Search for:

In brief

Phase 2 of the Healthcare Services Act 2020 (HCSA) has been implemented with effect from 26 June 2023.

Under Phase 2, medical or dental healthcare providers who deliver services outside the premises of clinics and via teleconsultation will be required to hold a HCSA licence, along with service providers offering outpatient medical and dental services, nuclear medicine, and outpatient renal dialysis, among others.

In more detail

The HCSA replaces the premises-based Private Hospitals and Medical Clinics Act (PHMCA). It shifts Singapore’s healthcare system from a premises-based framework to a services-based framework.

Phase 1 of the HCSA was implemented on 3 January 2023, bringing PHMCA laboratory licensees under the HCSA’s new regulatory regime. 

Phase 2 was implemented on 26 June 2023 and will affect the majority of services currently regulated under the PHMCA. These include the following:

  1. Home medical/dental and home palliative care service providers
  2. Medical or specialist clinics that engage or employ doctors to offer teleconsultation services
  3. Telemedicine platform companies that engage or employ doctors to provide teleconsultation services
  4. Individual doctors who offer teleconsultation services in their own professional capacity
  5. Doctors or dentists who offer home medical/dental care in their own professional capacity 
  6. Medical or dental practitioners who provide services outside of permanent clinic settings

Phase 3 is expected to be implemented in late 2023 and will encompass long-term care services, including nursing home services and preventive health services such as vaccinations.

Our previous newsletter covering the Phase 1 implementation can be found here.

* * * * *


© 2023 Baker & McKenzie.Wong & Leow. All rights reserved. Baker & McKenzie.Wong & Leow is incorporated with limited liability and is a member firm of Baker & McKenzie International, a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a “principal” means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an “office” means an office of any such law firm. This may qualify as “Attorney Advertising” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.


Andy Leck is the head of the Intellectual Property and Technology (IPTech) Practice Group and a member of the Dispute Resolution Practice Group in Singapore. He is a core member of Baker McKenzie's regional IP practice and also leads the Myanmar IP Practice Group. Andy is recognised by reputable global industry and legal publications as a leader in his field. He was named on "The A-List: Singapore's Top 100 lawyers" by Asia Business Law Journal 2018. In addition, Chambers Asia Pacific notes that Andy is "a well-known IP practitioner who is highlighted for his record of handling major trade mark litigation, as well as commercial exploitation of IP rights in the media and technology sectors. He's been in the industry for a long time and has always been held in high regard. He is known to be very fair and is someone you would like to be in the trenches with you during negotiations." Furthermore, Asian Legal Business acknowledges Andy as a leading practitioner in his field and notes that he “always gives good, quick advice, [is] client-focused and has strong technical knowledge for his areas of practice.” Andy was appointed by the Intellectual Property Office of Singapore (IPOS) as an IP Adjudicator to hear disputes at IPOS for a two-year term from April 2021. He has been an appointed member of the Singapore Copyright Tribunal since May 2010 and a mediator with the WIPO Arbitration and Mediation Center. He is also appointed as a Notary Public & Commissioner for Oaths in Singapore. He previously served on the International Trademark Association’s Board of Directors and was a member of the executive committee.


Ren Jun Lim is a principal with Baker McKenzie Wong & Leow. He represents local and international clients in both contentious and non-contentious intellectual property matters. He also advises on a full range of healthcare, as well as consumer goods-related legal and regulatory issues. Ren Jun co-leads Baker McKenzie Wong & Leow's Healthcare as well as Consumer Goods & Retail industry groups. He sits on the Law Society of Singapore IP Committee and on the Executive Committee of the Association of Information Security Professionals. He is also a member of the Vaccines Working Group, Singapore Association of Pharmaceutical Industries, a member of the International Trademark Association, as well as a member of the Regulatory Affairs Professionals Association. Ren Jun is ranked in the Silver tier for Individuals: Enforcement and Litigation and Individuals: Prosecution and Strategy, and a recommended lawyer for Individuals: Transactions by WTR 1000, 2020. He is also listed in Asia IP's Best 50 IP Expert, 2020, recognised as a Rising Star by Managing IP: IP Stars, 2019 and one of Singapore's 70 most influential lawyers aged 40 and under by Singapore Business Review, 2016. Ren Jun was acknowledged by WTR 1000 as a "trademark connoisseur who boasts supplementary knowledge of regulatory issues in the consumer products industry." He was also commended by clients for being "very responsive to enquiries and with a keen eye for detail, he is extremely hands-on. His meticulous and in-depth approach to strategising is key to the excellent outcomes we enjoy."

Write A Comment