Using an AI scribe in Singapore under the PDPA and AIHGle 2.0

A Singapore clinic can use an AI scribe when it tells patients what is recorded and why, obtains their consent, and makes sure the vendor protects the recording and keeps it no longer than needed. AIHGle 2.0 adds that the clinic governs the tool, records it in a registry of its AI solutions, and keeps a doctor in control of every note.

The Ministry of Health and the Health Sciences Authority published AIHGle 2.0 in March 2026, and it uses the ambient scribe as one of its worked examples.¹ Two randomised trials published in NEJM AI in late 2025 found that scribes reduced time on notes or measures of burnout, which is why many clinics are now deciding how to govern one.²³

How AIHGle 2.0 classifies a scribe

AIHGle 2.0 divides responsibility between developers, deployers, which are healthcare organisations, and users, which are healthcare professionals.¹ Its risk framework gives the scribe as its example of a clinical operations tool with a human in the loop. Software transcribes the consultation and summarises it into case notes for the doctor's review, and the doctor makes the final decision on the notes saved. The guidelines place that use at negligible to minor risk.¹

The guidelines also give real-time transcription as an example on both sides of the medical device line. Software that transcribes a consultation and gives no diagnosis or treatment recommendation is not regulated as a medical device under the Health Products Act, while software that does recommend a diagnosis or treatment is.¹ Ask your vendor which side its product sits on, and keep the answer in writing.

What the clinic must do as the deployer

AIHGle 2.0 asks healthcare organisations to set up internal governance that assesses and approves each AI tool, documents the decision to deploy it, and maintains a registry of every AI solution in use with its risk classification.¹ It states that human oversight is mandatory for all clinical and clinical operations use of AI. It also asks organisations to train staff, monitor performance on a regular basis, and agree an exit plan with the developer before they decommission a tool or change provider.¹

For a clinic with a handful of doctors, that governance can be one named person, one page of records and a monthly check. The steps below cover it.

Name the doctor who approves AI tools for the clinic, and record each approval with the reasons.
Add the scribe to the clinic's AI registry with its risk classification.
Train every doctor and nurse who will use it, covering its limits and how to report a problem, and record the training.
Review a sample of notes each month against what was said in the consultation.
Agree in the contract how recordings, transcripts and notes are returned or destroyed when you stop using the tool.

What the PDPA requires

The Personal Data Protection Act requires consent before a clinic collects, uses or discloses personal data, unless the Act or another law allows otherwise, and it requires the clinic to tell patients the purpose on or before collection.⁴ A clinic must protect personal data with reasonable security arrangements, and it must stop retaining it once it no longer serves a legal or business purpose.⁴

A scribe vendor that processes the recording on the clinic's behalf under a written contract is a data intermediary, and the protection and retention duties apply to it directly.⁴ If a breach is assessed as notifiable, the clinic must tell the Personal Data Protection Commission no later than three calendar days after that assessment.⁴ The clinic must also designate the person responsible for its compliance and publish their business contact details.⁴

Where the recording is stored

Personal data can be transferred out of Singapore only where the recipient gives it a standard of protection comparable to the Act.⁴ Ask the vendor where the audio, the transcript and the note are each hosted, how long each is kept, and who can access them. Get the answers in writing and keep them with the registry entry. wai hosts your clinic's records in Singapore, under Singapore's rules. We set this up with your clinic.

Telling patients

AIHGle 2.0 separates AI that is not relevant to a patient's medical management, such as billing or scheduling staff leave, from AI that is relevant to it. Where the use is relevant, it encourages organisations to set up a process for telling patients about the benefits, significant limitations and alternatives.¹ A scribe records the consultation itself, so a short notice at booking and a spoken sentence at the start of the visit are a practical way to tell patients what is recorded, why, and how to decline.

Say that the visit will be recorded so that the note can be written.
Say who can read the note, and how long the recording is kept.
Offer to switch the scribe off, and record the patient's choice in the note.

Questions to ask a scribe vendor

Does the product recommend a diagnosis or treatment, or does it only transcribe and summarise?
Where are the audio, the transcript and the note each hosted, and for how long?
Is the audio deleted once the note is signed, and can the clinic set that period?
How does a doctor report an inaccurate note, and how is it reviewed?
What happens to the clinic's data when the contract ends?

The doctor stays responsible

AIHGle 2.0 says healthcare professionals remain responsible for safe care whether or not they use AI, and must verify what goes into a tool and evaluate what comes out of it before it enters their workflow.¹ The trials support that caution. In a randomised trial of 238 physicians across 14 specialties, clinicians reported clinically significant inaccuracies occasionally with both scribes tested, and the authors concluded that ongoing vigilance is needed.²

What wai Clinicians does

wai Clinicians writes the note while the doctor talks to the patient and drafts the letter before the patient leaves, and nothing is sent until the doctor has read it and signed it. The change for the clinic is a doctor who keeps their attention on the patient through the consultation and leaves with the day's notes signed.

Questions

Is an AI scribe legal in Singapore?

Yes. The PDPA and MOH's AIHGle 2.0 guidelines allow it where the clinic obtains consent, tells patients the purpose, protects the data and keeps a doctor in control of every note.⁴¹

Is an AI medical scribe a medical device in Singapore?

Not if it only transcribes and summarises without recommending a diagnosis or treatment, according to AIHGle 2.0. A tool that does recommend a diagnosis or treatment is regulated as a medical device under the Health Products Act.¹

Do patients need to consent to an AI scribe in Singapore?

The PDPA requires consent to collect personal data unless an exception applies, and it requires the purpose to be explained on or before collection.⁴ A notice at booking and a spoken check at the start of the visit give the patient a clear chance to decline.

What does AIHGle 2.0 require of clinics that use AI?

It asks healthcare organisations to approve each AI tool through internal governance, keep a registry of the AI solutions they use with their risk classification, train staff and monitor performance.¹ Human oversight is mandatory for all clinical and clinical operations use.

Sources

Written and reviewed by the clinical team at wai. Last reviewed 9 October 2026.