The draft framework sets out key requirements from multiple regulatory and policy frameworks which apply to AI in health and social care and provides guidance for organisations adopting AI in health and social care.

RCN’s comments draw on its current policy positions on AI, its manifesto for the 2026 Scottish Parliamentary election (“The Gloves Are Off”), and the relevant recommendation from the Scottish Ministerial Nursing and Midwifery Taskforce. RCN broadly welcomes the draft Framework but makes four recommendations to improve it: (1) that a further key area of regulation and standards is added, to account for “the health and safety of the health and social care workforce” when adopting AI; (2) clarity for the public on lines of responsibility and accountability; (3) mandating Health Boards and Local Authorities to use the Scottish AI register; (4) Representatives of the nursing workforce included in all stages of the AI life cycle model.