The practice bought the scribe but the note is still yours

A product that listens to a consultation, transcribes it and drafts the note has become a normal fixture on NHS desktops. NHS England's guidance on these products was published on 27 April 2025 and last updated on 29 July 2026, the same date the MHRA published its guidance on ambient voice technology-enabled products and their status as medical devices. Both documents are written for organisations, which leaves a question for anyone who consults in a building they do not own: if the practice or the trust bought the tool, what does the clinician in the room carry personally?

What has to be in place before anyone uses one

NHS England's guidance sets out what must exist before an ambient scribing product is deployed. There are four requirements, and each one sits with the supplier or the organisation rather than with you.

None of these is a locum's responsibility to produce. All four are things a locum can be exposed by. A practice that has bought a subscription and rolled it out to the clinical team without a safety case, or without a DPIA that contemplates anyone beyond the partners, has a gap. The consultations run through that gap are yours.

The bring-your-own problem

The guidance assumes an organisation standing behind every deployment: a named Clinical Safety Officer, documented hazards, a monitoring framework. A clinician who carries a personal subscription from one practice to the next has none of that structure, and the site they walk into has not assessed the product, has not written it into a DPIA and does not know the audio exists.

LMC guidance circulating since the summer of 2026 states that liability for using a non-compliant solution sits with the deploying organisation or the individual clinician. That phrasing comes from local medical committee summaries rather than from NHS England's own text, so treat it as a pointer rather than a quotation of the rule. The practical reading does not change much either way. Use the product the organisation deployed, under the organisation's arrangements, with the organisation's consent process. Introducing your own tool to a site that has not assessed it puts you on the wrong side of a structure designed to protect you.

Whether it is a medical device depends on what it claims to do

NHS England's guidance does not itself decide which products are medical devices. That turns on the manufacturer's stated intended purpose, and NHS England directs readers to MHRA guidance. The MHRA published new guidance on ambient voice technology-enabled products on 29 July 2026, clarifying when these products are medical devices.

Trade commentary on that guidance, including a note published by Covington on 6 August 2026, reads it as putting summarisation at Class I as a minimum and products that generate diagnoses or management plans at Class IIa or above. That classification detail is commentary rather than regulator wording reproduced here, so check the MHRA guidance itself before relying on a class in a conversation with a practice manager.

The distinction is worth understanding even without the class numbers. A product that transcribes and structures what was said is a different proposition from one that proposes a diagnosis or a plan. The second is where your name on the record does the most work, and it is the point at which asking what the manufacturer says the product is for stops being pedantic.

What stays with you

NHS England is direct on this. Individual clinicians remain responsible for reviewing and revising outputs and for the accuracy of documentation. Nothing about the technology moves that.

On liability, the guidance notes that NHS organisations may still be liable for claims arising from the use of AI, particularly where a non-delegable duty of care is engaged. Read that carefully if you are self-employed. It describes the organisation's duty to the patient. It does not transfer your professional responsibility for a record you approved, and it is not a statement about your indemnity, which is your own arrangement. If you have not asked your defence organisation whether your cover contemplates consultations recorded and drafted this way, that is a five-minute call worth making before the shift rather than after a complaint.

Reviewing an output is not proofreading. It means reading the drafted note as if you were writing it from scratch and checking it against the consultation you actually had: what was omitted, what appears that was never said, whether negatives were recorded that you did not ask about, whether the safety netting you gave verbally made it into the text. If a rota is running to ten-minute appointments, the review time is part of the appointment, not a bonus.

Questions worth asking before the first consultation of the shift

• Is the product on the AVT Supplier Registry, and has the supplier completed DTAC?
• Who is the named Clinical Safety Officer for this deployment, and is there a DCB0160 safety case and hazard log covering this site?
• Does the DPIA cover locum, bank and sessional clinicians, or only the permanent team?
• What is the consent process, and what words does the organisation use with patients? The conversation happens in your room, so you need to know what has already been said and what is expected of you.
• Where is the audio held, for how long, and who can retrieve it?
• Am I working under a named account of my own, or a shared login? A shared login makes the audit trail meaningless and makes the note harder to defend.
• Does the draft reach the record only after I have reviewed and saved it?
• What is the fallback if the product is unavailable mid-surgery?

If the answer to the first three is a shrug, that is information. You can still work the shift and write your own notes.

What this means for your bookings

Keep a note of which organisations asked you to use one, what the product was called and the dates you used it. If a query about a consultation arrives eighteen months later, the version of events you need includes which system drafted the note and under whose deployment. A professional record that lists the organisations and tools you worked with makes that a lookup rather than a reconstruction.

Nothing here is specific to general practice, although that is where these products have spread fastest. The same four requirements and the same personal responsibility apply on a ward, in a clinic and in a community mental health team, which is worth knowing before the first shift at a new trust. Profession-specific detail on records and indemnity sits on the pages for locum GPs and locum hospital doctors. For anything touching your own indemnity or a specific incident, your defence organisation comes first.

Sources

• Guidance on the use of AI-enabled ambient scribing products in health and care settings (NHS England, published 27 April 2025, last updated 29 July 2026)
• Ambient voice technology-enabled products: medical device status (MHRA, gov.uk, 29 July 2026)
• Adopting ambient scribing products in health and care settings: the AVT Supplier Registry (NHS England Transformation Directorate, linked from the guidance above)
• New UK guidance clarifies medical device status of AI scribes (Covington, Inside EU Life Sciences, 6 August 2026)
• AI ambient scribing: NHS England warning and provisional LMC guidance (Surrey and Sussex LMCs, accessed September 2026)