotherapists Board's "First-contact Physiotherapist" page does not itself print a register, but the same page points to the Primary Care Directory, which carries a "First-contact Physiotherapy Service" filter; an eighteen-district search on 3 August 2026 returned 58 records. Note that those are practice records, submitted by service providers themselves, and are neither a statutory register nor proof that training was completed.

In 2026, do I still need a doctor's note to see a physiotherapist?

The statutory answer is at section 6 of the Physiotherapists (Registration and Disciplinary Procedure) Regulation (Cap. 359J): referral by default, the referrer being a registered medical practitioner or a registered Chinese medicine practitioner, with the four exception routes at sections 6(2)(a) to (d). ⚠ There is also a precondition that is not in the regulation: the Physiotherapists Board states that a physiotherapist must first complete training recognised by the Board before providing services under sections 6(2)(a), (b) and/or (c). And section 16(1) of Cap. 359 requires a registered person to hold a valid practising certificate before practising the profession.

Then how do "only knee osteoarthritis and low back pain" and "10 sessions or 30 days" work?

None of that is in section 6 — nowhere in Cap. 359J do the words 「腰背」, 「膝」, 「骨關節炎」 or 「30日」 appear. They are in the Primary Healthcare Commission's English clinical guideline. And the two-condition restriction binds only section 6(2)(b) (paragraphs 3.2.9 to 3.2.11 of the guideline sit under "II. Clinical care pathway for patients with a condition stipulated by clinical guidelines"); if within the past 12 months a registered medical practitioner or registered Chinese medicine practitioner has written down a diagnosis for you, you are travelling by section 6(2)(a) and are not confined to those two conditions. The limit of 10 sessions or 30 days is at paragraph 3.1.19 and applies to direct-access services as a whole, but it is not a countdown that has to run out before treatment can stop: paragraph 3.1.18 requires regular review throughout treatment, and once the condition deteriorates or red flag symptoms or atypical features emerge the first-contact physiotherapist must stop treatment at once and refer to a doctor, without waiting for 10 sessions or 30 days. Where you go after the course ends is written by paragraphs 3.1.20 and 3.1.21 together: no improvement means handing back to a doctor, and improvement plus a wish to continue also means handing back to a doctor for review and for the doctor to decide. And if you have more than one condition at once, paragraph 3.2.11 provides that the first-contact physiotherapist may provide direct-access services only for the stipulated condition.

What about the insurance side?

That depends on your own policy. The VHIS Certified Plan Policy Template does not make referral a condition of cover, but note (2) to the benefit schedule gives the insurer a right to ask for proof of the written recommendation, attached only to items (d), (i) and (k), and a referral letter is one of the two forms of proof the document itself names.

Why does the Primary Care Directory say patients must first obtain a doctor's referral?

The last-updated date in that site's footer is the first of July 2022, earlier than the 25 July 2025 commencement of the Allied Health Professions (Amendment) Ordinance 2025; the sentence also omits registered Chinese medicine practitioners as qualified referrers, while a government press release (11 December 2025) states that the Ordinance allows physiotherapists to accept referrals from registered Chinese medicine practitioners. Both are official documents, and the newer governs.

If I tick down a red flag checklist and nothing matches, can I just go and have manual therapy?

This article gives no checklist, and no rule by which you could rule out serious disease yourself. No authority has published a complete, closed list of red flags, the items different sources list disagree with one another, and Finucane and colleagues in 2020 state that for most red flags there is no high-quality evidence of diagnostic accuracy. Not being on the list is not the same as not being serious. For each source's own list and its respective time limits, see this site's dedicated article on back problems.

#Notes: the official texts

[Note 1] Allied Health Professions Ordinance (Cap. 359), Schedule 1, item 3, and item 4 of the same Schedule:

Physiotherapist — a person trained in the assessment and treatment of physical disability by therapeutic exercise, manual therapy and the application of mechanical, thermal or electrical energy. Occupational therapist — a person trained in the assessment and treatment, through intellectual, physical or social activity, of disability caused by illness or injury, so as to make the disabled person as independent as possible in daily living. (our translation from the Chinese original)

Chinese original:

「物理治療師 — 受訓以治療用運動、人手治療及以機械能、熱能或電能就身體殘疾予以評估與醫治的人。」 「受訓採用智能、體能或社交活動就因疾病或傷患造成的殘疾予以評估與醫治，使殘疾者在日常生活盡可能可以自立的人」

[Note 2] Chiropractors Registration Ordinance (Cap. 428), long title:

An Ordinance to provide for the registration of chiropractors (that is, persons trained and qualified in the chiropractic profession, being the profession which includes the prevention, diagnosis and treatment of disorders of human function by adjustment of joints, particularly the spine and surrounding joints and also the pelvis), for disciplinary control of the professional activities of registered chiropractors, and for matters connected with that registration and disciplinary control. (our translation from the Chinese original)

Chinese original:

「本條例旨在對脊醫(即在脊骨療法專業及其中所包括的藉矯正關節(尤指脊椎及周圍關節，亦包括骨盆)的方法對人體機能失調的病症加以預防並作出診斷治療的專業方面曾接受訓練並符合資格的人)的註冊、註冊脊醫專業事務的紀律管制及與該等註冊及紀律管制有關的事宜作出規定。」

[Note 3] The same ordinance, section 2:

registered chiropractor (註冊脊醫) means a person whose name is for the time being on the register. (our translation from the Chinese original)

Chinese original:

「註冊脊醫(registered chiropractor)指現時名列於名冊的人」

[Note 4] Medical Council of Hong Kong, "Registration Requirements". (The spaces around 「專科註冊申請」 are produced by that page making those characters a link, and are reproduced as in the original.)

Any person intending to practise medicine, surgery or midwifery in Hong Kong must, under the Medical Registration Ordinance, apply to the Medical Council to become a registered medical practitioner. A registered medical practitioner may submit to the Medical Council a specialist registration application to have their name entered under a specialty in the Specialist Register. (our translation from the Chinese original)

Chinese original:

「任何有意在本港從事內科、外科或助產科執業的人士，必須根據《醫生註冊條例》的規定，向醫務委員會申請成為註冊醫生。」 「註冊醫生可向醫務委員會遞交 專科註冊申請 ，將其姓名列入專科醫生名冊內的某一專科之下。」

[Note 5] Chiropractors Council, Code of Practice for Registered Chiropractors, Part I preamble, "Chiropractic — a brief history":

In Hong Kong, chiropractic can be traced to before the Second World War. With the founding of the Hong Kong Chiropractors' Association (formerly the Hong Kong Chiropractic Association) in 1967, practitioners began to organise. At a meeting in 1981 the association resolved on 「脊骨神經科」 and 「脊骨神經科醫生」 as the Chinese names for "chiropractic" and "chiropractors" respectively. With the passage of the Chiropractors Registration Ordinance, statutory registration of chiropractors began in Hong Kong in 1993. In conferring statutory healthcare professional status on chiropractors, that ordinance was the first in Asia. Since its enactment, only chiropractors whose names are on the register of registered chiropractors may practise the chiropractic profession and use the legally recognised Chinese title 「註冊脊醫」 and English title "registered chiropractor". (our translation from the Chinese original)

Chinese original:

「在香港，脊骨療法可追溯至第二次世界大戰前。隨着香港脊醫學會(前稱“香港脊骨神經科學會”)於一九六七年成立，業內人士開始組織起來。在一九八一年的會議上，該會議決以“脊骨神經科”及“脊骨神經科醫生” 分別作為“chiropractic” 及“chiropractors” 的中文名稱。」 「隨著《脊醫註冊條例》的通過，香港於一九九三年開始實施法定的脊醫註冊。賦予脊醫法定的醫療專業地位，該條例為亞洲之首。該條例制定後，只有名列於註冊脊醫名冊的脊醫可從事脊骨療法專業，並使用獲法律認可的“註冊脊醫”中文名銜及“registered chiropractor”英文名銜。」

[Note 6] Allied Health Professions Ordinance, section 1(1):

1. Short title and application (1) This Ordinance may be cited as the Allied Health Professions Ordinance. (Amended 33 of 2025 s. 4) (our translation from the Chinese original)

Chinese original:

「1. 簡稱及適用範圍 (1)本條例可引稱為《專職醫療業條例》。 (由2025年第33號第4條修訂)」

[Note 7] The same ordinance, section 21A:

21A. Practice of profession subject to supervision or referral requirements — a registered person must not practise a profession in Hong Kong unless the person complies with the supervision or referral requirements prescribed by the Regulation, as the case requires. (Added 33 of 2025 s. 27) (our translation from the Chinese original)

Chinese original:

「21A. 從事專業受監督或轉介規定所規限 — 獲註冊的人除非遵守《規例》所訂的監督或轉介規定(視情況所需而定)，否則不得在香港從事某一專業。(由2025年第33號第27條增補)」

[Note 8] Medical Registration Ordinance, section 28(2):

Subject to subsection (3), any person who, not being registered, provisionally registered or exempted from registration — (a) practises medicine or surgery, commits an offence and is liable — (i) on summary conviction to a fine at level 6 and to imprisonment for 3 years; or (Amended 7 of 1996 s. 34) (ii) on conviction on indictment to imprisonment for 5 years; or (Amended 7 of 1996 s. 34) (b) makes any medical diagnosis of, prescribes any medical treatment for, or carries out any medical treatment (including surgery) on, any person, thereby causing that person bodily injury, commits an offence and is liable — (i) on summary conviction to a fine of $200,000 and to imprisonment for 3 years; or (Amended 7 of 1996 s. 34) (ii) on conviction on indictment to imprisonment for 7 years. (Added 68 of 1986 s. 5) (our translation from the Chinese original)

Chinese original:

「除第(3)款另有規定外，任何人並非已註冊、臨時註冊或獲豁免註冊而 ——(a)從事內科或外科執業，即屬犯罪 ——(i)一經循簡易程序定罪，可處第6級罰款及監禁3年；或 (由1996年第7號第34條修訂)(ii)一經循公訴程序定罪，可處監禁5年；或 (由1996年第7號第34條修訂)(b)對某人進行任何醫學診斷、訂明任何醫藥治療或施行任何醫藥治療(包括外科手術)而導致該人受人身傷害，即屬犯罪 ——(i)一經循簡易程序定罪，可處罰款$200,000及監禁3年；或 (由1996年第7號第34條修訂)(ii)一經循公訴程序定罪，可處監禁7年。 (由1986年第68號第5條增補)」

[Note 9] The same ordinance, section 28(3) (two paragraphs extracted; not the whole subsection):

Subsection (2) does not apply to any of the following treatment — (d) treatment given in the course of practising one of the professions listed in Schedule 1 to the Allied Health Professions Ordinance (Cap. 359), by a person registered or otherwise permitted under that Ordinance to practise that profession; (Amended 33 of 2025 s. 188) (f) treatment given by way of chiropody, chiropractic or osteopathy; (Amended 47 of 1999 s. 164) (our translation from the Chinese original)

Chinese original:

「第(2)款不適用於下述任何治療 —— (d)在列入《專職醫療業條例》(第359章)附表1的其中一項專業的執業過程中，由任何根據該條例註冊或獲特許從事該專業執業的人作出者；(由2025年第33號第188條修訂) (f)以足病診療法、脊骨療法或骨療法作出者； (由1999年第47號第164條修訂)」

[Note 10] The same ordinance, section 28(5):

In subsection (3), treatment (治療) includes the diagnosis and prescribed medical method required for the giving of treatment. (our translation from the Chinese original)

Chinese original:

「在第(3)款中，治療(treatment)包括為給予治療而需要進行的診斷和訂明的醫療方法。」

[Note 11] Chiropractors Registration Ordinance, section 24 (four paragraphs extracted; not the whole section):

(g) not being on the register, accepts or uses any name, abbreviation, title, designation or description falsely implying that he is on the register; (h) not being on the register, practises the chiropractic profession; (i) not being the holder of a valid practising certificate, practises the chiropractic profession; (k) not being on the register, advertises or holds himself out as a registered chiropractor, or knowingly allows another person to advertise or hold him out as a registered chiropractor. (our translation from the Chinese original)

Chinese original:

「(g)並非名列於名冊，但卻接受或使用任何虛假地暗示其名列於名冊的名稱、英文縮寫字樣、名銜、頭銜或稱謂；(h)並非名列於名冊，但卻從事脊骨療法專業；(i)並非有效執業證明書持有人，但卻從事脊骨療法專業；(k)並非名列於名冊，但卻宣傳或表示自己是註冊脊醫，或明知而容許他人宣傳或表示他是註冊脊醫。」

[Note 12] Allied Health Professions Ordinance, section 21(1):

Subject to section 20(2), a person who practises a profession without being registered in respect of that profession commits an offence. (our translation from the Chinese original)

Chinese original:

「除第20(2)條另有規定外，任何人從事某專業而並無就該專業註冊，即屬犯罪。」

[Note 13] The same ordinance, section 16(1):

16. Registered person not to practise without practising certificate (1) A registered person must not practise a profession in Hong Kong unless the person holds a valid practising certificate for that profession. (Replaced 33 of 2025 s. 23) (our translation from the Chinese original)

Chinese original:

「16. 獲註冊的人無執業證明書不得執業 (1)獲註冊的人除非持有有效的某專業的執業證明書，否則不得在香港從事該專業。 (由2025年第33號第23條代替)」

[Note 14] Medical Registration Ordinance, section 32(1):

Notwithstanding section 31, and subject to subsection (1A), no person, unless he is a registered medical practitioner or is provisionally registered, shall hold himself out as being qualified, competent or willing to give treatment for diseases of the human eye, to prescribe any medical remedy, or to give advice in connection with the treatment of eye diseases. (our translation from the Chinese original)

Chinese original:

「儘管第31條另有規定，及在第(1A)款的規限下，任何人除非是註冊醫生或獲臨時註冊，否則不得顯示自己符合資格、有能力或願意為人類眼疾給予治療，或訂明任何醫療補救方法，或在與治療眼疾有關方面提供意見。」

[Note 15] Code of Practice for Registered Chiropractors, Appendix A, paragraph 4 (extract):

(b) the statutory titles "Registered Chiropractor" or "Chiropractor"; (c) other titles recognised by the Chiropractors Council, including 「脊骨神經科醫生」 (to be used only where it will not mislead anyone into thinking that the chiropractor is a medical practitioner); (our translation from the Chinese original)

Chinese original:

「(b) 法定名銜“ 註冊脊醫”(Registered Chiropractor) 或“ 脊醫” (Chiropractor)；(c) 其他脊醫局認可的名銜，包括“脊骨神經科醫生”(只限於不會令人誤以為該脊醫是醫生的情況下使用)；」

[Note 16] Code of Practice for Registered Chiropractors, last paragraph of Part II. The English original:

Patient care is conducted with due regard for environmental, nutritional and psycho-social factors, as well as first aid, rehabilitation and physiological therapeutic procedures designed to assist in the restoration and maintenance of neurological integrity and homeostatic balance.

The Chinese version of the same paragraph reads 「脊醫在醫治病人時，會顧及環境、營養和心理社交等因素，並會適當考慮為協助恢復和維持神經系統完整及體內平衡的急救、康復和物理治療程序。」 — that is, it renders "physiological" as 「物理治療」, physiotherapy. The Chinese version's own cover declares the English text to govern.

[Note 17] Physiotherapists (Registration and Disciplinary Procedure) Regulation (Cap. 359J), sections 6(1) and (2). The authentic English text:

(1) A physiotherapist must not provide any service of the physiotherapist's profession to a person unless the person is on referral by any of the following persons (each an eligible referrer)— (a) a registered medical practitioner; (b) a registered Chinese medicine practitioner. (2) However, subsection (1) does not apply if— (a) the physiotherapist— (i) has obtained, or has been provided with, a certificate (or other document in writing)— (A) that was issued by an eligible referrer not more than 12 months earlier; and (B) that sets out the diagnosis of the person's condition (diagnosed condition); and (ii) provides services only for the diagnosed condition; (b) the condition of the person is of a kind that is recognized by any clinical guideline as a kind for which the service of a physiotherapist's profession may be provided without a referral; (c) the person is enrolled in a cross-disciplinary collaboration arrangement of the Primary Healthcare Commission under which a physiotherapist may provide the service of the physiotherapist's profession to an enrolled person without a referral; or (d) the circumstances of the case fall within any of the specified circumstances in the Code of Practice that are considered an emergency situation, or that are considered to involve the provision of community services, in which, under the Code of Practice, the service of the physiotherapist's profession may be provided without a referral.

The authentic Chinese text:

「(1)除非某人是由下列任何人士轉介(各人皆為合資格轉介人)，否則物理治療師不得向該人提供該物理治療師專業的任何服務 ——(a)註冊醫生；(b)註冊中醫。 (2)然而，如有以下情況，則第(1)款不適用 ——(a)有關物理治療師 ——(i)已取得或獲提供符合以下說明的證明書(或其他書面文件) ——(A)由合資格轉介人在不超過12個月前發出；及(B)列明對有關的人的狀況的診斷(已診斷狀況)；及(ii)只為已診斷狀況提供服務；(b)該人的狀況屬以下說明的種類：獲任何臨牀指引認可，可在沒有轉介的情況下，就該狀況提供物理治療師專業的服務；(c)該人獲登記加入基層醫療署的跨專業協作安排，而於該安排下，物理治療師可在沒有轉介的情況下，向該獲登記的人提供物理治療師專業的服務；或(d)有關個案的情況符合執業守則視作緊急狀況或涉及提供社會服務的指明情況，而根據執業守則，在該等情況下，可在沒有轉介的情況下提供物理治療師專業的服務。」

[Note 18] Physiotherapists Board, "First-contact Physiotherapist" page, the English original:

Physiotherapists must fulfill the training requirement(s) as published by the Board by attending relevant course(s) accredited by the Board, prior to providing physiotherapy services under sections 6(2)(a), 6(2)(b) and/or 6(2)(c)

[Note 19] Cap. 359J, sections 6(3), (4) and (5):

(3) A physiotherapist who provides any service of the physiotherapist's profession to a person in the situation described in subsection (2)(b) must comply with the requirements specified in the clinical guideline. (4) A physiotherapist who provides any service of the physiotherapist's profession to a person in the situation described in subsection (2)(c) must comply with the requirements specified in the guidance published by the Primary Healthcare Commission for the cross-disciplinary collaboration arrangement concerned. (5) A physiotherapist whose name is in Part II must not practise otherwise than under the supervision of a physiotherapist whose name is in Part Ia. (our translation from the Chinese original)

Chinese original:

「(3)物理治療師如向在第(2)(b)款所述的情況下的人，提供該物理治療師專業的任何服務，則須遵從臨牀指引所列明的規定。 (4)物理治療師如向在第(2)(c)款所述的情況下的人，提供該物理治療師專業的任何服務，則須遵從由基層醫療署為有關跨專業協作安排而發布的指引所列明的規定。 (5)名列第II部的物理治療師須在一位名列第Ia部的物理治療師的督導下執業，否則不得執業。」

[Note 20] Primary Healthcare Commission clinical guideline, paragraph 3.2.10:

Notably, under this specific circumstance within the direct access arrangement, in case if the patient's presenting condition is not consistent with osteoarthritis of knee, low back pain, or any other conditions stipulated by a clinical guideline published by a referencing authority, the first-contact physiotherapist must refrain from providing direct access physiotherapy service, even if the condition can be effectively and safely managed by physiotherapy.

Paragraph 3.2.11:

Likewise, in case if the patient presents with more than one condition at the same time, the first-contact physiotherapist can only provide physiotherapy treatment for osteoarthritis of knee, low back pain, or any other conditions stipulated by a clinical guideline published by a referencing authority. He/she must refrain from providing direct access physiotherapy service to the patient's other condition(s), even if the condition can be effectively and safely managed by physiotherapy.

[Note 21] The same guideline, paragraph 3.1.18:

Regular review of the patient's clinical progress should be carried out throughout the course of physiotherapy treatment, for evaluation of treatment response, as well as changes in the patient's condition. Whenever the patient's condition deteriorates, or red flag symptom/sign or atypical feature emerges, the first-contact physiotherapist must discontinue treatment and promptly refer the patient to a medical doctor (preferably the patient's own family doctor) or emergency department for further care, according to the urgency of the condition (Table 3.1).

[Note 22] The same guideline, paragraph 3.1.19:

Notably, direct access physiotherapy service is time-defined, limited to a maximum of 10 treatment sessions or 30 days, whichever occurs first.

[Note 23] The same guideline, paragraph 3.1.20:

If the patient's condition has not improved upon completion of the physiotherapy treatment course, the first-contact physiotherapist must refrain from providing further physiotherapy treatment, and refer the patient to a medical doctor, preferably the patient's own family doctor, for diagnostic assessment/review, to guide prescription of the most appropriate management.

[Note 24] The same guideline, paragraph 3.1.21:

Upon completion of the physiotherapy treatment course, should the first-contact physiotherapist consider that the patient can benefit further from physiotherapy treatment for the same condition, the first-contact physiotherapy must send the patient to a medical doctor, preferably the patient's own family doctor, for review and decision for referral to further physiotherapy service.

("the first-contact physiotherapy must send" is the document's own wording, reproduced as in the original.)

[Note 25] VHIS Certified Plan Policy Template, Standard Plan benefit schedule, note (2). The English original:

(2) The Company shall have the right to ask for proof of recommendation e.g. written referral or testifying statement on the claim form by the attending doctor or Registered Medical Practitioner.

The Chinese original:

「(2) 本公司有權要求有關書面建議的證明，例如轉介信或由主診醫生或註冊醫生在索償申請表內提供的陳述。」

⚠ Both the Chinese and English versions of the template are official versions; this article quotes the originals of both and has translated neither.

[Note 26] Physiotherapists Board, "First-contact Physiotherapist" page (the spaces between characters have been removed):

The first-contact physiotherapist-patient relationship is established when, without a referral letter from a registered medical practitioner or registered Chinese medicine practitioner, a patient receives assessment and subsequent treatment services from a physiotherapist under sections 6(2)(a), (b) and/or (c) of the Physiotherapists (Registration and Disciplinary Procedure) Regulation (Cap. 359J), having given informed consent. (our translation from the Chinese original)

Chinese original:

「當病人在沒有註冊醫生或註冊中醫師的轉介信下，根據《物理治療師（註冊及紀律程序）規例》（第359J章）第6(2)(a)、(b)及／或(c)條，並已作出知情同意，接受物理治療師的評估及其後治療服務時，即建立了「首診物理治療師—病人關係」。」

[Note 27] Code of Practice for Registered Chiropractors, Part I preamble:

The Code of Practice for Registered Chiropractors (the Code) applies to all registered chiropractors. The Code offers guidance on the general areas of chiropractic professional conduct, but is not a comprehensive code of professional ethics. The Code is not a legal document, and its provisions should be given a fair and reasonable interpretation so as to achieve their purpose. (our translation from the Chinese original)

Chinese original:

「《註冊脊醫專業守則》(下稱“《守則》”)適用於所有註冊脊醫，《守則》就脊醫專業操守的一般範疇提供指引，但並非一套全面的專業道德守則。」 「《守則》並非法律文件，對其條文應作出公正合理的釋義以達致相關條文之目的。」

[Note 28] The same document, inside title page (before the contents, outside Part I):

Observing the Code of Practice for Registered Chiropractors is the professional responsibility of every registered chiropractor. A breach of the requirements of the Code constitutes conduct falling below the standard expected of a registered chiropractor and may lead the Chiropractors Council to institute disciplinary proceedings. (our translation from the Chinese original)

Chinese original:

「遵守《註冊脊醫專業守則》是每名註冊脊醫的專業責任。違反《守則》的規定，會構成低於註冊脊醫應有水平的行為，並可令脊醫管理局進行紀律處分程序。」

[Note 29] Government press release, 19 March 2025:

Physiotherapists or occupational therapists must at all times follow recognised clinical guidelines, including making a timely referral of the case to a doctor for diagnosis and management on noticing that a patient has particular warning symptoms. (our translation from the Chinese original)

Chinese original:

「物理治療師或職業治療師必須時刻遵照獲認可的臨床指引，包括在察覺病人出現特定警示病情徵狀時及時將個案轉介醫生診斷和處理。」

[Note 30] Cap. 359J, section 3:

(2) The register is to be divided into 4 parts, namely Part I, Part II, Part III and Part IV. (3) Part I referred to in subsection (2) is to be further divided into 2 parts, namely Part Ia and Part Ib. (33 of 2025 s. 159) (our translation from the Chinese original)

Chinese original:

「(2)註冊名冊須分為4部分，即第I部、第II部、第III部及第IV部。 (3)第(2)款所提述的第I部須細分為2部分，即第Ia部及第Ib部。(2025年第33號第159條)」

[Note 31] Physiotherapists Board, "First-contact Physiotherapist" page (spaces between characters removed):

Enrolment requirements: physiotherapists in Part Ia. Physiotherapists in Part Ib need to obtain from an employer proof of having completed 2 000 hours of clinical experience, and to make a statutory declaration of having completed 2 000 hours of clinical experience before a person specified in section 12 of the Oaths and Declarations Ordinance (Cap. 11) (that is, a Justice of the Peace, a notary public, a commissioner for oaths or any other person authorised by law to administer oaths may, in the manner provided by section 14, administer and take any declaration made before them). (Note: the Department of Health and the Home Affairs Department provide a free oath-taking service.) (our translation from the Chinese original)

Chinese original:

「報讀要求： 第 Ia 部的物理治療師 第 Ib 部的物理治療師需從雇主獲得完成2 000小時臨床經驗的證明，並在《宣誓及聲明條例》（第11章）第12條所指明的人士面前作出完成2 000小時臨床經驗的法定聲明（即太平紳士、公證人、監誓員或其他獲法律授權監誓的人，均可按第14條訂定的方式監理和接受任何人在其面前作出的聲明）。（註：衛生署及民政事務署提供免費的宣誓服務）」

[Note 32] The same page:

Physiotherapists should be responsible for keeping proof of completion of the training institution's course, and for using that proof where necessary — for example, by submitting it directly to the Primary Healthcare Commission to update the Primary Care Directory so as to reflect their qualification as first-contact physiotherapists. (our translation from the Chinese original)

Chinese original:

「物理治療師應負責保留完成培訓機構課程的證明，並在必要時使用該證明。例如，直接提交給基層醫療署以作更新基層醫療指南，反映其作為首診物理治療師的資格。」

[Note 33] Government press release, "Arrangement for registered Chinese medicine practitioners to refer patients for allied health services takes effect", 11 December 2025:

The Allied Health Professions (Amendment) Ordinance 2025 came into operation on 25 July 2025. That ordinance renamed the Supplementary Medical Professions Ordinance (Cap. 359 of the Laws of Hong Kong) as the Allied Health Professions Ordinance (the Ordinance) and made a number of amendments to it, including providing the legal basis for specified allied health professionals to accept referrals from registered Chinese medicine practitioners. In addition, the Ordinance allows physiotherapists and occupational therapists to accept referrals from registered Chinese medicine practitioners. To tie in with the above developments, the Chinese Medicine Practitioners Board has maintained close communication with the Supplementary Medical Professions Council, and understands that the Council has passed the codes of practice for radiographers, medical laboratory technologists, physiotherapists and occupational therapists allowing them to provide allied health services to patients referred by registered Chinese medicine practitioners, the relevant amendments likewise taking effect today (11 December). (our translation from the Chinese original)

Chinese original:

「《2025年輔助醫療業（修訂）條例》於二○二五年七月二十五日生效，該條例將《輔助醫療業條例》（香港法例第359章）重新命名為《專職醫療業條例》（《條例》），並對《條例》作出多項修訂，當中包括為特定專職醫療業人員接受註冊中醫師轉介提供法律基礎。」 「此外，《條例》容許物理治療師及職業治療師接受註冊中醫的轉介。」 「為配合上述發展，中醫組一直與輔助醫療業管理局保持緊密溝通，並知悉輔助醫療業管理局已通過放射技師、醫務化驗師、物理治療師及職業治療師的執業守則，容許他們可為註冊中醫師轉介的病人提供專職醫療服務，有關修訂同樣於今日（十二月十一日）生效。」

#Matters on which this article makes no statement

• This article lists no fees for physiotherapy, chiropractic or private medical consultations. None of the sources it relies on contains any first-hand price information.
• The scope of the sentence "no referral requirement is found in the Chiropractors Registration Ordinance" is limited to the section headings of that ordinance's twenty-seven sections and the full text of sections 23 to 25 (authentic Chinese and English texts, consolidated version dated the first of July 2022). This article makes no statement about provisions outside that scope.
• Whether the Chiropractors Registration Ordinance has been amended since the first of July 2022 has not been independently verified here. What this article uses is the Department of Justice consolidated version, whose consolidated version date is the first of July 2022.
• This article has no information about any actual prosecution or decision under section 24 of Cap. 428 or section 28 of Cap. 161. A decided case would be this article's strongest material, and it has not been obtained.
• This article has no information about what any particular insurer actually requires. It quotes only the VHIS Certified Plan Policy Template (the document prints "1 July 2022 version"); the template sets minimum requirements, and flexi plans or non-VHIS policies may impose others.
• Whether that template has been updated since the first-of-July-2022 version has not been independently verified here. What is quoted are the Chinese and English versions currently provided on the Health Bureau website, both of which print the same version date.
• This article does not have a total headcount for the Medical Council's registers. The Council publishes its registers on separate pages by specialty; the pages examined here print no total — and even adding the specialties would not give a headcount, since one doctor may be registered under more than one specialty.
• The Chinese version of the Code of Practice for Registered Chiropractors is a translation. Its cover declares that where the meaning differs from the English original, the English text governs. This article quotes its Chinese original having checked it against the English text; the divergence between 「物理治療程序」 and "physiological therapeutic procedures" in the last paragraph of Part II is flagged in the body, and this article reads that paragraph on the English text.
• For the sentence about the training requirement, what this article quotes is the English original of the Physiotherapists Board's "First-contact Physiotherapist" page, with its own rendering. That page has a Chinese version, but the source record this article relies on did not preserve the Chinese original of that sentence, and this article will not quote a Chinese rendering of its own as though it were the Board's Chinese original. This article makes no statement about the corresponding wording in that page's Chinese version.
• The "last revision date" on the Physiotherapists Board's website is a site-wide date, not a per-page date. The footer date on every page of that site (including "First-contact Physiotherapist", "Registration Requirements" and the register pages) is filled in from the same site-wide shared file, currently 30 June 2026. So this article can only say "the footer date on that site is 30 June 2026", not "that page was revised on that date". The Chinese on that site inserts a space between every character, which this article removes when quoting; that is noted here once for all.
• The figures of 1,293 and 58 in the Primary Care Directory are both practice records, not people, and this article has not de-duplicated them. The directory is submitted by service providers themselves and is not a statutory register. Both figures are live search results from 3 August 2026 and will change as the data is updated.
• "0 first-contact physiotherapy service records in the private category" is a statement about that directory, not a statement about whether the private market has first-contact physiotherapists.
• "0 records in the Hospital Authority category" says nothing at all about first-contact services, because that category itself returns 0 records on an eighteen-district search with no service filter; with no district filter at all, the category has 4 records.
• This article lists no red flag symptoms and no urgency stratification. The reason is in the body; for each source's own list and time limits, see this site's dedicated article on back problems.
• The Primary Healthcare Commission's clinical guideline for first-contact physiotherapists has no Chinese version (the document's own English name appears in the body and in the sources below). There is not one Chinese character within its 55 pages. This article quotes its English original, always placing any Chinese rendering outside the quotation marks and identifying it as this article's own; the document's name is likewise cited in its English original.
• This article does not quote that guideline's red flag stratification table (Table 3.1) or its various time limits. The reason is in the body.
• This article has not verified whether the Primary Healthcare Commission has published clinical guidelines for the purposes of section 6(2)(b) beyond knee osteoarthritis and low back pain. Section 6(6) allows four reference authorities — the Department of Health, the Hospital Authority, the Primary Healthcare Commission and the Chinese Medicine Hospital of Hong Kong — to publish clinical guidelines; this article has read only the Primary Healthcare Commission's.
• This article makes no comparison of the effectiveness of the three professions. Every source it relies on is an ordinance, a professional code or a registration body's page; not one is a study of effectiveness.

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#Disclaimer

免責聲明 本文僅供一般資訊用途，並不構成醫療建議。如需診斷或治療，請諮詢合資格的香港註冊醫生。

Disclaimer This article is for general information only and does not constitute medical advice. Consult a qualified Hong Kong-registered doctor for diagnosis or treatment.

免责声明 本文仅供一般信息用途，并不构成医疗建议。如需诊断或治疗，请咨询合资格的香港注册医生。

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#Sources

• Medical Registration Ordinance (Cap. 161), authentic Chinese and English texts (section 28(1), title offences; sections 28(2)(a) and (b), unregistered practice offences and penalties; sections 28(3)(d) and (f), exemptions; section 28(5), "treatment" includes the diagnosis required for the giving of treatment; section 32, treatment of diseases of the eye, and the exceptions in section 32(1A)), Hong Kong e-Legislation: https://www.elegislation.gov.hk/hk/cap161 (consolidated version date: 18 June 2026; retrieved: 3 August 2026)
• Allied Health Professions Ordinance (Cap. 359), authentic Chinese and English texts (section 1(1), short title, and its amendment by section 4 of Ordinance No. 33 of 2025; Schedule 1, item 3, definition of physiotherapist and item 4, definition of occupational therapist; section 13A, limited registration (with section 13A(7)(b)), section 13B, temporary registration (with section 13B(8)(b)), section 15, provisional registration; section 16(1), registered person not to practise without a practising certificate; section 18, display of the certificate of registration, section 19, premises, section 20, carrying on business through a company; section 21(1); section 21A), Hong Kong e-Legislation: https://www.elegislation.gov.hk/hk/cap359 (consolidated version date: 1 January 2026; retrieved: 3 August 2026)
• Physiotherapists (Registration and Disciplinary Procedure) Regulation (Cap. 359J), authentic Chinese and English texts (section 3, parts of the register; section 5, rules for inclusion in each part; sections 6(1) and (2), the referral requirement and the four exception routes; section 6(3), duty to comply with the clinical guideline; section 6(4), duty to comply with the guidance published by the Primary Healthcare Commission for a cross-disciplinary collaboration arrangement; section 6(5), supervision of Part II physiotherapists; section 6(6), definitions of "clinical guideline" and "reference authority"), Hong Kong e-Legislation: https://www.elegislation.gov.hk/hk/cap359J (consolidated version date: 1 January 2026; amendment notes: sections 159, 161 and 162 of Ordinance No. 33 of 2025; retrieved: 3 August 2026)
• Chiropractors Registration Ordinance (Cap. 428), authentic Chinese and English texts (long title; section 2, definition of "registered chiropractor"; sections 23(1), (3) and (4), title and business requirements; section 24, offences and penalties), Hong Kong e-Legislation: https://www.elegislation.gov.hk/hk/cap428 (consolidated version date: 1 July 2022; retrieved: 3 August 2026)
• Allied Health Professions (Amendment) Ordinance 2025 (Ordinance No. 33 of 2025) (section 4, the renaming; section 27, adding section 21A; section 188, amending section 28(3)(d) of Cap. 161) — the amending ordinance's Chinese name retains the former title; see the amendment notes to the provisions of Cap. 359 and Cap. 161 listed above
• Physiotherapists Board (Allied Health Professions Council), "First-contact Physiotherapist" (the first-contact physiotherapist-patient relationship; the duty to pass a case on "whether or not the patient holds a referral letter"; the training requirement — the English version of that page states that a physiotherapist must complete an accredited course before providing services under sections 6(2)(a), 6(2)(b) and/or 6(2)(c), and this article quotes the English original with its own rendering; the Part Ia/Ib enrolment requirements and the 2 000-hour statutory declaration; the free oath-taking service of the Department of Health and the Home Affairs Department; submitting proof of training to the Primary Healthcare Commission to update the Primary Care Directory): https://www.ahp-council.org.hk/pt/tc/content.php?page=fcp and the English version https://www.ahp-council.org.hk/pt/en/content.php?page=fcp (site footer date: 30 June 2026, a site-wide date; retrieved: 3 August 2026)
• Physiotherapists Board, "Registration Requirements" (that page's formulation that the register is divided into two parts; the "recognised experience" distinction between Parts Ia and Ib; provisional registration in Part II closed on 30 September 1997): https://www.ahp-council.org.hk/pt/tc/content.php?page=reg_quareg (site footer date: 30 June 2026, a site-wide date; retrieved: 3 August 2026)
• Physiotherapists Board, "List of Registered Persons" and registration summary (Part Ia 3,955; Part Ib 1,594; total 5,549; the "practice restriction" column prints "-"; nobody registered in Part II): https://www.ahp-council.org.hk/pt/tc/content.php?page=reg_reg , https://www.ahp-council.org.hk/hkifd/summary.php?search=PT&lang=zh , https://www.ahp-council.org.hk/hkifd/browse.php?search=PT1&lang=zh and https://www.ahp-council.org.hk/hkifd/browse.php?search=PT2&lang=zh , list index page https://www.ahp-council.org.hk/pt/tc/html/srh.html (the sentence 「沒有物理治療師在註冊名冊第II部分內註冊」 is on this page) (site footer date: 30 June 2026, a site-wide date; retrieved: 3 August 2026)
• Chiropractors Council, "List of Registered Persons" (361 registered chiropractors; registration numbers and Chinese and English names published item by item): https://www.chiro-council.org.hk/tc/content.php?page=reg_reg and the list page https://www.chiro-council.org.hk/hkifd/browse.php?search=CC&lang=zh (page updated: 30 June 2026; retrieved: 3 August 2026)
• Chiropractors Council, Code of Practice for Registered Chiropractors, Chinese version (Part I preamble, including "not a comprehensive code of professional ethics", "the Code is not a legal document" and "Chiropractic — a brief history"; Part II, the scope of chiropractic; paragraph 11.1, referral; Appendix A, paragraph 4, titles): https://www.chiro-council.org.hk/file/pdf/CC%20Code%20of%20Practice_Jan_2017%20(Chin).pdf and the English version https://www.chiro-council.org.hk/file/pdf/CC%20Code%20of%20Practice_Jan_2017%20(Eng).pdf (the Council's website marks it as effective from January 2017; the Chinese cover declares the English text to govern; retrieved: 3 August 2026)
• Primary Healthcare Commission, Clinical Guideline for First-contact Physiotherapists on Assessment and Cross-disciplinary Management Approach for Common Musculoskeletal Problems in Primary Care Setting (paragraph 3.1.18, regular review during treatment and the duty to stop treatment and refer at once on deterioration or red flag symptoms; paragraph 3.1.19, the 10-session/30-day limit; paragraph 3.1.20, referral where the condition has not improved after the course; paragraph 3.1.21, sending a patient who could benefit further back to a doctor for review; paragraphs 3.2.9 to 3.2.11, the two-condition restriction, the route it belongs to, and handling more than one condition at once): https://www.healthbureau.gov.hk/phcc/rfs/assets/pdf/home/discipline-based_guidelines/clinical_guideline_on_first_contact_assessment_and_cross-disciplinary_management_approach_for_common_msk_problems.pdf (the document itself: First published: Dec 2025; 55 pages in all; no Chinese version; retrieved: 3 August 2026)
• Health Bureau, VHIS Certified Plan Policy Template (Standard Plan benefit schedule, note (2), "proof of recommendation"; the three benefit items (d), (i) and (k) to which note (2) is attached): Chinese version https://www.vhis.gov.hk/doc/tc/information_centre/c_standard_plan_template.pdf , English version https://www.vhis.gov.hk/doc/en/information_centre/e_standard_plan_template.pdf (version date printed on the document: 1 July 2022; retrieved: 3 August 2026)
• Medical Council of Hong Kong, "Registration Requirements" (the five registration categories of the General Register; the Specialist Register; the lists published on the Council's website and in the Government Gazette): https://www.mchk.org.hk/tc_chi/registration/registration_requirement.html (retrieved: 3 August 2026)
• Medical Council of Hong Kong, Code of Professional Conduct for the Guidance of Registered Medical Practitioners, Chinese version (paragraph 17.1, referring patients): https://www.mchk.org.hk/tc_chi/code/files/Code_of_Professional_Conduct_(Chinese_Version)_2022.pdf (revised October 2022; retrieved: 3 August 2026)
• Health Bureau, Primary Care Directory — physiotherapist advanced search (the "First-contact Physiotherapy Service" filter; eighteen-district search results of 1,293 and 58 records; by practice category 1,002 / 276 / 15 / 0; service provider categories limited to the five of Chinese medicine practitioners, dentists, doctors, occupational therapists and physiotherapists; the sentence about patients having to obtain a doctor's referral first; the footer last-updated date): https://apps.pcdirectory.gov.hk/Public/TC/AdvancedSearch?ProfID=RPT (footer last-updated date: the first of July 2022; retrieved: 3 August 2026)
• Government press release, "Arrangement for registered Chinese medicine practitioners to refer patients for allied health services takes effect" (the Allied Health Professions (Amendment) Ordinance 2025 came into operation on 25 July 2025 and renamed Cap. 359; the Council passed the codes of practice for radiographers, medical laboratory technologists, physiotherapists and occupational therapists, effective 11 December 2025; ⚠ the release still uses the old name 「輔助醫療業管理局」): https://www.info.gov.hk/gia/general/202512/11/P2025121100448.htm (11 December 2025; retrieved: 3 August 2026)
• Government press release (the duty to refer on warning symptoms): https://www.info.gov.hk/gia/general/202503/19/P2025031900427.htm and the English version https://www.info.gov.hk/gia/general/202503/19/P2025031900434.htm (19 March 2025; retrieved: 3 August 2026)
• Finucane LM, et al. International Framework for Red Flags for Potential Serious Spinal Pathologies. J Orthop Sports Phys Ther 2020;50(7):350-372 (for most red flags there is no high-quality evidence of diagnostic accuracy) (PMID 32438853)

This article is written from the sources listed above; information date: 3 August 2026. It is general information and does not constitute medical advice. Decisions about individual diagnosis, imaging, drugs and surgery are for a doctor.