Key points
- The city of São Paulo had 80,834 registered doctors in 2024, the largest number of any Brazilian capital, at 6.80 per 1,000 residents.1
- 5,974,409 people in the city hold a private medical plan in the ANS coverage data updated in September 2026.2
- CFM Resolution 2.454, published on 27 February 2026 and in force 180 days later, keeps the doctor fully responsible for any act carried out with AI and bars handing the communication of a diagnosis to AI without human mediation.5
- Under the ANPD's incident rule, a clinic reports a qualifying data breach to the authority and to the patients affected within three working days.4
- wai hosts each clinic's records in its own country, under that country's rules. We set this up with your clinic.
Summary
A São Paulo clinic answers to the CFM and CREMESP for medical practice, to the LGPD and the ANPD for patient data, and to São Paulo state's patient rights law. Since late August 2026 the CFM's AI resolution has applied, so the doctor stays responsible and the patient is told when AI supports their care. wai drafts and a person at the clinic approves and signs, which is how those rules expect AI to work.
In São Paulo the patient who messages at 22:00 about a Saturday appointment now wakes to a paid booking and a reply drafted by wai and approved by the clinic's own team. The doctor starts the day with notes ready to sign and the evening clear.
The city has more registered doctors than any other Brazilian capital, and since 2026 its rules on health data and AI are specific.
Part of the JCI hub, with the framework explained, a readiness checklist and 8 guides.
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See it in your clinicThirty minutes on your own patients and doctors.
Request a demoSee a São Paulo demo with a late-evening WhatsApp booking, a deposit paid by card into your own Stripe account and a consult note ready to sign.
| Body or law | What it requires | What to ask | How wai meets it |
|---|---|---|---|
| CFM and CREMESP | Medical registration and ethics, with CREMESP supervising CFM resolutions in the state | Who signs every AI-drafted note and letter | The doctor reviews and signs every note and letter |
| CFM Resolution 2.454 of 2026 | Human supervision of AI, patient told and able to refuse, no AI-delivered diagnosis | Can any AI output reach a patient without a person | wai drafts and a person at the clinic approves or signs before anything is sent |
| LGPD and the ANPD | Health data as sensitive data, a legal basis for each use, breach notice within three working days | Who is controller, who is processor, and who notifies | Every message, draft, approval and signature is logged and exportable |
| São Paulo State Law 10.241 of 1999 | Secrecy of personal data and access to the record at any time | How fast can a patient get their record | Patients see visits, results and letters in their own wai Profile |
| RNDS | National interoperability across public and private services | How the clinic's records reach the national network | wai is built to connect to the RNDS, set up with the clinic |
| Data residency | Health data handled under Brazilian law | Where are records hosted | Records hosted in Brazil, set up with the clinic |
The private care market in São Paulo
The national medical demography study counted 80,834 doctors registered in the city of São Paulo in 2024, against an estimated 11,895,578 residents, the highest absolute number of any state capital.1 The wider state held 172,721 doctors, 65.0% of them with a specialist title, among them 3,926 dermatologists and 2,626 plastic surgeons.1
Many patients arrive with private cover. The ANS open data on plan coverage, updated in September 2026, shows 5,974,409 beneficiaries of medical and hospital plans living in the city.2 For a specialist clinic that means a steady mix of plan patients and private payers, and a diary that rewards fast replies and paid bookings.
The rules a clinic in São Paulo works under
Doctors practise under the Conselho Federal de Medicina and register with CREMESP, the regional council for São Paulo state, which supervises compliance with the CFM's AI resolution in the state.75
Health data is sensitive personal data under the LGPD. It may be processed with the patient's specific and highlighted consent, or without it where processing is indispensable for health protection by health professionals, health services or a health authority.3 The ANPD enforces the law, and its Resolution 15 of 2024 gives a controller three working days from learning of an incident to notify the authority and, on the same clock, the patients affected.64
CFM Resolution 2.454 of 2026 is the national rule on AI in medicine.5 It treats AI output as support that always needs human supervision, keeps the doctor fully responsible for acts carried out with it, gives the patient a right to be told when AI plays a relevant part in their care, and requires the doctor to respect a patient's informed refusal.5 It also forbids delegating to AI the communication of a diagnosis, prognosis or treatment decision without human mediation.5
São Paulo state adds Law 10.241 of 1999, which gives every user of health services in the state the right to professional secrecy over their personal data, to consent to or refuse procedures with adequate information, and to access their medical record at any time.8
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 São Paulo. The national exchange is the RNDS, the Ministry of Health's interoperability platform, which joins public and private services so a patient's history can follow them.9 wai is built to connect to the RNDS. We set up your clinic's connection with you.
The languages São Paulo patients write in
Federal Police data compiled by the city in December 2019 counted about 360,000 registered immigrants in São Paulo, from 203 nationalities.10 Bolivians made up 20.8% of them, Portuguese 14.5%, and Chinese and Japanese together 14.4%.10
wai works in any language.11 Bring real messages from your own inbox to the demo and judge each draft against the message it answers.
What a demo shows in São Paulo
A patient in Moema sends a WhatsApp at 22:10 asking for a dermatology slot on Saturday morning. wai reads the doctor's busy times from Google Calendar, Outlook or Apple Calendar, offers the open 9:30, and drafts the reply in the clinic's voice. The receptionist approves it at 8:00 and the booking link goes out.
The patient books on the clinic's own website in three taps and pays the deposit by card or Apple Pay into the clinic's Stripe account, with the clinic as merchant of record.12 A confirmation, a receipt and an intake questionnaire follow at once.12
In the consultation, recording consent was already taken at booking, and the screen shows the visit's top topics. wai drafts the note and the referral letter, and the doctor reviews and signs each one, which is the human supervision the CFM resolution asks for. Read how that approval step works in human approval for patient messages.
For hospital groups, health plans and public bodies in São Paulo
For larger organisations wai builds one defined care pathway at a time on the live platform, with data, workflow and model rights, portability and exit terms agreed in the contract, as set out on wai for organisations. Institutions running their own AI systems should note that Resolution 2.454 asks them to form an AI and telemedicine committee under medical coordination.5
Where to start
First, add a line to the patient consent form saying that AI supports note writing and that the patient may refuse it, as Resolution 2.454 provides.5 Second, write down who in the clinic reports an incident to the ANPD and how you would reach patients within three working days.4
Third, export one week of WhatsApp and email enquiries and mark which arrived after 19:00. Bring that week to a fifteen-minute demo and watch each one drafted for your team. The plans and their prices are listed on the pricing page.
Bring a week of your clinic's WhatsApp and email enquiries and see each one drafted for your team to approve.
Frequently asked questions
Does the CFM allow AI scribes in São Paulo clinics?
Yes, as a support tool under human supervision. Resolution 2.454 keeps the doctor fully responsible, gives patients the right to be informed and to refuse, and forbids AI from communicating a diagnosis without human mediation.5
Do we need patient consent under the LGPD to process health data?
Health data is sensitive data. The LGPD allows processing with specific consent, or without consent where it is indispensable for health protection by health professionals or services.3 Confirm the basis for each use with your counsel.
How quickly must a clinic report a data breach in Brazil?
Within three working days of learning that an incident affected personal data, to the ANPD and to the patients affected, under the ANPD's 2024 resolution.4
Who regulates doctors in São Paulo?
Where would our records be hosted?
wai hosts each clinic's records in its own country, under that country's rules. We set this up with your clinic. For a São Paulo clinic that is Brazil.
Does wai send messages to patients on its own?
No. wai drafts each reply and a person at the clinic approves it before it goes. Clinical notes and letters go out only after the doctor signs.
Sources
- 1Ministério da Saúde, FMUSP and AMB, 2025Demografia Médica no Brasil 2025, Tabela 4 and São Paulo state profileRead 15 October 2026Read source
- 2Agência Nacional de Saúde Suplementar (ANS), 2026Taxa de cobertura de planos de saúde, open data set PDA-047 (updated September 2026)Read 15 October 2026Read source
- 3Presidência da República, 2018Lei nº 13.709 de 2018, Lei Geral de Proteção de Dados Pessoais (LGPD), Article 11Read 15 October 2026Read source
- 4Diário Oficial da União, 2024Resolução CD/ANPD nº 15 de 24 de abril de 2024, Regulamento de Comunicação de Incidente de SegurançaRead 15 October 2026Read source
- 5Conselho Federal de Medicina, 2026Resolução CFM nº 2.454 de 11 de fevereiro de 2026, normatiza o uso da inteligência artificial na medicinaRead 15 October 2026Read source
- 6Governo Federal, 2026Agência Nacional de Proteção de Dados (ANPD), homepageRead 15 October 2026Read source
- 7CREMESP, 2026Conselho Regional de Medicina do Estado de São Paulo (CREMESP), homepageRead 15 October 2026Read source
- 8Assembleia Legislativa do Estado de São Paulo, 1999Lei nº 10.241 de 17 de março de 1999, direitos dos usuários dos serviços de saúde no Estado de São PauloRead 15 October 2026Read source
- 9Ministério da Saúde, 2026Rede Nacional de Dados em Saúde (RNDS)Read 15 October 2026Read source
- 10Prefeitura de São Paulo, 2019Informes Urbanos nº 41, Imigrantes na cidade de São Paulo (December 2019)Read 15 October 2026Read source
- 11wai, 2026wai changelog, intake answered by voice in any languageRead 15 October 2026Read source
- 12wai, 2026wai CheckoutRead 15 October 2026Read source
Every São Paulo enquiry answered before the first consult.
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