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Clinic AI in Munich, what private clinics and health systems should know in 2026

By the wai teamOctober 15, 20268 min read

Reviewed by The Wellness Clinical Team, October 5, 2026

A clinician at ease in a vast, light-filled private clinic in Munich, the city beyond the glass

Key points

Summary

A Munich practice can use AI for notes and patient messages in 2026 once each use is in its record of processing, the need for an impact assessment is checked and documented, and health data enters the tool only on a valid legal basis, as the Bavarian data protection authority's checklist sets out. Practices in the statutory system also fill the ePA with findings and letters.

Munich practices now finish the day with every letter signed and filed, and with the evening's enquiries from patients of 191 nationalities already drafted for the morning. Bavaria has its own data protection authority and its own medical chamber, and both have published clear expectations. The Bavarian rules come first here, then a demo built on a Munich evening.

Part of the QM-RL hub, with the framework explained, a readiness checklist and 7 guides.

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191
citizenships among Munich residents at the end of 2025 1
30.6%
of Munich's 1,612,429 registered residents held no German passport on 31 December 2025 1
73,631
working doctors in Bavaria at the end of September 2025, up 2.6% in a year 2

See an evening enquiry from a Munich family become an approved reply, a booking with a deposit in euros and, after the visit, a signed letter ready for the ePA, in fifteen minutes with a clinician who uses wai daily.

The rules at a glance for a Munich practice
Body or lawRuleWhat to askHow wai meets it
BayLDA, AI checklistEach AI use in the Article 30 record, and the need for an impact assessment checkedWhich personal data enters the tool, and on what legal basisPatient data never used to train models, and every access logged
BayLDA, section 38 BDSGData protection officer once 20 or more people regularly process data automaticallyWho at the vendor answers the officer's questionsSubprocessors named with their agreements, and 30 days notice before any change
Bayerische LandesärztekammerTen years minimum, 30 years recommended for liabilityHow long records are kept and how they are exportedEvery message, draft and signature logged and exportable
ePA, mandatory since 1 October 2025Findings and doctors' letters filled for each treatmentHow signed letters reach the patient's ePAwai is built to connect to the ePA, set up with the practice
GDPR Article 9Health data processed only on a valid exceptionWhere data is hostedRecords hosted in the clinic's own country, set up with the clinic

The private care market in Munich

Munich grew by 8,653 people in 2025 to 1,612,429 registered residents, a rise of 4.5% over ten years.1 Of those residents, 492,935 held no German passport, and the city's statistics office counts 191 citizenships.1

Across Bavaria the medical chamber counted 73,631 working doctors at the end of September 2025, up from 71,737 a year earlier.2 Nearly four in ten doctors in Bavarian practices, 38.86%, now work as employees.2

The rules a Munich practice works under

Private practices in Bavaria answer to the Bayerisches Landesamt für Datenschutzaufsicht, the BayLDA. Its guidance for medical practices says a data protection officer must be named once at least 20 people regularly work with automated processing of personal data, and everyone counts, including part-time staff, trainees and freelancers.4

The BayLDA's checklist for AI, dated 24 January 2024, asks a practice to record each AI application in its Article 30 record of processing, with a separate entry for each purpose, and to check and document whether an impact assessment under Article 35 is needed.5 It also asks the practice to document which personal data goes into the tool, and notes that health data needs consent or an exception under Article 9(2) of the GDPR.5 The consent form template covers the patient's side.

Doctors in Bavaria are members of the Bayerische Landesärztekammer. Its guidance on treatment records sets ten years as the professional minimum and recommends keeping the record for 30 years where possible, because liability claims can arise that late.3 Records of radiation treatment are themselves kept for 30 years.3

The ePA, Germany's electronic patient record, has been mandatory for care providers since 1 October 2025. Providers fill it with the data the law sets for each treatment, such as findings and doctors' letters, and private insurers may offer their members an ePA too.6 wai is built to connect to the ePA. We set up your clinic's connection with you.

wai hosts each clinic's records in its own country, under that country's rules. We set this up with your clinic. wai is compliant with these rules and built for clinics in Munich. Every subprocessor is named, with thirty days notice before any change.8

The languages Munich patients write in

The largest groups without a German passport at the end of 2025 held Turkish (39,620), Croatian (35,780), Italian (28,759) and Ukrainian (27,176) citizenship, followed by Bosnian, Greek, Austrian and Indian.1 Many families write to the practice in the language they speak at home.

wai works in any language, and a member of the team approves each reply before it is sent.7

What a demo shows in Munich

The demo starts with an email sent at 21.40 by a son in Schwabing asking whether his mother can see the internist before her flight home at the end of the month. wai files it in the mother's thread, reads the internist's busy times from Outlook, Google Calendar or Apple Calendar and drafts a reply in his language with two open mornings. The receptionist approves it at 7.45.

The booking link takes a deposit in euros through the practice's own Stripe account, and the practice stays the merchant of record. After the visit the internist edits and signs the drafted note and the letter to the mother's own doctor, and the signed letter is ready for her ePA. A missed call from the son that afternoon becomes a drafted text the team approves.

For hospital groups, insurers and public bodies in Bavaria

Hospital groups and private insurers in Munich can have a system of their own built on wai, under their own brand, with data rights and exit terms agreed in the contract. Each build starts with one pathway and the measures that decide it. The organisations page sets out the model.

Where to start

First, add an entry for each AI use to the record of processing and document the impact assessment check, as the BayLDA checklist asks.5 Second, count the people who work with patient data, including trainees and freelancers, to see whether a data protection officer is due.4

Third, settle the keeping period with the vendor, using the chamber's 30-year recommendation as the benchmark.3 Fourth, list which signed letters go to the ePA and who sends them.6 More on sign-off is in who signs an AI clinical note.

Bring last month's enquiries and your ePA workflow, and we show the week running on wai.

Frequently asked questions

Who supervises data protection for a Munich private practice?

The Bayerisches Landesamt für Datenschutzaufsicht, the BayLDA, which publishes guidance for medical practices and a checklist for AI.45

Does a Munich practice need a data protection officer?

Yes, once at least 20 people regularly work with automated processing of personal data, counting part-time staff and freelancers.4

Does the practice need an impact assessment before using an AI scribe?

The BayLDA checklist asks the practice to check and document whether one is needed under Article 35, and to record the AI use in its record of processing.5

Is the ePA mandatory for Munich practices?

Since 1 October 2025 all care providers in the statutory system must use the ePA and fill it with the data the law sets, such as findings and letters.6 wai is built to connect to the ePA. We set up your clinic's connection with you.

How long should a practice keep records in Bavaria?

At least ten years, and the Bayerische Landesärztekammer recommends 30 years where possible because of liability claims.3

Can patients write in their own language?

Yes. wai works in any language, and nothing reaches the patient until someone at the practice has approved the draft.7

Sources

  1. 1Statistisches Amt der Landeshauptstadt München, 2026Münchner Statistik, 1. Quartalsheft 2026, Demografie der Münchner Bevölkerung 2025Read 15 October 2026Read source
  2. 2Deutsches Ärzteblatt, 2025Anteil angestellter Ärzte in bayerischen Praxen bei fast 40 Prozent (reporting Bayerische Landesärztekammer figures)Read 15 October 2026Read source
  3. 3Bayerische Landesärztekammer, 2026BehandlungsdokumentationRead 15 October 2026Read source
  4. 4Bayerisches Landesamt für DatenschutzaufsichtDatenschutzbeauftragter im medizinischen Bereich (Auslegungshilfe)Read 15 October 2026Read source
  5. 5Bayerisches Landesamt für Datenschutzaufsicht, 2024Datenschutzkonforme Künstliche Intelligenz, Checkliste mit Prüfkriterien nach DS-GVORead 15 October 2026Read source
  6. 6Bundesministerium für Gesundheit, 2026Die elektronische Patientenakte (ePA) für alleRead 15 October 2026Read source
  7. 7wai, 2026wai changelog, intake answered by voice in any languageRead 15 October 2026Read source
  8. 8wai, 2026Security at waiRead 15 October 2026Read source
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