techUK's response to the National Commission’s Findings on AI Regulation in Health
Last week, the MHRA published the findings of the National Commission into the Regulation of AI in Healthcare's Call for Evidence, the most substantial assessment yet of how the UK should regulate AI in health and care. The Commission is the independent advisory group convened by the MHRA to recommend a new regulatory framework for AI in healthcare. It is chaired by Professor Alastair Denniston and draws on working groups led by MHRA Chief Executive Lawrence Tallon, both of whom techUK has engaged closely over the past year. Its findings rest on 761 responses from patients and the public, clinicians, providers, academics and industry, and techUK's own submission.
For techUK members, this is an important milestone to see the growing the alignment and cooperation between the MHRA and industry, as the priorities techUK advocated for via our response and engagement sessions are strongly featured into the Commission’s publication.
Where techUK and the Commission align
The closest test of impact is to set the two documents side by side. The Commission identified ten key findings; the following six map directly onto positions techUK proactively put forward in its submission.
1. A proportionate, risk-based approach across the full lifecycle
techUK called for "a pragmatic calibration of regulation by risk and use" and a "dual-path" offering "a low-risk fast track and a higher-risk full route."
The Commission found (Key Finding 1): "There is a clear call for a proportionate, lifecycle-based approach to regulation," with stakeholders seeking an approach that is "risk-based" and "addresses existing duplication and fragmented oversight."
2. Significant reform, not a complete overhaul
techUK called for a framework that "requires significant reform, centred on proportionate regulation, reusability of assurance, and clearer coordination."
The Commission found (Key Finding 2): "There is strong consensus for significant regulatory reform," with most respondents saying the framework "needed 'significant reform' but did not need a 'complete overhaul'."
3. Post-market surveillance built for adaptive AI
techUK called for the MHRA to "define post-market surveillance expectations that are aligned with dynamic AI tools (drift monitoring, improper use, escalation triggers)."
The Commission found (Key Finding 3): "broad consensus that AI systems will increasingly require continuous post-market surveillance and monitoring," with upgraded approaches needed to "manage performance drift, validate performance in real world settings, and track changes in performance over time." Key Finding 9 adds support for "a national reporting system for AI incidents."
4. Clearer liability and genuinely shared responsibility
techUK called for the MHRA to "improve consistency and clarity of guidance, especially on liability," warning that "fragmented liability fosters a pervasive fear environment."
The Commission found (Key Finding 4): "Responsibility should be shared across the system, with each individual and institution understanding their essential role and responsibilities," alongside "a consistent emphasis on the need for greater clarity and consistency in how liability is allocated." The findings even echo our framing, cautioning that liability must not create "excessive fear among clinicians or provider organisations."
5. Clearer device classification, and curbing "shadow AI"
techUK called for the MHRA to "clarify medical device classification for AI low-risk scenarios to reduce unintended capture of 'shadow or general' AI," flagging "over-classification of AI as 'medical device' and blurred boundaries with general-purpose AI."
The Commission found (in response to how the framework should be improved): respondents called for "clearer guidance on classifications and safety standards for AI systems" to "help the healthcare sector better understand which AI systems are regulated as medical devices."
6. An end to NHS duplication: reuse, coordination and a single front door
techUK called for "a more centralised 'once-assessed unlock-access' reuse mechanism, like the Innovator Passport, to tackle NHS duplication," and to "align parallel regulatory regimes and develop a simplified 'front door'," citing "duplicative assurance and procurement burdens across the NHS."
The Commission found (Key Finding 1 and the framework-improvement responses): the proportionate approach must "address existing duplication and fragmented oversight," with respondents calling for "better coordination between regulators and improvements to be made to NHS procurement processes."
What this means, and what comes next
These findings are a descriptive account of the evidence base, not yet the Commission's recommendations. Those recommendations are due in the summer and will directly inform the new regulatory framework committed to under the 10 Year Health Plan and the Life Sciences Sector Plan. But the direction of travel is unmistakable, and industry's priorities, as articulated through techUK, are well represented in the evidence that will shape it.
techUK will continue to engage with the MHRA and the National Commission through to publication, and to feed the sector's expertise into the framework as it takes shape. To get involved in our response to the Commission's recommendations this summer, contribute to future submissions, or join the Health and Social Care programme's policy discussions, please contact the techUK team.
Robert Walker
Head of Health & Social Care, techUK
Robert Walker
Head of Health & Social Care, techUK
Robert joined techUK in October 2022, where he is now Programme Manager for Health and Social Care.
Robert previously worked at the Pension Protection Fund, within the policy and public affairs team. Prior to this, he worked at the Scottish Parliament, advising politicians and industry stakeholders on a wide range of issues, including rural crime and health policies.
Robert has a degree in Politics and International Relations (MA Hons) from the University of Aberdeen, with a particular focus on strategic studies and energy security. Outside of work he enjoys activities such as running, rugby, boxing and cooking!
Rachel joined techUK in December 2024, as a Programme Manager in the Health and Social Care team.
Prior to this, Rachel worked at a specialist health and social care public affairs agency, working with a range of organisations and trade bodies across the medical technology, pharmaceutical, digital health and social care sectors. As well as this, Rachel was part of the Secretariat for a number of health and care related All-Party Parliamentary Groups.
Rachel has a Masters in Global Governance and Diplomacy from the University of Leeds, as well as a first-class honours in Politics BA from Newcastle University.
Lewis Stewart
Programme Manager ‑ Health and Social Care, techUK
Lewis Stewart
Programme Manager ‑ Health and Social Care, techUK
Lewis brings a multidisciplinary background spanning health policy, stakeholder engagement, digital innovation, and elite sport. A former Commonwealth Games champion, he draws on the resilience, adaptability, and team-driven mindset gained through years of high-performance competition.
Before joining techUK, Lewis supported a Member of Parliament in the House of Commons, where he led on constituency engagement and produced evidence-based research to inform debates, committee work, and policy advocacy. He has also helped shape youth wellbeing policy through the Youth Sport Trust, collaborating with government, education, and grassroots networks to drive impact.
Lewis has played key roles in health tech and mobility startups, helping to bring innovative solutions to market and improve user experience in complex systems. With a degree in Biochemistry and Pharmacology, he combines analytical thinking with a passion for evidence-led, people-centred change.
Junior Programme Manager, Health and Care Team, techUK
Viola Pastorino
Junior Programme Manager, Health and Care Team, techUK
Viola Pastorino is a policy, governance, and strategic communication specialist.
She joined techUK as the Junior Programme Manager in the Health and Care Team in April 2024.
She has obtained a Bachelor of Sciences in Governance, Economics, and Development from Leiden University, and a Master's programme in Strategic Communications at King's College London. Her academic background, leading up to a dissertation on AI policy influence and hands-on campaign development, is complemented by practical experience in international PR and grassroots project management.
She is skilled in qualitative and quantitative analysis and comfortable communicating findings to varying stakeholders. Above all, she is deeply passionate about the intersection of technology and government, especially how technology and global discourse shape one another, the processes that lead to belief polarisation and radicalisation of communities, and crafting strategic narratives that steer public discourse.
Outside of work she loves reading, live music light operation, and diving.
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