A psychiatrist finishes a session, looks at the screen and sees that the conversation has already become a draft note in the patient record. She corrects the name of one medicine and signs. The same thing happens in other rooms all day, through a supplier that was chosen by the departments that needed relief first.
This is the normal state among the larger Dutch mental health organisations in 2026. The first monitor of the sector by M&I/Partners, published on 1 October 2026 with 25 of the 50 largest organisations taking part, found that 96 percent work with speech driven reporting and that all of them use generative artificial intelligence, with about eleven applications per organisation on average. A quarter, 24 percent, have an adopted vision and strategy and 64 percent are still writing one. No element of readiness was rated as in order by more than a third of the participants. Almost half, 44 percent, have no development capacity of their own.
Several rules meet in that consulting room and they belong to different supervisors. A recorded treatment conversation is health data under the General Data Protection Regulation and falls under medical professional secrecy. NEN 7510, the Dutch standard for information security in care, is an obligation for care providers, and organisations certified against it have until 20 February 2027 to move to the version of 2024. The Inspectie Gezondheidszorg en Jeugd, the Dutch health and youth care inspectorate, reported on 27 May 2026 that a majority of the larger mental health organisations do not meet the legal requirements for information security. Since 15 August 2026 the Cyberbeveiligingswet adds duties to register, to take security measures and to report significant incidents, and it makes the board approve the measures and oversee how they are carried out. On 11 August 2026 the inspectorate published its assessment framework for digital care, 35 pages that it calls the starting point of its supervision.
The European Union Artificial Intelligence Act, Regulation (European Union) 2024/1689, comes on top of that. As we read Annex III, a tool that turns speech into a draft note is absent from the list of high risk uses, and the requirements for the uses on that list apply only from 2 December 2027. What applies to this organisation today is narrower: since 2 February 2025 the duty to take measures that support the artificial intelligence literacy of staff, and since 2 August 2026 the transparency duties.
The usual response has two halves and both fall short. The first is a policy document. In the monitor 68 percent of the organisations have one. Yet in a survey by Nivel among 890 care workers across Dutch care, published in April 2026, only 8.8 percent said that a clear policy on artificial intelligence exists where they work, and almost nine in ten had never had training. The second half is trust in what the supplier promises. Those promises cover the product. Who in your organisation reads the note before it enters the record remains your own arrangement, and Dutch health lawyers have pointed out that a professional who signs a generated note without checking it can face disciplinary liability.
What a board can sign is a route decision for each type of work. Dictated treatment notes are among the most sensitive text the organisation produces, and the decision is whether that audio may go to a model provider's online interface under contract, to a private deployment in a European region, or only to equipment on the organisation's own premises. A German university hospital tested open models on its own hardware for this reason and reported in 2024 that 95 of 102 generated reports, 93.1 percent, were usable as they were or with small changes. That shows the third route can work for some tasks. It is no lighter to govern, because a model in your own server room still needs a known origin and licence, access control, logs and retention periods that respect the limits data protection law puts on keeping personal data.
Whichever route the board chooses, the governance is the same list. It starts with an inventory of the eleven or so applications, including the ones departments bought themselves, and the organisation's role under the Act for each, which will normally be deployer. Each supplier contract is read for processing location, retention and reuse of data for training. The tool is evaluated on a sample of your own sessions, scored by clinicians. The system logs who generated each note and who approved it. A written rule on human oversight says that the professional reads before signing. Training reaches the people who dictate. The incident route covers a data breach, with its notification within 72 hours, and also a wrong note that reached a record.
The AI Guys prepares these documents with care organisations and gives no medical or legal advice. Next month the board should have four things on the table: the inventory with an owner for each application, the route decision for dictated notes with the reasons written out, the list of supplier contracts that were read and the gaps that were found, and the date on which the executive directors follow the training that the Cyberbeveiligingswet requires of them, for which the law allows two years counted from 15 August 2026.