AI-generated draft content. This page is educational and does not constitute legal advice. Regulatory obligations depend on your jurisdiction, organisation type, and specific AI use case — qualified legal, compliance, or clinical review is always required before adoption.

AI Risk Register for Healthcare & MedTech

Covers hospitals, clinics, primary care, digital health platforms, medical device manufacturers, in vitro diagnostics, pharmaceutical AI, clinical decision support, radiology AI, digital pathology, surgical robotics, remote patient monitoring, mental health technology, and health insurance claims AI. Any AI system that influences clinical decisions, patient triage, diagnosis, treatment selection, or medical device functionality falls within this overlay..

Why Responsible AI matters in healthcare

Organisations in healthcare face AI obligations that generic templates don’t cover — clinical-safety duties, sector-specific regulators, data protection expectations for the populations you serve, and emerging AI-specific legislation. Blanket policies written for software companies miss most of what matters.

The AI Risk Register produces a pre-scored AI risk register tailored to your jurisdiction, risk appetite, and the specifics of healthcare. It is a drafting aid built to accelerate — not replace — qualified review by your in-house practitioners or external counsel.

AI risks that matter in healthcare

Drawn from published evidence and regulatory guidance specific to healthcare. Each is pre-scored on a 5×5 likelihood × impact matrix in the Risk Register tool and referenced in the generated policy.

CriticalLikelihood 3 · Impact 5

AI Diagnostic Error Causing Delayed or Incorrect Treatment

An AI diagnostic or clinical decision support system produces an incorrect output — a missed malignancy, contraindicated drug recommendation, or false-negative screening result — that a clinician acts upon without sufficient independent verification, causing delayed, omitted, or incorrect treatment and direct patient harm.

CriticalLikelihood 4 · Impact 5

Demographic Bias Producing Disparate Clinical Outcomes Across Patient Groups

AI systems trained on historically unrepresentative datasets produce systematically less accurate outputs for underrepresented populations — including women, Black, Asian, and minority ethnic patients, elderly individuals, and patients with disabilities — leading to inequitable diagnostic accuracy, risk stratification, and treatment recommendations that perpetuate existing health disparities.

HighLikelihood 4 · Impact 4

AI Model Drift Causing Undetected Real-World Performance Degradation

A clinical AI model validated at deployment progressively deteriorates in real-world performance due to changes in patient population demographics, clinical workflows, disease prevalence, or medical imaging equipment, without the degradation being detected through post-market monitoring, resulting in a sustained period of substandard AI-assisted clinical care.

HighLikelihood 4 · Impact 4

Clinician Automation Bias and Unsafe Over-Reliance on AI Outputs

Clinical staff accept AI recommendations without applying adequate independent clinical judgment — particularly in high-volume settings using AI for triage or worklist prioritisation — resulting in systematic failures to catch AI errors that a vigilant clinician would have identified, and misallocation of clinical attention toward AI-flagged cases at the expense of AI-missed cases.

HighLikelihood 3 · Impact 4

Unlawful Processing of Patient Health Data in AI Training Without Valid Legal Basis

A healthcare AI system is trained or fine-tuned on patient health records, diagnostic images, or genomic data without adequate legal basis under GDPR Article 9 or HIPAA — for example by treating routine clinical data as available for commercial AI training without explicit consent — exposing the organisation to regulatory enforcement, patient trust damage, and potential criminal liability.

CriticalLikelihood 4 · Impact 5

Generative AI Hallucination in Clinical Documentation or Medical Information

Large language model-based AI tools used for clinical documentation, patient communication, or treatment protocol retrieval generate plausible-sounding but factually incorrect medical information — including fabricated drug interactions, incorrect dosage guidance, or invented clinical evidence — that enters the clinical record or influences treatment without being identified as erroneous.

How the five principles apply to healthcare

Human oversight

Outputs support, rather than replace, the qualified practitioners in your healthcare team. Human review is treated as a core step, not a rubber stamp.

Safety & validation

Before any AI system is acted on in healthcare, it is tested in the specific population, workflow, and risk context of your organisation — not just in a vendor's demo environment.

Transparency & explainability

Outputs carry enough context — regulatory references, assumptions, known limitations — that a reviewer in healthcare can trace and challenge them.

Accountability

Named roles — named individuals, named committees — are accountable for the AI decisions that affect people in your healthcare organisation.

Equity & inclusiveness

Performance is reviewed across the demographic groups your healthcare organisation actually serves, not just a representative-of-the-dataset average.

How the AI Risk Register works

You select jurisdiction, industry, and risk appetite. The tool produces an XLSX register pre-populated with 12 to 15 AI risks relevant to your sector — each already scored on a 5×5 matrix with suggested mitigations.

The workbook is designed for review inside your existing risk-management process: add organisation-specific risks, adjust scores, assign owners, and set review cadence. The starting point is a credible draft, not a blank template.

The output is a draft calibrated to healthcare — it still requires review by qualified in-house or external practitioners before adoption.

What you get — measured and defensible

  • Arrives as a working spreadsheet — not a PDF — so it fits straight into your risk workflow.
  • Each risk carries the regulatory obligation it maps to, so reviewers can trace the "why" without re-researching.
  • Bias considerations drawn from published evidence relevant to your sector, surfacing failure modes that generic templates miss.
  • Designed to be signed off by a qualified risk owner — the output does not replace that review, it accelerates the drafting stage.

Regulatory and governance considerations

Selected obligations the tool’s output references for healthcare. This is not a complete statement of your legal obligations — qualified counsel should verify applicability in your jurisdiction and context.

EU

EU AI Act — High-Risk AI in Medical Devices (Annex III §1 read with Annex I)

AI systems intended to be used as safety components of medical devices regulated under EU MDR 2017/745 and IVDR 2017/746 are classified as high-risk under EU AI Act Annex III §1, capturing AI-powered diagnostics, clinical decision support, predictive risk scoring, AI-driven drug dosing, and any AI embedded in a regulated medical device.

EU

EU Medical Device Regulation (MDR 2017/745) — AI Software as a Medical Device

Regulation (EU) 2017/745 governs all medical devices placed on the EU market, including software that qualifies as a medical device (SaMD). Under MDCG 2019-11 guidance, AI/ML software intended to diagnose, prevent, monitor, predict, prognose, treat, or alleviate disease typically qualifies as SaMD requiring CE marking.

EU

EU In Vitro Diagnostic Regulation (IVDR 2017/746) — AI in Diagnostic Analysis

Regulation (EU) 2017/746 governs IVD medical devices, including AI software used to analyse diagnostic specimens such as digital pathology slides, genomic sequencing outputs, and laboratory test results. AI-powered digital pathology tools and AI interpreting laboratory data for clinical purposes are captured under this regulation.

US

FDA AI/ML-Based Software as a Medical Device (SaMD) — Marketing Submission Recommendations 2023

The FDA regulates AI/ML-based SaMD in the United States through its 510(k), De Novo, and PMA pathways. FDA's 2023 Marketing Submission Recommendations and Predetermined Change Control Plan (PCCP) framework govern how AI medical software is reviewed, approved, and updated post-market.

Built to strengthen in-house expertise

Every output is an editable draft. Every section carries the regulatory basis it was built from, so reviewers in your healthcare team can verify, challenge, and adapt it to local context. Nothing is a finished legal instrument; nothing is intended to bypass qualified review.

We publish explicit disclaimers in the generated documents themselves, and treat human oversight as a default — not an opt-in. The tool’s role is to reduce the time your qualified practitioners spend on the first draft, so they can focus on review and adaptation.

Explore the AI Risk Register for Healthcare & MedTech

Review a sample of what the tool produces, then generate a draft tailored to your own healthcare organisation. $19.95 · one-time.

Laws the output references for healthcare

26 regulations across 8 jurisdictions. This list is descriptive, not exhaustive, and is subject to change — verify applicability with qualified counsel before relying on any reference.

BR

  • ANVISA RDC 657/2022 (ANVISA Resolução RDC 657/2022 — Requisitos para Software como Dispositivo Médico (SaMD))ANVISA Resolução RDC 657/2022 establishes specific requirements for Software as a Medical Device (SaMD) in Brazil, including AI/ML-based diagnostic, prognostic, and clinical decision support software. AI software meeting the SaMD definition requires ANVISA registration before commercialisation, with risk classification levels I–IV determining the requirements for technical documentation, clinical evidence, and quality management system certification.
  • Brazilian Artificial Intelligence Bill (PL 2338/2023 — Senate)Proposed Brazilian AI regulation establishing a risk-based governance framework with special obligations for high-risk AI systems used in consequential decisions affecting individuals in education, employment, credit, healthcare, and public services.

CN

  • Cybersecurity Law of the People's Republic of China (CSL 2017)Establishes cybersecurity obligations for network operators and critical information infrastructure operators in China, including mandatory security reviews for AI systems deployed in critical sectors and data localisation requirements.

EU

  • EU AI Act — High-Risk AI in Medical Devices (Annex III §1 read with Annex I)AI systems intended to be used as safety components of medical devices regulated under EU MDR 2017/745 and IVDR 2017/746 are classified as high-risk under EU AI Act Annex III §1, capturing AI-powered diagnostics, clinical decision support, predictive risk scoring, AI-driven drug dosing, and any AI embedded in a regulated medical device.
  • EU Medical Device Regulation (MDR 2017/745) — AI Software as a Medical DeviceRegulation (EU) 2017/745 governs all medical devices placed on the EU market, including software that qualifies as a medical device (SaMD). Under MDCG 2019-11 guidance, AI/ML software intended to diagnose, prevent, monitor, predict, prognose, treat, or alleviate disease typically qualifies as SaMD requiring CE marking.
  • EU In Vitro Diagnostic Regulation (IVDR 2017/746) — AI in Diagnostic AnalysisRegulation (EU) 2017/746 governs IVD medical devices, including AI software used to analyse diagnostic specimens such as digital pathology slides, genomic sequencing outputs, and laboratory test results. AI-powered digital pathology tools and AI interpreting laboratory data for clinical purposes are captured under this regulation.
  • EU Data Act (Regulation 2023/2854)Establishes rules on who may access and use data generated by connected products and related services, and enables public sector bodies to access privately held data in exceptional need.
  • EU Data Governance Act (Regulation 2022/868)Creates a framework for voluntary sharing of data held by public bodies for re-use, establishes requirements for data intermediation service providers, and introduces data altruism organisations.
  • NIS2 Directive (Directive 2022/2555)Establishes cybersecurity obligations for essential and important entities operating critical infrastructure and digital services across the EU, including AI systems forming part of critical infrastructure.
  • Revised EU Product Liability Directive (Directive 2024/2853)Extends product liability to AI systems and software, enabling consumers to seek compensation for harm caused by defective AI products without proving fault, with new disclosure obligations on defendants.

GLOBAL

  • IEC 62304 — Medical Device Software Lifecycle Processes (AI and ML Systems)IEC 62304 is the international standard for medical device software lifecycle processes, referenced in EU MDR, FDA guidance, and most national medical device regulatory frameworks globally. It defines software development, maintenance, risk management, and configuration management requirements for SaMD including AI and ML components.
  • WHO Guidance on Ethics and Governance of Artificial Intelligence for Health (2021)The WHO's foundational guidance on health AI ethics is referenced by health ministries and regulators globally as the international benchmark for AI governance in health settings where jurisdiction-specific regulation is absent or developing, covering the full AI lifecycle from design through decommissioning.

JP

  • PMDA Guidance on AI-Enabled Software as a Medical Device (March 2022) and the PMD ActThe Pharmaceuticals and Medical Devices Agency (PMDA) regulates AI-enabled SaMD in Japan under the Act on Securing Quality, Efficacy and Safety of Products including Pharmaceuticals and Medical Devices (PMD Act). AI medical software providing diagnosis, treatment, or prognosis support requires PMDA conformity assessment and marketing approval. Continuously learning AI/ML models require a Post-Market Change Control Programme (PCCP) agreed with PMDA before deployment, aligned with IMDRF SaMD framework principles.

UAE

  • Dubai Health Authority (DHA) AI in Healthcare Strategy and Digital Health StandardsThe Dubai Health Authority regulates healthcare delivery in the Emirate of Dubai. The DHA AI in Healthcare Strategy sets expectations for AI adoption by DHA-licensed facilities, requiring compliance with DHA digital health standards including AI clinical validation, data localisation under UAE PDPL, and licensing conditions for AI-enabled clinical decision support.
  • Abu Dhabi Department of Health (DoH) Digital Health Strategy 2.0 and AI GovernanceThe Abu Dhabi Department of Health regulates healthcare delivery in the Emirate of Abu Dhabi. DoH Digital Health Strategy 2.0 establishes AI governance requirements for DoH-licensed facilities, including Malaffi (UAE health information exchange) integration requirements and AI clinical validation expectations. AI clinical decision support tools may additionally require registration with the federal Ministry of Health and Prevention (MOHAP) as medical devices.
  • UAE National AI Strategy 2031National strategy to position the UAE as a global AI leader by 2031, establishing AI governance principles, an AI ethics framework, and sector-specific AI adoption roadmaps for government, healthcare, transport, education, and energy.
  • UAE Department of Health — AI and Digital Health Governance PolicyUAE government policy governing the use of AI in healthcare settings including AI diagnostic systems, clinical decision support, predictive analytics, and health data management by licensed healthcare providers.

UK

  • UK MHRA Software and AI as a Medical Device Policy and SaMD Change ProgrammeThe MHRA regulates AI SaMD in Great Britain under the Medical Devices Regulations 2002 (as amended) and is developing bespoke UK AI SaMD requirements through its Software and AI as a Medical Device Change Programme, expected to introduce proportionate, risk-based obligations for AI clinical tools from 2025 onwards.
  • DCB0160 Clinical Safety Standard (DCB0160 (NHS Digital Clinical Safety Standard))DCB0160 is a mandatory clinical safety standard issued by NHS Digital (now NHS England) that applies to all Health IT systems deployed in NHS-commissioned services in England, including AI-powered clinical decision support, diagnostic tools, e-prescribing, and patient triage systems. It requires a documented clinical risk management process overseen by a qualified Clinical Safety Officer (CSO) who must hold GMC, NMC, or equivalent registration. Applies only to NHS England/Wales deployments — private healthcare, EU, and non-NHS deployments are out of scope.
  • Care Quality Commission Standards (Health and Social Care Act 2008 / CQC Fundamental Standards)The Care Quality Commission regulates health and social care providers in England under the Health and Social Care Act 2008. All CQC-registered providers — including NHS trusts, independent hospitals, GP practices, and care homes — that deploy AI in patient-facing care settings must ensure AI use is consistent with the CQC's Fundamental Standards (safe, effective, caring, responsive, well-led care) and the CQC's emerging guidance on digital and AI-enabled care.

US

  • FDA AI/ML-Based Software as a Medical Device (SaMD) — Marketing Submission Recommendations 2023The FDA regulates AI/ML-based SaMD in the United States through its 510(k), De Novo, and PMA pathways. FDA's 2023 Marketing Submission Recommendations and Predetermined Change Control Plan (PCCP) framework govern how AI medical software is reviewed, approved, and updated post-market.
  • HIPAA Privacy and Security Rules — AI Processing of Protected Health InformationThe Health Insurance Portability and Accountability Act (45 CFR Parts 160, 162, and 164) governs use and disclosure of protected health information by covered entities and business associates, including any AI system that accesses, processes, stores, or transmits PHI such as clinical NLP tools, AI diagnostic platforms, and care management AI.
  • Colorado Artificial Intelligence Act (SB 24-205)Requires developers and deployers of high-risk AI systems in Colorado to use reasonable care to protect consumers from algorithmic discrimination in consequential decisions including employment, credit, insurance, and healthcare.
  • California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA)Grants California residents comprehensive rights over their personal information and regulates how businesses collect, use, sell, and share personal data, including data used in automated decision-making.
  • FTC Act Section 5 — Unfair or Deceptive Practices Applied to AIThe FTC applies its Section 5 authority prohibiting unfair or deceptive acts and practices to AI systems, including deceptive AI-generated content, biased algorithmic decisions, and harmful AI-enabled practices targeting consumers.
  • Illinois Biometric Information Privacy Act (BIPA)Regulates the collection, storage, use, and disclosure of biometric identifiers and biometric information — including facial recognition and fingerprints — by private entities operating in Illinois.