UK adopts all 44 recommendations of NHS GP-led expert panel on artificial intelligence

On 6 October 2026 the UK Government confirmed that it will accept all 44 recommendations from the National Commission into the Regulation of Artificial Intelligence in Healthcare and set out how they will be delivered across the UK. Alongside the response, the Medicines and Healthcare products Regulatory Agency (MHRA) has opened tenders for the third phase of AI Airlock, its regulatory sandbox for AI-enabled medical devices.

Delivery commitments and key dates

The Commission’s report, published on 10 September 2026, concluded that the current regulatory approach needs to evolve into a more proportionate and lifecycle-based framework, with AI-enabled medical devices assessed and monitored throughout their working life rather than over-reliance on one-off assessments.

Among the first steps, the response commits the MHRA to publishing draft guidance by December 2026 on a new approach to managing changes to AI-enabled medical devices as they adapt and improve over time. The MHRA will also begin consulting next year on how to qualify and classify AI-enabled devices, the Commission’s first recommendation. Further commitments include exploring phased authorization pathways that would allow promising AI tools to be used in the NHS early and under close supervision as further real-world evidence is gathered.

The Government has also committed to working with partners across the health system to strengthen patient involvement in decision-making, improve access to remedies where standards of care fall below expectations and ensure the benefits of AI are shared equitably across all communities, including disadvantaged groups. The response adds new commitments to keep patients informed about when AI is used in their care.

Phase 3 of AI Airlock for applications opened

The MHRA published guidance for the implementation of Phase 3 on 6 October 2026. After a pilot program and Phase 2, AI Airlock has secured three years of additional government funding and the guidance states that the current phase is funded until April 2029. Phase 3 focuses specifically on post-market surveillance and lifecycle regulation, working with developers, regulators and healthcare partners to test how AI devices can be monitored and managed safely post-implementation, generating evidence intended to inform future MHRA guidance and policy.

A webinar for potential applicants will take place on October 22, 2026 at 10:00 am and the first wave of innovators will be selected in November 2026. Applications are assessed in scheduled review waves with continuous onboarding; Applicants wishing to undergo the current wave of review will need to apply by October 31, 2026, and a subsequent selection period will take place in Spring 2027.

The guidance sets out three priority topics: continuous assurance throughout the lifecycle, including how surveillance captures deployment context factors such as local infrastructure, workflow integration, data quality and user interaction; surveillance suitable for contexts with different levels of clinical or organizational supervision, such as remote, direct-to-consumer or greater autonomy systems; and effectively communicating performance, safety, update, and recovery information to regulators, providers, professionals, and patients. Proposals outside these sectors may be submitted as an expression of interest, but priority goes to aligned applications.

Each test plan is customized and typically lasts six to 12 months in three environments: a simulated airlock of roundtable workshops, a virtual airlock digital test space using real or synthetic data, and a real-world airlock that observes devices in real-use environments outside of patient journeys, such as shadow deployment. Suitability requires a potential patient benefit, an innovative product or concept, a regulatory challenge to address, and willingness to trial. Organizations of all sizes can apply, and the lead applicant can collaborate with others. There is no application or participation fee, but applicants are required to fund their own studies and tests. The Information Commissioner’s Office will support the program through a referral service offering advice on data protection by design.

The Commission behind the recommendations

The MHRA established the National Commission in September 2025 as an independent expert advisory body. It was chaired by Professor Alastair Denniston, Professor of Regulatory Science and Innovation at the University of Birmingham and Honorary Consultant Ophthalmologist, with the Vice-Chair Professor Henrietta Hughes, a practicing GP and Patient Safety Commissioner for England. The Commission brought together expertise from health, technology, law, patient groups, government, the NHS and partners from England, Scotland, Wales and Northern Ireland, and invited stakeholders from the US, Europe and Singapore.

Its recommendations report organizes the 44 recommendations around three related areas: proportionate life cycle regulation; system-level accountability and safe management; and trust, transparency and predictability. The recommendations were based on a program of research and engagement which included an open call for evidence, public deliberation events organized with The Health Foundation, engagement with rarely heard groups supported by National Voices, professional and industry roundtables and specialist working groups. According to the report, 77% of healthcare professionals surveyed called for a complete overhaul or significant reform of the regulatory framework, two-thirds of industry respondents and half of healthcare professionals believe the current framework limits innovation, and 65% of respondents disagree that current post-market surveillance approaches are sufficient.

Reactions from ministers, the MHRA and the devolved nations

Minister for Health Innovation James Frith said the Government wants all patients to benefit from AI with confidence that it is safe, effective and properly supervised, adding: “But innovation must never come at the expense of patient safety.” MHRA chief executive Lawrence Tallon described the Commission’s blueprint as clear and ambitious and said the Government was fully accepting its recommendations, setting out a plan and oversight structure to deliver them.

Denniston welcomed the response and said the Government had listened not only to the Commission “but to the more than 12,000 patients, doctors and members of the public who made our recommendations”, describing the AI Airlock Phase 3 priorities as an early sign of the lifecycle approach being put in place from day one. Hughes welcomed the commitment to monitor AI throughout its use in practice, strengthening patient involvement in decision-making and ensuring clear pathways to remedy when things go wrong.

Artificial Intelligence Minister Kanishka Narayan said the Government was working to make promising new tools available to people across the country soon, while Lord Willetts, chair of the Regulatory Innovation Office, welcomed the response and referred to the momentum from the MHRA’s recent environmental guidance. Welsh Government Health and Care Minister Mabon ap Gwynfor and Northern Ireland Health Minister Robbie Butler both welcomed the recommendations and promised continued collaboration with the MHRA and partners across the UK. Sir Andrew Goddard, chairman of the board of AI Airlock, said that over the next three years the program will focus on understanding how AI products can be effectively monitored once in use. The Bureau of Life Sciences and ABHI also welcomed the decision.

The new program committee will convene, with work already underway between Government, the MHRA, NHS partners and devolved authorities on the nine priority areas set out in the response. A comprehensive implementation roadmap covering the timelines and responsibilities of all 44 recommendations will follow by spring 2027, with regular updates on progress.