AI scribes have quickly become one of the more visible perks in recent GP recruitment. Some practices now advertise “AI scribe provided” in job ads, alongside billings and flexibility, because the tools cut the after-hours documentation load that drives so much GP burnout. Uptake has been rapid: around 40% of newsGP readers reported regularly using an AI scribe by November 2025, with Heidi Health and Lyrebird the most common products. Source.
The regulatory picture has not kept pace. Reporting on 9 July 2026 revealed that redacted government documents, obtained by The Guardian under freedom of information laws, show officials warning that many AI scribes “fall outside this framework and have little oversight”. At the same time, the Therapeutic Goods Administration (TGA) is running a dedicated review of the most widely used digital scribes, with a summary of outcomes expected in coming months. Source.
For practice owners and recruiters, that gap matters. An AI scribe can be a real drawcard when you are competing for GPs, but it is a clinical governance decision, not simply an IT purchase. This is a practical overview of what the review means, the obligations that already apply, and what to check before your practice signs up. The same points apply to medical imaging and other practices adopting scribes.
Key Summary
- Fast adoption: around 40% of newsGP readers reported regularly using an AI scribe by November 2025, most commonly Heidi Health and Lyrebird. (newsGP)
- “Little oversight”: FOI documents show officials warning that many AI scribes fall outside the regulatory framework, with some marketed as “outside regulatory levers” or “privacy compliant” with limited transparency. (newsGP)
- A review is underway: the TGA’s 2025 clinical AI review recommended an urgent review of digital scribes; that dedicated review is ongoing, with a summary due in coming months. (TGA / newsGP)
- The line in the sand: a scribe that only drafts notes is generally not a medical device; one that suggests a diagnosis or treatment may be. (TGA / RACGP)
- Consent is not optional: RACGP says GPs must obtain patient consent before using an AI scribe, and AHPRA stresses informed consent for tools that record consultations. (RACGP / AHPRA)
- Data can leave Australia: practices must check whether scribe data is processed or stored offshore, and how it may be reused. (RACGP)
- You stay responsible: the GP remains responsible for the accuracy of the record and must review every note. (RACGP / AHPRA)
Why AI Scribes Have Become a Recruitment Drawcard
The appeal is easy to see. Documentation, and the notes GPs finish after hours, is a well-recognised contributor to burnout and to doctors cutting back their hours. An ambient AI scribe listens to the consultation and drafts the note, letter or summary, which can hand time back to the clinician. As uptake climbed through 2025, “AI scribe provided” started to appear in job ads as a signal that a practice takes clinician workload seriously. Source.
For a practice competing on more than pay, that signal can help. It sits alongside sensible rostering, mixed billings and real flexibility as one of the levers that make a role easier to fill and a GP more likely to stay. Our overview of working with a recruiter in 2026 covers how candidates read these signals.
Recruitment reality check: a scribe can be a real drawcard, but it is a clinical governance decision, not just a perk or an IT choice. The obligations below sit with the practice and the treating clinician, whoever chose the software.
What the FOI Papers and the TGA Review Actually Say
The reporting that prompted this article is based on heavily redacted departmental papers, obtained by The Guardian under freedom of information laws and reported by newsGP on 9 July 2026. In them, officials warn that “many AI products, such as AI medical scribes, fall outside this framework and have little oversight”. The documents also note that some products are “marketed as outside regulatory levers (eg, not a medical device) or as privacy compliant, often with limited transparency”, and that “some suppliers may be unaware their cloud platforms send data outside Australia”. Source.
The TGA’s position has been building for a year. In its broader clinical AI review, published in July 2025, the TGA found that some digital scribes may already meet the definition of a medical device, particularly where they suggest diagnoses or treatments, and recommended an urgent review of digital scribes. Source. That dedicated review is now underway, prioritising the products most widely used in Australia, with the TGA planning to publish a summary of outcomes in coming months. Source.
The practical test for now is where the tool sits. Under existing TGA guidance, a digital scribe is generally not a medical device if it only generates clinical notes, summaries or letters for a patient record. It moves towards being a regulated medical device once it starts to suggest a diagnosis or recommend treatment. Source.
| Generally not a medical device | May be a regulated medical device |
|---|---|
| Transcribes the consultation and drafts notes, summaries or letters for the record | Suggests or proposes a diagnosis |
| Leaves all clinical decisions to the treating clinician | Recommends or ranks treatment options |
| Output is checked and signed off by the GP | Interprets findings or presents them as clinical conclusions |
As Dr Sean Stevens, RACGP Specific Interests Digital Health and Innovation Chair, puts it: “AI scribes should not be counted as software as a medical device unless they’re helping make or making diagnosis and recommending treatments. That is the line in the sand.” He adds that what is most important is that the GP or other doctor retains clinical oversight. Source.
The Compliance Caveats to Check Before You Advertise One
None of this stops a practice using an AI scribe, and none of it waits for the TGA review to finish. RACGP and AHPRA guidance already set clear expectations. Here is what to have in place.
1) Get patient consent, every time
RACGP is explicit that GPs must obtain consent from patients before using an AI scribe during a consultation. Some medical defence organisations recommend written consent, while verbal consent documented in the notes may be acceptable where written consent is not required. Source. AHPRA adds that informed consent is particularly important for AI models that record private conversations, and that it should be documented in the health record. Source.
2) Know where the data goes
RACGP advises practices to check whether data collected by the scribe is processed or stored outside Australia, and if it is, to confirm the vendor applies privacy standards and protections similar to Australia’s. It also recommends reviewing the user agreement to see whether data will be reused for secondary purposes by the vendor or a third party. Source. This is the concern the FOI papers singled out, where some suppliers may not realise their cloud platforms send data offshore. Source.
3) Remember who owns the record
The clinician remains responsible. RACGP states that GPs using AI scribes are responsible for ensuring their patients’ health records are accurate and up to date, and should review the notes as soon as possible after each consultation. Source. AHPRA’s guidance is that the practitioner remains responsible for safe, quality care and must apply human judgment to any AI output, and that TGA approval of a tool does not reduce that duty. Source. Dr Stevens’ practical advice is to read through all of the scribe’s output, focusing on the critical areas: “medications, doses of medications, recommended treatments, left and right”. Source.
4) Understand the tool before you rely on it
AHPRA expects practitioners to understand how a tool is trained and tested, its intended use and limitations, and whether patient data is used to retrain the model. Buying the software is not the end of the diligence; someone in the practice needs to be able to answer those questions. Source.
5) Put a practice policy in place
RACGP recommends practice owners develop a policy on AI scribe use, setting out which tools are permitted and how any breaches are reported. A written policy also makes the “AI scribe provided” line in your job ads something you can stand behind. Source.
6) The same rules apply beyond general practice
These obligations are not unique to GP clinics. Medical imaging and radiology practices adopting ambient scribes for consultations or reporting face the same consent, data location and oversight questions. It helps to separate two different uses of AI in imaging: a documentation scribe that drafts notes, and AI that interprets images or flags findings. The second is far more likely to be a regulated medical device in its own right, which is a separate governance question from the scribe. For where imaging demand is strongest, see our medical imaging hot spots overview, and for the broader shift towards AI capability across the professions, our note on AI tools to AI leadership.
Before you advertise “AI scribe provided”, confirm:
- a consent process is in place and documented;
- you know whether patient data is stored or processed offshore, and on what terms;
- the practice has a written AI scribe policy naming permitted tools;
- every clinician understands they still own, and must review, the record.
Conclusion
AI scribes are a useful tool and a fair thing to offer when you are recruiting. The caution in the FOI papers is not that the tools are unusable; it is that oversight has not caught up with how fast they have spread. Source.
The sensible position while the TGA review runs is to treat a scribe as a clinical governance decision: get consent, know where the data lives, keep a policy, and keep the clinician firmly in charge of the record. Do that, and “AI scribe provided” becomes a perk you can advertise with confidence. Each practice should confirm its own obligations directly with the TGA, RACGP, AHPRA and its medical defence organisation.
Disclaimer: This blog is a general overview and should not be construed as professional legal, financial or medical advice.
FAQs
- Are AI scribes regulated as medical devices in Australia?
A scribe that only drafts notes, summaries or letters for the record is generally not a medical device under current TGA guidance. One that suggests a diagnosis or recommends treatment may be. The TGA is reviewing widely used digital scribes and expects to publish a summary of outcomes in coming months.
- Do I need patient consent to use an AI scribe?
Yes. RACGP says GPs must obtain patient consent before using an AI scribe in a consultation. Some medical defence organisations recommend written consent, while verbal consent documented in the notes may be acceptable where written consent is not required. AHPRA stresses informed consent for tools that record private conversations.
- Where is my patients’ data stored, and does it matter?
It can matter a great deal. RACGP advises checking whether scribe data is processed or stored outside Australia and, if so, confirming the vendor applies privacy protections similar to Australia’s. Government documents flagged that some suppliers may not realise their platforms send data offshore, which is a patient data security risk.
- Who is responsible if the scribe’s note is wrong?
The treating clinician. RACGP says GPs are responsible for ensuring records are accurate and must review notes after each consultation. AHPRA says a practitioner must apply human judgment to any AI output, and that TGA approval of a tool does not change that responsibility.
- What is the TGA review, and when will it report?
After its clinical AI review in 2025 recommended an urgent look at digital scribes, the TGA began a dedicated review of the most widely used products. It has said it plans to publish a summary of outcomes in coming months.
- Can practices still advertise an AI scribe as a job perk?
Yes. Nothing prevents a practice offering one. The key is to treat it as a clinical governance decision: consent, data location, a written policy, and clear clinician oversight, so the perk is one you can stand behind.
Information Sources
- newsGP (RACGP): “‘Little oversight’: Officials air AI scribe worries”, 9 July 2026
- Therapeutic Goods Administration: Digital scribes
- Therapeutic Goods Administration: AI Review, outcomes report published
- RACGP: Artificial intelligence (AI) scribes
- AHPRA: Meeting your professional obligations when using Artificial Intelligence in healthcare
