TRW & Co · Technology, IP & Data
Telemedicine and Digital Health in Singapore
Telemedicine in Singapore has been a licensed activity under the Healthcare Services Act since June 2023. Providers need an approved remote mode of service delivery, a qualified clinical governance officer and protocols that meet tightened licence conditions. This guide explains licensing, enforcement lessons, product and data rules, and practical steps for providers and investors in 2026.
Key pointThe HCSA licenses the service, not the channel: a governance failure in teleconsultations can cost a provider its whole licence, including its physical clinic, as MOH's December 2024 revocation showed.
At a glance
Licensed since June 2023
HCSA Phase 2 made teleconsultation by doctors and dentists licensable from 26 June 2023, covering clinics, platform companies and individual doctors providing remote care.
S$360 per mode
The Outpatient Medical Service licence fee is S$360 for each stand-alone mode of service delivery, with bundles combining remote care with premises or house calls.
CGO e-training required
The clinical governance officer must reside in Singapore, be fully SMC-registered and, for the remote mode, complete MOH's telemedicine e-training.
Tighter remote conditions
MOH Circular 64/2025 required licensees to implement modified licence conditions for remote outpatient medical services by 17 October 2025.
HSA administers from November
From 1 November 2026 HSA handles HCSA licence administration, inspections and enforcement, with HALP moving to HSA; MOH remains the licensing authority.
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What telemedicine in Singapore covers
Telemedicine in Singapore covers healthcare delivered when the patient and the professional are in different places: video and audio teleconsultations, remote monitoring of chronic conditions, e-prescribing and medication delivery, online medical certificates, and digital health apps that support diagnosis or treatment. It sits within a wider digital health market that includes software as a medical device, wearables, AI-assisted triage and patient-facing health platforms.
Since 26 June 2023, teleconsultation by doctors and dentists has been a licensed activity under the Healthcare Services Act 2020 (HCSA). That changed the legal question for founders, clinic groups and investors. It is no longer whether telemedicine is allowed, but who must hold the licence, what conditions attach to it and how quickly the regulator will act if standards slip.
Recent enforcement shows the stakes. In December 2024 the Ministry of Health revoked a telemedicine-heavy clinic's outpatient licence, ending its in-person, home and remote services together. Licence conditions for remote services were then tightened from October 2025, and from 1 November 2026 the Health Sciences Authority administers HCSA licensing on MOH's behalf.
The legal and regulatory framework
HCSA licensing of remote services
The HCSA licenses healthcare services rather than premises. A provider holds a licence for a service, such as an Outpatient Medical Service or Outpatient Dental Service, and is approved for one or more modes of service delivery: permanent premises, temporary premises, conveyance and remote. Teleconsultation is the remote mode.
According to MOH's announcement of HCSA Phase 2, the licensing regime for teleconsultation took effect on 26 June 2023. Licences are needed by clinics that engage doctors to offer teleconsultation, telemedicine platform companies that employ or engage doctors to provide it, and individual doctors offering it in their own capacity.
The HCSA guidance on Outpatient Medical Service sets out the licence scope, the modes of service delivery, the requirements for a clinical governance officer and the fees. The licence fee is S$360 for each stand-alone mode, with bundles available, so a clinic offering in-person care, house calls and teleconsultation can pay a single S$360 fee.
The clinical governance officer
Every Outpatient Medical Service licensee must appoint a clinical governance officer (CGO). The CGO must reside in Singapore, be fully registered with the Singapore Medical Council with a valid practising certificate, and be a registered family physician, a registered specialist or have at least five years of relevant full-time practice. For the remote mode, the CGO must also have completed MOH's telemedicine e-training. Suitability rules exclude people with certain convictions, bankruptcies or past licence revocations.
Licence conditions and professional standards
Remote services are subject to specific licence conditions. MOH Circular No. 64/2025 required licensees to implement modified licence conditions for remote outpatient medical services by 17 October 2025, after consultation in August 2025. Breach can lead to action under the HCSA, including suspension or revocation, shortening of the licence term, directions or a financial penalty.
Doctors remain bound by the Singapore Medical Council's Ethical Code and Ethical Guidelines, and MOH's National Telemedicine Guidelines set out good practice on clinical, technical and administrative standards. Decisions on diagnosis, prescribing and medical certificates without physical examination are matters of professional judgement, and the SMC has issued guidance on telemedicine and online medical certificates.
Other laws that apply
- Health Products Act 2007 and HSA rules. Software and apps that diagnose, monitor or treat may be medical devices requiring HSA registration, and medicine delivery engages pharmacy and telepharmacy rules.
- Personal Data Protection Act 2012. Governs consent, notification, security and overseas transfers of patient data.
- Health Information Act 2026. Expected to apply from early 2027, requiring HCSA licensees to contribute to the National Electronic Health Record and meet cybersecurity and data security standards.
- HCSA advertising rules. Healthcare advertising is restricted, including use of the title "Doctor" and claims about services.
| Model | Typical licensing position | Key compliance points |
|---|---|---|
| Clinic adding teleconsultation | Existing Outpatient Medical Service licence with remote mode approved | Remote licence conditions; CGO e-training; patient selection protocols |
| Telemedicine platform employing or engaging doctors | Platform company holds Outpatient Medical Service licence (remote) | Clinical governance over contracted doctors; quality controls on consultation length and prescribing |
| Technology-only platform | May fall outside licensing if it does not provide healthcare services itself | Contracts with licensed providers; data roles; advertising; medical device status of software |
| Individual doctor teleconsulting | Licence held by the doctor in own capacity | Same remote conditions as a clinic; records and continuity of care |
| Remote monitoring and digital therapeutics | HSA medical device rules may apply; HCSA licence where clinical care is delivered | Product classification, registration and post-market duties |
| Medicine delivery after teleconsultation | Pharmacy licensing and telepharmacy rules | Prescription validity, dispensing controls and delivery standards |
Enforcement lessons from 2024 to 2026
MOH's revocation of MaNaDr Clinic's licence with effect from 20 December 2024 is the clearest signal of how the regulator views telemedicine in Singapore. MOH said that, in a sampled month, more than 100,000 teleconsultations involved video calls of one minute or less, the shortest lasting one second. It found an entrenched disregard for clinical and ethical standards and a lack of effective oversight.
The consequences went beyond the remote service. The clinic could no longer provide care at its permanent premises, at temporary premises or remotely, and its participation in CHAS, MediSave and Healthier SG ceased. MOH said it would continue to monitor licensees providing teleconsultation.
A telemedicine licence is a clinical governance licence. Regulators judge it by what happens in each consultation, not by the elegance of the app.
Three practical lessons follow. Consultation metrics such as duration, prescribing rates and medical certificate issuance are evidence the regulator can and will examine. Licensees must actively supervise the doctors on their platform, not simply contract with them. And a failure in the remote channel can put the whole licence, and every mode of service delivery, at risk.
Key decisions for providers and investors
Who holds the licence
Decide whether the platform, a partner clinic or individual doctors hold the licence. The licensee carries clinical governance responsibility, so the commercial model must give it real control over doctors and protocols.
Scope of remote care
Define which conditions are suitable for remote management, when video rather than audio is required, and when patients must be referred for in-person examination.
Prescribing and certificates
Set rules on what can be prescribed remotely, repeat prescriptions and medical certificates, with audit triggers for outliers. These are the areas regulators watch most closely.
Product classification
Decide early whether symptom checkers, triage tools or monitoring software are medical devices. Classification drives registration timelines, evidence requirements and post-market obligations.
Our healthcare regulation and medical device compliance teams work on these questions together, because the answers interact.
Digital health beyond the video consultation
Teleconsultation is only one part of telemedicine in Singapore. Many of the fastest-growing services combine remote consultations with monitoring devices, AI tools, medicine delivery and employer or insurer partnerships. Each layer brings its own rules.
Remote monitoring and AI tools
Remote monitoring programmes for diabetes, hypertension or cardiac conditions typically combine a connected device, an app and a clinical team reviewing data. The device and software may be regulated by HSA, and the clinical review is a licensable healthcare service. Contracts should allocate responsibility for alerts that are missed or acted on late, set response times the clinical team can actually meet, and explain to patients that monitoring is not an emergency service.
AI-assisted triage and documentation tools raise similar questions. If an AI feature influences clinical decisions, consider medical device status, validation evidence, clinician oversight and how errors are detected and reported. Our AI governance team works with clinical leads on those controls.
Medicine delivery, payment and partnerships
Delivering medicines after a teleconsultation engages pharmacy licensing and telepharmacy standards, and prescription-only medicines must be dispensed under appropriate professional control. Payment models matter too. Access to government schemes such as CHAS, MediSave and Healthier SG depends on accreditation and scheme rules, which can be lost through enforcement, as the 2024 revocation showed.
Corporate wellness and insurer partnerships are common routes to scale for telemedicine in Singapore. They raise questions about who the patient's provider is, what information the employer or insurer may receive and whether referral or fee-sharing arrangements are permitted. Patient consent and strict limits on data flowing back to employers or insurers are essential, particularly as the Health Information Act prohibits use of the national health record for employment or insurance purposes.
Liability, complaints and insurance
Remote care does not lower the standard of care. A doctor who cannot examine a patient must recognise the limits of the consultation and refer when needed; failing to do so can found negligence claims and professional complaints to the Singapore Medical Council. The licensee may face vicarious or direct liability, and regulatory consequences under the HCSA.
Check that medical indemnity cover for each doctor extends to teleconsultation, and that the platform has its own professional and cyber liability cover. Keep complete consultation records, including whether video was used, the information the patient provided and the advice given on when to seek in-person care. Those records are the main evidence if a complaint or claim arrives months later.
Process: launching a telemedicine service in Singapore
- Map the service. Describe the clinical services, patient journey, technology and revenue model, and identify every licensable activity and regulated product.
- Choose the licensing structure. Decide who will be the licensee, prepare the corporate structure and select a CGO who meets the residence, registration, experience and e-training requirements.
- Apply through HALP. Submit the licence application through the Healthcare Application and Licensing Portal, which from 1 November 2026 is hosted by HSA at halp.hsa.gov.sg. MOH remains the licensing authority.
- Build clinical protocols. Write remote suitability criteria, escalation and referral pathways, prescribing and certificate rules, and quality review processes that reflect the current licence conditions.
- Settle data and technology. Complete PDPA documentation, vendor contracts, security controls and, where relevant, HSA classification of software. Plan for Health Information Act requirements from 2027.
- Review marketing. Check website, app store and social media content against healthcare advertising rules before launch.
- Launch and monitor. Track consultation metrics, complaints and incidents, and run periodic clinical audits with findings reported to the CGO and board.
Build a monthly dashboard of consultation duration, prescribing and certificate rates by doctor, and require the CGO to review outliers. It is the cheapest way to detect the kind of practice MOH acted on in 2024, and it gives the licensee evidence of active governance if the regulator asks.
Documents and evidence to prepare
- Licence application and approvals, including CGO and key office holder details and the approved modes of service delivery.
- Clinical governance manual covering remote suitability, escalation, prescribing, certificates and record-keeping.
- Doctor engagement agreements requiring compliance with protocols, audits and training, with termination rights for non-compliance.
- Patient terms and consents explaining the limits of remote care, emergency arrangements and data use.
- Privacy notice and data protection documentation, including overseas transfer safeguards.
- Technology and vendor contracts with uptime, security, incident notification and data return obligations.
- Medical device assessment for any software features, and HSA registrations where required.
- Audit records and dashboards showing ongoing quality oversight.
Risks and common mistakes
Treating doctors as independent contractors beyond oversight
Platforms often engage doctors as contractors and assume clinical decisions are the doctors' responsibility alone. Under the HCSA, the licensee is accountable for providing services in a clinically and ethically appropriate manner, and MOH has said it expects effective internal oversight and controls. Contracts must give the licensee the right to set protocols, audit consultations, require training and remove doctors who do not comply, and the licensee must actually use those rights.
Optimising for speed over clinical quality
Short consultations and high throughput may look efficient, but very brief video calls were central to the 2024 revocation. Design incentives, user interface and doctor remuneration so they do not reward speed at the expense of appropriate assessment. Where a condition needs physical examination, the pathway to in-person care should be easy and visible. Document why particular conditions are considered suitable for remote management.
Missing the medical device question
A symptom checker, risk calculator or monitoring app that informs clinical decisions may be a medical device. Launching without classification can lead to regulatory action and force product changes after launch. Assess intended purpose and claims early, consider HSA's guidance on software and telehealth products, and keep marketing claims consistent with the classification. Changes to features or claims can change the classification.
Advertising that breaches healthcare rules
Digital health businesses are used to growth marketing, but healthcare advertising in Singapore is restricted. Testimonials, superlative claims, inducements and misleading statements about outcomes can breach HCSA advertising rules and professional standards. Review campaigns, influencer content and app store descriptions before publication. Our post on healthcare advertising controls explains the boundaries.
Under-preparing for the Health Information Act
Telemedicine providers licensed under the HCSA fall within the Health Information Act framework, which is expected to apply from early 2027. That means contributing prescribed data to the National Electronic Health Record, meeting cybersecurity and data security standards and notifying the regulator of notifiable incidents within 2 hours of assessment. Platforms built on third-party technology need vendors that can support these duties. See our health data governance page.
The cross-border angle
Telemedicine in Singapore is naturally cross-border. Platforms may serve patients in several countries from one technology stack, engage doctors located outside Singapore or host data in regional clouds. Each country regulates the practice of medicine on its own terms, and a Singapore licence does not authorise care elsewhere. Equally, foreign platforms serving patients in Singapore should expect Singapore licensing and professional registration rules to apply to care delivered here.
TRW & Co's network is relevant at several points. Bangladeshi health technology companies and hospital groups exploring Singapore as a regional base need structures that separate Singapore-licensed services from operations at home. UK digital health businesses entering Asia must adapt models built for NHS and CQC regulation. UAE and Gulf healthcare investors are acquiring regional platforms and need due diligence on licensing, governance and enforcement history, and Chinese health technology firms often supply the underlying software, raising medical device and data questions together.
Where Singapore court or tribunal representation is required, we work alongside Singapore-qualified counsel.
How TRW & Co helps with telemedicine in Singapore
Licensing and structure
We advise on licensing structures, CGO and key office holder requirements and applications, and on corporate structures that place clinical responsibility where it can be exercised.
Governance and protocols
We help draft clinical governance manuals, doctor engagement terms and audit frameworks that reflect current remote licence conditions.
Product and data
We assess medical device status of software, prepare PDPA documentation and vendor contracts, and plan for Health Information Act obligations.
Investment and enforcement
We run regulatory due diligence on telemedicine targets and support responses to regulator inquiries, inspections and notices.
See our practices, including data protection and professional regulation, or contact us to discuss a digital health project.
Checklist for decision-makers
- Is it clear which entity holds the HCSA licence and carries clinical governance responsibility?
- Does the CGO meet all requirements, including telemedicine e-training for the remote mode?
- Have the modified remote licence conditions been implemented and documented?
- Are consultation duration, prescribing and certificate metrics monitored by doctor?
- Has every software feature been assessed for medical device status?
- Are marketing materials reviewed against healthcare advertising rules?
- Is the service ready for Health Information Act contribution, security and reporting duties?
- For cross-border telemedicine in Singapore and beyond, have licensing and registration rules been mapped in each patient market?
Providers that can answer yes to these questions are well placed to grow and to withstand the regulatory scrutiny that now accompanies remote care.
Frequently asked questions
01Do we need a licence to offer teleconsultations in Singapore?
Yes, if you provide outpatient medical or dental services remotely. Since 26 June 2023 the Healthcare Services Act 2020 requires clinics, telemedicine platform companies that employ or engage doctors, and individual doctors teleconsulting in their own capacity to hold a licence with the remote mode of service delivery approved. A business that only supplies technology to licensed providers, without providing healthcare services itself, may fall outside licensing, but the line depends on the facts and should be checked.
02Who can be the clinical governance officer for a telemedicine service?
The CGO must reside in Singapore during the appointment, be fully registered with the Singapore Medical Council with a valid practising certificate, and be a registered family physician, a registered specialist or have at least five years of relevant full-time practice. For the remote mode, the CGO must also complete MOH's telemedicine e-training. Suitability rules exclude people with certain convictions, undischarged bankruptcy or involvement in providers whose licences were revoked.
03What happened in the MaNaDr case and why does it matter?
MOH revoked MaNaDr Clinic's outpatient medical service licence from 20 December 2024. MOH said that in a sampled month more than 100,000 teleconsultations involved video calls of one minute or less, and found an entrenched disregard for clinical and ethical standards. The clinic lost its ability to provide care at its premises, at temporary premises and remotely, and its CHAS, MediSave and Healthier SG participation ended. It shows that remote governance failures can cost the entire licence.
04Can doctors issue medical certificates and prescriptions after a video call?
They can where it is clinically appropriate, but it is a matter of professional judgement, not an automatic right. Doctors must follow the SMC Ethical Code and Ethical Guidelines, the National Telemedicine Guidelines and the licensee's remote licence conditions. Licensees should set clear rules on which conditions are suitable for remote management, when video is required and when patients must be seen in person, and should audit prescribing and certificate patterns.
05Is our health app a medical device?
It may be. Software intended to diagnose, monitor, treat or prevent disease can be a medical device regulated by HSA under the Health Products Act, depending on its intended purpose and claims. General wellness and administrative tools are usually outside the regime. Assess the product before launch, keep marketing claims consistent with the assessment, and reassess when features change. Registration requirements and timelines depend on the risk classification.
06Does the Health Information Act apply to telemedicine providers?
Yes. The HIA applies to healthcare providers licensed under the HCSA, which includes licensees providing remote services. When it takes effect, expected from early 2027, providers will need to contribute prescribed data to the National Electronic Health Record, meet the Cybersecurity and Data Security Essentials and report notifiable incidents to the regulator within 2 hours of assessment. PDPA duties continue to apply alongside it.
07What changes when HSA takes over HCSA administration?
From 1 November 2026 HSA becomes responsible for administering licensing, inspections, audits and enforcement under the HCSA, while MOH remains the licensing authority and licences continue in MOH's name. Existing licences remain valid, requirements are unchanged and applications continue through HALP, now hosted at halp.hsa.gov.sg. Enquiry channels move to HSA addresses. Update internal contact lists and compliance calendars accordingly.
Sources and official materials
- HCSA: Outpatient Medical Service — Modes of service delivery, CGO requirements and fees
- MOH: Phase 2 of Healthcare Services Act to start on 26 June 2023 — Licensing of teleconsultation services
- MOH: Revocation of MaNaDr Clinic's licence — Enforcement action on teleconsultation practices
- HSA: Integrated Regulatory System for Healthcare — Transfer of HCSA administration to HSA from 1 November 2026
- HSA: Medical devices — Regulation of medical devices including software
- MOH: Overview of the Health Information Act — NEHR and security duties for HCSA licensees
General information only, current as at 20 October 2026. It is not legal advice and does not create a lawyer–client relationship. Singapore law and regulatory practice change; check current official sources and take advice on the facts of your matter.
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