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

By the wai teamOctober 15, 20267 min read

Reviewed by The Wellness Clinical Team, October 5, 2026

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

Key points

Summary

A Shanghai clinic can use AI for notes and patient messages with the patient's separate consent for health data, records kept in China under PIPL and the CAC's cross-border rules, and a doctor's signature on every clinical output. In wai the AI drafts and the coordinator approves.

A Shanghai clinic on wai answers the overnight email from a visiting executive before 9am and signs the note before the patient leaves. The city's free trade zone is where China tests new rules on data and foreign investment, and the ones that touch a clinic are set out below.

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6,566
health institutions in Shanghai at the end of 2025, with 282,100 health technicians 1
7.23 million
foreign visitors to Shanghai in 2025, up 45.3% on 2024 1
163,954
foreign and Hong Kong, Macao and Taiwan residents counted in Shanghai in the 2020 census 2

See an overnight email from an international patient answered with a draft the coordinator approves, and a consultation note signed in the room, in fifteen minutes.

The rules at a glance for a clinic in Shanghai
Body or lawRuleWhat to checkHow wai meets it
Shanghai Municipal Health Commission, foreign-owned hospital plan, 2024Electronic medical record servers located in ChinaWhere every copy of the record is storedRecords hosted in the clinic's own country, set up with each clinic
PIPL, Articles 28, 29 and 38Separate consent for health data, and a lawful route before any data leaves ChinaConsent recorded before the scribe startsThe doctor asks first, and the answer sits in the record
CAC provisions on cross-border data flows, 2024Security assessment for sensitive data of 10,000 or more people a yearWhich subprocessors touch the dataSubprocessors named, with 30 days notice of change
Lingang New Area general data lists, 2024 (reported)Listed biomedical research data can move abroad under the zone's procedureWhether any research data falls under a listReviewed with the clinic during setup

The private care market in Shanghai

The Shanghai Municipal Statistics Bureau counted 6,566 health institutions and 282,100 health technicians at the end of 2025, and 288 million patient visits during the year.1 The same bulletin recorded 9.36 million inbound visitors, 7.23 million of them foreign nationals, with international tourism income of 14.8 billion US dollars.1

Foreign investment in hospitals is opening. Xinhua reported in November 2024 that Shanghai is one of nine places where wholly foreign-owned hospitals may be set up.6 Shanghai's own plan, issued by the Shanghai Municipal Health Commission and three other departments in December 2024, allows in principle up to two such hospitals in each special function zone or area where foreign residents cluster.7

The rules a clinic in Shanghai works under

The Shanghai Municipal Health Commission supervises medical institutions in the city.7 Its plan for foreign-owned hospitals requires their information systems to connect to the city and district supervision platforms, and the servers that store electronic medical records and device data to be located in China.7

Health data counts as sensitive personal information under PIPL and needs the patient's separate consent, so the consent to record a consultation for an AI note belongs in the record.3 Any transfer out of China runs through a PIPL route, and the CAC adds a security assessment once sensitive data of 10,000 or more people a year is involved.34

People's Daily reported that on 17 May 2024 the Lingang New Area published the first general data lists for cross-border scenarios, covering connected vehicles, public funds and biomedicine, with scenarios such as clinical trials and drug research across 64 data categories and more than 600 fields.5 The lists serve research and industry, and a clinic's patient records stay under the national rules.

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 Shanghai. The doctor signs every note before anything clinical leaves the clinic.

The languages Shanghai patients write in

Most patients write in Chinese. The 2020 census counted 163,954 Shanghai residents from Hong Kong, Macao and Taiwan or with foreign nationality, behind only Guangdong and Yunnan, and foreign visits grew 45.3% in 2025.21

wai works in any language.8 Bring last week's enquiries from overseas patients, in the languages they arrived in, and judge each draft yourself.

What a demo shows in Shanghai

An email sent at midnight by a visiting executive asking for a check-up this week shows the open times, a slot held and a reply waiting for the coordinator to approve at 8:30. A call missed during clinic becomes a drafted text, and email, web and phone history sit in one thread per patient.

In the consultation room, the note is drafted while the doctor talks, after the patient has agreed, and the referral letter is ready to sign before the next patient. Every draft and signature is logged and exportable.

For hospital groups and insurers in Shanghai

Groups planning a foreign-owned hospital or an international clinic network can have wai built around one pathway, with data rights and exit terms agreed in the contract and records kept in China. The organisations page has the details.

Where to start

First, add a separate consent line for recording and AI drafting to intake.3 Second, get in writing where records are stored and processed and whether any personal information leaves China, using the questions in the data residency guide.4

Third, if the clinic runs research in the free trade zone or Lingang, check with counsel whether any research data falls under the zone's lists.5 Fourth, bring a week of international and local enquiries to a fifteen-minute demo, then pilot with one doctor and the patient coordinator for a month.

Bring a week of your own international and local enquiries, and see each one drafted, approved and filed in the patient's thread.

Frequently asked questions

Does a Shanghai clinic need consent to record a consultation for AI notes?

Yes. Health data is sensitive personal information under PIPL, and the patient's separate consent is required.3

Where must a foreign-owned hospital in Shanghai keep its records?

Shanghai's 2024 plan requires the servers storing electronic medical records and device data to be located in China.7

Does the Lingang data list cover clinic records?

The 2024 biomedical list was reported as written for scenarios such as clinical trials and drug research, so a clinic's patient records stay under the national rules.5

Can a foreign investor own a hospital in Shanghai?

Yes, under the pilot reported by Xinhua in November 2024 and Shanghai's own plan, which excludes traditional Chinese medicine hospitals and the purchase of public hospitals.67

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.

Who approves a reply before it reaches the patient?

The coordinator. wai drafts, a person at the clinic reads and sends, and the doctor signs every clinical document.

Sources

  1. 1Shanghai Municipal Statistics Bureau, 20262025 Shanghai statistical communique on national economic and social developmentRead 14 October 2026Read source
  2. 2National Bureau of Statistics of China, 2021Seventh national population census bulletin No. 8, Hong Kong, Macao and Taiwan residents and foreign nationalsRead 14 October 2026Read source
  3. 3National People's Congress, 2021Personal Information Protection Law of the People's Republic of China, Articles 28, 29 and 38Read 14 October 2026Read source
  4. 4Cyberspace Administration of China, 2024Provisions on promoting and regulating cross-border data flowsRead 14 October 2026Read source
  5. 5People's Daily, 2024Lingang New Area publishes general data lists for cross-border data scenarios (news report)Read 14 October 2026Read source
  6. 6The State Council of the People's Republic of China, from Xinhua, 2024China allows establishment of wholly foreign-owned hospitals in major cities (Xinhua report)Read 14 October 2026Read source
  7. 7Shanghai Municipal Health Commission and others, via the Shanghai Municipal People's Government, 2024Shanghai plan to deepen the pilot opening of wholly foreign-owned hospitals (上海市深化外商独资医院领域扩大开放试点工作方案), 沪卫医〔2024〕134号Read 15 October 2026Read source
  8. 8wai, 2026wai changelog, intake answered by voice in any languageRead 14 October 2026Read source
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