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Aipedia: Nurses and allied health professionals

NMC and HCPC on AI: what registrants need to know

Neither the NMC nor the HCPC has published AI-specific rules, so the NMC Code and the HCPC standards of conduct, performance and ethics apply to AI use as they stand. Registrants are judged on the same duties whether or not software was involved.

In short

As at 27 October 2026, the NMC has no AI-specific guidance, but its future standards page says the modernised Code is likely to cover artificial intelligence, with a consultation due by the end of November. The HCPC said in July 2026 that its standards apply to AI use and promised AI guidance in its Meeting our standards resources this autumn; none had appeared by late October. Both regulators signed a PSA-led Joint Statement of Intent on shared AI principles on 17 September 2026. Until then, existing duties on records, competence, confidentiality, delegation and indemnity govern AI-assisted practice.

Where the regulators stand

ItemDateStatusKey point
NMC CodeEffective 31 Mar 2015, updated 10 Oct 2018Binding professional standardsNo AI wording; general duties apply
NMC future standards (Code review)Consultation due by end of NovemberProposalModernised Code likely to cover AI
HCPC standards of conduct, performance and ethicsIn force 1 Sept 2024BindingHCPC says they apply to AI use
HCPC AI researchAnnounced 23 July 2026Research under wayRegistrant survey from Aug 2026; no findings yet
HCPC AI guidancePromised for autumn 2026Not yet published as at 27 Oct 2026To sit in Meeting our standards
Joint Statement of Intent17 Sept 2026Statement of intentPSA-led; shared high-level AI principles to follow

The NMC position

The NMC has not published guidance specific to AI. Its 17 September 2026 statement on shared AI principles does not refer to any existing NMC AI guidance. Its future standards page says the modernised Code will address areas "such as equality, diversity and inclusion (EDI), artificial intelligence", and lists "the progress of artificial intelligence" among the reasons the standards need updating. The Code consultation is due to launch by the end of November. A revalidation consultation will follow at least six months later.

Until a new Code is in force, these existing paragraphs of the Code carry the weight:

NMC CodeDutyHow it applies to AI
5.1 to 5.2Respect privacy; tell people how information is used and sharedPatient data entered into AI tools; telling patients a scribe or app is used
6.2Maintain knowledge and skills for safe practiceUnderstanding a tool's limits before relying on it
10.1 to 10.3Prompt, accurate records without falsificationChecking AI-drafted notes before they enter the record
11.1 to 11.3Delegate within competence, supervise, confirm the outcomeSupport staff using AI tools on your behalf
12.1Appropriate indemnity for your scope of practiceCover that reflects AI-assisted work
13.1 to 13.5Recognise worsening health, refer, work within competence, train before a new roleNot relying on an algorithm over your own assessment
19.1 to 19.2Reduce mistakes; consider human factors and system failuresAlert fatigue, automation bias and system faults

The HCPC position

In its 23 July 2026 announcement, the HCPC said its standards of conduct, performance and ethics apply to AI use. Ipsos UK is surveying a sample of registrants for it from August 2026, alongside focus groups and interviews; no findings have been published. It said it would add AI guidance to its Meeting our standards resources "this autumn". As at 27 October 2026, no AI item appears on the Meeting our standards page.

The standards most relevant to AI are:

Standards 6 (risk) and 7 (reporting safety concerns) also matter when a tool is behaving unsafely.

The wider picture

The PSA oversees both regulators. Its April 2026 workshop report with the University of Bristol frames the open question of how responsibility is shared between the professional, the employer, the developer and the regulator. The government response to the National Commission on AI in healthcare (6 October 2026) accepted that professional regulators, with DHSC, the MHRA, CQC, NHS Resolution and the PSA, will "clarify health and care professional responsibilities" (Rec 24), that professional AI capability needs building (Rec 32), and that reporting AI product problems forms part of the "duty of care" (Rec 34).

What it means in practice

Registrants should not wait for AI-specific rules. A regulator considering a concern will ask whether the record was accurate, whether the registrant assessed the patient, whether they worked within their competence and whether confidentiality was respected. "The software said so" is unlikely to answer those questions. Keep evidence of training on each tool, record when you depart from or accept an AI output in a significant decision, and report faults through local incident systems. See AI scribes and nursing records and AI, delegation and support workers for task-level detail.

What it means for indemnity

Indemnity is a legal requirement for registrants under SI 2014/1887, and the NMC expects cover to suit the role, scope and risks of the work. Neither regulator sets a minimum limit, and neither says anything specific about AI and indemnity. If AI changes what you do, for example taking on remote triage or app-based rehab, your scope of practice may have changed too, and the arrangement should reflect it. See does nurse and AHP indemnity cover AI errors, the nursing and allied health AI hub and PI for professionals using AI.

How Apex helps

Apex arranges indemnity for self-employed nurses, midwives and HCPC registrants. A broker can check whether your arrangement matches your current scope, including AI-supported services, before the new Code and HCPC guidance land.

Sources

Frequently asked

Does the NMC Code mention AI?

No. The current Code, effective 2015 and updated 2018, has no AI-specific wording. Its duties on records, confidentiality, competence, delegation and risk apply to AI use, and the NMC says its modernised Code is likely to cover artificial intelligence.

Has the HCPC published its AI guidance?

Not as at 27 October 2026. The HCPC said in July 2026 it would add AI guidance to Meeting our standards in the autumn, but no AI item had appeared on that page. Its standards of conduct, performance and ethics already apply.

What is the Joint Statement of Intent?

A PSA-led statement signed on 17 September 2026 by the NMC, the HCPC and other partners, committing them to develop shared, high-level principles on AI. It is a statement of intent, not binding guidance, and no principles had been published by late October 2026.

Will the new rules change my indemnity?

Not directly. The statutory requirement for appropriate cover already applies. What may change is the detail of what regulators expect, which could affect what scope of practice your arrangement needs to reflect. NHS England and NHS Resolution are also developing indemnity guidance on AI.

Check your indemnity covers how you use AI

Tell us about your practice and the work you do. A broker will review how your current cover 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.