Russian Telemedicine Law

Legislative Framework

Russian telemedicine law is governed primarily by the Federal Law on the Fundamentals of Health Protection (No. 323-FZ of 21 November 2011), as amended by Federal Law No. 242-FZ of 29 July 2017, which introduced comprehensive provisions on telemedicine technologies (telemeditsinskie tekhnologii). The 2017 amendments, which entered into force on 1 January 2018, established the legal basis for remote medical consultations and laid down the regulatory architecture for digital healthcare services.

The law defines telemedicine technologies as information technologies ensuring remote interaction between medical workers, patients, and healthcare information systems. The primary legal framework is supplemented by the Federal Law on Personal Data (No. 152-FZ of 27 July 2006), which governs the processing of medical data as a special category of personal data, and the Federal Law on Information and Information Technologies (No. 149-FZ of 27 July 2006), which regulates electronic document management and information systems.

The Doctor-to-Doctor Limitation

The 2017 legislation adopted a conservative approach, primarily permitting doctor-to-doctor consultations rather than direct doctor-to-patient consultations. Under Article 36.2 of Law No. 323-FZ, remote consultations are permitted between medical professionals for the purpose of establishing a diagnosis, determining a treatment plan, and monitoring treatment outcomes. A remote consultation between a doctor and a patient is permitted only after an in-person examination has established a preliminary diagnosis and prescribed a treatment course.

This limitation reflected concerns about patient safety, the reliability of remote diagnosis, and the professional autonomy of the medical profession. The doctor-to-patient telemedicine encounter is confined to: follow-up consultations for patients with an existing diagnosis; monitoring of treatment effectiveness; and preventive health consultations. The initial diagnosis must be made in person. This restrictive approach distinguished Russian telemedicine regulation from more permissive regimes in the United States and European Union, where direct-to-patient telemedicine has been more broadly adopted.

Electronic Prescriptions

The 2017 amendments partially liberalised the prescription regime. Article 74 of Law No. 323-FZ permits the issuance of electronic prescriptions (elektronnye retsepty) under certain conditions. Electronic prescriptions may be issued for medications included in a list approved by the Ministry of Health. The prescription must be signed with an enhanced qualified electronic signature (usilennaya kvalifitsirovannaya elektronnaya podpis) of the attending physician.

Implementation of electronic prescriptions has proceeded unevenly across Russian regions. Moscow has been the most advanced, integrating electronic prescription services with the Unified Medical Information and Analytical System (EMIAS). Other regions have adopted electronic prescription systems more slowly, constrained by infrastructure limitations and the fragmentation of regional healthcare information systems. The prescription of narcotic and psychotropic substances remains subject to paper-based procedures.

Gosuslugi Integration

The Unified Portal of State and Municipal Services (Gosuslugi) has become the primary digital platform for telemedicine services. Under Federal Law No. 242-FZ, Gosuslugi functions as a centralised authentication and service delivery platform for state-funded healthcare. Patients may access telemedicine consultations through the Gosuslugi portal, which provides identity verification, appointment scheduling, electronic prescription management, and access to electronic health records.

The integration of telemedicine with Gosuslugi was accelerated by the Digital Economy national programme and the regional healthcare modernisation initiatives. By 2025, more than 70% of Russian regions had integrated their healthcare information systems with the Gosuslugi platform. The platform processes more than 100 million healthcare-related transactions annually, including appointment bookings, sick leave certificates (elektronnye listki netrudosposobnosti), and electronic referrals.

COVID-19 Temporary Relaxations

The COVID-19 pandemic produced significant temporary relaxations of the telemedicine regime. In March 2020, the Ministry of Health issued Decree No. 198n, temporarily permitting remote diagnosis and prescription for COVID-19-related conditions without a prior in-person consultation. The relaxation applied to patients with confirmed or suspected COVID-19, including the issuance of electronic prescriptions, electronic sick leave certificates, and remote monitoring of treatment outcomes.

These temporary measures substantially expanded the scope of telemedicine. Private telemedicine providers experienced rapid growth, with the Russian telemedicine market expanding by 270% in 2020. The State Duma considered but did not adopt legislation permanently removing the doctor-to-patient limitation. After the pandemic emergency period ended in 2022, many of the temporary relaxations were withdrawn, though the experience accelerated digital health transformation and demonstrated the feasibility of broader telemedicine adoption.

Data Protection and Privacy

Telemedicine services are subject to enhanced data protection requirements. Medical data constitutes a special category of personal data under Article 10 of the Personal Data Law, which prohibits processing of data concerning health except in specifically enumerated circumstances. Telemedicine platforms must obtain the patient’s written consent to data processing, implement organisational and technical measures to protect data, and comply with the data localisation requirement under Article 18, which mandates storage of personal data on servers physically located within the Russian Federation.

The Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) enforces personal data requirements in the healthcare sector. Telemedicine service providers must register as operators of personal data, maintain data processing records, and notify Roskomnadzor of any data breaches. Violations carry administrative fines of up to 75,000 RUB for officials and up to 500,000 RUB for legal entities, with enhanced penalties for repeated violations.

Licensing of Telemedicine Services

Medical activities in Russia, including telemedicine services, require a licence under the Federal Law on Licensing (No. 99-FZ of 4 May 2011). The Licensing Regulation on Medical Activities, approved by Government Decree No. 291 of 16 April 2012, specifies that telemedicine services are considered a component of medical activities and must be licensed within the general medical licensing framework. The licensing authority for medical activities is the Federal Service for Surveillance in Healthcare (Roszdravnadzor).

Licensing requirements include: the availability of premises and equipment meeting established standards; the employment of medical personnel with the required qualifications and certificates; compliance with medical record-keeping requirements; and the existence of an internal quality control system. Telemedicine-only providers must satisfy all standard medical licensing requirements, including the physical premises requirement, which has been a significant barrier to the development of pure-play telemedicine companies. The Government has considered revisions to the licensing framework to accommodate telemedicine-only models but has not adopted them as of early 2026.