Telemedicine Industry in India
Telemedicine has emerged as a transformative force in India's healthcare ecosystem, especially accelerated by the COVID-19 pandemic. The sector combines healthcare delivery with digital technology, enabling remote consultations, diagnosis, and treatment. With robust regulatory guidelines from the National Medical Commission (NMC), telemedicine is now a legitimate and growing practice in India.
Market Overview
- Market Size: India's telemedicine market valued at $1.5+ billion, growing rapidly
- Growth Rate: CAGR of 25-30% expected through 2026
- User Adoption: Over 100 million telemedicine consultations annually
- Platform Growth: 500+ telemedicine platforms operating in India
- Regulatory Framework: NMC guidelines provide clear practice protocols
Types of Telemedicine Services
Real-time Telemedicine
Live video/audio consultations between doctor and patient. Most common form including apps like Practo, Apollo 24/7, and Tata Health.
Store-and-Forward
Asynchronous transmission of medical data (images, reports) for later review by specialists. Common in radiology and dermatology.
Remote Patient Monitoring
Continuous monitoring of patient vitals using IoT devices. Used for chronic disease management and post-operative care.
Mobile Health (mHealth)
Health services and information delivered through mobile devices. Includes health apps, SMS reminders, and wellness tracking.
NMC Telemedicine Guidelines
The National Medical Commission (erstwhile MCI) has issued comprehensive guidelines for telemedicine practice in India. These guidelines establish the legal framework and practice standards.
Key Regulatory Requirements
Who Can Practice Telemedicine?
- • Only Registered Medical Practitioners (RMPs) with valid NMC/MCI registration
- • Must be registered in the state where the patient is located
- • Foreign doctors cannot provide telemedicine to Indian patients without NMC registration
- • AYUSH practitioners can practice under their respective councils
Consultation Types and Limitations
- • First consultation can be telemedicine for minor ailments only
- • Prescription of Schedule X drugs prohibited via telemedicine
- • Emergency cases must be referred to physical facility
- • Proper documentation of every consultation mandatory
- • Informed consent required from patient
Technology and Platform Requirements
- • Platform must ensure privacy and data security
- • RMP must verify patient identity before consultation
- • Consultation records must be maintained for 3 years
- • E-prescriptions must follow standard format
Prohibited Practices
- ✗ Prescribing abortion drugs via telemedicine
- ✗ Narcotic and psychotropic substances (Schedule X)
- ✗ Medical certificates for legal purposes without physical exam
- ✗ Emergency care without referral mechanism
Company Registration for Telemedicine
Setting up a telemedicine platform requires careful consideration of business structure, licensing, and compliance requirements.
Recommended Business Structures
Private Limited Company
Best for: Telemedicine platforms seeking investment, multiple founders, or planning to scale. Limited liability and easier fundraising make this the preferred structure.
Limited Liability Partnership (LLP)
Best for: Smaller platforms, doctor partnerships, lower compliance burden. Suitable when founders want flexibility with liability protection.
Required Registrations
Company Registration
Private Limited or LLP registration with MCA. DIN for directors, DSC for filings.
Clinical Establishment Registration
State-specific registration under Clinical Establishments Act. Required in most states for healthcare facilities.
GST Registration
Mandatory for healthcare services with turnover above ₹20 lakhs. GST at 18% for telemedicine services.
Startup India Recognition
DPIIT recognition for eligible startups. Benefits include tax exemptions, self-certification.
Platform Development Requirements
Building a compliant telemedicine platform requires attention to technology infrastructure, security, and user experience.
Technical Requirements
- ☐ Secure video/audio consultation platform
- ☐ End-to-end encryption for communications
- ☐ E-prescription generation system
- ☐ Electronic Health Records (EHR)
- ☐ Appointment scheduling system
- ☐ Payment gateway integration
- ☐ Multi-language support
Compliance Features
- ☐ Doctor verification and NMC registration check
- ☐ Patient identity verification
- ☐ Consent management system
- ☐ Consultation history and audit trails
- ☐ Data backup and disaster recovery
- ☐ Grievance redressal mechanism
- ☐ Rating and review system
ABHA Integration
Ayushman Bharat Health Account (ABHA) integration is recommended for seamless health record exchange. Benefits: Unified health ID, consent-based record sharing, interoperability with ABDM ecosystem.
Data Privacy and Security
Telemedicine platforms handle sensitive health data requiring strict compliance with data protection regulations.
Applicable Regulations
Digital Information Security in Healthcare (DISHA)
Proposed legislation for health data protection. Current requirements include: Patient consent for data collection, data localization (health data must be stored in India), strict access controls, breach notification requirements, rights to access, correct, and erase data.
DPDP Act 2023
Digital Personal Data Protection Act applies to health data processing. Requirements: Consent for data processing, data fiduciary obligations, data localization, purpose limitation, grievance redressal mechanism.
Information Technology Act
Sensitive personal data protection under IT Act. Reasonable security practices mandatory. Data breach reporting requirements.
Security Best Practices
Technical Safeguards
- • ISO 27001 certification
- • SOC 2 Type II compliance
- • End-to-end encryption
- • Multi-factor authentication
- • Regular security audits
Operational Measures
- • Staff training on data privacy
- • Access control policies
- • Incident response plan
- • Business continuity planning
- • Vendor security assessments
Doctor Onboarding and Verification
Ensuring only qualified and registered doctors provide consultations is a critical compliance requirement for telemedicine platforms.
NMC Registration Verification
Verify doctor's registration with NMC/MCI through official NMC website. Check registration number, validity, and any disciplinary actions.
State Medical Council Registration
Doctors must be registered in the state where patients are located. Cross-check with respective state medical councils.
Qualification Verification
Verify medical degrees and additional qualifications. Check university accreditation and degree authenticity.
Background Checks
Police verification, reference checks, malpractice history verification. Essential for patient safety.
Doctor Agreement Essentials
- • Scope of services and limitations
- • Consultation fees and payment terms
- • Data confidentiality obligations
- • Non-compete clauses (reasonable)
- • Indemnification provisions
- • Termination conditions
Professional Indemnity Insurance
Insurance is critical for telemedicine platforms to protect against medical negligence claims and cyber risks.
Required Insurance Coverage
Professional Indemnity Insurance
Mandatory for all telemedicine platforms. Covers medical negligence claims.
- • Minimum cover: ₹20-50 lakhs per doctor
- • Aggregate coverage based on consultation volume
- • Covers legal defense costs
- • Group policies available
Cyber Liability Insurance
Essential for data breach protection.
- • Data breach response costs
- • Regulatory fines and penalties
- • Business interruption coverage
- • Crisis management support
General Liability Insurance
Covers operational risks.
- • Third-party bodily injury
- • Property damage claims
- • Advertising injury
Directors & Officers (D&O) Insurance
Protects founders and board members.
- • Management liability coverage
- • Regulatory defense costs
- • Employment practices liability
Investment and Cost Structure
Starting a telemedicine platform requires significant investment in technology, compliance, and operations.
Initial Setup Costs
- • Company registration: ₹15,000-25,000
- • Platform development: ₹25 lakhs - ₹2 crores
- • Security audits: ₹2-5 lakhs
- • Legal and compliance: ₹3-8 lakhs
- • Clinical establishment: ₹5,000-20,000
- • Initial marketing: ₹10-50 lakhs
Annual Operating Costs
- • Technology maintenance: ₹10-50 lakhs
- • Insurance premiums: ₹2-10 lakhs
- • Compliance costs: ₹3-8 lakhs
- • Cloud infrastructure: ₹5-20 lakhs
- • Legal retainers: ₹2-5 lakhs
- • Security updates: ₹2-5 lakhs
Revenue Models
Common monetization: Commission from consultation fees (10-25%), Subscription plans for patients, Corporate wellness contracts, Value-added services (diagnostics, pharmacy), Data insights (anonymized).
Frequently Asked Questions
Can foreign doctors provide telemedicine in India?
Foreign doctors cannot provide telemedicine services to Indian patients unless: 1) They are registered with NMC/MCI (NRI registration), 2) They have temporary registration for specific cases, 3) Second opinion on existing diagnosis (limited scope). Foreign telemedicine platforms cannot directly serve Indian patients without establishing Indian entity with NMC-registered doctors.
What is the penalty for non-compliance with NMC guidelines?
Non-compliance can result in: Disciplinary action against doctors by NMC/State Medical Councils, Platform liability under consumer protection laws, Potential criminal liability under IPC for medical negligence, FEMA violations for foreign platforms, Data protection penalties under IT Act. Ensure strict compliance to avoid regulatory action.
Can telemedicine platforms sell medicines?
Telemedicine platforms cannot directly sell medicines. Options: 1) Partner with licensed pharmacies for delivery, 2) Display e-prescriptions for patients to buy from any pharmacy, 3) Some platforms operate separate pharmacy entities with drug licenses. E-pharmacy requires separate license under Drugs and Cosmetics Act. Prescription required for Schedule H and other restricted drugs.
What records must be maintained?
Mandatory record keeping: 1) Patient consultation records (3 years), 2) Prescriptions issued, 3) Doctor credentials and verification, 4) Consent forms, 5) Data processing records, 6) Grievance handling records, 7) Audit trails of platform activity. Digital records must be secure and backed up.
Key Takeaways for Telemedicine Business
Essential Compliance
- ✓ NMC registration for all doctors
- ✓ Clinical establishment registration
- ✓ Data privacy compliance (DPDP Act)
- ✓ Professional indemnity insurance
- ✓ Secure technology platform
Success Factors
- ✓ Quality doctor network
- ✓ User-friendly platform
- ✓ ABHA integration
- ✓ Multi-language support
- ✓ Strong data security