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AI symptom checkers: Intended purpose matters more than the chatbot label

Appointment support and individual medical decision support are different uses. Define and verify the scope before putting an assistant on a website.

Editorial review:

Background & source findings

An opening-hours assistant differs from software assessing individual symptoms for diagnostic or therapeutic decisions. MDCG guidance examines medical intended purpose and function; a non-binding disclaimer does not remove that assessment. [1]

Where software qualifies as a medical device, applicable classification rules consider its purpose and the consequences of decisions based on its output. A website deployment is not itself an exemption. [1]

Health-data processing additionally requires its own purpose, legal basis, necessary scope and recipient assessment. Medical-device status does not resolve GDPR obligations. [2]

Scope & limitations

Not every chatbot is a medical device or has the same risk class. No automatic AI Act high-risk classification is asserted; that requires a separate current assessment of the specific system.

In plain language

Fictional example: A practice approves an appointment assistant, but testing reveals individual symptom assessment. The extra behaviour triggers restriction or reassessment, not an informal expansion of scope.

Practical recommendations

Our recommendation: Align permitted questions, marketing, manufacturer documents and actual outputs. Obtain intended-purpose and conformity evidence for medical functions and seek competent regulatory review before processing patient inputs.

Provide clear emergency and human-contact routes. Minimise data and prevent sensitive inputs reaching advertising or unnecessary analytics services. Test scope boundaries with fictional questions. Warnings complement, but cannot replace, suitable system design.

Primary source / reference

  1. [1] MDCG 2019-11 Rev. 1 (Juni 2025): Qualification and classification of software, insbesondere Abschnitte 3 und 4.2.1
  2. [2] EDPB: Process personal data lawfully, including sensitive data