Under HCSA, the licensee may be the corporate entity or a natural person (e.g., CEO of the licensable healthcare service). There is no restriction on who may be appointed as the licensee, nor is there any requirement for the licensee to have clinical expertise.

For example, an acute hospital may appoint its CEO as the licensee, or the licence may be held by the corporate entity (e.g., company) that owns the acute hospital. This similarly applies to other services, such as a medical clinic group, a clinical laboratory or a nursing home. In a much simpler business set-up, such as a solo GP clinic, the licensee may be the sole doctor who owns and practises at the clinic.