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Aipedia: Doctors and medical practices
The GMC applies Good medical practice to AI rather than issuing a separate standard, while NHS England and the MHRA set the rules for the tools themselves. Knowing which documents bind you helps you defend a complaint, a claim or a fitness-to-practise referral.
Part of: AI in doctors and medical practices
In short
Doctors are bound by Good medical practice 2024, which the GMC says covers AI: competence (paras 3 and 13), records (paras 69 to 71) and reporting incidents with software and digital tools (para 73). NHS England's ambient scribing guidance sets requirements for NHS organisations using AI scribes. The MHRA regulates AI as a medical device. The National Commission's 44 recommendations, all accepted by the government on 6 October 2026, set a direction of travel but are not yet rules. The 17 September 2026 joint regulator statement promises shared principles with no timetable.
The GMC regulates doctors, physician associates and anaesthesia associates and sets professional standards. It says it does not regulate or approve technologies; that is the job of the MHRA, which regulates software and AI as medical devices and runs the AI Airlock sandbox. NHS England issues operational guidance for NHS services, and the CQC registers and inspects providers in England. The Professional Standards Authority oversees the GMC and the other health regulators and co-chairs a Task and Finish Group on AI with the MHRA. The ICO regulates data protection.
| Body and document | Date | Status | Key point |
|---|---|---|---|
| GMC, AI and innovative technologies learning resource | Undated, live October 2026 | Guidance applying binding GMP duties | Existing GMP principles apply to AI |
| GMC, Good medical practice | 2024 | Binding professional standard | Paras 3, 13, 69 to 71 and 73 apply directly |
| NHS England, ambient scribing guidance (version 2) | v1 28 April 2025 | National guidance for NHS bodies | MHRA registration, DCB0129 and DCB0160, DPIA, telling patients |
| National Commission report | 10 September 2026 | Advisory | 44 recommendations |
| Joint statement of intent on AI | 17 September 2026 | Commitment | Shared UK-wide principles to follow |
| Government response | 6 October 2026 | Policy | All 44 recommendations accepted |
The GMC's AI and innovative technologies resource makes clear there is no separate AI code. The duties it relies on are binding because they sit in Good medical practice:
The resource also says doctors must use professional judgement, should discuss AI use with patients (including alternatives, uncertainties and limitations) and should raise concerns if a technology may put patients at risk. Developers, employers and doctors who create, test or update a tool stay responsible for those parts. Domain 4 adds that information you communicate must be accurate, not false or misleading, and checked first.
NHS England's ambient scribing guidance, now version 2, is the most detailed AI guidance aimed at NHS clinicians. Transcription-only tools are likely not medical devices, but generative summarisation is likely a medical device and must be MHRA-registered. Suppliers must meet DTAC and DCB0129; deploying organisations must complete DCB0160 with a safety case, hazard log and monitoring, and a DPIA. Users must review and approve outputs. Patients must be told before processing starts and given a chance to object. On liability, the guidance warns that if no liable party can be found, liability may default to the trust or primary care provider. Our AI scribes guide covers this in detail.
The MHRA set up the National Commission into the Regulation of AI in Healthcare on 26 September 2025. Its report (10 September 2026) made 44 recommendations, and the government response (6 October 2026) accepted all of them. Those most relevant to doctors are:
The Commission did not recommend product liability reform. The MHRA plans draft AI change-management guidance by December 2026, a classification consultation in 2027 and a roadmap by spring 2027.
On 17 September 2026 the PSA, GMC, NMC, HCPC, GDC, GPhC and five other regulators, plus the Accredited Registers Collaborative, issued a joint statement of intent. They will develop high-level UK-wide principles for how professionals use AI. It is the first joint regulator commitment on AI, but no timetable has been given, so the GMC resource remains the reference point.
The BMA principles call for robust safety assessment, staff training and clarity on legal liability, including for AI developers, and say doctors must be able to challenge AI decisions. A medical defence organisation has published practical advice, such as not entering patient personal data into generative AI and keeping AI-generated notes accurate and contemporaneous. These are not binding rules, but a tribunal or court may treat them as evidence of reasonable practice.
In practice, treat GMP as the rulebook, NHS England guidance as the standard for NHS deployments, and the Commission's work as signals of what is coming. For indemnity, the guidance points one way: the clinician who reviews, signs or acts on an AI output is expected to own it. Following guidance helps both your defence and your cover, because one defence organisation's published position requires compliance with law and national guidance. Regulatory hearings fall outside NHS schemes; see regulatory and disciplinary costs cover and where NHS indemnity stops. Return to the doctors AI hub or read does medical indemnity cover AI and the GMC indemnity requirements.
The resource itself is a learning resource, but it applies duties in Good medical practice 2024, which are binding professional standards. A doctor who fails to check AI-drafted records or report an incident involving a digital tool risks breaching GMP paras 69 or 73, not just ignoring advice.
The ambient scribing guidance is written for NHS health and care settings. Private clinics are not formally bound by it, but it describes recognised safeguards such as MHRA registration, clinical safety cases and a DPIA, and it may be used as a benchmark of reasonable practice if something goes wrong.
No. The government accepted all 44 Commission recommendations, but the Rec 24 working group will clarify professional responsibilities without redistributing them. There is no commitment to product liability reform, so clinicians and providers remain exposed under existing negligence principles.
No date has been set. The 17 September 2026 statement commits the GMC and other regulators to develop shared high-level principles, but gives no timetable. Until then, the GMC learning resource and Good medical practice are the reference points.
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