It is impossible to say without getting a test kit and doing a test. Sometimes yellow marks similar to those on your plant are caused by insect damage or Nitrogen deficit.

I agree with Arthur. You cannot tell from the pictures if it is a virus. For a definitive answer will need to get it tested. I have used Critter Creek Labs, but I don't see their website anymore.

Now having said that, I would not jump to virsus if I saw those spots on my Phragmipedium. I would consider cultural issues like environment, nutrient, or fungus. Have you change anything about your culture recently?

Please show a view from under the leaf.

View from underneath.

I'd like to say that nothing has changed about its culture but it's been a very hot and dry spring here. It feels much more like August than June. I have forgotten to feed my plants regularly recently, but I often do that.

I have used test kits from Agda and called them for advise on how to perform the tests. They told me that viruses are more concentrated in the flowers because of the increased cell activity. My thinking is that if the flowers look normal it is probably not a virus. Also I think if the new growth looks normal it's another sign that it's not a virus because a plant can recover from fungal and bacterial issues but not from a virus. But there is no way to know for sure without testing.