Telemedicine has emerged as a significant modality of healthcare delivery globally, and Vietnam has been developing its regulatory framework to accommodate it. For Australian doctors who wish to provide telemedicine services to patients in Vietnam—whether residing in Australia or physically present in Vietnam—understanding the current legal landscape is essential. This guide examines the telemedicine regulatory framework in Vietnam and its implications for Australian physicians.
Vietnam’s Legal Framework for Telemedicine
Vietnam does not yet have a comprehensive standalone telemedicine law, but telemedicine activities are addressed within the Law on Medical Examination and Treatment 2023 (the “2023 Law”) and Circular 30/2023/TT-BYT. The 2023 Law defines Telemedicine is a form of clinical service rendered by application of telecommunication equipment and information technology without direct contact between practitioners and patients
Under the current framework, a physician providing medical consultation, diagnosis, or treatment recommendations to patients physically located in Vietnam is deemed to be practicing medicine in Vietnam, regardless of where the physician is physically located. This means Australian doctors providing telemedicine services to Vietnamese patients are subject to Vietnamese licensing requirements.
Does an Australian Telemedicine Doctor Need a Vietnamese License?
The Vietnamese MOH’s position, consistent with the 2023 Law, is that any individual providing medical services (including remote consultation) to patients in Vietnam must hold a valid Vietnamese medical practice license. An Australian doctor providing telemedicine services to Vietnamese patients without this license would technically be in violation of Vietnamese healthcare law.
This requirement applies regardless of the platform used (app, video call, phone), the duration of the consultation, or whether fees are charged. The key trigger is that a Vietnamese patient is receiving medical advice or treatment decisions from the practitioner.
The Telemedicine Licensing Pathway for Australian Doctors
Australian doctors wishing to legally provide telemedicine services to Vietnamese patients must:
- Complete the standard credential recognition process (AHPRA registration recognized by Vietnamese MOH under Article 29 of the 2023 Law).
- Obtain a Vietnamese medical practice license under Article 30.
- Be affiliated with or employed by a Vietnamese-licensed healthcare facility (under current Vietnamese law, individual practitioners generally cannot hold an operating license independently—services must be delivered through a licensed facility).
- Ensure the telemedicine platform complies with Vietnamese regulations on electronic health data, patient privacy, and cybersecurity.
The employing or affiliated Vietnamese facility must itself have a healthcare operating license that covers telemedicine or remote consultation services.
Practical Challenges and Workarounds
Given the current state of Vietnamese telemedicine regulation, Australian doctors face several practical challenges:
- The regulatory framework for cross-border telemedicine (doctor in Australia, patient in Vietnam) remains ambiguous;
- Vietnamese cybersecurity and data localization laws may require patient health data to be stored on servers within Vietnam;
- Reimbursement frameworks for telemedicine services are still developing under Vietnamese health insurance regulations;
- Platform compliance with both Australian Privacy Act requirements and Vietnamese cybersecurity law requires legal review.
Some international healthcare groups are navigating this space by having the telemedicine service formally delivered through a licensed Vietnamese facility (physical or online), with Australian doctors as affiliated practitioners—effectively anchoring the service in the Vietnamese licensing framework.
Future Regulatory Developments
Vietnam’s MOH has signaled intent to develop more specific telemedicine regulations as part of the broader digital health transformation agenda. Draft regulations currently under development may include specific licensing categories for telemedicine providers, cross-border consultation protocols, and data standards. Australian doctors interested in the Vietnamese telemedicine market should monitor these developments closely, as the regulatory landscape is expected to evolve significantly over 2025–2026.
Conclusion
Australian doctors providing telemedicine services to Vietnamese patients currently operate in a framework that technically requires a Vietnamese medical practice license and facility affiliation. While cross-border telemedicine regulation is still developing, proactive compliance through the standard licensing pathway is the safest approach. TTVN Legal monitors Vietnamese digital health regulations and advises Australian telemedicine providers on compliant market entry strategies.
Need legal assistance with medical licensing in Vietnam? Contact TTVN Legal today. 101 Nguyen Van Thu, Tan Dinh Ward, Ho Chi Minh City | +84 349661336 | tham@ttvnlegal.com.vn | https://ttvnlegal.com.vn/
