— By Dean Mawson, Founder and Clinical Director, DPM.
A safer route through the AVT “Wild West”?
When it came to AVT (ambient voice technology) — or “AI Scribes” — in the NHS, 2026 started with a bang.
Or perhaps more accurately, a damp whistle.
The long-awaited NHS AVT Registry was launched with much fanfare, positioned as a response to the “Wild West” of digital health tools entering the system.
Many of us were hoping for a list of assured technologies ready for rollout. A list that would cut down on paperwork and duplicative safety assessment processes and allow NHS organisations to select and work with suppliers confident in the knowledge that the tool was safe.
But we were disappointed.
The NHS AVT Registry is not a clinical safety assurance mechanism. And treating it like one risks creating a dangerous false sense of security.
What the NHS AVT Registry is
The NHS AVT Registry is, in practice, a self-certified list.
Yes, each listed supplier has to submit paperwork to prove they hold Class I Medical Device Accreditation and a current DTAC assessment, and they must provide some form of evidence of NHS benefit — which may be as limited as a case study.
BUT — here’s the key part — NHS England hasn’t reviewed what’s actually in the paperwork. In other words, the registry confirms that paperwork exists. It does not confirm that the underlying clinical risk has been robustly assessed or mitigated.
The responsibility of this will still sit with whichever individual NHS organisations want to buy that particular product. Many of which lack the capacity, time, and skills to do the work.
It is by no stretch of the imagination a list of tech that is safe to deploy.
Compliance is not the same as clinical safety
Regulatory classification is not the same as clinical assurance.
A Class I medical device registration reflects how a product is categorised under medical device regulations — not whether its real-world deployment in complex clinical environments has been rigorously stress-tested.
DTAC demonstrates that a supplier has met digital standards. It does not replace a local clinical safety case.
Documentation can demonstrate compliance. It cannot, on its own, demonstrate safety in use.
That distinction is important — particularly with AVT systems generating clinical documentation that becomes part of the patient record.
The risk of false reassurance for NHS buyers
The existence of the NHS AVT Registry without proper assurances risks creating a false sense of safety amongst buyers by listing suppliers without independently validating clinical safety. Each buyer will still have to do their own checks, their own clinical safety cases, their own due diligence.
I’m not saying that being on the list means the technologies must be unsafe. But it’s not verifying they are safe either.
Whilst the principle of a registry is solid, the reality of what has been launched falls short of what is needed to ensure clinical safety.
The assurance burden still sits locally
The registry exposes a wider structural issue: central visibility without central validation.
The accountability for safe deployment still sits with individual NHS organisations — many of which lack the time, specialist expertise, or clinical safety capacity to interrogate complex AI systems properly.
Procurement teams need safe shortcuts. They need trusted assurance artefacts that reduce duplication without reducing rigour.
The current registry does not yet provide that.
AVT “passports”: the missing step?
The “innovator passports” we heard about last summer point toward what good could look like for the next stage of the NHS AVT Registry. Standardised, independently reviewed assurance that travels with the product.
If the registry evolves into something that includes meaningful clinical validation — shared safety cases, transparent risk mitigation strategies, named accountable Clinical Safety Officers (CSOs) — then it could accelerate safe adoption.
Perhaps that’s the next step for this list — properly assuring the technologies on it so they can be rolled out quickly and safely without unnecessarily duplicative processes.
If we want safe AVT adoption, we need real assurance
Ambient voice technology has enormous potential to reduce administrative burden and release clinical time. But confidence in these systems will only grow if assurance mechanisms are credible and trusted.
Minimum compliance is not the same as meaningful clinical scrutiny.
If you are an NHS organisation deploying AVT and need additional clinical safety capacity — whether that’s a named CSO, independent assessment, or support building internal expertise — we can help.
And if you are a supplier seeking to strengthen your medical device registration, DTAC position, or clinical risk management systems, we work with teams to ensure their assurance stands up to real-world stress.
The system and suppliers often lack capacity. You don’t have to navigate that alone.
AI Governance and Risk Management training: register now.
Many healthcare organisations are deploying AI faster than they can safely govern it. And when something goes wrong, responsibility still sits with named individuals – like Clinical Safety Officers (CSOs).
To help address the gap, DPM has launched two one-day training courses designed specifically for professionals responsible for safety-critical systems. Each course provides practical frameworks and tools to apply safety thinking to AI with confidence.
- AI Governance
Focuses on organisational control and accountability – equipping participants to oversee AI safely and responsibly in real healthcare environments. - AI Risk Management
Covers technical safety assessment and hazard control – building the specialist skills needed to assess AI.
Both courses are led DPM’s Founder and Clinical Director, Dean Mawson. He has 30+ years of experience in frontline care, healthtech project delivery, and clinical safety leadership – the ideal leader to support organisations across the NHS and digital health sector with their AI capabilities through a safety lens.
Register your interest: https://wkf.ms/4ajTEWJ
