What Lagos State's first telemedicine licence taught me about regulating remote care

When we went for a telemedicine operating licence in Lagos State, there was no established path to follow — the category was new to everyone in the room, including the regulator. What I expected was resistance. What I found was a set of entirely reasonable questions that no telemedicine pitch deck answers.

The questions a regulator actually asks

• Who is the clinician, are they registered, and how do you prove it at the point of consultation?
• What happens when a remote consultation discovers an emergency? Name the receiving facility.
• Who prescribes, on what authority, and how is the prescription dispensed and reconciled?
• Where does the record live, who can see it, and how long do you keep it?
• What is the complaint route, and who is accountable when the model harms someone?

None of these are technology questions. Every one of them is a clinical governance question, and a founder who arrives with an escalation pathway, a named referral partner and a prescriber policy has a materially easier conversation than a founder who arrives with a product walkthrough.

Precedent is a real asset

Being first was expensive. We spent months on definitional work — what counts as a consultation, what counts as a facility when there is no waiting room, what supervision means when the supervising physician is in another city. That work became the reference frame for operators who came afterwards, which is a strange kind of contribution: you do the regulatory engineering and the market inherits it.

It is also why I now tell founders that the licence is not the deliverable. The governance model is the deliverable; the licence is its receipt.

What the clinical model has to survive

A remote care service faces three tests at once, and most only design for the first. It must be clinically defensible — a physician should be willing to send their own family through it. It must be commercially viable at the price a Nigerian household will actually pay, which is far below the price the model was probably designed around. And it must be operationally boring, because a pathway that depends on heroics from a small clinical team stops working the week it scales.

The Mutti Doctor telepharmacy model held up because the escalation route was concrete: a named pharmacy footprint, a defined clinical scope, a triage protocol that pushed anything ambiguous into physical review. Constraint on scope is what made remote delivery safe, and pretending otherwise is how remote care earns the regulatory backlash it periodically gets.

For anyone applying now

Bring a written clinical protocol, an escalation and referral pathway with named partners, evidence of practitioner registration and indemnity, a prescribing policy, a data protection impact assessment under the Nigeria Data Protection Act 2023, and a complaints procedure with a named accountable clinician.

Expect to educate rather than to persuade. And expect the process to improve your service, because every one of those questions is one your patients would ask if they knew to.