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How to actually buy an AI scribe in the NHS

By the wai teamOctober 14, 20268 min read

Reviewed by The Wellness Clinical Team, October 5, 2026

Summary

There are two live NHS Shared Business Services routes. Digital Dictation, Speech Recognition and Outsourced Transcription 2, worth £150m and running from 1 October 2025 to 30 September 2027, which covers ambient voice and AI scribing tools. And the Healthcare AI Solutions framework, launched on 11 May 2026 at £900m. The AVT Supplier Registry is not a third one. NHS England states plainly that it is not a commercial framework.

Two things get confused constantly here, and confusing them wastes weeks. A route to market tells you how you are allowed to contract. An assurance process tells you whether the product is safe and lawful to deploy. They are different questions, they are answered by different people, and passing one says nothing about the other.

The AVT Supplier Registry sits in the middle and is routinely mistaken for both. NHS England describes it as a national self-certified registry and says directly that it is not a commercial framework and that it does not endorse the suppliers on it.

What follows is the routes that exist, what each covers, and the order to do things in so that procurement and assurance do not each wait for the other.

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Routes and registries, and what each one actually is
What it isWhat it is not
NHS SBS Digital Dictation, Speech Recognition and Outsourced Transcription 2£150m framework, 1 Oct 2025 to 30 Sep 2027, covers AVT and AI scribingNot an assurance process
NHS SBS Healthcare AI Solutions£900m framework launched 11 May 2026Not scribe specific
AVT Supplier RegistryNational self-certified list with an evidence repositoryNot a framework, not an endorsement, not compulsory
DTACThe assessment a supplier completesNot a purchase route
Local or ICB agreementWhere most GP practice buying actually landsNot a substitute for the assurance work

The two frameworks that exist

NHS Shared Business Services runs Digital Dictation, Speech Recognition and Outsourced Transcription 2, a £150m agreement covering software, hardware, integration, training, consultancy and support, with provision for ambient voice technology and AI-enabled scribing tools as they reach market. The agreement period runs from 1 October 2025 to 30 September 2027.

NHS SBS also launched a Healthcare AI Solutions framework on 11 May 2026, at £900m, with supplier applications open to 23 June 2026. It is broader than scribing and covers healthcare AI generally.

A framework gives you a compliant way to contract with pre-vetted suppliers without running your own tender. It does not tell you the product is clinically safe in your setting, and no framework in this market does.

The registry, one more time

NHS England launched the AVT Supplier Registry on 16 January 2026, with applications reopening on 3 February 2026 through the Find a Tender service. It has been reported as holding 13 suppliers, with more to be added as they complete compliance and validation.

Inclusion has been described as requiring a completed DTAC assessment and MHRA registration as a medical device where applicable. Those last two words carry weight after the MHRA guidance of 29 July 2026, which took most transcription and summarisation products out of the device definition entirely.

So the registry is a place to gather evidence quickly, not a purchase route and not a pass mark. A product absent from it faces no stated restriction, whatever the secondary coverage says. Our full read of the current position is in AI scribes in the NHS.

The order that stops the deadlock

The common failure is procurement waiting for assurance while assurance waits for a named product, and both waiting for a budget that needs a business case that needs a price. Break it by doing the parts that do not depend on each other first.

Start the Clinical Safety Officer appointment and training immediately, because it is the longest lead time and it is product independent. Start the baseline measurement at the same time, because you cannot recover it later. Draft the DPIA skeleton against the processing you intend rather than the vendor you have not chosen.

Then shortlist, and ask every supplier for the DCB0129 safety case, the DTAC and the DSPT position before a demo rather than after an order. Our guide to what to ask a scribe vendor is the list, and the business case covers what to measure.

Primary care buys differently

Most GP practice and primary care network purchasing does not go anywhere near a national framework. It lands as a local agreement, often with an integrated care board involved and often funded from a transformation pot rather than a core budget.

NHS England's guidance is explicit that organisations should not enter commercial agreements with suppliers without ensuring the supplier meets all national and local requirements agreed through your ICB or region. In practice that means the ICB's digital or information governance team has a view, and finding out what it is early is cheaper than finding out late.

The other primary care reality is that something may already be installed. The messaging platform in around 98 percent of English GP practices now has a scribe available inside it, which makes the lowest friction trial the one that needs no procurement at all.

A pilot is not a procurement workaround

NHS England states that running a pilot or proof of concept does not exempt a supplier from compliance, and that pilots may continue only if they are time-limited, up to four months, and are not used to bypass compliance.

That closes the most common shortcut, which is calling a deployment an evaluation so the paperwork can follow. The safety case, the hazard log, the DPIA and the Clinical Safety Officer are required before the first patient either way.

Used properly the four months are generous. Our guide to running a scribe pilot sets out the acceptance criteria worth agreeing in writing before it starts, so the evaluation answers the purchase question rather than producing impressions.

The independent clinic, which has no framework at all

Everything above describes how an NHS organisation is permitted to buy. An independent clinic has no framework, no registry and no procurement route to satisfy, and buys the way any business buys software. That removes a constraint, and it also removes a filter that was working on the buyer's behalf.

What a framework did was check the supplier before the clinic ever saw it. The legal entity behind the brand, the insurance, the data handling and the financial standing were assessed by somebody else as a condition of being listed. A private buyer either does that work itself or does not do it, and not doing it is the common case.

The questions that survive the move out of the NHS estate are the regulatory ones rather than the procurement ones. Which legal entity you are contracting with, where the data sits, and what the system can evidence when somebody asks. Those are set out regulation by regulation in software and CQC, what is actually being assessed.

Where wai sits

wai is built for private practice rather than for the NHS estate, and the honest position is that an NHS organisation has better-fitted options today. If you are an NHS buyer, the questions on this page still apply to every supplier you speak to, including the ones we compete with.

For a private clinic none of the framework machinery applies. The price is published on one page, there is no procurement cycle, and the assurance conversation is a DPIA and a processor agreement rather than a national assessment.

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Frequently asked questions

Which framework can an NHS organisation buy an AI scribe through?

NHS Shared Business Services runs Digital Dictation, Speech Recognition and Outsourced Transcription 2, worth £150m and running from 1 October 2025 to 30 September 2027, which covers ambient voice technology and AI scribing tools. NHS SBS also launched a broader £900m Healthcare AI Solutions framework on 11 May 2026.

Is the AVT Supplier Registry a framework?

No. NHS England states directly that it is not a commercial framework and that it does not endorse the suppliers listed on it. It is a national self-certified registry with a repository of supporting evidence, launched on 16 January 2026, intended to speed up local procurement and assurance rather than replace either.

How many suppliers are on the AVT registry?

It has been reported as holding 13 suppliers, with more to be added as they complete compliance and validation. Applications reopened on 3 February 2026 through the Find a Tender service and remain open.

Does being on a framework mean a product is compliant?

No, and this is the most expensive confusion in the process. A framework is a route to contract. Clinical safety, data protection and device status are separate assessments carried out by different people. Passing one says nothing about the other.

How does a GP practice or PCN buy one?

Usually as a local agreement rather than through a national framework, often with the integrated care board involved. NHS England's guidance says organisations should not contract without ensuring the supplier meets national and local requirements agreed through the ICB or region, so find out the ICB's position early.

Can we start a pilot while the paperwork catches up?

No. NHS England states that a pilot or proof of concept does not exempt a supplier from compliance and may continue only if time-limited to four months and not used to bypass it. The safety case, hazard log, DPIA and Clinical Safety Officer are required before the first patient.

What should we start before choosing a supplier?

The Clinical Safety Officer appointment and training, because it is the longest lead time and does not depend on the product. The baseline measurement, because it cannot be recovered afterwards. And a DPIA skeleton written against the processing you intend rather than the vendor you have not picked yet.

Which framework does a private clinic buy an AI scribe through?

None. Frameworks are NHS procurement instruments and an independent clinic has no route to satisfy. The practical consequence is that the checks a framework performed as a condition of listing, on legal entity, insurance, data handling and financial standing, fall to the clinic instead.

Sources

  1. NHS SBS, framework for market-ready ambient voice and AI scribing tools
  2. NHS England, ambient scribing and the AVT Supplier Registry
  3. NHS England, guidance on the use of AI-enabled ambient scribing products in health and care settings
  4. MHRA, ambient voice technology enabled products, published 29 July 2026

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