UK compliance hubClinical safety and NHS assurance

What does NHS England's guidance on ambient voice technology say?

Short answer

NHS England's guidance on AI-enabled ambient scribing products (version 3, updated 29 July 2026) tells adopting organisations to appoint a clinical safety officer, complete DCB0160, run a DPIA, confirm medical device status, make sure users review outputs before acting on them, tell patients, set retention periods and monitor accuracy.

Who the guidance is for

The guidance is for health and care settings in England adopting an ambient scribing product, or a new function in one. It is written mainly for chief information officers and chief clinical information officers, with a technical appendix for product teams. It does not cover individuals using tools outside their organisation's oversight. Private clinics are not bound by it, but it is the most detailed public checklist for adopting an AI scribe in the UK.

The steps it expects

  • Clinical safety: assign a clinical safety officer, identify technical and clinical risks, and complete DCB0160 documentation, including a safety case, hazard log and monitoring plan. Get the supplier's DCB0129 evidence. See DCB0129 and DCB0160.
  • Data protection: complete a DPIA, involving information governance early. See DPIA for clinic AI.
  • Medical device status: confirm the product has been correctly assessed under medical device regulation and is registered with the MHRA where applicable. Status depends on the manufacturer's intended purpose.
  • Human review: users review and approve outputs before any further action, are trained on approved use, and remain responsible for what they approve.
  • Patient information: explain what is recorded, what the output is, who uses it and how it is stored. Update privacy notices and inform patients before processing so they can object. See patient consent and transparency.
  • Retention and security: define how long audio, transcripts and outputs are kept, confirm where data is stored, and check UK GDPR, DSPT and Cyber Essentials.
  • Integration: integrate with the electronic patient record rather than relying on copy and paste.
  • Monitoring: audit documentation accuracy, review incidents and performance, and check for bias, including performance across accents and dialects.

Pilots and liability

Pilots should last no more than four months, and running a pilot does not exempt a supplier from compliance. The guidance also asks organisations to involve legal teams early and make sure contracts clearly set out what the supplier and the organisation are each responsible for.

The AVT supplier registry

Alongside the guidance, NHS England runs a self-certified registry of ambient scribing suppliers, with supporting evidence to help local procurement. It sets supplier expectations including DTAC completion, MHRA registration where applicable, integration capability and performance monitoring. It is not a commercial framework: NHS England only checks that submissions are complete and does not endorse listed suppliers. Each organisation still runs its own assurance.

What Motics does

  • Motics Scribe Agent is a Class I medical device under UK MDR, and our DCB 0129 clinical safety case is available on request.
  • Motics has been assessed against DTAC. Evidence is on our Trust Centre.
  • Every note is a draft that the clinician reviews and approves before it is saved.
  • Audio is deleted within 48 hours. Transcript and note retention is set per clinic.
  • Approved notes save to the patient record in Cliniko, Nookal or Meddbase, so there is no copy and paste.

Full detail on our security and compliance page and the Trust Centre. Ask any vendor, including us, to put these answers in writing.

Primary sources

  1. NHS England: Guidance on the use of AI-enabled ambient scribing products in health and care settings
  2. NHS England: DCB0160 Clinical Risk Management, its application in the deployment and use of health IT systems
  3. NHS England: Digital Technology Assessment Criteria (DTAC)
  4. ICO: When do we need to do a DPIA?

Practical orientation for UK clinics, not legal advice. For your own circumstances, take advice from your data protection officer, indemnity provider or a solicitor.

FAQ

Common questions

Not formally. It is written for health and care settings in England adopting these products, particularly NHS organisations. Private clinics are not bound by it, but it is the most detailed published checklist for adopting an AI scribe safely, and following it puts you in a strong position with inspectors, insurers and NHS partners.

A national, self-certified registry of ambient voice technology suppliers run by NHS England, with supporting evidence to help organisations with procurement and assurance. Suppliers are expected to have completed DTAC and to hold MHRA registration where applicable.

No. NHS England only checks that submissions are complete, and it does not endorse listed suppliers. The registry is not a commercial framework. Each organisation still has to do its own assurance, including DCB0160 and a DPIA.

It asks organisations to check their legal basis and whether consent is needed, to explain to patients what is recorded and how it is used, to update privacy notices, and to inform patients before processing so they can object. In practice most clinics tell patients and ask before recording.

The guidance says pilots should last no more than four months, and that running a pilot or proof of concept does not exempt a supplier from compliance.

No fixed period. It asks organisations to define how long audio, transcripts, user interactions and outputs are kept for review, monitoring and audit, and to confirm where data is stored and shared.

It does not decide which products are medical devices. Status depends on the manufacturer's stated intended purpose. The guidance asks organisations to confirm the product has been correctly assessed and registered with the MHRA where applicable.

Running a compliance review?

We work with clinic owners, compliance leads and DPOs. Bring your DPIA or vendor questionnaire and we will come prepared.