Issued2026-10-16

Digital Scribes — Medical Device Regulatory Guidance

Regulatory GuidanceSector

Summary

Explains when AI and ambient digital scribes are medical devices in Australia. Administrative recording, transcription and summarization without new clinical suggestions generally fall outside device regulation; intended diagnostic, treatment, triage or other therapeutic functions can bring a scribe within medical-device requirements. Intended purpose includes claims, functionality and presentation.

Healthcare Implications

Developers and suppliers should assess each scribe function and reassess regulatory status when features change. Medical-device functions generally require ARTG inclusion unless exempt; administrative-only tools can remain subject to privacy and other laws. General disclaimers do not negate therapeutic functionality or claims.

Impact Level

Medium

Keywords

Transparency & Governance; Safety & Risk; Clinical Quality & Efficacy

Stakeholders

Providers & Health Systems; Developers & Vendors; Regulators & Government