Telemedicine grew quickly in Pakistan and the framework has been catching up ever since. Platforms launch as technology products, and only later discover that they are being treated as healthcare providers.
The central question, for anyone building in this space, is whether you are a marketplace connecting patients to doctors or a healthcare service. Everything else follows from the answer — and the answer depends on how you actually operate, not on what your terms say.
Who may practise
Only registered practitioners. Any doctor consulting on your platform must hold current PMDC registration in the appropriate category, and other professionals must hold their own council registration.
Verify at onboarding and re-verify at renewal. A platform carrying an unregistered practitioner is facilitating quackery, which is an offence and is enforced.
Scope of practice. A practitioner must stay within their qualification. Platforms that route any complaint to whichever doctor is online are creating exactly the exposure they think they have outsourced.
Foreign doctors consulting into Pakistan raise a further question, because practising here generally requires registration here. If your model involves overseas practitioners, resolve this before launch.
The Sindh Healthcare Commission and the corresponding provincial commissions regulate healthcare establishments, and the extent to which a telemedicine service is treated as an establishment is a question to confirm with the regulator for the model you actually operate. See setting up a clinic, hospital or lab.
Marketplace or provider?
You are much closer to being a provider — with the liability that brings — if you:
- Set or control the fee and take payment in your own name
- Assign the patient to a doctor rather than letting the patient choose
- Employ or exclusively engage the practitioners
- Control the clinical protocols and the consultation format
- Present the service under your brand as "our doctors"
You are closer to a marketplace if practitioners set their own fees, patients choose, and your role is genuinely introduction and scheduling — and your terms and your conduct both say so.
Being a provider is a legitimate model. Being a provider while believing you are a marketplace is the dangerous position, and it is the common one.
See when your agent binds you.
Liability when something goes wrong
A patient harmed by remote advice may bring a claim against the practitioner, and frequently against the platform as well — in contract, in negligence, and before the healthcare regulator.
What determines the platform's position:
Verification of the practitioner's registration and scope.
Triage. A safe telemedicine service has clear rules on what cannot be handled remotely and must be redirected to in-person or emergency care. Chest pain, breathing difficulty, pregnancy complications, paediatric emergencies and mental health crises need explicit escalation pathways, visible to the patient and enforced in the product.
Records. A complete, retained record of every consultation. Without it, neither the doctor nor the platform can defend anything.
Consent, obtained and recorded, including consent to remote consultation and its limitations.
Insurance — professional indemnity for practitioners, and the platform's own cover.
See medical negligence claims and professional negligence claims.
Contractual limitations help but do not eliminate exposure: a disclaimer saying "we are only a platform" is worth little if the patient's experience and your marketing both say otherwise.
Prescribing and pharmacy
The highest-risk area, and the one regulators watch.
Prescription-only medicines require a valid prescription from a registered practitioner. If your platform issues prescriptions, generates them digitally, or integrates with a pharmacy, you are inside the drug regulatory framework — and delivery adds licensed-premises, storage and cold chain questions.
Controlled substances, antibiotics and weight-loss and sexual-health products prescribed after a form-filling exercise with no genuine consultation are exactly the pattern that attracts enforcement, and it should be avoided regardless of what competitors do.
See pharmacy and medical store licensing and food and pharma licensing.
Records, privacy and confidentiality
Health data is the most sensitive category you can hold, and in this sector confidentiality is a professional duty as well as a contractual one.
Requirements to build in:
- Access control — clinicians see only their patients; support staff see the minimum
- Encryption in transit and at rest
- Retention, and secure deletion after it
- No clinical data in WhatsApp groups — this is endemic in Pakistani practice and it is indefensible
- Consent for any secondary use, including research and product improvement
- Breach response, with notification obligations. See responding to a data breach
- Where consultations are recorded, explicit consent and clear retention terms
See data protection for Pakistani businesses and cloud contracts and data localisation.
Marketing and claims
Health claims are the most heavily scrutinised category in advertising. Do not promise outcomes, do not publish testimonials you cannot verify, and do not use before-and-after imagery without consent and accuracy.
Diagnostic or triage features driven by AI need particular care: they must be presented as decision support, not diagnosis, with a human practitioner accountable for clinical decisions, and the record must show that. See using AI in your business, digital advertising and claim substantiation and consumer protection claims.
Building the business
Structure. A company, given the liability profile. See choosing a business structure.
Practitioner agreements — status, fees, verification obligations, insurance, record-keeping, confidentiality, and what happens to patient relationships on exit. See employment contracts.
Patient terms and privacy policy that describe the service accurately.
Payments — if you hold funds or offer instalments, the payments framework applies. See fintech licensing.
App store rules for health apps are stricter, including on medical claims and data. See publishing a mobile app.
Insurance and panel arrangements, if you contract with insurers — payment terms, disallowances and audit rights. See a rejected insurance claim.
For overseas patients and families
Many Pakistani telemedicine users are overseas Pakistanis arranging care for family here. Two points worth stating to them: the practitioner's obligations and any claim generally arise under Pakistani law, and a platform's terms may select a particular forum. Where a serious incident occurs involving a relative in Pakistan, the claim is pursued here, and can be pursued from abroad through counsel. See powers of attorney from abroad.
How the firm can help
We advise telemedicine and health platforms on regulatory status and practitioner verification, draft patient terms, consent, privacy and clinical governance documentation, prepare practitioner and pharmacy agreements, review triage and escalation design against liability exposure, and act in regulatory complaints and negligence claims.