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Under the Swimming Pools Regulation (Cap. 132CA), any Hong Kong pool that the public can use, or that is operated by a club, institution, association or other organisation, must hold a swimming pool licence from the Director of Food and Environmental Hygiene. The only exemption FEHD publishes is a pool serving not more than 20 residential units with no public access — so almost every estate clubhouse, hotel and club pool is a licensed pool. The licence comes with working obligations: the plant must be able to hold the water to a bacteriological and clarity standard at all times, pH must sit between 7.0 and 7.8 with free residual chlorine of at least 1 ppm while bathers are in the water, chlorine and pH must be tested every day with the results recorded in a register and displayed at the entrance, and lifeguard and operating records must be kept ready for inspection.
Swimming pools in Hong Kong sit under the Swimming Pools Regulation (Cap. 132CA), made under the Public Health and Municipal Services Ordinance. FEHD's application guide states the rule plainly: no person may establish or maintain a swimming pool, or take any part in its management, except under and in accordance with a licence granted by the Director of Food and Environmental Hygiene.
Which pools does that catch? FEHD's licensing guide defines the licensable pool as any artificially constructed pool used for swimming or bathing to which the public have access (whether on payment or otherwise) or which is operated by any club, institution, association or other organisation. There is one published exemption: a pool that serves not more than 20 residential units and to which the public have no access.
Read those two sentences together and the practical answer for most building managers is short: a clubhouse pool in an estate of more than 20 units, a hotel pool, a private club pool — these are licensed pools. The licence application itself goes to an FEHD Licensing Office on form FEHB 105, with plans approved before issue, a letter of requirements to comply with, and a verification inspection before the licence is granted.
Before a licence is issued, FEHD must be satisfied that the pool's filtration or purification plant is capable of maintaining the purity of the water at all times. The guide's licensing requirements spell the standard out:
FEHD's guide notes that the applicant can demonstrate this capability with a pool water test report issued by an accredited laboratory — which is exactly the kind of evidence worth continuing to collect after the licence is issued, not just once to obtain it.
The plant must also turn the water over: circulation through the filtration system, or renewal from source, at least once every 4 hours for a covered pool and once every 6 hours for an open-air pool. Alongside the water standard sit physical requirements — non-slip sidewalks, footbaths and showers positioned so bathers must pass through them, sanitary fitments, depth markings, and a 200-lux lighting system where the pool is used after sunset — all listed in the same FEHD guide.
Once the pool is operating, the licence conditions published in FEHD's guide set the numbers the operator has to hold and prove:
| Obligation | What FEHD's published conditions say |
|---|---|
| Free residual chlorine | Not less than 1 ppm at all times bathers are using the pool, where chlorine compounds disinfect the water; not less than 0.5 ppm where chlorine supplements disinfection by ozone |
| pH | Not less than 7.0 and not more than 7.8 |
| Testing | Pool water tested daily for free residual chlorine and pH; a water testing kit kept on site for use |
| Register | A register kept recording the results of the daily tests |
| Display | The day's chlorine and pH results, and the relevant standards, displayed on a notice board at the pool entrance, facing bathers and unobstructed |
| Storage tank | Where a water storage tank fills the pool, its inside thoroughly cleansed every three months while the pool is in use |
| Fatal incident | Any fatal drowning reported to FEHD on the prescribed form within 2 working days |
Two things are worth noticing. First, the chlorine and pH duties are continuous — the condition says "at all times during which the pool is in use by bathers", not "at the morning test". A pool that passes at 9 am and drifts below 1 ppm by mid-afternoon is off-condition. Second, the licence band of pH 7.0–7.8 is slightly wider than the 7.2–7.8 that international guidance recommends for effective chlorination — run the pool at 7.2–7.6 and you satisfy both at once. Why the pH matters so much to what your chlorine actually does is covered in pool water balance: pH, alkalinity and hardness.
Conditions are per pool. FEHD's guide is explicit that licensing staff may stipulate non-standard requirements and conditions case by case, on top of the main ones summarised here. Your own licence and letter of requirements are the final word for your pool — keep both where the duty manager can find them.
The licence also fixes a minimum number of qualified life-saving attendants who must be at the pool edge, facing the water, whenever the pool is open to bathers. Under the conditions in FEHD's current guide, the licensee must verify each attendant's identity and Pool Lifeguard Award before engaging them, keep a signed daily duty log for every attendant, record the pool's opening hours each day, and retain all of these records for at least 90 days, available on demand to FEHD. A notice stating the minimum lifeguard number, in English and Chinese, and a board showing the on-duty lifeguards' names and photographs, must be displayed at the entrance.
Enforcement is not theoretical. The government told the Legislative Council in 2023 that FEHD inspects licensed pools monthly while they are open. And the published conditions set an escalation ladder for lifeguard breaches: immediate closure until the shortfall is fixed; a 6-month licence suspension after two breaches within 12 months; cancellation after three.
For an estate or clubhouse manager, the licence turns into a filing discipline. This is the folder we suggest a duty manager should be able to produce on request — the first five items are drawn directly from the published licence requirements and conditions; the last two are good practice that makes the rest defensible:
Notice the shape of the licence: a standard the water must hold, a daily test that proves it, a register that records it, and documents an inspector can ask for. Compliance is not one product — it is chlorine and pH-correction chemicals arriving before the drum runs dry, a test regime that catches drift before the notice board does, and paperwork that agrees with itself.
That is how we structure pool work for managed buildings: chlorine tablets and sodium hypochlorite supplied locally, scheduled water testing with samples analysed by a HOKLAS-accredited independent laboratory, and a dated, plain-language report after every visit that can be filed alongside the daily register. For the estate context — where the same committee also owns fresh water tanks and cooling plant — see water treatment for estates & pools.
Almost always, yes. Under the Swimming Pools Regulation (Cap. 132CA), a pool to which the public have access, or which is operated by a club, institution, association or other organisation, must be licensed by the Director of Food and Environmental Hygiene. The only exemption FEHD publishes is for a pool that serves not more than 20 residential units and to which the public have no access — a bar that virtually every estate clubhouse pool exceeds.
FEHD's licensing conditions require the pool water to be tested every day for free residual chlorine and pH, with a register kept of the results and the day's readings displayed on a notice board at the pool entrance. The pool's filtration or purification plant must also be capable of holding the water to a bacteriological and clarity standard at all times, and FEHD accepts an accredited laboratory's pool water test report as evidence of that capability.
Free residual chlorine of not less than 1 part per million at all times bathers are using the pool, where chlorine compounds disinfect the water — or not less than 0.5 part per million where chlorine supplements disinfection by ozone — with pH held between 7.0 and 7.8. The exact figures for your pool are set in your own licence conditions, so read those first.
Apply to an FEHD Licensing Office on form FEHB 105. FEHD approves the plans before issue, sends a letter of requirements to comply with, and carries out a verification inspection before the licence is granted. It must also be satisfied that the filtration or purification plant can hold the water to the bacteriological and clarity standard at all times — a pool water test report from an accredited laboratory is accepted as evidence.
E. coli absent in 100 ml, a total bacteria count not exceeding 200 per ml (48-hour plate count at 37 °C), turbidity not exceeding 5 NTU and colour not exceeding 5 Hazen units — with the plant turning the water over at least once every 4 hours for a covered pool or every 6 hours for an open-air pool. In operation, free residual chlorine must stay at not less than 1 ppm while bathers are in the water, with pH between 7.0 and 7.8.
The government told the Legislative Council in 2023 that FEHD inspects licensed pools monthly while they are open. Lifeguard breaches carry an escalation ladder: immediate closure until the shortfall is fixed, a 6-month licence suspension after two breaches within 12 months, and cancellation after three.
We supply the chemicals, arrange testing through a HOKLAS-accredited independent laboratory, and write plain-language reports you can file next to the daily register.