Telemedicine in clinics: regulations and practice in 2026

Telemedicine and video consultations are back on the agenda for Spanish healthcare management due to a combination of regulatory updates and public statements about organisational rollout. In September the BOE (Spain’s official gazette) published Order PJC/1001/2025, of 10 September, linked to developments of Real Decreto 589/2022, and at the regional level ORDEN 3/2026, of 9 September, of the Conselleria de Sanidad (Comunitat Valenciana) — which amends a previous administrative development order — has been circulated. At the same time, sector media have reported that the “hybrid” care model — coordinated in-person and virtual care — requires process changes and organisational evidence, not just technology, according to Redacción Médica and iSanidad. For the private practice, the immediate management effect is clear: review workflows, documentation, contracting and data protection compliance before generalising the video consultation.

What changes in the regulatory framework clinics should monitor

These recent publications do not, by themselves, create a single “telemedicine law” for the whole sector, but they do remind us that remote provision rests on general rules and on administrative developments that can affect organisation, accreditation or procedures. Order PJC/1001/2025 published in the BOE is framed within the rollout of Real Decreto 589/2022, according to the official text. For a clinic, the practical implication is to identify whether remote activity is provided by trainees or within structures subject to training or procedural requirements that that regulation orders or modifies, and to pass that analysis to the clinic’s labour and healthcare advisers.

At the regional level, ORDEN 3/2026 of the Conselleria de Sanidad (Comunitat Valenciana), reported by Noticias Jurídicas, amends a prior administrative development order envisaged in a Consell decree. Although the content is administrative in nature, the takeaway for managers is straightforward: requirements and workflows can vary by autonomous community, so a clinic with centres or activity in more than one territory must avoid applying a single internal procedure without checking it against the applicable regional rules.

Operational implication: regulatory map by site and by service

Given these publications, management’s task is not to “implement telemedicine” but to document which services are offered remotely, from which site, by which professionals and under which applicable rules, according to the BOE and the relevant regional regulation. This affects: internal protocols, patient information documents, activity logs and terms of provision.

Hybrid care: what management forums are asking for

The reporting by Redacción Médica and iSanidad agrees on one point: “hybrid care” is not just opening a video call channel, but redesigning processes and coordinating in-person and virtual care. For a private practice, this approach requires treating the video consultation as another clinical act within the working system: schedule, roles, timings, documentation and follow-up.

What to review day to day: schedule, identification and traceability

From the process priorities reported by Redacción Médica and iSanidad arise controls that the clinic must have in place before scaling activity: how appointments are booked (and who validates them), how the patient is identified, how what was done is recorded and how continuity of the episode is managed between face-to-face and virtual consultation. Management must demand traceability: that the workflow leaves recorded, auditable evidence.

Data protection and confidentiality: design obligation, not just a tool

Video consultation involves processing health data and therefore carries a high level of data protection requirement. In practice, the compliance risk usually does not stem from “doing telemedicine” but from doing it without prior analysis of the processing: who accesses data, from where, with what measures and how the call environment is managed. The clinic should escalate these decisions to the internal data controller and to its data protection officer, where applicable, and rely on criteria and guidance from authorities such as the AEPD (Spain’s data protection authority) when relevant.

Implication for the clinic: documentation and contracts with suppliers

In daily management two fronts recur: (1) documentation of the processing (internal registers, risk assessment and policies) and (2) relationships with suppliers involved in the video platform or related storage (data processor contracts and terms). The clinic must verify that contracts and annexes reflect the actual type of service and that the access workflow to the video consultation minimises data exposure.

Billing and tax obligations: consistency between the act and its support

Video consultation does not remove administrative obligations: if an invoice is issued for a professional act, the clinic must ensure that the description of the service, the accrual criterion and the evidence of the act align with its billing system and applicable tax obligations. That analysis belongs to the adviser, but the manager must ensure the internal workflow does not leave billing “hanging” in an email or a call without record.

What must be tied down: internal evidence and reconciliation

From a management perspective, it is advisable that each video consultation is linked to an appointment, an assigned professional, an entry in the clinical record and proof of payment or invoicing, according to the centre’s model. Coordination between the front desk, administration and medical management is what prevents inconsistencies in audits or reviews.

Hiring and organisation of healthcare staff

Remote provision changes work organisation: shifts, availability, spaces and supervision. In addition, the regulatory movements published in the BOE regarding training and procedural aspects (Order PJC/1001/2025 in relation to Real Decreto 589/2022) require the clinic to confirm role alignment and, where applicable, any requirements that may affect trainees or teaching structures.

Spaces and confidentiality: infrastructure also matters

The importance of the physical environment even appears in the public sector: Europa Press reported the opening of a health centre in Villava (Navarra) that includes a room dedicated to telemedicine, fitted to reduce echo and improve privacy. In a private clinic, this translates into an investment and compliance decision: whether the video consultation is conducted from a cubicle, an office or an open workstation, management should assess the risk of information exposure and adapt spaces and internal rules.

Digitisation and public funding: monitor current calls

Recent news focus on organisational rollout rather than concrete grants. Even so, management should monitor active calls for digitalisation and healthcare modernisation when published by the competent official channels, and check the compatibility of investments with justification requirements if applying for aid. At this point the operating principle is documentary: no investment should be budgeted as “subsidisable” without a published call and conditions.

References and links

• BOE: Orden PJC/1001/2025
• Comunitat Valenciana: ORDEN 3/2026 (Noticias Jurídicas)
• Telemedicina (infraestructura): Centro de Salud de Villava, Europa Press
• Sanidad híbrida: Redacción Médica
• Salud digital (congreso y gestión): iSanidad

This article summarises public sector information. It is not legal or tax advice.