NMC glossary · What the notice covers
Third-Party Intermediary: What It Means Under The NMC Rules
Also searched as: Marketing agency, Agency responsibility, Third party
Using an agency, influencer, platform or other intermediary does not by itself take responsibility off a doctor or hospital for content they authorised, commissioned, sponsored, adopted or knowingly permitted. A third party cannot be used to do indirectly what the doctor cannot do directly.
Updated 7 November 2026. Reviewed by Tamojit Lodh, Founder of Medmatis. Built around the NMC's Public Notice No. R-13014/01/2024-Ethics of 6 October 2026. Not legal advice.
Key facts, with sources
Hide the 4 key facts and their sourcesShow the 4 key facts and their sources
| Fact | Detail | Source |
|---|---|---|
| Term | Third-Party Intermediary (also searched as Marketing agency, Agency responsibility, Third party) | Medmatis |
| In the notice | Not defined by the notice; this entry explains how the notice uses it. | NMC notice of 6 Oct 2026, cl. 4.4, cl. 8.1 (ii), cl. 8.1 (xi) |
| Applies to | Doctors (RMPs) and hospitals/medical institutions that use agencies, influencers or platforms | NMC notice of 6 Oct 2026 |
| In force | From 6 October 2026, with immediate effect. The NMC may issue clarifications and advisories (cl. 12). | NMC notice of 6 Oct 2026 |
In plain words
Clause 4.4 says publishing through a digital platform, third party, advertising agency or influencer does not, by itself, absolve the RMP or institution of responsibility for content it authorised, commissioned, sponsored, adopted or knowingly permitted. The competent authority decides the consequences under the applicable law.
Clause 8.1 (xi) adds that no RMP or hospital may use a third party as an intermediary to do indirectly what it is prohibited from doing directly. In practice, handing a banned claim to an agency changes nothing.
What it does not mean
- It does not directly regulate agencies, and it creates no NMC approval or certification for agencies.
- It does not resolve how clause 8.1 (ii), which lists engaging a third party for marketing medical services among things an RMP shall not do, fits with clause 8.1 (viii), which deals with agency engagements paid in a particular way. That is an interpretation question for a medical-law adviser.
The notice’s own words
Quoted from the NMC notice of 6 October 2026. Check the clause number against the original.
cl. 4.4The fact that an advertisement or promotional communication is published through a digital platform, third party, advertising agency, influencer or other intermediary shall not, by itself, absolve an RMP or medical institution from responsibility for content which it has authorized, commissioned, sponsored, adopted or knowingly permitted. The disciplinary or statutory consequences shall, however, be determined by the competent authority under the applicable law.
cl. 8.1 (ii)Shall not solicit patients directly or indirectly, promote his/her professional services through self-promotion, engage any third party for marketing medical services, permit the use of their name, image, voice, testimonial or endorsement for promotion of services or any products, participate in promotional campaigns giving an impression of commercialization of medical practice.
cl. 8.1 (xi)No RMP shall use or permit any celebrity, influencer, patient, employee or third party to promote professional services through prohibited testimonials, endorsements or recommendations. Any material commercial relationship in lawful public-health or informational communication shall be transparently disclosed in accordance with applicable law. No RMP or hospital/medical institution shall use a third party as an intermediary to do indirectly what the RMP or institution is prohibited from doing directly.
Our plain-language guide to the whole notice → Check your own text against these rules →
Frequently asked questions
If my agency posts something wrong, who is responsible?
The doctor or institution can remain responsible for content it authorised, commissioned, sponsored, adopted or knowingly permitted (cl. 4.4). The disciplinary or statutory consequences are for the competent authority to decide.
Can a doctor hire a marketing agency at all?
The notice lists engaging a third party for marketing medical services among things an RMP shall not do (cl. 8.1 ii), yet also sets rules for how agency engagements are paid (cl. 8.1 viii). It does not say how the two fit together, so take medical-law advice before deciding.
This entry explains a public notice in plain language and quotes its clause numbers. It is not legal advice. Read the original NMC notice and take advice on your own situation.
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