Telemedicine Law in Bangladesh: Launching and Operating a Platform in 2026

Telemedicine law in Bangladesh: what governs a platform in 2026

Telemedicine law in Bangladesh has no single statute. A founder launching a video-consultation app, a hospital group moving outpatient follow-up online or a foreign health platform entering Dhaka meets a set of overlapping rules instead. These are the Bangladesh Medical and Dental Council (BMDC) Telemedicine Guidelines, the Medical and Dental Council Act 2010, the Drugs and Cosmetics Act 2023, the private clinics Ordinance of 1982, the Personal Data Protection Act 2026, the Consumers' Right Protection Act 2009 and the Payment and Settlement Systems Act 2024. Each one controls a different step of the patient journey, and each has its own regulator.

This guide is about launching and operating the platform: choosing the operating model and entity, onboarding doctors, consent and identity, e-prescriptions and medicine rules, data protection, consumer law, payments, and liability and insurance. Two companion TRW insights go deeper on adjacent questions: hosting patient data in the cloud and whether a health app may give medical advice. This article is current as at 21 October 2026.

Summary: A telemedicine platform in Bangladesh may connect patients only with BMDC-registered doctors, must verify and publish each doctor's registration details, and must leave diagnosis and prescribing to the doctor. Prescribing is restricted by medicine list and consultation mode, online medicine sale needs a drug licence, health data is sensitive personal data under the 2026 Act, and fees must be collected through a Bangladesh Bank-licensed payment route.

Key point: The BMDC Guidelines speak directly to platforms. Section 7 obliges a technology platform to ensure patients consult only BMDC-registered doctors, to publish each doctor's name, qualification and registration number, to run a grievance mechanism and to keep artificial intelligence away from counselling and prescribing. A platform found in breach may be blacklisted, after which registered doctors may not use it.

At a glance

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Table of Contents

Telemedicine law in Bangladesh: the 2026 framework

Telemedicine law in Bangladesh is built from professional regulation, sector statutes and general commercial law. No Act of Parliament deals with remote consultation as such, and as at October 2026 the core operational instrument is still the BMDC's Telemedicine Guidelines, published in July 2020 during the pandemic.[1] They are professional guidance for registered doctors, enforced through the Council's disciplinary powers, but several provisions address technology platforms by name, and a platform that registered doctors are forbidden to use has no product.

Around that core sit the statutes. The Medical and Dental Council Act 2010 controls who may practise and who may call themselves a doctor.[2] The Drugs and Cosmetics Act 2023 governs prescribing and the sale, storage and display of medicines, including through internet-based processes.[5] The Medical Practice and Private Clinics and Laboratories (Regulation) Ordinance 1982 licenses private clinics and sets record and fee-display duties.[6] Data, consumer, payment and electronic-records law complete the picture.

What the framework does not yet contain

There is no telemedicine licence, no statutory e-prescription standard and no dedicated patient-redress tribunal. In October 2025 the interim government circulated two draft ordinances on patient safety and health-worker protection,[12] and in June 2026 the Health Services Division formed a committee to draft a unified Health Protection Act.[13] Until a law is passed, a platform must build compliance from the instruments that exist.

Choosing the operating model and the entity

The first legal decision is commercial: what is the platform actually selling? The answer decides which licences apply, who contracts with the patient and who carries clinical risk. Four models recur in Bangladesh, and many platforms combine two or more.

Four operating models

• Marketplace: the platform lists independent doctors, books appointments and collects fees as agent; the doctor provides the clinical service.
• Virtual clinic: the platform employs or retains doctors, sets protocols, brands the service and owns the patient relationship.
• Hospital extension: a licensed hospital uses a software vendor's tools to see its own patients remotely.
• Integrated care and pharmacy: consultation, e-prescription and medicine delivery inside one app, sometimes with diagnostic sample collection.

Each step away from pure software adds weight: a marketplace still owes the platform duties in the BMDC Guidelines, a virtual clinic takes on an employer's clinical governance, and an integrated model adds a drug licence and the medicine-sale offences.

Incorporation and foreign ownership

Most platforms operate through a private limited company registered with the Registrar of Joint Stock Companies and Firms, with a trade licence, tax and VAT registration and the online-business registrations described in our guide to e-commerce company formation in Bangladesh.

Healthcare and medical services do not appear on the reserved or controlled sector lists published under the former investment framework, so no ministry clearance was required before investment registration on that ground.[9] Since 23 August 2026 investment promotion and approvals sit with Invest Bangladesh, which replaced BIDA, BEZA and the PPP Authority.[14] A foreign group should settle the entity, funding route and fee repatriation before signing doctors. Our foreign company establishment practice handles that structuring.

Does the platform need a clinic licence?

The 1982 Ordinance defines a private clinic as a clinic, hospital or nursing home, by whatever name called, owned by a person other than the Government, and section 8 prohibits establishing one without a licence.[6] A pure software marketplace with no premises is difficult to fit within that definition. A platform that opens physical consultation booths, sample-collection points or a branded "clinic" where patients attend should assume the Ordinance applies and obtain a licence from the Directorate General of Health Services (DGHS) for those premises.

The Ordinance also binds registered practitioners directly. Section 6 requires a register of patients' names and addresses and printed receipts for fees, and section 7 requires charges to be displayed prominently.[6] DGHS enforces the licensing regime actively: on 11 June 2026 it cancelled the licence of Ad-din Hospital in Dhaka under section 11(2)(b) after the deaths of six newborns, with a 30-day right of appeal under section 12.[7] A hospital's telemedicine arm puts that licence at stake.

Doctor registration and onboarding under the BMDC Guidelines

Doctor onboarding is where telemedicine law in Bangladesh bites hardest on the platform itself. The BMDC Guidelines limit telemedicine to a registered doctor, and section 3.5 requires every doctor intending to consult remotely to complete an online course on telemedicine.[1] A platform should therefore collect evidence of both registration and course completion before activating an account.

The platform duties in section 7

Section 7 of the BMDC Guidelines is addressed to technology platforms that network registered doctors with patients. Under it, a platform must:[1]

• ensure that patients consult only doctors registered with the BMDC (7.1);
• carry out due diligence before listing a doctor and publish the doctor's name, qualification, registration number and contact details (7.2);
• report non-compliance to the BMDC's Executive Committee (7.3);
• ensure that any artificial intelligence or machine-learning tool does not counsel patients or prescribe medicines (7.4);
• maintain a proper mechanism for customer queries and grievances (7.5).

Section 7.6 allows the BMDC to designate a non-compliant platform as blacklisted, after which doctors may not use it to provide telemedicine.[1] That sanction is commercially terminal, so onboarding controls deserve the same priority as payments or uptime.

Titles, specialities and false representation

Section 29 of the Medical and Dental Council Act 2010 restricts the use of the title "Doctor". In March 2025 the High Court Division held that nobody may use "Doctor" before their name without an MBBS or BDS degree; a violation carries up to three years' imprisonment, a fine of Tk 1 lakh or both, with a minimum Tk 50,000 additional fine for each repeat.[2] A platform that lets unqualified practitioners, alternative-medicine providers or assistants appear under a "Dr" label is exposed. Speciality claims, such as "cardiologist", should be checked against the qualification on the register rather than accepted from the doctor's profile.

Foreign doctors and cross-border consultations

The BMDC Guidelines state that the practice of telemedicine is limited to the territory of Bangladesh.[1] In January 2022 the BMDC barred two Indian specialists whose consultations were being promoted online, on the basis that they had not registered with the Council and that practising without registration breaches the 2010 Act.[3] A platform offering second opinions from overseas specialists to patients in Bangladesh should either secure BMDC registration for those doctors or structure the service so that a registered doctor in Bangladesh remains the treating practitioner.

Contracting with doctors

The clinician agreement should cover registration and course evidence, re-verification, scope of practice, clinical independence, consent and records, prescribing limits, emergency referral, fees, complaints, incidents, data access on exit, insurance and termination. It should not pretend that the platform controls the clinical judgment of a registered doctor. Our corporate and commercial advisory team drafts these agreements alongside the patient terms.

Consent, identity and the consultation workflow

The BMDC Guidelines translate directly into product requirements. A telemedicine consultation cannot be anonymous: the doctor must verify the patient's name, age, address, email, phone number or another suitable identifier, and must introduce themselves with their name and qualifications.[1] The doctor must explicitly ask the patient's age before prescribing, and a minor may be consulted only with an identified adult present.[1]

Explicit consent for every consultation

Explicit patient consent is required for every telemedicine consultation. It may be given in any form, such as an email, text message or audio or video statement, and the doctor must record it in the patient's records; Annexure 1 of the BMDC Guidelines supplies a model consent form.[1] A sign-up checkbox accepting terms of service is not a substitute. The product should capture consent per consultation, with a timestamp, the consultation mode, the identity of the patient or guardian and the version of the information shown.

Clinical consent and data-protection consent are related but distinct. The first authorises remote care; the second is one of the lawful bases for processing health data under the 2026 Act, discussed below. Keep them as separate events so that withdrawing marketing consent never blocks access to care or to the patient's record.

Video, audio and text

The BMDC Guidelines recognise three modes. Video is closest to an in-person consultation; audio suits urgent contact but makes identification harder and rules out visual examination; text, including apps, messaging and email, suits follow-ups and document exchange.[1] The chosen mode affects what may be prescribed, so the platform must record it reliably for each consultation.

Physical examination and emergencies

Telemedicine cannot replace a physical examination. Where examination is critical, the doctor should not proceed until it can be arranged in person. In an emergency, remote care is limited to first aid, life-saving advice, counselling and referral, and the patient must always be told to seek in-person care as soon as possible.[1] Product design should support that: visible emergency warnings, a one-tap route to hospital or ambulance information, and no completion incentive that rewards a doctor for continuing a consultation that should have become a referral.

Records and logs

Doctors must keep logs of the interaction, whether call, chat, email or video, together with the patient records, reports and images used, and must retain prescription records as they would for an in-person visit.[1] The BMDC Guidelines leave the retention period to be prescribed from time to time. The platform should set a documented retention schedule that reconciles clinical continuity, limitation periods and the 2026 Act.

E-prescriptions and medicine rules

Prescribing is where a technology product enters the most tightly regulated part of telemedicine law in Bangladesh. The BMDC Guidelines make prescribing a matter of the doctor's professional discretion, with the same accountability as an in-person consultation, and state that prescribing without an appropriate diagnosis or provisional diagnosis amounts to professional misconduct.[1]

The medicine lists

Annexure 2 of the BMDC Guidelines sorts medicines by consultation type and mode:[1]

• List O: may be prescribed in any mode, covering common over-the-counter needs such as paracetamol and oral rehydration salts.
• List A: may be prescribed at a first consultation only by video, and re-prescribed as a refill at follow-up; it includes certain antibiotics, antifungals and chronic-condition refills.
• List B-1: may be added at follow-up for a condition already treated in person, such as antihypertensives, antidiabetics and insulin.
• List B-2: any approved allopathic medicine not otherwise prohibited, but only during a video consultation with another trained registered medical graduate present with the patient.
• Prohibited: narcotic and psychotropic substances may not be prescribed by telemedicine.

The e-prescription module should enforce these rules in code. It should know the consultation mode, whether this is a first or follow-up consultation, and whether a second clinician is present, and it should block prohibited medicines entirely. Prescribing a restricted-list medicine outside the permitted mode is itself listed as misconduct.[1]

Signed e-prescriptions

The doctor must give the patient a photo, scan or digital copy of a signed prescription, or an e-prescription, and the prescription must comply with BMDC conduct regulations and the drug law.[1] The Information and Communication Technology Act 2006 supports this: section 6 recognises electronic records where a law requires writing, section 7 recognises digital signatures where a law requires a signature, and section 9 allows retention requirements to be met electronically.[10] A platform should authenticate the doctor at signing, lock the prescription once issued, and keep an audit trail of any amendment. Our guide to digital signature law in Bangladesh explains the certification options.

Sending prescriptions to pharmacies

If a registered doctor transmits a prescription directly to a pharmacy, the doctor must obtain the patient's explicit consent, and the patient remains entitled to have the medicine dispensed by a pharmacy of their choice.[1] Defaulting every prescription to the platform's partner pharmacy, without a real choice, is inconsistent with that rule and invites a conflict-of-interest complaint.

Drugs and Cosmetics Act 2023

The 2023 Act is the statutory backstop. Section 14(2) prohibits using an internet or web-based process to sell, store, distribute or display medicines for sale without a licence from the licensing authority or outside its conditions; the Schedule sets a penalty of up to five years' rigorous imprisonment, a fine of up to Tk 5 lakh or both.[5] Licences run for two years and are renewable.[5] Section 40(d) bars the sale of antibiotics or any other non-OTC medicine without a registered physician's prescription, punishable with a fine of up to Tk 20,000.[5]

Two further provisions catch platforms. Section 72 prohibits a doctor from prescribing a medicine that is not registered under the Act, save for registered imports approved by the licensing authority. Section 71 prohibits publishing any advertisement claiming that a medicine is useful for, or cures, a condition without the licensing authority's prior approval.[5] Growth teams running symptom-led campaigns should clear copy against section 71 before publication. Our analysis of pharmaceutical company registration in Bangladesh covers the Directorate General of Drug Administration's licensing route.

Health data under the Personal Data Protection Act 2026

For telemedicine law in Bangladesh, the Personal Data Protection Act 2026 is now the central data statute. It is Act No. 63 of 2026, assented to on 10 April 2026 and published in the Gazette the same day. Under section 1(3) it is deemed to have taken effect on 6 November 2025, except section 23 and sections 31 to 35, which commence on a date the Government notifies after an 18-month period.[4] The Act reaches processing outside Bangladesh that is connected with providing goods or services to, or monitoring, people in Bangladesh, so an offshore platform serving Bangladeshi patients is within scope.[4]

Health data is sensitive personal data

Section 2(21) lists health-related data as sensitive personal data, alongside genetic and biometric data and real-time geo-location.[4] Under section 7, sensitive personal data may be processed only on a listed condition: the data subject's specific consent, a contract with the data subject, employment or social-security duties, a health worker's performance of medical duties and emergency care where life or health is at risk, a legal duty, or data the subject has voluntarily made public.[4] Consent itself must be informed, clear, specific and voluntary under section 2(20).[4]

Children, processors and records

Section 9 requires the consent of a parent, guardian or authorised person to process a child's data; a child is anyone under 18 unless the Government prescribes otherwise.[4] Section 8 makes the data fiduciary answerable for its processors: processing by a processor on its behalf is treated as its own.[4] Cloud, video, messaging, analytics and payment vendors therefore need written processing terms. Section 19 requires records relating to personal data to be kept for at least five years, and section 20 requires a breach likely to cause significant harm to be notified to the Authority in the form and time set by regulation.[4]

Transfers abroad

Section 29 lets the Government classify personal data as public, internal, confidential or restricted, permits transfers abroad with consent or under a contract to which the data subject is party, and allows transfers only to places with the storage technology that regulations prescribe.[4] The ICT Act 2006 adds a confidentiality offence in section 63 for unauthorised disclosure of electronic records.[10] Hosting design and transfer mechanics are covered in our companion insight on patient data in the cloud, and the wider statute in our guide to Bangladesh data protection law.

Consumer protection, pricing and marketing

Patients are consumers, and under telemedicine law in Bangladesh a platform sells a service. The Consumers' Right Protection Act 2009 makes it an offence to deceive consumers through false or misleading advertisements, punishable with up to one year's imprisonment, a fine of up to Tk 2 lakh or both, and to fail to supply a promised product or service for the price paid, punishable with up to one year, a fine of up to Tk 50,000 or both. A complainant is entitled to 25 per cent of the fine realised.[8]

Section 39 of the same Act also requires a seller of goods or services to keep and display a price list.[8] For a platform, the practical exposures are promises it cannot keep: "a doctor in five minutes", guaranteed specialists, hidden follow-up charges or refunds that never arrive.

What patients should see before paying

Publish the consultation fee, any follow-up or prescription charge, the refund and cancellation policy, the doctor's identity and registration number, the expected response time, the limits of remote care and the grievance route. The 1982 Ordinance already requires fees to be displayed and receipts issued,[6] and the BMDC Guidelines treat soliciting patients through advertising or inducements as misconduct.[1] A consistent, plain-language fee page satisfies all three regimes at once. Our consumer protection practice reviews launch copy and complaint procedures.

Payments and fee collection

Consultation fees must move through a regulated channel. The Payment and Settlement Systems Act 2024, passed in July 2024, makes it unlawful to provide payment services without a Bangladesh Bank licence under section 4(2) or to operate a payment platform or gateway without authorisation under section 15(2), and section 37(1) treats the offence as cognisable and non-bailable.[11] On 27 September 2026 Bangladesh Bank named 22 unlicensed online payment aggregators and warned businesses not to transact with them.[11]

Structuring the money flow

Collect fees through a bank or a licensed payment system operator or service provider, and check the licence before integrating. Decide whether the platform collects as principal or as the doctor's collection agent, and make the clinician agreement, invoices and tax treatment match. Record refunds against the original transaction so disputes can be reconstructed.

A foreign parent should not collect Bangladeshi patients' fees offshore and remit a share to local doctors without foreign-exchange advice; a local operating company paying the parent under documented service or licensing arrangements is cleaner.

Liability, insurance and incident management

Under telemedicine law in Bangladesh, clinical responsibility stays with the treating doctor, and the BMDC Guidelines say so in terms. They also provide that a doctor is not responsible for a confidentiality breach caused by a technology failure or an unrelated third party if the doctor took reasonable care in choosing the service,[1] which pushes technology risk toward the platform. A platform is therefore exposed in contract to patients, under consumer law, in negligence for its own systems and in regulatory proceedings for its own duties. Our guide to medical negligence in Bangladesh explains the civil, consumer, criminal and disciplinary routes patients use.

Reform on the horizon

The draft Patient Safety and Redress Ordinance 2025 proposed special tribunals for negligence and patient-rights cases, a one-year limitation period from knowledge of the incident, mandatory review of serious unexpected incidents, and criminal liability only for intentional harm, fraud or gross negligence.[12] The June 2026 Health Protection Act committee was tasked with producing a draft within 20 working days.[13] Build incident logs now.

Insurance

Require each doctor to hold professional indemnity cover for the scope of practice, and record it at onboarding. At platform level, consider cyber, technology errors and omissions and general liability cover, checking exclusions for telehealth, cross-border consultations and artificial-intelligence tools. Our overview of insurance law in Bangladesh sets out the regulatory context for placing cover locally.

Incident response

Write one protocol for adverse clinical events, prescribing errors, breaches of health data and regulator contact. It should preserve logs without altering the clinical record, notify the registered doctor, any hospital partner and, where required, the data Authority, and route public statements through counsel.

Regulators and institutions

A platform will deal with several bodies, and each holds a different lever over the business.

Assign an owner for each relationship and keep regulator correspondence in one compliance file.

Telemedicine law in Bangladesh: a launch checklist

The sequence below turns these rules into a launch gate. Each step should be signed off by a named owner before the first paid consultation.

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Repeat steps three, five and six every quarter: registrations lapse, vendors change and the regulations under the personal data statute will add detail.

Comparing operating models

The table summarises how the main regulatory requirements fall on each operating model. On a phone, scroll it sideways.

Platforms that add pharmacy, diagnostics or subscriptions drift toward the integrated model, and each addition should trigger a fresh licensing review.

Telemedicine law in Bangladesh: what to watch in 2026 and 2027

Three developments matter most: a statutory patient-redress regime emerging from the Health Protection Act work;[13] regulations under the 2026 data statute on breach timing, transfers and data classification, together with commencement of its deferred sections, including section 23 on chief data officers;[4] and continued Bangladesh Bank enforcement against unlicensed payment aggregators.[11]

The BMDC Guidelines date from 2020 and may be revised. A platform that can evidence compliance with their consent, identity, prescribing and platform duties will absorb any revision with little disruption. For a review of your launch model, clinician agreements and data architecture, contact TRW.

Frequently asked questions

Is there a specific telemedicine law in Bangladesh?

No single statute governs telemedicine. The core rules are the BMDC Telemedicine Guidelines of July 2020, supported by the Medical and Dental Council Act 2010, the Drugs and Cosmetics Act 2023, the 1982 private clinics Ordinance, the Personal Data Protection Act 2026 and consumer and payments law.[1] [4] [5]

Does a telemedicine platform need a licence in Bangladesh?

There is no telemedicine licence as such. A platform needs the ordinary company, trade and tax registrations, a drug licence if it sells or displays medicines online, and a DGHS clinic licence for any physical premises where patients attend.[5] [6]

What must a platform publish about its doctors?

Section 7.2 of the BMDC Guidelines requires the doctor's name, qualification, registration number and contact details, after due diligence confirming BMDC registration.[1]

Can foreign doctors consult patients in Bangladesh through an app?

Not without BMDC registration. The Guidelines limit telemedicine to the territory of Bangladesh, and the BMDC has barred unregistered foreign doctors whose consultations were promoted online.[1] [3]

Is patient consent required for every online consultation?

Yes. The Guidelines require explicit consent for each telemedicine consultation, given by email, text, audio or video and recorded by the doctor in the patient's records.[1]

Which medicines can be prescribed through telemedicine?

It depends on the medicine list and the consultation mode. List O medicines may be prescribed in any mode, List A only by video at a first consultation, List B-1 at follow-up and List B-2 only with a second registered clinician present on video. Narcotic and psychotropic medicines are prohibited.[1]

Can an AI tool on the platform prescribe or advise patients?

No. Section 7.4 of the Guidelines bars AI and machine-learning tools from counselling patients or prescribing; they may only support a registered doctor who communicates with the patient directly.[1]

Is it legal to sell medicines through a telemedicine app?

Only with a licence. Section 14(2) of the Drugs and Cosmetics Act 2023 prohibits internet-based sale, storage, distribution or display of medicines without a licence, punishable with up to five years' imprisonment, a Tk 5 lakh fine or both.[5]

Is health data protected under the 2026 data protection law?

Yes. The Personal Data Protection Act 2026 lists health data as sensitive personal data, deemed in force from 6 November 2025, and allows processing only on conditions such as specific consent or a health worker's medical duties.[4]

Can a telemedicine platform use any payment gateway?

No. Payment services require a Bangladesh Bank licence under the Payment and Settlement Systems Act 2024, and in September 2026 the central bank warned businesses against 22 unlicensed aggregators.[11]