Is teleradiology legal in India? The rules that apply in 2026

Teleradiology is legal in India. The National Medical Commission (NMC) has issued no regulation that permits or prohibits remote reporting by name, and none that sets conditions specific to it.⁴ What applies is the general law of medical practice: the radiologist must be a registered medical practitioner, must personally interpret the study, must take responsibility for the report under their own name and registration number, and the hospital’s treating doctor remains responsible for the patient. Every large teleradiology service in India, and the IRIA’s own 2022 White Paper on Teleradiology, works from that basis.¹⁴

The one official statement often quoted against teleradiology is an RTI reply from the NMC dated 3 January 2025. It says the Telemedicine Practice Guidelines do not permit a registered medical practitioner to sign pathology and radiology laboratory reports “via remote authentication without physical presence and supervision”.² Read in full, the reply addresses ghost-signing: a doctor authenticating a report produced by somebody else. It does not address a registered radiologist reading the images and writing the report.

The Telemedicine Practice Guidelines 2020

The Telemedicine Practice Guidelines (TPG) do not mention radiology. They were issued in March 2020 by the Board of Governors in supersession of the Medical Council of India and now sit under the NMC. They apply to allopathic registered medical practitioners (RMPs), cover consultations by text, audio and video, and allow an RMP to consult patients “across the entirety of the nation”. They exclude tele-surgery, research and education, and consultations with patients outside India. Nowhere do they refer to diagnostic reporting, image interpretation or PACS.¹

The closest fit in the TPG for a teleradiology read is the RMP-to-RMP consultation, where a treating doctor seeks the opinion of another doctor. The hospital’s doctor keeps responsibility for the patient; the radiologist gives a specialist opinion on the images. Raydiac follows that model: the report goes back to the referring clinician at the site.

The NMC RTI reply of 3 January 2025

The RTI reply is not a regulation. It is an answer to a question, filed in November 2024, about whether the TPG allow an RMP to sign pathology and radiology reports remotely. The NMC Ethics section answered “No” and added that the guidelines “do not address” the question.² The applicant’s stated target was ghost-signing of laboratory reports with scanned signatures, and the applicant himself distinguished that from legitimate doctor-to-doctor consultation on transferred images.²

A hospital can tell the two apart with four questions. Do the viewer logs show the reporting radiologist opened this study? Did that radiologist author the report text? Is the signature theirs, and cryptographic rather than an image? Does the report carry their name, qualification, registration number and council? Raydiac logs viewer events per study, has no sign-off-only workflow, and prints all four identity fields on every report. The radiologist page describes how a read is assigned and signed.

State registration and the inter-state grey zone

A radiologist must be registered with a State Medical Council or the NMC, and the report must carry the registration number. Registration has always been state-based, so a radiologist registered in Punjab reporting for a hospital in Kerala sits in a grey zone: the TPG allow consultation across the nation, but they leave inter-state jurisdiction for grievances unresolved.¹ Every teleradiology service in India operates inside that same grey zone.

Two things are changing it. The NMC opened registration on the National Medical Register (NMR) in August 2024. On 11 August 2026 it notified the draft Registration of Medical Practitioners and Licence to Practice Medicine (Amendment) Regulations 2026, which propose a centrally generated Unique ID making a doctor eligible to practise anywhere in India without fresh state registration, with NMR registration mandatory.⁶ Uptake is slow: about 1,800 doctors had completed NMR registration by December 2025, with roughly 30,000 applications pending.⁵ The regulations are a draft and have not been finalised.

Until they are, the practical mitigation is to verify the state registration against the Indian Medical Register, record the council, and show the council on every report. The guide on verifying NMC registration walks through the search and what to record.

Signatures on reports

No law prescribes a digital signature certificate for a radiology report. The Information Technology Act 2000 sets out which electronic signatures carry statutory equivalence to a handwritten one, and that is the frame a hospital should use when judging what a vendor puts on the report.⁷

Whatever the method, a report must carry the radiologist’s name, qualification, registration number, the council that issued it, and a timestamp. Raydiac signs every finalised report with the radiologist’s own Aadhaar eSign, adds a platform PAdES counter-signature and a QR verification page, and never prints a scanned signature image. The security page describes the signing chain and the audit trail behind it.

AERB: the hospital side

AERB obligations belong to the hospital, not to the remote radiologist. Every institution operating an X-ray or CT unit needs a Licence for Operation issued through the e-LORA portal under the Atomic Energy (Radiation Protection) Rules 2004; a CT installation also needs an AERB-approved Radiation Safety Officer, and radiation workers on site are declared and issued TLD badges.⁸ A reporting radiologist who never enters the radiation area has nothing to file. Raydiac records the site’s AERB licence number at onboarding as a legitimacy check. The AERB licence guide covers e-LORA, the RSO and renewals.

PC-PNDT: why obstetric ultrasound stays on site

Obstetric ultrasound cannot sensibly be reported remotely. The Pre-Conception and Pre-Natal Diagnostic Techniques Act requires every place with an ultrasound machine to be registered (Form A, five-year validity); section 3(3) bars conducting a pre-natal diagnostic technique anywhere other than the registered place; Rule 3(3)(1)(b) restricts who may scan a pregnant woman; Rule 10(1A) requires a declaration on each report; and Rule 9 requires a Form F for every woman scanned. Penalties under section 23 include imprisonment and removal from the medical register.⁹

The whole architecture assumes that the qualified person who conducts the scan, at the registered place, is the person who signs. A remote read of obstetric ultrasound is therefore either redundant, because a qualified doctor scanned and must already sign, or a cover for a technician-performed scan, which is itself an offence. Raydiac reports CT and MRI only and does not accept ultrasound. The PC-PNDT guide covers registration, Form F and the monthly returns.

Data protection

The Digital Personal Data Protection Act 2023 applies, with the DPDP Rules 2025 notified on 14 November 2025. The Data Protection Board provisions took effect on publication; consent manager rules follow about a year later (around 14 November 2026); the substantive obligations on notice, security safeguards, breach reporting, erasure, children’s data and cross-border transfer follow at eighteen months (around 14 May 2027).¹⁰ Until then the SPDI Rules 2011 under section 43A of the IT Act continue to apply. The hospital is the data fiduciary for its patients; a reporting platform is a data processor for the hospital’s diagnostic purpose and needs a written processor contract. The DPDP guide for hospitals sets out the safeguards, the 72-hour breach report and the penalties.

Records and retention

The operative code is still the MCI (Professional Conduct, Etiquette and Ethics) Regulations 2002. Regulation 1.3.1 requires indoor patient records to be kept for three years from the start of treatment; regulation 1.3.2 requires records to be supplied within 72 hours of a request from the patient, an authorised attendant or a legal authority.¹¹ The NMC’s Registered Medical Practitioner (Professional Conduct) Regulations 2023 were gazetted on 2 August 2023 and put on hold on 23 August 2023, so they do not change the position.¹² Raydiac keeps signed reports for eight years and images for 90 days hot, then according to each site’s contract, and can export both on request.

CDSCO and reporting software

A viewer and reporting platform is not a medical device unless it analyses images. The CDSCO Guidance Document on Medical Device Software (Doc No. CDSCO/MD/GD/MDSW/01/2026, circular dated 21 July 2026) lists, in section 5.2, software outside the Medical Devices Rules 2017: software that transfers, stores, archives and communicates data, and image management systems that display, annotate, manage and share images. The attached note says that if such a system adds image analysis as an aid to diagnosis, it may be a medical device. Computer-aided detection and AI triage tools are given as covered examples and fall in Class B to D, and there is no decision-support carve-out.¹³

Checklist: a hospital outsourcing reads

1. Confirm each reporting radiologist’s registration on the Indian Medical Register and keep a dated copy of the lookup; re-check annually.
2. Require every report to carry the radiologist’s name, qualification, registration number, council and timestamp, signed with a DSC or Aadhaar eSign rather than a scanned image.
3. Confirm the vendor has no sign-off-only workflow and can produce viewer logs showing who opened each study.
4. Sign a data processing agreement covering purpose limitation, security safeguards, sub-processors, breach cooperation and data location in India.
5. Agree retention and export: reports for at least three years, images at least until the hospital confirms archival, and export within 72 hours on request.
6. Keep the AERB licence current and give the vendor the licence number; keep obstetric ultrasound reporting on site.
7. Agree a service-level target per priority and a documented critical-results path with acknowledgement.

Checklist: a radiologist reading remotely

1. Hold a current State Medical Council or NMC registration and complete NMR registration as it becomes mandatory.
2. Open and read the full study yourself; never authenticate a report you did not write.
3. Sign with your own DSC or Aadhaar eSign; do not supply a scanned signature to anyone.
4. Carry professional indemnity and record the policy number with each hospital you report for.
5. Decline obstetric ultrasound and any ultrasound where you are not the named, registered person at the centre.
6. Report for a platform that keeps images and reports in India and logs access.

Position as of September 2026. The draft Unique ID regulations and the DPDP phased dates may change; check the primary sources before relying on either.