AI Ambient Scribing – NHS England Warning and Provisional LMC Guidance

NHS England has issued a Priority Notification on the safe and assured adoption of AI-enabled ambient scribe technologies (ambient voice technologies, or AVT).

These tools may eventually help reduce administrative burden and support clinicians. However, NHS England is clear that non-compliant solutions currently being marketed present risks to clinical safety, data protection, and the wider NHS digital strategy.

NHS England’s position (June 2025 notification)

  • Do not use AVT solutions that are not compliant with NHS standards.
  • Any AVT solution that summarises consultations requires, at minimum, MHRA Class 1 medical device status.
  • Providers must complete a clinical safety risk assessment and Data Protection Impact Assessment (DPIA) before deployment (under DCB0160).
  • Liability for using a non-compliant solution sits with the deploying organisation or individual clinician.
  • NHS England is developing a national delivery proposal to support a standardised, compliant rollout across care settings.
Read NHS England’s full advice (opens in new tab)

LMC provisional guidance for practices

  • Each deployment must be overseen by a Clinical Safety Officer (CSO), registered with an appropriate professional body and trained in DCB0160.
  • It is unrealistic for every practice to appoint its own CSO. The LMC recommends raising this with your ICB so that a dedicated GP can be funded and trained to deliver the role on behalf of practices.
  • Training in clinical safety is available via eLFH at essential and intermediate levels, which is free for NHS users. Practitioner level training costs £475, and opportunities are limited.
  • Practices must complete a DPIA and clinical safety case (DCB0160) before deployment.
  • Engaging with the ICB for advice and assurance is strongly recommended, though many ICBs are not yet in a position to provide this consistently. Where ICB assurance is unavailable, practices remain responsible for ensuring compliance.
  • All AI-generated outputs must be checked and confirmed by a clinician before being entered into the patient record.

Immediate actions for practices

  1. Do not adopt AVT solutions unless NHS standards are demonstrably met.
  2. Ensure a DPIA and clinical safety case (DCB0160) are completed before deployment.
  3. Seek ICB input and assurance where available. If this is not possible, practices remain responsible for compliance.
  4. Ensure staff understand that liability for unsafe or non-compliant deployment will sit locally with the practice or individual.
  5. Await further national guidance on safe, standardised rollout.