This article is produced by CMS Holborn Asia, a formal law alliance between CMS Singapore and Holborn Law LLC.

In line with Singapore's Smart Nation initiative of strategic deployment of technology across the nation, Singapore is updating its healthcare regulation environment. The Singapore Ministry of Health (“MOH”) has announced that the current Private Hospitals and Medical Clinics Act (“PHMCA”) will be replaced by a new Healthcare Services Bill (“Bill”) in the second half of 2018.

Key Changes

The key changes proposed by the Bill include:

  1. Wider Scope –The regulatory scope will include healthcare services, allied health and nursing services, traditional medicine, and complementary and alternative medicine.
  2. Services-based Licensing - Traditionally, almost all healthcare services were provided from physical “brick-and-mortar” locations. Pursuant to the Bill, healthcare providers will be licensed based on the type of services they provide, which will cover telemedicine.
  3. National Electronic Health Record (“NEHR”) – NEHR is a platform that brings together patient records such as their medication and laboratory reports from different care providers. The information is shared across providers. The Bill will require that licensees like healthcare institutes, contribute patient data to the NEHR on a compulsory basis.
  4. Enhanced safety for vulnerable patients – The Bill will impose restrictions on licensees employing staff to work in healthcare services that cater to frail or vulnerable patient groups.
  5. Updated penalties – Under the Bill, the maximum fine will be raised from SG$20,000 to SG$100,000, while the jail term will remain unchanged at 24 months.


It is anticipated that the Act following the Bill will be implemented in three phases:

  • Phase 1 (From December 2019), existing PHMCA medical and dental clinics, as well as clinical laboratories will come under the new legislation.
  • Phase 2 (From June 2020), all PHMCA-licensed hospitals and nursing homes will come under the new legislation.
  • Phase 3 (From December 2020), new services such as Telemedicine and Sterile Pharmaceutical services etc. that have not been regulated under PHMCA will come under the new legislation.

Current Status

There is currently a public consultation on the Bill, which will take place from 5 January 2018 to 15 February 2018. Please refer to the MOH’s website for more details.


We welcome the regulatory developments, which are necessary to keep pace with the healthcare digital revolution. Although there may be challenges in the area of data security, to ensure consistent quality of care and enabling the private and public sectors to coexist in a future-ready way, we believe this is a bold step by a forward-looking regulator, which will engender opportunities for innovation.