EMR for Aesthetic Clinics: Which Facilities Must Implement by December 31, 2026, and How to Prepare
Under Circular 13/2025/TT-BYT, aesthetic and dermatology clinics licensed to provide medical examination and treatment must complete the implementation of electronic medical records by December 31, 2026. This article summarizes which facilities are in scope, what to prepare, and how Qub-X is building its EMR feature.
Under Circular 13/2025/TT-BYT of the Ministry of Health, medical examination and treatment facilities other than hospitals, including specialized dermatology clinics and licensed aesthetic clinics, must complete the implementation of electronic medical records no later than December 31, 2026. As of late September 2026, only about three months remain. This article summarizes the regulations on EMR for aesthetic clinics, 6 steps to prepare, and how Qub-X is building its EMR feature.
What is an electronic medical record (EMR)?
An electronic medical record (EMR) is a medical record that is created, updated, displayed, signed, stored, managed and used by electronic means. In other words, examination and treatment information is entered and signed directly in the system from the start, instead of being written on paper and then archived.
What does Circular 13/2025/TT-BYT regulate?
Circular 13/2025/TT-BYT provides guidance on implementing electronic medical records. It took effect on July 21, 2025 and replaces the former Circular 46/2018/TT-BYT.
Implementation timeline
Facility type | Completion deadline |
|---|---|
Hospitals | No later than September 30, 2025 |
Other medical examination and treatment facilities providing inpatient, day-patient or outpatient treatment | No later than December 31, 2026 |
Which facilities fall within the scope?
The regulation applies to facilities licensed to provide medical examination and treatment, including specialized dermatology clinics and aesthetic clinics. Spas that only offer beauty care services and do not hold a medical examination and treatment license are generally outside this scope. However, facilities that offer medical-type services should double-check with their local Department of Health.
Key requirements
Record content: complete information as required in Chapter X of Circular 32/2023/TT-BYT.
Signing and confirmation: healthcare staff and patients sign or confirm using one of three methods: a legally valid electronic signature, biometrics, or another form of electronic confirmation under the Law on Electronic Transactions.
Identity linkage: records are linked to the patient's personal identification number.
IT infrastructure: at a minimum, workstations, network connectivity, servers and a data storage solution, including backup storage.
Security and data protection: compliance with regulations on information security and personal data protection.
Why should aesthetic clinics prepare now?
Implementing electronic medical records is not just a matter of installing software. Clinics need time for three things:
- 1
Migrating existing data: moving customer records and treatment histories currently kept on paper, in Excel or in legacy software onto the new system.
- 2
Changing workflows: deciding who enters information, who reviews it, who signs, and when a record is locked.
- 3
Training staff: doctors, nurses and receptionists need to get familiar with the system before it is officially rolled out.
A clinic that starts close to the deadline is likely to end up handling errors while running day-to-day operations, which affects the customer experience.
EMR for aesthetic clinics: 6 steps to prepare
- 1
Review your license and scope of operations to determine whether your clinic is required to implement EMR.
- 2
Take stock of existing data: where records are stored, in what format, and how many customers there are.
- 3
Standardize your service list in line with the list of techniques registered with the Department of Health.
- 4
Choose software that can meet the requirements of Circular 13, and ask clearly about the implementation roadmap.
- 5
Prepare the infrastructure: workstations, network, a storage plan and backups.
- 6
Design the signing workflow and access permissions, then pilot it with a group of customers before applying it across the board.
How is Qub-X building its EMR feature?
Qub-X is a management platform for spas and aesthetic clinics operating multiple branches. Qub-X is currently developing an electronic medical records feature built right into the system, based on real-world requirements from dermatology clinics that use Qub-X.
Draft, review and end-of-day lock workflow
During the day, staff enter examination and procedure information as drafts. A doctor or the person in charge then reviews it. Only at the end of the day is the record officially locked. This lets clinics correct mistakes before the record becomes part of the official archive.
Change log and addenda instead of direct edits
Once a record is locked, any change is added as an addendum, together with a log of who made it and when. The original record stays intact, ensuring transparency during inspections or in the event of a dispute.
Connected to customer records and appointments
Medical records sit in the same system as appointments, customer records, treatment plans and before-and-after photos. Doctors don't need to open several different programs to see a customer's full treatment history.
Data migration support
For clinics already using Qub-X, their existing customer data serves as a ready foundation for moving to electronic medical records. The Qub-X Onboarding team supports clinics throughout setup and migration.
Frequently asked questions
Are spas required to implement electronic medical records?
Spas without a medical examination and treatment license are generally outside the scope of Circular 13/2025/TT-BYT. Licensed dermatology clinics and aesthetic clinics are within the scope and must complete implementation by December 31, 2026.
Do scanned paper records count as electronic medical records?
No. Electronic medical records must be created, signed and stored by electronic means. A scan is only a copy of a paper record.
Is a digital signature mandatory?
A digital signature specifically is not mandatory. The Circular allows three methods: a legally valid electronic signature, biometrics, or another form of electronic confirmation under the Law on Electronic Transactions.
When will Qub-X's EMR feature launch?
Qub-X will announce the official launch date on its website and Facebook page. Clinics can sign up for early updates to get advice on their preparation roadmap.
Legal basis
This article is for reference only and does not replace legal advice. Clinics should check against the original document and the guidance of their local Department of Health.
Conclusion
The December 31, 2026 deadline is approaching. Aesthetic and dermatology clinics within the scope should start reviewing their data, workflows and software now to ensure a smooth transition without disrupting daily operations.
Sign up for early updates on Qub-X's electronic medical records feature