Statute Details
- Title: Healthcare Services (Fees) Regulations 2021
- Act Code: HSA2020-S1032-2021
- Legislative Type: Subsidiary legislation (SL)
- Authorising Act: Healthcare Services Act 2020 (section 57)
- Commencement: 3 January 2022
- Status: Current version (as at 27 Mar 2026)
- Key Provisions (from extract): Regulations 1–7; Schedules 1–3
- Notable Definitions: “charitable healthcare service provider”; “temporary premises”
- Primary Fee Themes: Application fees, approval fees, pro-ration, conversion/second licences, and lower fees for charitable providers
What Is This Legislation About?
The Healthcare Services (Fees) Regulations 2021 (“Fees Regulations”) set out the fee framework for licensing and regulatory approvals under Singapore’s Healthcare Services Act 2020 (“HSA”). In practical terms, the Regulations tell applicants and licensees how much they must pay when applying for a licence, renewing a licence, seeking approvals for premises or service delivery modes, and requesting approvals for specified services.
The Regulations also address special fee treatment for (i) charitable healthcare service providers and (ii) certain licensing transitions—such as converting a medical transport licence into an emergency ambulance licence, and obtaining a second licence for related services. Finally, the Regulations include rules on pro-rating fees where licences or approvals are granted for periods shorter than the standard two-year term.
Although the Fees Regulations are “about fees”, they are tightly linked to the licensing architecture in the HSA and the Healthcare Services (General) Regulations 2021. For a practitioner, the key value is that the Fees Regulations operationalise the HSA’s licensing and approval processes by specifying exact amounts and clarifying when application fees are included or excluded.
What Are the Key Provisions?
Regulation 1 (Citation and commencement) confirms the legal identity of the instrument and that it came into operation on 3 January 2022. This matters for practitioners assessing whether a fee regime applies to applications made before or after commencement, and for determining which version of the Regulations governs a particular transaction.
Regulation 2 (Definitions) is critical because fee obligations often depend on whether the applicant or licensee is a “charitable healthcare service provider”. The Regulations define that term to include a charity registered under section 7 of the Charities Act 1994, or an exempt charity under section 2(1) of the Charities Act 1994, provided it is established to provide healthcare services. The definition is therefore not merely descriptive; it is a legal gateway to preferential fee treatment under the Regulations.
Regulation 3 (Fees for general cases) is the core charging provision for most licensing and approval matters. It applies to an applicant or licensee that is not a charitable healthcare service provider at the time the application for grant or renewal is made. The Regulations then specify:
- Application fee for grant or renewal of a licence: generally $100 for each licence (subject to specific items and carve-outs).
- Additional application-fee rules: certain licence items and certain approvals for permanent premises, conveyances, or other service delivery modes also attract a $100 application fee per application, subject to exceptions.
- Approval-related amendment fees: for amendments to licence particulars or information (such as licensee name, business name, address of approved permanent premises, or registration number of an approved conveyance), the application fee payable to the Director-General is $100 per application.
- Schedule-based fees: the substantive fees for the matters listed in the First Schedule are payable to the Director-General, with the amounts determined by the “second column” of the Schedule.
- Two-year term linkage: the Schedule fees apply where the licence is granted or renewed for a period of 2 years.
- Inclusion rule: to avoid doubt, the Schedule fees (except for late renewal applications) are inclusive of the application fees mentioned in Regulations 3(2), 3(2A), and 3(2B), whichever is applicable.
From a practitioner’s perspective, the inclusion rule is particularly important for billing and compliance. It prevents double-charging by clarifying that the Schedule fees already incorporate the application fee component, except in the late renewal context.
Regulation 3A (Fees for specified services) addresses approvals to provide “specified services” under the HSA framework. For each application seeking approval to provide a specified service listed in the Third Schedule, the application fee is $100. The substantive approval fees are then payable according to the Third Schedule, and—again—those fees are linked to a two-year licence period. The Regulations also clarify that the Third Schedule fees are inclusive of the $100 application fee.
Regulation 4 (Pro-ration of fees) provides the mechanism for adjusting fees when licences or approvals are granted for periods shorter than two years. The pro-ration rules do not apply to a licensee who is a charitable healthcare service provider.
Where a licence is granted (including renewal) for a term shorter than two years, the fees payable under Regulation 3(4) (less the relevant application fee) are pro-rated based on the number of months. The pro-ration logic is extended to approvals for permanent premises, conveyances, service delivery modes, and approvals for specified services where the remaining duration of the underlying licence is less than two years at the time the approval is granted.
Regulation 5 (Conversion of licences for emergency ambulance or medical transport service) introduces a targeted fee rule for a specific regulatory scenario. The extract indicates that where a non-charitable licensee holds a medical transport licence, gives notice of intention to wholly stop providing the medical transport service, and applies during the validity of the first licence for an emergency ambulance licence that starts on the date the medical transport service stops and expires when the first licence would have expired, the fee for the grant of the converted licence is $100 regardless of the number of approved conveyances used or to be used under the first licence or the converted licence.
Even though the extract is truncated, the structure signals a deliberate policy: to avoid imposing multiple or escalating fees during a conversion that is time-aligned with the expiry of the original licence. Practitioners should therefore treat conversion applications as a distinct fee category rather than attempting to apply general Schedule fees mechanically.
Regulation 6 (Second licence for medical transport or emergency ambulance service) (not fully shown in the extract) similarly addresses situations where a licensee obtains a second licence for related services. The presence of this regulation indicates that the fee regime is not purely additive; instead, it likely provides a controlled fee outcome to reflect the regulatory relationship between the licences.
Regulation 7 (Lower fees for charitable healthcare service providers) is the preferential provision. While the extract does not reproduce the full text, its placement and the existence of the Second Schedule strongly suggest that charitable healthcare service providers pay reduced fees for the matters covered by the Second Schedule, rather than the standard fees in the First Schedule.
For practitioners, the key compliance step is to confirm charitable status at the relevant time. Regulation 3’s applicability hinges on whether the applicant or licensee is charitable “at the time the application for the grant or renewal of a licence is made”. That timing requirement can be decisive if charitable registration status changes between application and grant.
How Is This Legislation Structured?
The Fees Regulations are structured as follows:
- Regulation 1: Citation and commencement.
- Regulation 2: Definitions (including “charitable healthcare service provider”).
- Regulation 3: Fees for general cases (non-charitable providers), with detailed rules on application fees, schedule fees, inclusion, and two-year term linkage.
- Regulation 3A: Fees for specified services (application and approval fees, schedule-based amounts, and inclusion of application fees).
- Regulation 4: Pro-ration rules for licences and approvals granted for periods shorter than two years (non-charitable providers only).
- Regulations 5 and 6: Special fee rules for conversion and second licences involving emergency ambulance and medical transport services.
- Regulation 7: Lower fees for charitable healthcare service providers.
- Schedules:
- First Schedule: Fees for general cases (standard fee table).
- Second Schedule: Fees for charitable healthcare service providers (reduced fee table).
- Third Schedule: Fees for approval of specified services.
Who Does This Legislation Apply To?
The Fees Regulations apply to applicants and licensees under the Healthcare Services Act 2020, but the fee rules differ depending on whether the applicant/licensee is a charitable healthcare service provider.
In general, Regulations 3 and 4 apply to non-charitable providers, while Regulation 7 and the Second Schedule provide the lower-fee regime for charitable providers. The pro-ration rules in Regulation 4 expressly do not apply to charitable providers, indicating that charitable providers either pay fixed fees or are subject to a separate pro-ration approach under the charitable fee schedule.
Why Is This Legislation Important?
For practitioners, the Fees Regulations are important because they convert the HSA’s licensing and approval processes into a predictable fee schedule. They reduce uncertainty by specifying (i) application fees, (ii) approval fees, (iii) how fees interact with the two-year licence term, and (iv) when fees are included versus charged separately.
From a compliance and advisory perspective, the most practically significant issues are:
- Charitable status timing: fee category depends on whether the applicant/licensee is charitable at the time the application is made.
- Schedule fee inclusion: the Regulations clarify that Schedule fees are inclusive of certain application fees (except late renewal), which affects invoicing, budgeting, and dispute avoidance.
- Pro-ration mechanics: where licences or approvals are for less than two years, fees must be pro-rated based on months, with application fee deductions where specified.
- Special licensing transitions: conversion and second licence scenarios are treated differently (e.g., conversion fee of $100 in the extract), which means general fee tables may not be the correct starting point.
Finally, because the Regulations are currently amended (with amendments noted in the timeline, including amendments effective 26 June 2023 and 1 January 2025), practitioners should always verify the applicable version for the relevant application date. Fee disputes often arise from applying the wrong version or misunderstanding which fee component is already included in a Schedule amount.
Related Legislation
- Healthcare Services Act 2020 (Act 3 of 2020) — licensing and approval framework; section 57 (power to make regulations); provisions referenced in the Fees Regulations (e.g., sections 10, 11A, 11C, 15, 17).
- Charities Act 1994 — defines charities and exempt charities relevant to “charitable healthcare service provider”.
- Healthcare Services (General) Regulations 2021 (G.N. No. S 1035/2021) — referenced for the meaning of “business name”.
Source Documents
This article provides an overview of the Healthcare Services (Fees) Regulations 2021 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.