
One Dentist, One APC: Modernise Locum Regulations for Malaysian Dentists
The Issue
A registered dentist does not suddenly become less qualified, less competent or less safe simply because they practise at a different registered dental clinic.
Yet under the current APC framework, a dentist holding a valid Annual Practising Certificate may still be unable to provide locum cover at another clinic simply because that particular clinic is not listed in their APC.
This needs to be reviewed. Private dental practice has evolved.
Today, many dentists work across multiple clinics. Some practise primarily as locums or freelancers. Others provide cover when a colleague is sick, on emergency leave, attending training, or when another branch is unexpectedly short of manpower.
However, the current APC framework still requires practising locations to be individually tied to the practitioner.
This is not merely an inconvenience for dentists or clinic owners.
It can affect patients too.
When a clinic suddenly loses its dentist, finding a qualified locum is already difficult. Requiring that locum to also have that specific clinic listed in their APC further limits the available pool of dentists who can step in.
The result can be cancelled appointments, delayed treatment, reduced operating hours and disruption to continuity of care. Even when registered and qualified dentists are available and willing to provide cover.
This raises an important question:
What additional patient-safety objective is achieved by requiring every clinic where a dentist performs locum work to be individually incorporated into that dentist’s APC?
The dentist is already registered with the Malaysian Dental Council.
The dentist already holds a valid APC and remains professionally accountable.
The dental clinic itself is also required to be properly registered and regulated.
If the purpose is accountability and traceability, there should be a more practical way of achieving the same objective.
We are therefore calling for a review of the current APC framework for locum dental practice.
We ask the Ministry of Health and Malaysian Dental Council to develop a practical mechanism that allows dentists with a valid APC to provide locum services across multiple registered dental clinics, without requiring every clinic to be incorporated into their APC beforehand.
This could involve a simplified digital registration, notification or declaration system, or another mechanism deemed appropriate by the regulators.
The specific mechanism can be developed through consultation with regulators, professional bodies and dental practitioners.
But the principles should remain clear:
Patient safety must be protected.
Practitioners must remain accountable.
Locum practice must remain traceable.
And patients’ access to dental care should not be unnecessarily disrupted by administrative processes.
This is not a call for deregulation.
It is a call to modernise regulation so that it continues to protect the public while reflecting the realities of dental practice today.
When both the dentist and the dental clinic are legitimate, registered and properly regulated, there should be a practical pathway for that dentist to provide locum care when patients need it.
If you believe Malaysia’s dental regulations should remain robust while becoming more practical, proportionate and patient-centred, please support this petition.

2,521
The Issue
A registered dentist does not suddenly become less qualified, less competent or less safe simply because they practise at a different registered dental clinic.
Yet under the current APC framework, a dentist holding a valid Annual Practising Certificate may still be unable to provide locum cover at another clinic simply because that particular clinic is not listed in their APC.
This needs to be reviewed. Private dental practice has evolved.
Today, many dentists work across multiple clinics. Some practise primarily as locums or freelancers. Others provide cover when a colleague is sick, on emergency leave, attending training, or when another branch is unexpectedly short of manpower.
However, the current APC framework still requires practising locations to be individually tied to the practitioner.
This is not merely an inconvenience for dentists or clinic owners.
It can affect patients too.
When a clinic suddenly loses its dentist, finding a qualified locum is already difficult. Requiring that locum to also have that specific clinic listed in their APC further limits the available pool of dentists who can step in.
The result can be cancelled appointments, delayed treatment, reduced operating hours and disruption to continuity of care. Even when registered and qualified dentists are available and willing to provide cover.
This raises an important question:
What additional patient-safety objective is achieved by requiring every clinic where a dentist performs locum work to be individually incorporated into that dentist’s APC?
The dentist is already registered with the Malaysian Dental Council.
The dentist already holds a valid APC and remains professionally accountable.
The dental clinic itself is also required to be properly registered and regulated.
If the purpose is accountability and traceability, there should be a more practical way of achieving the same objective.
We are therefore calling for a review of the current APC framework for locum dental practice.
We ask the Ministry of Health and Malaysian Dental Council to develop a practical mechanism that allows dentists with a valid APC to provide locum services across multiple registered dental clinics, without requiring every clinic to be incorporated into their APC beforehand.
This could involve a simplified digital registration, notification or declaration system, or another mechanism deemed appropriate by the regulators.
The specific mechanism can be developed through consultation with regulators, professional bodies and dental practitioners.
But the principles should remain clear:
Patient safety must be protected.
Practitioners must remain accountable.
Locum practice must remain traceable.
And patients’ access to dental care should not be unnecessarily disrupted by administrative processes.
This is not a call for deregulation.
It is a call to modernise regulation so that it continues to protect the public while reflecting the realities of dental practice today.
When both the dentist and the dental clinic are legitimate, registered and properly regulated, there should be a practical pathway for that dentist to provide locum care when patients need it.
If you believe Malaysia’s dental regulations should remain robust while becoming more practical, proportionate and patient-centred, please support this petition.

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Petition created on 1 November 2026