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

The private care market in Shenzhen

Shenzhen had 18.25 million residents at the end of 2025, up 259,000 in a year.⁵ The city had 6,011 medical and health institutions, of which 171 were hospitals, with 139,474 health technicians, and its medical institutions recorded 141.02 million patient visits in the year.⁵

Hong Kong and Macao residents made 10.45 million overnight visits to Shenzhen in 2025, up 26.6%, and foreign visitors made 2.09 million, up 70.1%.⁵ Since October 2015, eligible Hong Kong elderly people have been able to use Hong Kong health care vouchers for outpatient care at the University of Hong Kong Shenzhen Hospital, and the scheme reached all nine mainland Greater Bay Area cities in 2025.⁶

The rules a Shenzhen clinic works under

PIPL Article 55 requires a personal information protection impact assessment before a clinic processes sensitive information, entrusts it to a processor or sends it abroad, and Article 66 allows fines for serious breaches of up to 50 million yuan or 5% of the previous year's turnover.¹ Medical health information is sensitive under Article 28 and needs separate consent under Article 29.¹ Under the 2024 CAC provisions, sensitive data of fewer than 10,000 people a year leaves under the standard contract or certification, and 10,000 or more goes through a security assessment by the provincial cyberspace office.²

For data moving between Shenzhen and Hong Kong, the CAC and Hong Kong's Innovation, Technology and Industry Bureau published a Greater Bay Area standard contract in December 2023, filed with the Guangdong cyberspace office within 10 working days of taking effect.⁹

The Shenzhen Special Economic Zone Data Regulations, in force since 1 January 2022, require the necessity and impact of processing sensitive personal data to be shown with a more conspicuous mark, and define biometric data to include voice prints.³ Shenzhen's Medical Regulations, in force since 1 January 2023, require clinics to record service information accurately and upload it to the city health information platform under Article 96, encourage AI-assisted diagnosis under Article 101, and let a clinic keeping compliant electronic records skip paper copies if patients can view, print or copy them.⁸

The national Internet Diagnosis and Treatment Supervision Rules state that other people and AI software may not impersonate or replace the physician, ban AI-generated prescriptions, and keep online consultation records for at least 15 years and audio and video process records for at least 3.⁴

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 Shenzhen. The physician reviews and signs every draft, and each signature is logged for the clinic to export.

The languages Shenzhen patients write in

Putonghua is the working language, and the 10.45 million overnight visits from Hong Kong and Macao, where Cantonese and traditional characters dominate, sit alongside 2.09 million foreign visits.⁵

wai works in any language.⁷ A coordinator reads and approves each reply before it goes, in the language the patient wrote in.

What a demo shows in Shenzhen

The demo starts with an email sent at 21.40 from a woman in Kowloon, asking whether her mother can see a cardiologist tomorrow morning after crossing at Shenzhen Bay. wai reads it in the family's thread, checks the cardiologist's busy times, finds an open 10.30 slot and drafts the reply. The coordinator checks it carries the clinic's highlighted sensitive-data notice and approves it before closing.

After the consultation, the cardiologist edits and signs the drafted note and any letter, and only the physician prescribes. Bring three real evening enquiries from Hong Kong patients and watch them run. The guide to human approval of patient messages covers the approval step.

For hospital groups and insurers in Shenzhen

Hospital groups and insurers working across Shenzhen and the Greater Bay Area can run a system of their own on wai, under their brand, starting with one pathway and with data and model rights agreed in the contract. See the organisations page.

Where to start

First, add a separate PIPL consent for health information and consultation audio to intake, with the sensitive-data notice highlighted as the Shenzhen data regulations require.¹³ Second, complete the Article 55 impact assessment for the AI tool before go-live.¹

Third, get in writing where records are stored and, for any transfer to Hong Kong, whether the Greater Bay Area standard contract applies.⁹ Fourth, confirm 15-year retention for consultation records and full export in the contract.⁴

Frequently asked questions