Telemedicine has rapidly moved from a peripheral healthcare option to a mainstream mode of medical practice in India, driven by rising digital adoption and the need for accessible, timely care. The COVID-19 pandemic accelerated this shift, prompting regulators to formally recognise remote consultations as a legitimate extension of clinical practice. Today, telemedicine enables patients to connect with Registered Medical Practitioners (RMPs) through video, audio or text-based interactions, offering a practical alternative to in-person visits for a wide range of conditions.
For healthcare providers and digital health startups, telemedicine represents a significant opportunity blending clinical expertise with technology to deliver scalable, cost-efficient services. At the same time, it introduces new responsibilities around quality of care, data governance and patient safety. This write-up aims to unpack the Telemedicine Practice Guidelines, 2020[1] (“Telemedicine Guidelines”) and contextualise their relevance within India’s evolving digital health ecosystem.
Legal and Regulatory Framework
Telemedicine in India is regulated through a layered statutory architecture, within which the Telemedicine Guidelines (2020) operate as the core framework for remote clinical practice. The Ministry of Health and Family Welfare notified the National Medical Commission Act, 2019 (“NMC Act”) in September 2020 as the primary legislation governing medical education and the medical profession. Under the NMC Act, only individuals holding a recognised medical qualification and registered with a State Medical Council are legally permitted to practise medicine in India.
The NMC Act replaced the Indian Medical Council Act, 1956 (“IMC Act”) but preserves all rules and regulations made under the IMC Act until new standards are issued. Consequently, the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002 (“MCI Code”), which set ethical and professional standards for medical practice, continue in force. In August 2023, the NMC introduced the Registered Medical Practitioner (Professional Conduct) Regulations, 2023[2] (“NMC Code”), which also incorporated updated telemedicine norms, but this regulation has since been placed in abeyance. Pending re-notification, the MCI Code and the Telemedicine Guidelines (2020) remain the operative framework.
Scope and Applicability of the Telemedicine Guidelines
The Telemedicine Guidelines apply exclusively to Registered Medical Practitioners (“RMPs”) who are duly qualified and registered under the NMC Act and are therefore authorised to practise medicine in India. The Telemedicine Guidelines define telemedicine as the delivery of healthcare services using information and communication technologies where the patient and RMP are geographically separated. These services may be delivered through video, audio, or text-based modes, and may occur synchronously or asynchronously.
The Telemedicine Guidelines recognise multiple consultation models, including patient-to-RMP, caregiver-to-RMP, health-worker supported consultations, and RMP-to-RMP interactions. While telemedicine is permitted across a wide range of clinical scenarios, it is not intended for situations requiring immediate physical examination or emergency intervention, except for limited triage and first-aid advice.
Importantly, the Telemedicine Guidelines form an extension of the MCI Code and are binding on all RMPs practising medical care through digital channels.
Establishing the Telemedicine Relationship: Identification and Consent
The Telemedicine Guidelines require that every remote consultation begins with proper identification of both the patient and the RMP. Patients must provide their name, age and any relevant verification details, while the RMP must disclose their name, qualification and registration number to ensure transparency and accountability.
The Telemedicine Guidelines also distinguish between implied and express consent. Implied consent is sufficient when a patient initiates a teleconsultation, whereas express consent is required when the consultation is initiated by the RMP or a caregiver. Once identification and consent are established, a valid doctor–patient relationship is formed, enabling the RMP to exercise professional judgement remotely.
The Telemedicine Guidelines further differentiate between a first consult and a follow-up consult, with follow-ups permitted only when a recent in-person or telemedicine interaction has occurred.
Clinical Duties, Assessment Standards and Prescription Framework
Under the Telemedicine Guidelines, RMPs are required to uphold the same standard of care expected in an in-person consultation, exercising independent professional judgement at all times. Before offering medical advice, the RMP must make a sufficient assessment of the patient’s condition based on the available information, such as history, symptoms, images or reports, and document the interaction appropriately.
In emergency scenarios, the RMP’s role is limited to triage, first-aid advice and referral, with the Guidelines expressly prohibiting full remote management of emergencies.
The prescription framework under the Telemedicine Guidelines categorises medicines into:
a. List O (OTC; permitted via any mode),
b. List A (video-based first consult required),
c. List B (follow-up consults only), and
d. Prohibited drugs, including Schedule X and narcotic/psychotropic substances
E-prescriptions must clearly include the RMP’s signature, registration number and relevant details to maintain auditability and legal validity.
Telemedicine Platforms: Roles, Restrictions and Compliance
The Telemedicine Guidelines recognise technology platforms as facilitators of teleconsultations but clearly prohibit them from engaging in any form of clinical decision-making. Platforms may enable scheduling, communication and record storage, but they cannot prescribe, diagnose or provide medical advice, all of which remain the exclusive domain of RMPs.
Platforms must display the registration details of RMPs and ensure that only duly registered practitioners are allowed to consult patients on their systems. They are expressly barred from soliciting patients, ranking RMPs, promoting specific drugs or creating incentives linked to prescription volume.
The Telemedicine Guidelines also emphasise transparency: consultation fees must be clearly communicated in advance, and appropriate receipts must be issued. While platforms may support secure data transmission and documentation, the responsibility for clinical care and prescriptions rests solely with the RMP, ensuring clear delineation of liability.
Data Protection and Digital Health Governance
Telemedicine inherently involves the processing of sensitive health information, and the Telemedicine Guidelines mandate that consultations occur over secure, privacy-compliant platforms that ensure confidentiality and data integrity. These requirements now operate alongside India’s evolving digital health framework.
The Digital Personal Data Protection Act, 2023 (“DPDP Act”) establishes the overarching obligations for entities processing personal data, including patient consent, purpose limitation, data minimisation, reasonable security safeguards, and strict rules on data retention and deletion. Telemedicine platforms and RMPs processing personal data in digital form are required to comply with these statutory standards and remain accountable for unauthorised access or misuse.
Further, the Ayushman Bharat Digital Mission (“ABDM”) provides the national architecture for interoperable digital health records. Its Health Information Provider (HIP) and Health Information User (HIU) frameworks enable telemedicine platforms to participate in secure health-data exchanges, subject to explicit patient consent.
The ABDM’s Health Data Management Policy enhances patient rights, such as notice, access, correction and consent-management, while requiring a federated, decentralised data architecture to reduce aggregation risks.
Combined, these instruments create a unified governance layer ensuring that telemedicine services operate with robust privacy, security and accountability safeguards.
Emerging Technologies and Regulatory Gaps
Telemedicine in India is increasingly shaped by emerging technologies such as AI-driven clinical decision-support systems, digital triage tools, remote monitoring devices and wearables. While the Telemedicine Guidelines provide a foundational framework for remote consultations, they do not expressly regulate the use of autonomous or semi-autonomous technologies in clinical assessment or prescription workflows. As a result, AI tools must currently operate in an advisory, non-diagnostic capacity, with ultimate responsibility resting on the RMP’s independent professional judgement.
Similarly, the growing adoption of Internet of Medical Things (IoMT) devices and remote monitoring systems intersects with India’s medical device regulatory regime under the Medical Device Rules, 2017, creating dual compliance requirements that the Telemedicine Guidelines do not fully address. Integrated care models involving telemedicine, e-pharmacies and tele-diagnostics also face ambiguity due to fragmented regulatory oversight.
Additionally, the proposed NMC Code (presently in abeyance) attempted to update telemedicine norms, signalling an eventual shift towards more granular regulation of digital health practices. Until such updates are formally notified, the Telemedicine Guidelines remain the operative standard, leaving notable gaps around AI governance, interoperability standards and platform-level accountability in India’s evolving digital health ecosystem.
[1] Available at: https://esanjeevani.mohfw.gov.in/assets/guidelines/Telemedicine_Practice_Guidelines.pdf
[2] Available at: https://www.nmc.org.in/rules-regulations/national-medical-commission-registered-medical-practitioner-professional-conduct-regulations-2023-reg/