Statute Details
- Title: Pharmacists Registration (Exemption) Order 2018
- Act Code: PRA2007-S102-2018
- Legislative Type: Subsidiary Legislation (SL)
- Authorising Act: Pharmacists Registration Act (Cap. 230), section 71
- Enacting Formula / Maker: Minister for Health (after consultation with the Singapore Pharmacy Council)
- Commencement: 28 February 2018 (see section 1)
- Current Version: Current version as at 27 March 2026
- Key Provision: Section 2 (Exemption), including amendments reflected by S 576/2018 and S 402/2023
- Notable Amendment: S 402/2023 (effective 26 June 2023) aligns the exemption with the Healthcare Services (Collaborative Prescribing Service) Regulations 2023
What Is This Legislation About?
The Pharmacists Registration (Exemption) Order 2018 is a targeted exemption order made under the Pharmacists Registration Act. In plain terms, it carves out a specific category of practitioners—“collaborative prescribing practitioners”—from the operation of a particular pharmacists registration requirement, but only when they are performing defined activities within a regulated collaborative prescribing framework.
The order recognises that modern healthcare delivery often involves team-based care, where medication management may be shared among different healthcare professionals under structured agreements and regulatory safeguards. Rather than requiring every collaborative prescribing practitioner to satisfy the pharmacists registration rule in the same way as a traditional pharmacist, the exemption allows certain medication-related functions to be carried out by collaborative prescribing practitioners when they act “for and on behalf of” an approved person and in accordance with a collaborative practice agreement.
Although the order is short, its practical effect is significant: it enables collaborative prescribing services to operate without creating a registration barrier for the collaborative prescribing practitioner, provided the practitioner’s scope of work is limited to administering medication, initiating or modifying medication therapy, and managing medication therapy—each performed in the course of the collaborative prescribing service.
What Are the Key Provisions?
Section 1 (Citation and commencement) sets the legal identity and start date of the instrument. The Order is cited as the “Pharmacists Registration (Exemption) Order 2018” and comes into operation on 28 February 2018. For practitioners, this matters when determining whether conduct occurred before or after the exemption took effect.
Section 2 (Exemption) is the operative provision. The Order states that section 28(1)(a) of the Pharmacists Registration Act does not apply to a collaborative prescribing practitioner if two conditions are met.
First condition (service context and authorisation): Under section 2(1)(a), the exemption applies only where the collaborative prescribing practitioner provides a collaborative prescribing service for and on behalf of an “approved person”. The “approved person” must be (i) authorised by a licence under the Healthcare Services Act 2020 to provide a licensable healthcare service, and (ii) approved under section 11D of that Act to provide a collaborative prescribing service. This ties the exemption to an organisational and regulatory approval framework, not merely to the individual practitioner’s qualifications.
Second condition (activity scope and agreement compliance): Under section 2(1)(b), the exemption applies only if, for the purpose or in the course of providing the collaborative prescribing service, the collaborative prescribing practitioner performs specified medication-related actions in accordance with the collaborative practice agreement with the approved person. The permitted actions are enumerated:
- (i) administers medication;
- (ii) initiates or modifies medication therapy;
- (iii) manages medication therapy.
These three categories are the heart of the exemption. They define the functional boundary of what the collaborative prescribing practitioner may do without triggering the pharmacists registration rule referenced in section 28(1)(a) of the Pharmacists Registration Act. Practically, a practitioner relying on this exemption should ensure that their actual clinical tasks fall within these categories and are performed as part of the collaborative prescribing service.
Definitions and regulatory cross-references: Section 2(2) provides key definitions. It defines “approved person” by reference to the Healthcare Services Act 2020 licensing and approval requirements. It also imports definitions for “collaborative practice agreement,” “collaborative prescribing practitioner,” and “collaborative prescribing service” from regulation 2 of the Healthcare Services (Collaborative Prescribing Service) Regulations 2023. This is legally important: the exemption’s scope depends on how those 2023 Regulations define the terms, including any conditions, limitations, or procedural requirements.
Amendment history and legal alignment: The text reflects two amendment markers. The Order was originally amended by S 576/2018 (effective 17 September 2018) and later amended by S 402/2023 (effective 26 June 2023). The 2023 amendment is particularly relevant because it updates the exemption to align with the 2023 collaborative prescribing regulatory regime. For counsel advising on compliance, the amendment history signals that the legal basis and cross-references may have changed—meaning that the operative requirements for “collaborative prescribing service” and related terms should be checked against the current 2023 Regulations.
How Is This Legislation Structured?
The Order is structured in a simple, two-section format:
- Section 1: Citation and commencement. This section identifies the instrument and states when it begins to operate.
- Section 2: Exemption. This is the only substantive section and sets out the conditions under which section 28(1)(a) of the Pharmacists Registration Act does not apply to collaborative prescribing practitioners.
There are no additional parts or complex schedules in the extract provided. The legal “architecture” of the exemption is therefore achieved through cross-references: section 2 relies on the Healthcare Services Act 2020 and the Healthcare Services (Collaborative Prescribing Service) Regulations 2023 to define the relevant actors and the regulatory framework in which the exemption operates.
Who Does This Legislation Apply To?
The exemption applies to collaborative prescribing practitioners—but only in the narrow circumstances described in section 2. It does not operate as a general waiver for all non-pharmacists or all healthcare professionals. Instead, it is conditional and function-specific.
In addition, the exemption is linked to an “approved person” who must be authorised and approved under the Healthcare Services Act 2020 to provide a collaborative prescribing service. Therefore, the exemption is best understood as a three-way relationship: (1) the collaborative prescribing practitioner, (2) the approved person (the licensed and approved healthcare provider), and (3) the collaborative practice agreement and the collaborative prescribing service regulated under the 2023 Regulations.
Why Is This Legislation Important?
For practitioners and healthcare providers, the Pharmacists Registration (Exemption) Order 2018 is a compliance enabler. It allows collaborative prescribing services to function efficiently by removing a potential statutory barrier under the Pharmacists Registration Act—so long as the practitioner’s role is properly situated within the regulated collaborative prescribing framework.
From a legal risk perspective, the exemption is also a boundary-setting instrument. Because it is conditional, it creates a clear compliance checklist: the practitioner must be providing the service for and on behalf of an approved person, and the practitioner must perform only the enumerated medication-related actions in accordance with the collaborative practice agreement. If any of these conditions are not met—such as performing medication therapy tasks outside the agreement, or acting without the approved person’s authorisation—the exemption may not apply, and the underlying pharmacists registration prohibition could become relevant.
For counsel advising on structuring collaborative prescribing arrangements, the order underscores the importance of robust documentation and governance. Collaborative practice agreements should be drafted and maintained to reflect the permitted activities (administering medication; initiating or modifying medication therapy; managing medication therapy) and to ensure that the practitioner’s conduct remains within the scope authorised by the approved person and the applicable regulations. Given the 2023 amendment, practitioners should also verify that their agreements and operational processes remain aligned with the current definitions and regulatory requirements imported by section 2(2).
Related Legislation
- Pharmacists Registration Act (Cap. 230) — particularly section 28(1)(a) (the provision from which the exemption is carved out) and section 71 (the enabling power)
- Healthcare Services Act 2020 — licensing and approval framework for approved persons providing collaborative prescribing services (including section 11D)
- Healthcare Services (Collaborative Prescribing Service) Regulations 2023 (G.N. No. S 398/2023) — definitions and regulatory framework for collaborative prescribing services, including regulation 2 definitions
- Subsidiary Legislation amendments: S 576/2018; S 402/2023
Source Documents
This article provides an overview of the Pharmacists Registration (Exemption) Order 2018 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.