Aipedia: Counsellors and psychotherapists

Recommending AI mental health apps to clients

Aipedia, by the Apex broking team · Last reviewed 2026-10-30

Before recommending an AI mental health app, assess it as you would any tool you use, including its data handling and whether it is regulated as a medical device. A recommendation carries your professional authority, so harm from an app you suggested can lead back to you.

Part of: AI in counselling and psychotherapy

In short

Therapists may suggest apps for mood tracking, mindfulness or practising skills between sessions, and many now include AI chat features. BACP 2.1(e) requires members to assess the risk of any AI tool, digital tool or online platform before using it, and to be open about benefits and risks. Recommending an app is a form of use. The MHRA regulates AI mental health apps that are medical devices, so check how the developer describes the app's purpose and status. If an app gives harmful advice to a client you referred, a complaint is likely to focus on how you chose it and what you told the client.

How therapists recommend apps

Apps can support therapy: a client logs mood daily, practises breathing exercises, or works through structured skills content. A growing number add an AI chat function that responds to whatever the user types, and some market themselves as an "AI therapist". When you suggest an app, clients reasonably assume you have checked it.

The duties that apply

The relevant duties are:

2.1(e) of the BACP Ethical Framework 2026: assess the risk of any AI tool, digital tool or online platform before using it. Recommending a tool to a client sits squarely within this.
2.1(e)(i) and (ii): understand the tool well enough to recommend it, including how it handles and stores data.
2.1(e)(iii): be honest and transparent with the client about benefits and risks.
2.1(a): work within your competence.
1.2(a): be accurate about what any service, including an app you suggest, offers.

BACP's Ethics essentials session stresses caution with untested systems. UKCP's feature on AI notes that people harmed by AI therapy tools may have no professional redress route, which puts more weight on the therapist's choice.

Checking regulatory status

The MHRA regulates software, including AI mental health apps, that qualifies as a medical device. An app that claims to diagnose, treat or monitor a mental health condition is more likely to fall into that category than a general wellbeing or meditation app. Before recommending, read how the developer describes the intended purpose, whether it states a medical device status, and what it says about clinical evidence, crisis handling and data. If an app makes clinical claims but says nothing about regulation, treat that as a warning sign.

What can go wrong

Illustrative scenario: a counsellor suggests an app with an AI chat feature to help a client with anxiety between fortnightly sessions. The counsellor has used the meditation content but never tried the chat. During a bad night, the client tells the chat function they feel hopeless; its reply is generic and does not point them to crisis support. The client later complains that the counsellor recommended a tool that failed them when they were at risk, and that they were never told its limits.

Data is the other risk: some apps share usage data widely, and a client who learns their mood logs reached third parties may blame the person who recommended it.

How PI usually responds

A claim that you negligently recommended an unsuitable tool is a professional services allegation that PI usually responds to, subject to the policy terms. Your PI will not cover the app developer's liability, and a policy may treat claims arising from third-party technology differently. Check for AI or technology wording (see AI exclusions and clauses) and what to document about AI use. If you are paid or rewarded for recommending an app, tell your insurer, as that can change the nature of the activity.

Practical controls

You can reduce the risk with these steps:

Try any app yourself, including its AI chat features, before recommending it.
Record a short assessment: purpose, regulatory status as described by the developer, crisis handling, data sharing and privacy terms.
Tell clients what the app is for, what it cannot do, and where to get urgent help.
Note the recommendation and the conversation in the client record.
Review your list of recommended apps periodically, as features change.
Avoid recommending AI chat apps to clients at high risk without careful thought and supervision.

How Apex helps

Apex arranges PI for counsellors and psychotherapists and can check how your cover treats recommendations of third-party tools. See also clients using AI chatbots, AI and suicide risk and the counselling AI hub.

Sources

Frequently asked

Is recommending an app the same as using it under BACP 2.1(e)?

In practice it should be treated that way. 2.1(e) requires a risk assessment of any AI tool, digital tool or platform before using it, and recommending one to a client draws on your professional judgement. Assess it, explain its limits, and record the advice.

How do I check if an AI mental health app is regulated?

Read how the developer describes the app's intended purpose and whether it states a medical device status. The MHRA regulates mental health apps that are medical devices. Apps making clinical claims with no mention of regulation or evidence warrant extra caution.

Should I tell clients an app uses AI?

Yes. BACP 2.1(e)(iii) requires honesty and transparency about AI tools and their benefits and risks. Explain whether the app includes AI chat, what it is designed for, what it cannot do, and where to go for urgent help, and note the conversation in the record.

Who is liable if a recommended app harms my client?

The developer may be liable for the app itself. A client may also complain about, or claim against, the therapist who recommended it, focusing on how the app was chosen and what the client was told. A record of your assessment and advice helps your defence.

Check your PI covers how you use AI

Tell us about your firm and the work you do. A broker will review how your current PI treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.