In Pakistan, every family has a designated hakim and at least one relative who dabbles in WhatsApp diagnoses, offering unverified remedies and unsolicited second opinions. Against this backdrop, digital health can easily be dismissed as just another fad, a shiny new layer over a culture of informal care, self-medication and a general mistrust of formal medical systems.
However, with a total population of 253 million, 116 million being internet users, Pakistan’s digital transformation is no longer theoretical, it is already underway. From banking to transport to food delivery, technology has disrupted sectors once thought immune to change; healthcare, though slower to evolve, is poised to follow. The demand is real, the reach is wide, and the opportunity to modernise healthcare has never been greater. The pressing question is how fast regulation and infrastructure can catch up.
There is no doubt that Pakistan is in dire need of scalable digital health platforms. Our health systems are overburdened, underfunded and deeply unequal. Public hospitals remain overcrowded, rural health units are understaffed, and private care is unaffordable for much of the population. Meanwhile, mobile phones with internet access are nearly everywhere, with social media platforms serving as first points of care, however risky that may be.
Enter digital health platforms: whether by virtue of offering AI-assisted triage or diagnostic services, telemedicine consults, e-pharmacy services or electronic medical records, these platforms have the potential to fill critical gaps. They can extend services to remote areas, reduce unnecessary visits to understaffed clinics, ensure continuity of care, and empower patients with information and agency.
The innovations already exist; the issue is that they currently operate in a legal grey area.
Where Are We Right Now?
Pakistan’s digital health legal framework may be patchy, but to its credit, the country has not been sitting idle. The National Digital Health Framework (NDHF 2022-2030), developed by the Ministry of National Health Services, Regulations and Coordination in collaboration with provincial health ministries, outlines a strategic roadmap for modernising healthcare delivery across the country. With a strong focus on accessibility and innovation, it aims to:
- Share digital health knowledge across the country;
- Advance the implementation of national digital health strategies;
- Strengthen digital health governance at national and provincial levels;
- Advocate people-centered digital health systems;
- Create a national, interoperable digital health ecosystem in Pakistan.
This vision sets the tone for future reform, but real progress will depend on how other laws evolve to support it.
- AI Diagnostics, E-Pharmacies and the Role of DRAP
Globally, AI tools that perform diagnostics or triage as a first line of digital health checks are increasingly treated as “Software as a Medical Device” (SaMD). Pakistan’s own Drug Regulatory Authority of Pakistan Act 2012 (DRAP Act), read with the Medical Devices Rules 2017, is aligned with this global thinking, treating software with diagnostic elements as medical devices. This reflects a growing recognition that AI in healthcare is not just a tech trend, it’s a regulatory reality.
The same regulator, DRAP, is also monitoring the rise of e-pharmacies. Any digital platform involved in the sale or delivery of medicine, prescription or over-the-counter, must comply with DRAP’s licensing rules. These include requirements for pharmacist oversight, proper storage conditions, sale record-keeping and advertising standards. DRAP is clear that digital does not mean exempt from compliance.
- Data Protection: A Turning Point Waiting to Happen
The long-anticipated Personal Data Protection Bill 2025, stuck on the legislative floor since 2023, could be a game-changer for digital health. The Bill recognises health data as sensitive personal data, requiring informed consent for collection and use, along with mandatory data breaching reporting obligations.
Importantly, once enacted, the Bill proposes the establishment of an autonomous National Commission for Personal Data Protection (NCPDP) to oversee compliance and enforcement. For digital health platforms, this legislation could mark a turning point, offering clarity on data responsibilities and privacy and paving the way for more secure, trustworthy interactions with users who share personal data.
In the interim, however, the Protection of Electronic Crimes Act (PECA 2016), originally enacted to curb cybercrime, remains the default framework for dealing with unauthorised access, misuse, or breach of digital health data. While PECA is punitive by design, it is an inadequate legal instrument for regulating health-tech platforms that require a more nuanced, rights-based data governance. Together, PECA and the pending Bill highlight the need for a coherent legal framework that balances innovation with user protection, ensuring accountability for data handlers as well as meaningful recourse for end users in cases of harm.
- Doctors, Clinics & the Federal-Provincial Divide
While healthcare delivery is a provincial subject post-18th Amendment of the Constitution of Pakistan, the regulation of medical practitioners, even in the context of digital healthcare, remains a federal responsibility. Any doctor practising via a digital platform must be registered with the Pakistan Medical & Dental Council (PMDC) as per the PMDC Act 2022. This means that a doctor in Gilgit consulting a patient in Multan via a health app must be registered with PMDC, with said information being verifiable.
Meanwhile, provincial health commissions step in to regulate where and how telemedicine services operate, approving facilities, setting service standards, and issuing operational guidelines. So, while doctors need federal approval, clinics and healthcare facilities (virtual or otherwise) need provincial approval, raising the bar for legal compliance but also creating ambiguity.
As digital consultations grow, there is a need for clearer licensing standards, defined service protocols and shared accountability frameworks across provinces.
Toward a Unified Legal Architecture
While recent reforms signal that Pakistan is warming up to digital healthcare, the current legal regime feels like it is still playing catch-up. Health-tech startups and investors must navigate a regulatory maze: DRAP compliance for medical devices and pharmacies, PMDC registration for practitioners (doctors, healthcare service providers), provincial approvals for healthcare facilities, and a pending data protection regime. This fragmented structure currently exists without a unified entry point, raising compliance costs and diluting accountability, putting both users and providers at risk.
What Pakistan urgently needs is a dedicated, standalone legal framework for digital health, one that recognises the unique nature of platform-based care and provides a one-window regulatory solution. Such a framework should consolidate licensing, set quality benchmarks, streamline registration processes and offer clarity around jurisdiction, enforcement and liability.
The goal is not to reinvent the regulatory wheel. Countries like the Philippines, India and Rwanda offer helpful models with centralised digital health ecosystems, unified health identification procedures, consolidated records and enforceable data privacy laws.
Connecting the Dots
Pakistan has all the right ingredients: a young, tech-savvy population, high mobile penetration and growing policy awareness. However, without a coherent legal architecture, digital health will remain a side hustle to an already struggling system.
The law now needs to do what digital health promises: connect the dots, simplify the journey and restore confidence for innovators and patients alike.
