“Enhancing the Teacher Registration Mechanism through Amendments to the Education Ordinance (Cap. 279)”
“Enhancing the Teacher Registration Mechanism through Amendments to the Education Ordinance (Cap. 279)”
Our Recommendations
Executive Committee
The Hong Kong Association of the Heads of Secondary Schools (HKAHSS)
6th February 2026
[The Executive Committee has written to all Legislative Council members on 5th February 2026. Copies were also sent to:
Convenor of Non-official Members of the Executive Council;
Secretary for Education; and
Chair and members of the Education Coordination Committee.]
The Hong Kong Association of the Heads of Secondary Schools, upholding professionalism, has consistently made recommendations to the HKSAR Government on education development and talent cultivation. In response to the discussion paper submitted by the Education Bureau (EDB) to the Legislative Council Panel on Education on 6th February 2026, regarding “Enhancing the Teacher Registration Mechanism through Amendments to the Education Ordinance (Cap. 279),” the Executive Committee of the HKAHSS recognizes the principle mentioned in Item 9 of the discussion paper: “Strike a balance between upholding the requirements expected of the education profession and meeting the actual operational needs of schools, with a view to ensuring that the implementation details are reasonable and conducive to achieving the objectives.” We raise the following concerns and opinions on the discussion paper in the hope of assisting in the enhancement of the amendments to the Ordinance.
1. Purposes
4.
Introduce the practising certificate and regular renewal requirements, so as to ensure that all school teachers in Hong Kong are fit and proper persons, thus upholding the professionalism of the teaching force.
8.
To enhance teachers’ professionalism: In line with the registration mechanisms of other professions, the new mechanism will enhance the society’s recognition of the education profession and raise the social status of teachers.
The HKAHSS agrees with the purposes and direction of the amendments to the Ordinance and hopes that teachers’ professionalism and status can be enhanced through the regular renewal of teacher registration and practising certificate.
2. Main Recommendations
2.1 Application and Verification of Practising Certificate:
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Persons who apply for a practising certificate must meet the following requirement: Being employed by a school as its teacher;
15.
The EDB will draw up guidelines on application for practising certificate, enabling applicants and schools to fully understand the application procedures, the documents required, the application fee, the vetting time, notification of application results, etc.
2.1.1
According to the discussion paper, persons who apply for a practising certificate must be “employed by a school as its teacher”. Does it mean that those who are not currently employed by schools but meet the requirements for teachers’ registration cannot apply for teaching positions with practising certificate? Taking the legislation of the Nursing Council of Hong Kong as reference, the practising certificate serves as proof of the applicant’s legal practice in Hong Kong. At the time of application, proof of holding valid registration is only required and pay the relevant fee. Individuals already listed in the register of the Nursing Council of Hong Kong can apply for the practising certificates regardless of their employment status. Similarly, the current Certification for Principalship is also of the same practice. Being employed by a school as principal is not a prerequisite for obtaining the Certification for Principalship.
2.1.2
Regarding the application procedure, it is recommended that the effective practices of other professions in Hong Kong can be taken as reference. In line with the digital development of the HKSAR Government, it is recommended that teachers submit applications and upload the required documents through an electronic platform (such as “iAM Smart+”), thereby simplifying the administrative work.
2.1.3
If schools must play a significant role in the “application procedures”, i.e. schools need to regularly “renew the practising certificate” for a certain number of in-service teachers at the end of each school year. There is great concern regarding the potential confusion that might arise during the implementation of this legislation, as there is no detail about the relevant procedures in the current discussion paper. If all schools need to renew the practising certificate for the in-service teachers each year from May to August while simultaneously applying for the teacher registration together with practising certificate for the newly-recruited teachers, do schools and the relevant government department have sufficient administrative capacity to handle a huge volume of applications, allowing teachers to be verified as teachers with practising certificate by 1st September?
2.1.4
The HKAHSS recommends that there will be a transition period before the Ordinance takes effect, allowing various types of schools to have ample time to refine the relevant school policies and administrative procedures. This can also allow teachers to try the electronic platform system and the EDB to handle different issues.
2.2 Validity Period and Effective Date of Practising Certificate:
2.2.1
The discussion paper states that individuals applying for practising certificate “would be required to meet the target of achieving 150 hours of CPD every 3 years”. Thus, its key proposal for the validity period of the practising certificate is also 3 years. We suggest taking the validity period of five years for the Certificate for Pincipalship as reference. Adopting the same practice for the practising certificate for the education sector for 5 years can reasonably explain the principle and appropriately adjust the workload for the administrative work.
2.2.2
If applicants for practising certificate are required to “meet the target of achieving 150 hours of CPD every 3 years”, to ensure smooth and reasonable operation of the system, the validity period of practising certificates should be set for more than 3 years. Otherwise, applicants may only have less than 36 months to complete the target of their professional development, affecting them to renew the certificate before the expiry date of their practising certificate.
2.2.3
The current requirement of 150 hours of continuous professional development within a three-year cycle is a “soft target”. If the requirement is modified to a “hard target”, sufficient time must be provided to enable teachers to meet the continuous professional development requirements before the Ordinance takes effect. Moreover, consideration should be made to minimize the impact on student learning and teacher deployment.
2.3 Requirements for Compliance with the Designated Continuous Professional Development (CPD):
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As regards the requirements on CPD, apart from setting a soft target of 150 hours of CPD in each three-year cycle for teachers, from the 2020/21 school year onwards, the EDB has developed a training framework for newly-joined teachers, in-service teachers and those aspiring for promotion, under which in-service teachers are required to spare a minimum of 30 hours in each three-year cycle to take part in core training under two categories, namely Teachers’ Professional Roles, Values and Conduct and Local, National and International Education Issues, with not less than six hours spent on each category. With reference to this arrangement, the EDB proposes that in-service teachers would be required to meet the target of achieving 150 hours of CPD every three years for fulfilling the application criteria for a practising certificate.
2.3.1
The report by the Teacher Education and Teacher Quality Advisory Committee in 2003 states that “the teaching profession is a profession which takes learning as the core”. Teachers must continuously engage in professional development, reflection, research, and further education, and their professional growth should balance both quality and quantity. At present, the two core training areas, which are “Teacher Professional Roles, Values, and Conduct” and “Local, National, and International Education Issues”— have already laid a solid foundation for teachers’ professional development. In the future, activities promoting professional learning communities and teaching innovations (such as lesson observations post-lesson discussion, educational research, lesson studies) can be included and counted as the professional development hours.
2.3.2
Continuous professional development will be revised from the current “soft target” to “”hard target”. Therefore, the EDB must establish operational system and principles to clearly state which continuous professional development activities/courses can be counted toward the required hours. Moreover, a “specific application program” should be set up for in-service teachers to record, calculate, and verify training hours, making it easy for teachers to input attendance information and upload proof. If relevant work requires verification from schools, the EDB should specify clearly the verification principles, the calculation of CPD hours, etc.; and streamline the relevant administrative work to minimize the impact on school operation and student learning.
2.3.3
To balance teachers’ continuous professional development and the impact of day-time in-service training on student learning, it is recommended that the EDB continues to provide more online courses and accept the relevant courses provided by other institutions. The EDB also needs to consider the number of days, time, and dates of in-service training courses, as well as the planning and the schedule of mainland study tours, allowing teachers to flexibly arrange professional training based on personal needs and interests, thereby reducing the impact of hiring substitute teachers on student learning.
2.3.4
The EDB must provide sufficient quotas for the training courses, allowing teachers to meet the required hours of continuous professional development. Taking the requirements of the “three-tier course” for catering for students with special educational needs in the EDB Circular No. 10/2021 as an example, at present, schools actively arrange for teachers to attend the courses annually, but some of them are not admitted because of the quota. The same situation also appears for the online courses.
2.3.5
It is recommended that the EDB establishes a mechanism for discretionary consideration for teachers who are unable to meet the continuous professional development requirements due to personal reasons, such as long-term sick leave or maternity leave.
2.4 Declaration of Criminal Convictions in the Past Three Years:
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Persons who apply for a practising certificate must meet the following requirement: Declare whether they have been convicted of any criminal offences in the past three years;
2.4.1
To enhance the protection of students’ welfare, the HKAHSS agrees that applicants should declare any criminal convictions within the past three years, both locally and overseas.
2.4.2
Regarding this requirement, it is recommended that the EDB provides clearer explanation. For instance, if a teacher commits a criminal offence unrelated to teaching, such as being charged under the Road Traffic Ordinance, does that disqualify him/her from applying for a practising certificate?
2.5 Definition of “Ordinarily Reside in Hong Kong”:
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According to the definition of “ordinary residence” as stated on the website of the Immigration Department (https://www.immd.gov.hk/eng/services/roa/term.html), a person has ordinary residence in Hong Kong if he/she remains in Hong Kong legally, voluntarily and for a settled purpose (such as for education, employment or residence), whether of short or long duration. Under this definition, the factors for consideration include the reason, duration and frequency of any absence from Hong Kong; whether he/she has habitual residence in Hong Kong; whether he/she is employed by a Hong Kong based company; and the whereabouts of the principal members of his/her family.
2.5.1
Regarding this requirement, it is recommended that the EDB provides a clearer explanation. For instance, for individuals who commute daily from the Greater Bay Area, do they meet the requirement of ordinarily residing in Hong Kong?
2.6 Training Arrangements for the Daily-rated Supply Teachers with a Longer Appointment Term and those who Re-join the Teaching Profession:
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According to EDB’s records, there are currently more than 160 000 RT, with about 70 000 teachers teaching in publicly-funded schools, private schools, international schools and kindergartens. The rest are mainly individuals who have attained retirement age, left the teaching profession or had no appointment records in schools.
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In meeting the schools’ actual operational needs, the EDB proposes that short-term supply teachers, who are employed for not more than 30 school days within a 12-month period, shall be exempt from the practising certificate requirement.
As for daily-rated supply teachers with a longer appointment term and those who re-join the teaching profession, the EDB will explore training programmes for them to meet relevant requirements.
Those who join the teaching force immediately upon graduation will be considered to have met the CPD requirements by the EDB.
2.6.1
Currently, hiring quality substitute teachers is challenging; if long-term substitute teachers are required to hold a practising certificate, the EDB must promptly propose specific training measures to enable those who have reached retirement age, non-active teachers, and those wishing to return to the education sector to meet the practising certificate application requirements. For example, creating e-Services accounts for them to enrol in courses, or providing course training and recording system through the Hong Kong Education City.
2.6.2
If 30 school days within 12 months is set as the boundary for short-term and long-term substitute teachers, schools may not be able to accurately track each substitute teacher’s accumulated workdays. Moreover, it would affect the continuity of substitute work due to this requirement.
2.7 Cancellation of Practising Certificate and Appeal Mechanism:
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Teachers holding a practising certificate must meet all the requirements set out in paragraph 12 throughout its entire validity period. For teachers who are suspected of committing serious offences or professional misconduct, in case their teacher registration is to be cancelled, their practising certificates will be cancelled accordingly.
2.7.1
Apart from having their teacher registration canceled, will teachers’ application for a practising certificate be canceled, temporarily revoked, or denied for other reasons?
2.7.2
According to Section 72 of the Education Ordinance (Cap.279) concerning restrictions on entry into school premises, no person shall, without the permission in writing of the Permanent Secretary, enter or remain in any school, such as a person who has been refused registration as a manager or a teacher, or having been so registered has had his registration cancelled; a person who has been refused approval as the supervisor or principal of a school, or having been so approved has had such approval withdrawn. The EDB should clarify whether individuals whose practising certificates are cancelled or temporarily revoked are subject to the regulations of Section 72 of the Education Ordinance (Cap. 279).
2.7.3
The EDB should clarify the appeal mechanism for individuals whose practising certificate applications are denied or revoked.
2.8 Verification Mechanism for the Register of Teachers:
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The EDB will maintain a register of teachers with their names and practising certificate numbers.
2.8.1
It is recommended to establish a mechanism that complies with the Personal Data (Privacy) Ordinance, allowing teachers or relevant members of the public to access the register.
3. Consultation with the Education Sector and Work Plan
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The concerns raised by the sector are mostly about the implementation details, such as the specific CPD requirements, as well as the application procedures for a practising certificate and the implementation timeline. The EDB takes heed of their concerns and will continue to listen to and study their views carefully for formulating the specific implementation details.
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The EDB has commenced working on the amendments to the EO and will continue to consult the Department of Justice to finalise the amendments to the legislative provisions. Subject to Members’ views, we plan to introduce the amendment bill to the Legislative Council for scrutiny in the second half of 2026.
3.1
The HKAHSS believes that the key to the effective enforcement of the legislation is whether the “implementation details” can be carried out. Currently, the discussion paper only outlines the schedule for discussion in the Legislative Council, without mentioning a schedule for the consultation with the education sector, nor the target audience in “the sector”. We recommend that the HKSAR government promptly announces the consultation schedule to effectively gather and incorporate opinions from frontline principals, teachers, and stakeholders to enhance the amendments to the Education Ordinance (Cap. 279).
We hope that the Legislative Council, the Education Bureau, various sectors of the society, and the education sector can work together to refine the teacher registration mechanism. Through this revised legislation, the professional quality of the teaching team can be enhanced, and students’ welfare can be safeguarded.
