Bottom Line: Ask any VPN company for a signed business associate agreement (BAA) before patient data crosses it, and expect the answer to depend on your plan: NordLayer says it signs one only on annual or longer billing, and Cloudflare says only with enterprise customers. A VPN alone does not make a practice HIPAA compliant.
What this page is for
This page is for a practice manager or owner choosing a business VPN. It sits under our best VPN for business guide, which covers what a business VPN is and how it differs from a personal one. For larger organisations see the enterprise VPN guide, and for the general privacy picture the data protection guide. Law firms face a different rule; see best VPN for law firms.
We do not run our own security tests. Everything vendor-specific below is what the vendor says on its own pages, with the date we read it, and HHS and federal regulation text are linked under Resources. This is general information, not legal advice.
Is there a HIPAA compliant VPN?
No. HHS says the Office for Civil Rights does not endorse, certify or recommend specific technology or products, so no VPN carries a government HIPAA certification. Cloudflare’s own page makes the same point: HHS does not recognize a certification for HIPAA compliance. A vendor can sign a BAA and offer controls that support your programme. A VPN alone does not make you compliant.

What to ask a VPN company before patient data crosses it
- Will you sign a BAA, and on which plan and billing term? Get the answer in writing. NordLayer says it will not sign on monthly billing.
- Is the VPN product itself covered by the BAA? A company can sign a BAA for one product and not another. Proton, for example, says it offers BAAs to all users, but we could not confirm from public pages that the VPN is covered.
- Which controls come with my plan? Dedicated IP, single sign-on (SSO) and multi-factor sign-in (MFA) are gated by plan at the vendors below.
- What happens before the BAA is signed? NordLayer says patient data may not go through it until the BAA is executed, so a monthly trial is for testing without patient data.

Which plans say they sign a BAA
Every row is what the vendor says on its own pages, read on 8 October 2026, with NordLayer, Cloudflare and Proton read again on 29 October 2026. A vendor page is evidence of what the vendor says, not of what it will sign.
| Provider | What it says about a BAA | Plan or term condition | Source |
|---|---|---|---|
| NordLayer | Signs a BAA | Annual or longer billing only | NordLayer help centre[1] |
| Proton VPN for Business | Offers BAAs to all Proton users | VPN scope not confirmed | Proton for Business[2] |
| Cloudflare Zero Trust | Signs BAAs | Enterprise customers only | Cloudflare[3] |
| Surfshark VPN for Teams | No statement found | Not stated | n/a |
| ExpressVPN for Teams | No statement found | Not stated | n/a |
Cloudflare has no review page on VPN.com, so it is not linked internally. NordLayer has no review page either, so NordLayer links to its own site through our partner link. We earn a commission if you buy NordLayer through it; that does not change what its pages say.
Final Verdict
| If this is your situation | Start the conversation with |
|---|---|
| You want a BAA on a standard business plan | NordLayer on annual billing, or Proton for Business. Ask each to confirm in writing that the VPN product is covered |
| You already hold an enterprise contract with a network vendor | Cloudflare, which says it signs BAAs only with enterprise customers |
| You need a dedicated IP on a small plan | NordLayer Core or above, or Proton Professional, as each vendor says |
| A vendor will not confirm its position in writing | Do not send patient data through it |
Whatever you pick, the VPN is one safeguard. Your risk analysis, staff training and vendor contracts are what a regulator asks about.
References
- Nordlayer. n.d. NordLayer help centre. https://help.nordlayer.com/docs/nordlayer-hipaa-baa.
- Proton. n.d. Proton for Business. https://proton.me/business/healthcare.
- Cloudflare. n.d. Cloudflare. https://www.cloudflare.com/trust-hub/us-privacy-compliance/.
- HHS. n.d. HHS: 2024 Report to Congress on the Breach Notification Program. https://www.hhs.gov/sites/default/files/breach-report-to-congress-2024.pdf.
- HHS. n.d. HHS: Guidance on HIPAA and Cloud Computing. https://www.hhs.gov/hipaa/for-professionals/special-topics/health-information-technology/cloud-computing/index.html.
- HHS. n.d. HHS: Are the US Postal Service and similar couriers business associates? https://www.hhs.gov/hipaa/for-professionals/faq/245/are-entities-business-associates/index.html.
- ECFR. n.d. 45 CFR 164.312, technical safeguards. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-C/section-164.312.
- ECFR. n.d. 45 CFR 164.308, administrative safeguards. https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-C/section-164.308.
- Nordlayer. n.d. NordLayer pricing. https://nordlayer.com/pricing/.
