We welcome the National Commission into the Regulation of AI in Healthcare’s strong focus on transparency, accountability and human relationships.

The commission’s new report features recommendations for how AI could be regulated in in healthcare, including in mental health.

Ben Kay, our Chief Experience Officer, said: “AI has the potential to help improving people’s mental health, but only if we are resolute that technology should strengthen and complement human care and not replace it.

“Healthcare workers bring inherently human skills of connection, judgement, responsibility and relationship. These are fundamental to positive outcomes and must never be lost.”

The independent commission was established by the Medicines and Healthcare Products Regulatory Agency (MHRA) in September 2025. It drew on expertise across health, regulation and AI, as well on extensive public consultation to inform its recommendations. The commission’s recommendations reflect many of the points we made during its consultation.

While much of its report focuses on physical health, its report and recommendations have clear implications for any future regulation of AI use in mental health, including counselling and psychotherapy.

The opportunity to widen access, reduce barriers, provide useful information and support to practitioners is significant.
Good quality, ethical mental health care is be grounded in trust, empathy, professional judgement and relationship, which AI cannot replace.

The report says that a patient-centred, practitioner-enabling regulatory system for AI in healthcare must protect patients and manage risk, enable innovation and timely access and build confidence in how AI is regulated and used.

Technology that strengthens human connection

We’re pleased the report recognises that AI should support, not replace, human relationships, and that people want human connection.
In counselling and psychotherapy, the therapeutic relationship is fundamental.

AI could complement that relationship by supporting appropriate tasks, improving access to resources and helping professionals focus their time where human presence matters most.

It can’t replicate the empathy, authenticity, attunement and relational understanding that a trained professional brings to therapy.

Confidence through transparency, choice and consent

Public confidence will depend on people being told clearly when and how AI is being used, what role it plays, and where its limitations and risks lie.

Meaningful choice, informed consent and appropriate opt-outs can help people benefit from innovation while retaining agency over their care. AI should make support clearer and more accessible, never obscure who is responsible for a decision.

It’s good to see this need for transparency, accountability and responsibility recognised throughout the report.

Training

The report says that healthcare professionals have a responsibility to become competent in technologies that form part of their role. This is in line with our call for ongoing training and capability building for healthcare professionals to understand AI’s strengths, limitations, and risks. We recognise that not everyone will want to use AI as part of their practice, but we want to ensure there’s high quality training available to support those who do.

Monitoring and reporting after implementation

In our response to the MHRA consultation we called for robust post-market surveillance, including monitoring adverse incidents and adapting regulation as AI technologies evolve. The Commission recommends stronger powers for the MHRA, including enhanced enforcement powers, to ensure that where AI systems fall short of the standards patients expect, the regulator can act decisively.

Clear and credible regulation essential

Ben continued: “While the opportunities for positive use of AI in healthcare are significant, the risks and challenges must be addressed especially when the consequences can profoundly impact people’s lives. Clear and credible regulation is essential to public protection.

“These recommendations are a starting point for clearer AI regulation in mental health – but there’s much more work to do. We look forward to working with our members, policy-makers Government, and other organisations to ensure any use of AI in mental health is safe, accountable, and transparent. And importantly, that the irreplaceable human and relational elements of therapy are clear to everyone.”

The government and the MHRA will consider the Commission’s recommendations and respond.

Read the commission’s report and recommendations.