Updated: 2026-08-31

The Medical Council of Hong Kong's Ethical Guidelines on Practice of Telemedicine, promulgated in December 2019, states two things plainly: "Standards of care that protect patients during face-to-face medical consultations apply equally to telemedicine." and "If a physical examination is likely to add critical information, the doctor should not proceed until a physical examination can be arranged." The same guidelines state: "Telemedicine must not be viewed as a cost-effective substitute for in-person consultation". ⚠️ Two limits to know: the guidelines say of themselves "This is not a legal document", and that they are "not intended for regulation of overseas doctors who practise telemedicine on patients in Hong Kong". Chinese medicine has its own: the Chinese Medicine Practitioners Board of the Chinese Medicine Council issued 《遙距醫療服務專業道德指引》 in September 2021, applying to both registered and listed practitioners, likewise requiring them to "bear the same professional responsibility as in an in-person consultation" and stating that "telemedicine should not be a substitute for in-person consultation merely on cost-effectiveness grounds". The Consumer Council's study of 19 August 2025 found that of 19 service providers examined, 15 did not clearly state the refund arrangement where the practitioner considers the patient unsuitable for telemedicine, and 4 claimed their service "should not be regarded as diagnosis or treatment". This article covers the rules and what to ask. It rates no platform and offers no medical advice.


How is "telemedicine" defined in Hong Kong?

Establish the scope first, because "asking a doctor on WhatsApp" may already count.

The Consumer Council cites the World Health Organization's definition: telemedicine is the exchange of information using information and communications technology to diagnose and treat illness and injury even where the health professional and the patient are far apart.

The Medical Council's guidelines define it more broadly. Paragraph 3:

"'telecommunication systems' include telephone, email, social media (e.g. SMS, WhatsApp, Facebook, internet forum & etc.); and other means of electronic communication between two or more people in different locations, at least one of which is within the Hong Kong Special Administrative Region"

So a "platform" is not required for it to count. Discussing your condition with a doctor by messaging app and getting a prescription falls within these guidelines. ⚠️ But the same paragraph draws a line: the definition requires that at least one party is within the Hong Kong SAR; and paragraph 7 separately states that the guidelines are not intended to regulate overseas doctors practising telemedicine on patients in Hong Kong (see below).

The Council's study bears this out: over half of consumer respondents (50.5%) used instant messaging or video conferencing software, and practitioners likewise mainly used instant messaging (55%).

Who most needs to know this: anyone thinking "I'm not using a telemedicine app, I'm just messaging my doctor" — the same guidelines apply.


Which document governs? Two layers: professional guidelines, plus the premises code

The first layer is the professional guidelines issued by each of the two regulators; the second is the licensing code of the facility you attend. ⚠️ At the second layer this article cites only the Code of Practice for Clinics (2026 Edition); the Codes for private hospitals and day procedure centres also have 2026 editions whose telemedicine provisions are not cited here, so what follows concerns clinics.

Professional guidelines on remote consultation. Sources: Medical Council of Hong Kong, *Ethical Guidelines on Practice of Telemedicine* (last page prints December 2019); Chinese Medicine Practitioners Board, Chinese Medicine Council of Hong Kong, 《遙距醫療服務專業道德指引》 (last page prints September 2021). Retrieved 2026-08-31.
 Dedicated telemedicine guidelinesApplies to
Registered medical
practitioners
Medical Council,
promulgated December 2019
registered medical
practitioners
Chinese medicine
practitioners
Chinese Medicine Practitioners Board,
issued September 2021
registered and
listed practitioners

The second layer: where you are seen — the 2026 Code of Practice for Clinics

⚠️ Besides the personal professional duties of the doctor or practitioner, the licensed clinic providing the service has duties of its own. Section 3.10, "Telemedicine", of the Department of Health's Code of Practice for Clinics (PHF(E) 31A, 2026 Edition), from the English original:

3.10.2 Where telemedicine service is provided, policies and procedures must be in place to ensure the overall standard of care delivered by telemedicine is not compromised as compared with in-person service.

3.10.3 All staff providing telemedicine service must have the necessary qualification and competence. Staff and patients must be able to identify each other in each encounter.

3.10.4 The facility must have policies and procedures to safeguard privacy and security of data and records for telemedicine service.

Why does this layer matter? Because it is the facility's duty, enforced through licensing — so even where no individual can be identified as responsible, the licensed clinic itself has a code to follow.

The Consumer Council's telemedicine study page bears this out; its scope is defined as: "among the 13 categories of healthcare professional requiring statutory registration to practise in Hong Kong, this study covers only Western medicine practitioners and Chinese medicine practitioners, who are currently regulated by telemedicine guidelines."

⚠️ In other words: those regulated by telemedicine guidelines are Western and Chinese medicine practitioners; the other 11 categories of statutorily registered healthcare professional were not covered by that study.

What do the Chinese medicine guidelines say?

The Board's guidelines open with scope and definition:

"telemedicine, whether charged for or not, means diagnosis, treatment and related medical acts conducted between practitioner and patient by any mode other than in-person consultation, including but not limited to telephone, email, applications and social media. Such acts include diagnosing and treating patients, giving medical advice and prescribing Chinese medicines."

Several principles echo the Western medicine guidelines:

  • Equal professional responsibility: a practitioner conducting telemedicine should 「負起與當面診症同等的專業責任」.
  • Not merely to save money:遙距醫療不應純粹因成本效益因素而作為與病人面診的替代安排」 — almost the same sentence as the Medical Council's paragraph 20.
  • Know your limitations: practitioners should fully understand the limitations and risks of the mode and equipment used, "for example the inability to examine the patient physically, such as pulse-taking", and ensure the overall standard of care is "no worse than in an in-person consultation".
  • First consultation in person where possible: telemedicine "is more suitable for patients whose condition is stable and whose physical state the practitioner clearly understands"; "practitioners are advised to conduct a first consultation in person where possible".
  • Stop if the condition changes: where a patient "is unsuitable for telemedicine, the practitioner should arrange an in-person consultation or refer them to another physical healthcare facility".
  • Cross-boundary practice: practitioners must "ensure they hold qualifications to practise telemedicine in the jurisdiction where the patient is".

Informed consent must cover five things (the guidelines' wording): "how telemedicine works and its limitations, such as the possibility of technical failure and the risk of privacy breach; other suitable alternatives; privacy protection measures; the operation of the communication system; and the arrangements for issuing prescriptions."

On prescriptions and children, the Chinese medicine guidelines are more specific:

  • A prescription "should be issued to the patient, though it may be in electronic form".
  • ⚠️ Under 16: "a consultation for a child under 16 requires the guardian's informed consent"; and on prescribing, "a child under 16 should be consulted and prescribed for only with a guardian present".
  • Duties on delivery: where medicine is couriered, the practitioner "should mark the patient's name and address on the package, properly separate packages for different prescriptions within one parcel where applicable, and enclose the prescription, to prevent error"; has a duty to remind the patient or carer, on receipt, to check the information on the packaging and "confirm it is correct and the packaging intact"; and "should also tell the patient what to do if anything is abnormal about the delivered medicine".
  • Sick notes: a registered practitioner "may consider issuing a sick leave certificate electronically".

Practising certificates may be displayed electronically. The Code of Conduct for registered Chinese medicine practitioners (fourth revision, December 2025) states: "the practising certificate must be displayed conspicuously at the practice premises or clinic, physically or electronically, but must be clear and readily accessible" — ⚠️ but that is a rule about display at the practice premises; it does not make "show me your certificate on camera" the officially prescribed method of verifying identity. To confirm a practitioner's identity, the reliable route is to search the Chinese Medicine Council's registers of registered and listed practitioners; in a remote consultation both parties also have a duty to verify each other's identity.

Breach of the code "may constitute professional misconduct leading to disciplinary inquiry by the Board under section 98 of the Chinese Medicine Ordinance".

What do the Medical Council's guidelines actually say?

Ten passages that set what you can reasonably expect. The guidelines are in English and are quoted here from the original.

One. The standard does not drop because there is a screen. (paragraph 11)

"Standards of care that protect patients during face-to-face medical consultations apply equally to telemedicine."

Two. Where a physical examination is needed, the doctor should stop. (paragraph 24)

"If a physical examination is likely to add critical information, the doctor should not proceed until a physical examination can be arranged."

Three. It is not to be treated as the cheap option. (paragraph 20)

"The doctor must be satisfied that the patient is suitable for a telemedicine interaction… Telemedicine must not be viewed as a cost-effective substitute for in-person consultation with patients."

Four. A prior in-person relationship is safer, but is not mandatory. (paragraph 16, and Q&A item 4)

"It is advisable to practise telemedicine only in cases in which a prior in-person relationship exists between a doctor and a patient." Q&A item 4: "An in-person consultation prior to teleconsultation is advisable but not mandatory.…the doctor must take appropriate steps to establish a credible doctor-patient relationship with the patient before practising telemedicine."

⚠️ "Advisable but not mandatory" is the original wording — so a first consultation by telemedicine is not a breach, but the guidelines place the gatekeeping duty on the doctor.

Five. Prescribing has conditions, especially the first time; and delivery carries a legal risk. (paragraphs 25 and 26; Q&A item 11)

⚠️ Take one sentence first. Q&A item 11:

"Dispensation of dangerous drugs to a patient through a third party, such as a courier, may be in breach of the Pharmacy and Poisons Ordinance, Cap. 138, Laws of Hong Kong."

(In plain terms: dispensing dangerous drugs through a courier or other third party may breach the Pharmacy and Poisons Ordinance, Cap. 138.)

The same item also cautions doctors to exercise care when exporting pharmaceutical products to countries or places whose laws and registration systems differ from Hong Kong's.

"A doctor may prescribe for a patient via electronic means only when he has adequate knowledge of the patient's health… A doctor must consider: (a) the limitations of the medium… (b) the need for physical examination or other assessments; and (c) whether he has access to the patient's medical records." "Before prescribing any medicine for the first time to the patient, it is advisable for the doctor to have an in-person consultation with that patient."

Six. Data must be encrypted; recording needs prior consent. (paragraph 34; Q&A item 8)

Paragraph 34: "Data obtained during a telemedical consultation must be secured through encryption and other security precautions must be taken to prevent access by unauthorized persons." Q&A item 8: a doctor "should make an audio and/or video recording of a teleconsultation only if he has obtained the patient's prior consent. It is a must, instead of a matter of courtesy… a doctor should always record the consent in the patient's medical record."

Seven. Informed consent is spelled out in detail. (paragraph 23)

"…including how telemedicine works, its limitations and adequacy to meet the desired standard of care, other suitable alternatives available, privacy concerns, the possibility of technological failure including confidentiality breaches, protocols for contact during virtual visits, prescribing policies, and coordinating care with other healthcare professionals."

Eight. If the connection is too poor to meet the standard, it must be terminated. (paragraph 38)

"If technical and environmental limitations affect the quality of a telemedicine consultation such that minimum standards cannot be met, the consultation must be terminated and alternatives must be considered."

Nine. If something needs prompt attention and an in-person consultation cannot be arranged, you should be told to see a doctor nearby. (paragraph 22)

"…if specific medical advice or treatment is required and in-person consultation cannot be promptly arranged, patients should be advised to consult doctors in the vicinity."

The same paragraph also states that providing general information about a condition is acceptable, and that first-aid information may be given in an emergency.

Ten. Do not use email for anything urgent. (paragraph 37)

"…the doctor should advise patients not to use email if urgent advice is required."

What happens on breach? Paragraph 9: "Contravention of these ethical guidelines may render a doctor liable to disciplinary proceedings."


Two limits on these guidelines you must know

⚠️ One: they say of themselves that they are not a legal document. Paragraph 5: "Given the diversity of telemedicine settings, these ethical guidelines aim to be broad and generic in nature since telemedicine is still in the developing stage in Hong Kong. This is not a legal document…"

⚠️ Two: they do not reach overseas doctors. Paragraph 7: "These ethical guidelines are not intended for regulation of overseas doctors who practise telemedicine on patients in Hong Kong. However, the Medical Council may report any person, who not being a registered medical practitioner (or exempted from registration) practises telemedicine on patients in Hong Kong, to the relevant professional body and/or law enforcement agency for investigation and prosecution."

In one line: if the person on the other side of the screen is not a Hong Kong registered doctor, the disciplinary machinery in these guidelines essentially does not cover them — what the Medical Council can do is refer the matter to the relevant professional body and/or a law enforcement agency. So "who are they, and where are they registered" is the first question to ask before booking.

There is a further layer: the Consumer Council points out that the current framework does not even cover every platform — "the current regulatory framework and guidelines cover only private healthcare facilities and Western and Chinese medicine practitioners among telemedicine providers, and not platforms operated by non-private-healthcare-facility operators and insurers."


What did the Consumer Council find across 19 providers?

The study was published on 19 August 2025. Method and denominators: a consumer survey of 400 users and 440 non-users; a practitioner survey of 833; a trader survey of 14 providers; and examination of the websites, promotional material and apps of 19 providers, or telephone/online enquiries with them.

Main findings of the Consumer Council's study “Trust and Innovation: Enhancing Telehealth Governance”. Source: Consumer Council press release, 19 August 2025, retrieved 2026-08-30. Denominators in the right column; "practitioners" means Western and Chinese medicine practitioners together.
FindingFigureDenominator
No clear refund arrangement where the
practitioner considers the patient
unsuitable for telemedicine
1519 providers examined
Differing standards for which conditions
are suitable for telemedicine
1619 providers examined
Excluding legal liability through
terms of service
819 providers examined
─ of which, disclaiming liability for
financial loss from system failure
1of those 8
Claiming the service "should not be
regarded as diagnosis or treatment"
419 providers examined
No terms of service online319 providers examined
No terms of service for telemedicine at all414 traders surveyed
Greatest concern: inability to
examine physically
44.5%
/ 77%
consumers surveyed /
practitioners surveyed
Concern about medical incident
or misdiagnosis
27.8%
/ 41%
consumers surveyed /
practitioners surveyed
Consider telemedicine services
need improvement
99.5%practitioners surveyed
Consider strengthening guidelines
very important
66.5%practitioners surveyed
Complaints citing inability to provide
the service or refunds
57.1%telemedicine complaints
received by the Council
Consider platform technical support
insufficient or unclear
17.9%consumers surveyed

⚠️ Two things easily misread:

One: "15 with no refund arrangement" is a narrowly defined statement. The Council's wording is 「15 個沒有明確指明在中西醫認為病人不適合進行遙距醫療情況下的退款安排」 — that is, the specific situation where the practitioner concludes you are unsuitable for telemedicine, not "no refund policy at all".

Two: 57.1% is a proportion, not a number of cases. The press release states that this is the share accounted for by the most common reason among the telemedicine complaints the Council received, and publishes no total; this article cites no case count.

Other findings worth knowing: 73% of consumer respondents who had used telemedicine had used it more than once; 73.7% of private practitioners who had provided remote consultations continued to do so after the pandemic. On privacy, 40.3% of consumers and 42.7% of private practitioners worried that consultations might be tracked and monitored, and 29.9% of consumers worried that platforms collect excessive personal and payment data.


Will insurance pay? Does eHealth hold your records?

Two questions, and both answers are "not necessarily".

Insurance: the Council is direct — "unlike other common outpatient services, whether insurance covers telemedicine depends on how each insurer designs its medical plan." So this must be asked policy by policy; there is no general answer. One of the Council's recommendations is precisely that insurers "consider extending medical insurance cover more broadly to telemedicine".

eHealth: the Council records two practitioner concerns — the inability to examine physically (consumers 44.5% / practitioners 77%) and the lack of medical history — noting that upload rates from the private sector have long been low: "as at November 2024, over 99% of the interoperable electronic health records on eHealth came from public healthcare institutions".

⚠️ How to read that 99% accurately: it describes the distribution of the sources of records on eHealth, not the probability that your doctor will see no records of yours — the doctor consulting you may hold their own clinic's history, or receive reports by routes outside eHealth. This article converts the proportion into no individual-level probability.

This is exactly why paragraph 25 of the guidelines tells doctors to consider "whether he has access to the patient's medical records".

On the public side: Hospital Authority Board Paper No. 377 (26 March 2026) lists the launch dates of HA Go's modules, among them 「遙距醫療(2020 年 10 月)」 — public telemedicine services have been provided through HA Go since October 2020 (HA Go itself launched on 12 December 2019; the same paper records over 3.5 million registered users as at January 2026). ⚠️ This article cites no specialties, eligibility or charges for public telemedicine — HA Go's service page lists "telemedicine" as an item without printing those details.


Ask about these

Six questions before booking; the answers to the first four should be visible before you book.

  1. Which doctor or practitioner? What is their Hong Kong registration number? Do they know where you are? ⚠️ Both sets of guidelines carry the same cross-boundary rule: the Medical Council's paragraph 6 requires a doctor to "comply with the law governing the practice of medicine in all jurisdictions where patients receive his medical services", and paragraph 14 requires a doctor treating or prescribing through telecommunication systems to "ensure that he possesses appropriate licensure in all jurisdictions where patients receive his medical services"; the Chinese medicine guidelines likewise require practitioners to hold qualifications to practise telemedicine in the jurisdiction where the patient is. So if you are outside Hong Kong when consulted, this rule concerns you. To check identity, search the Chinese Medicine Council's registers (see the next question).
  2. If a Chinese medicine practitioner: registered or listed? The registers and the documents displayed differ — a registered practitioner displays a practising certificate, a listed practitioner posts a listed practitioner notice; the Chinese Medicine Council keeps separate registers for each. The Board's telemedicine guidelines also require both parties to "use effective means to identify and verify each other before starting".
  3. Where are the terms of service, and what do they say about refunds? Ask one question in particular: "if the doctor concludes I am not suitable for telemedicine, what happens to the fee?" — that is exactly what 15 of the 19 did not spell out.
  4. Which situations will they not handle? 16 of the 19 had differing standards for which conditions suit telemedicine.
  5. Can they prescribe? How is it delivered? Will they prescribe on a first consultation? The guidelines say an in-person consultation before prescribing for the first time is "advisable".
  6. Does my policy cover this? There is no general answer; ask your insurer.

One thing to remember during the consultation: if the connection is too poor to hear or see properly, paragraph 38 states the consultation "must be terminated" and alternatives considered — you can raise it yourself.


Frequently asked questions

  • Is the standard of care lower in a remote consultation? Paragraph 11 of the Medical Council's guidelines states: "Standards of care that protect patients during face-to-face medical consultations apply equally to telemedicine."
  • Can a first consultation be by video? Paragraph 16 says a prior in-person relationship is "advisable"; Q&A item 4 states it is "advisable but not mandatory". Without a prior in-person consultation the doctor must take appropriate steps to establish a credible doctor-patient relationship, and must consider the need for physical examination or other assessments and whether they can access the patient's medical records. The Chinese medicine guidelines likewise advise conducting a first consultation in person where possible.
  • When should the doctor stop? Paragraph 24: if a physical examination is likely to add critical information, the doctor should not proceed until one can be arranged. Paragraph 38: if technical and environmental limitations mean minimum standards cannot be met, the consultation must be terminated and alternatives considered. Paragraph 22: if specific advice or treatment is required and an in-person consultation cannot be promptly arranged, the patient should be advised to consult a doctor in the vicinity.
  • Do Chinese medicine practitioners have their own telemedicine guidelines? Yes. The Chinese Medicine Practitioners Board of the Chinese Medicine Council issued 《遙距醫療服務專業道德指引》 in September 2021, applying to both registered and listed practitioners and covering definition, principles, clinical context, informed consent, prescribing, sick leave certificates, records and patient privacy. It states that practitioners should bear the same professional responsibility as in an in-person consultation. The general requirements of the Code of Conduct for registered practitioners (fourth revision, December 2025) also apply, and breach may lead to a disciplinary inquiry by the Board under section 98 of the Chinese Medicine Ordinance.
  • Do the Medical Council's guidelines reach overseas doctors? What if I am outside Hong Kong? Paragraph 7 states they are not intended to regulate overseas doctors practising telemedicine on patients in Hong Kong; but the Medical Council may report a person who, not being a registered medical practitioner (or exempted), practises telemedicine on patients in Hong Kong to the relevant professional body and/or law enforcement agency for investigation and prosecution. Conversely, paragraphs 6 and 14 require a doctor to comply with the law and hold appropriate licensure in every jurisdiction where the patient receives the service; the Chinese medicine guidelines have the same requirement.
  • Are platforms regulated? The Consumer Council points out that the current framework and guidelines cover only private healthcare facilities and Western and Chinese medicine practitioners, and not telemedicine platforms operated by non-private-healthcare-facility operators and insurers. However, where the service is provided by a licensed clinic, section 3.10 of the Code of Practice for Clinics (2026 Edition) imposes facility-level duties: policies and procedures ensuring the overall standard of care is not compromised compared with in-person service; staff and patients being able to identify each other in each encounter; and policies and procedures safeguarding the privacy and security of data and records.
  • Is there any risk in having medicine delivered after a video consultation? Medical Council Q&A item 11 states that dispensing dangerous drugs to a patient through a third party such as a courier may be in breach of the Pharmacy and Poisons Ordinance (Cap. 138), and that a doctor should also exercise caution when exporting pharmaceutical products to a jurisdiction whose legislation and registration system differ from Hong Kong's. The Chinese Medicine Practitioners Board guidelines require a courier delivery to carry the name and address on the package, to keep packages for different prescriptions separate with the prescription attached, and to remind the patient to check the details and that the packaging is intact.
  • Will my medical insurance cover a remote consultation? Can the consultation be recorded? On insurance, the Consumer Council notes that whether cover extends to telemedicine depends on how each insurer designs its plan; there is no single answer, and you must ask your insurer. On recording, Medical Council Q&A item 8 states that a doctor may make an audio or video recording only after obtaining the patient's prior consent, stressing that this is a requirement rather than a courtesy; consent may be given orally but should be recorded in the patient's medical record.

Also in this series:

  • What the words "specialist doctor" mean in law, and what a referral letter actually buys: "What do the words 'specialist doctor' mean in law? A full breakdown of two registers, seven tiers of provisions, and what a referral letter actually buys"
  • How to book a Family Medicine Clinic, the public route: "How do you book a Family Medicine Clinic (formerly GOPC)? Two routes, no fixed slot-release time, and caller ID required from 15 August"

What this article does not claim

  • It names, compares and rates no telemedicine provider. The Council's study refers to "19 providers examined" and "14 traders surveyed", and this article follows suit. The messaging-software names that appear come from the Medical Council's definition of "telecommunication systems", not from any trader named in the Council's results.
  • It cites no number of telemedicine complaints. The Council's press release publishes only the 57.1% proportion, with no total; case counts circulating informally have no first-hand source and are not used.
  • It does not cite the body text of CHOICE issue 587. That article's body did not display when opened on 30 August 2026; all figures come from the Council's press release of the same period.
  • It cites no specialties, eligibility or charges for public telemedicine. It cites only the launch date in the Hospital Authority Board paper (telemedicine module, October 2020) and HA Go's service page listing "telemedicine"; neither prints scope or charges.
  • It gives no URL for searching the register of medical practitioners. The Medical Council's register search page could not be opened from its Chinese homepage or two attempted paths on 30 August 2026; this site has a separate article on the two registers, linked above.
  • The Medical Council's telemedicine guidelines and their Q&A exist in English only. This English version quotes them from the English originals; the Q&A document itself prints no date, and none is attributed to it here.
  • It comments on no platform's privacy or security practices. The concern percentages the Council recorded (40.3% / 42.7% / 29.9%) are respondents' subjective concerns, not a technical assessment of any tool.
  • It cites no telemedicine provisions from the codes for private hospitals or day procedure centres. Only section 3.10 of the Code of Practice for Clinics (2026 Edition) was opened and cited; the other two codes were not checked provision by provision.
  • It converts eHealth's record-source proportion into no individual-level probability. "Over 99% from public healthcare institutions" describes the distribution of record sources.
  • It does not deal with telemedicine arrangements for the other 11 categories of statutorily registered healthcare professional. The Council's study covers only Western and Chinese medicine practitioners currently regulated by telemedicine guidelines, and this article makes statements about those two only.
  • It offers no medical advice and judges no condition suitable or unsuitable for remote consultation. The guidelines place that responsibility on the doctor and the practitioner; whether your situation suits is for the doctor to decide.

Provenance: compiled from professional codes, a statutory body's study and official publications; every figure is marked with its source, its denominator and the date the document itself prints.

Quotations from Chinese-language official documents and press materials appear in our own English translation; the original wording governs.

資料來源 (Sources)

Compiled by the editorial team from professional codes, a statutory body's study and official publications; every rule is attributed to its source. This is health information, not medical, legal or insurance advice.