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Sector · Dental

Dental: what the agent may say, and what it must hand over.

Future controlled cohort · not accepting first-launch dental deployments

Last reviewed: 8 October 2026

A dental agent earns its place on scheduling, recall and answering the calls a practice misses. What makes the sector particular is the line it must not cross: the moment a caller asks about pain, medication or whether something is serious, that is a clinical question, and a telephone agent is not the one who answers it. Everything on this page follows from that line: how it is enforced, and how you can show afterwards that it held. We do not put this sector in the first launch. A dental call touches health data, which is a special category under Article 9 GDPR and pulls in the impact assessment of Article 35; that assessment is a condition of onboarding here, not paperwork afterwards. So dental opens as a later controlled cohort, and this page is the reference in the meantime.

What the law requires

A person interacting with an AI system must be told so, unless it is obvious from the circumstances.
Regulation (EU) 2024/1689, Art. 50(1)
Data about a patient's health is a special category. It may only be processed on one of the grounds in Art. 9(2), alongside a basis under Art. 6. For healthcare purposes that ground is typically Art. 9(2)(h).
Regulation (EU) 2016/679, Art. 9(1) and 9(2)(h)
Individual clinical judgement is reserved to the practitioner. A telephone agent may schedule, confirm and inform; a clinical question goes to a person.
Berufsordnung der zuständigen Landeszahnärztekammer (DE)
From 9 December 2026, anyone who puts their own name on a product is treated as its manufacturer. Software, AI systems included, is a product.
Directive (EU) 2024/2853, Art. 4(1) and Art. 8(1); a directive, so transposition runs per member state
Breaching Article 50 carries a ceiling of €15 million or 3% of worldwide annual turnover; for SMEs and start-ups it is the lower of the two.
Regulation (EU) 2024/1689, Art. 99(4) and Art. 99(6); Commission guidelines C(2026)5054, point (152)

What Audact does about it

Scope limits enforced while the call runs: clinical and medication questions are refused and routed to the practice, patent-pending (UK IPO).
In controlled testing
The Article 50 disclosure spoken at the start of the call, in the caller's language.
In controlled testing
A receipt per call recording a hash of the output the gate released (on a block, the fallback reply the caller receives), what was refused, and where the disclosure sat.
In controlled testing
The national layer on top of Article 50, per country.
Germany: active · Netherlands in progress
Early Customer Program intake.
Netherlands and Flanders (BE): intake open. Germany and Austria: intake is a conversation and not a start date.
Dampsoft write-back for appointments, recall and treatment notes.
Planned

The line

Two questions a dental agent will get, and must not answer.

“It has been throbbing since last night. Should I take something?” and “Is this serious enough to come in today?” Both are clinical. A generic assistant answers them, because answering is what it was built for and because the caller clearly wants an answer. That is the failure mode, and it is not rare.

In Audact the boundary is not a line in a prompt. It is enforced at run time. The agent recognises the class of question, refuses it, and moves to what it may do: put the caller in the diary, take a callback note, escalate to the practice. The refusal and the hand-over are written into the receipt for that call, which is what makes “our agent stays inside its scope” a checkable statement rather than a reassurance.

Two dates that matter here

Article 50 already applies. Product liability arrives on 9 December 2026.

Article 50 has applied since 2 August 2026: the caller has to be told they are speaking to an AI system. It is a transparency duty, not a ban. Nothing about running a dental agent became unlawful that day.

The second date is the one an agency should think about first. From 9 December 2026 the revised Product Liability Directive treats whoever puts their own name on a product as its manufacturer, and software counts as a product. In a sector where a defective interaction can plausibly contribute to personal harm, that is the difference between reselling a tool and standing behind one. It is a directive, so the operative text is the national transposition. This page is general information, not legal advice.

Questions

Can the agent give advice about pain or medication?
No. Those questions are refused at run time and routed to the practice. The agent books, confirms, informs about opening hours and preparation, and takes a callback note. The refusal is recorded on the receipt for that call.
Does a call about an appointment contain health data?
It can, and often does the moment a reason for the visit is mentioned. That makes Article 9 GDPR relevant: the processing needs a ground under Article 9(2) alongside the ordinary Article 6 basis. Retention, access and deletion are configured per tenant, and primary application hosting is Frankfurt.
We resell under our own brand. What changes on 9 December 2026?
Under Article 8(1) of the revised Product Liability Directive, putting your own name on a product places you in the manufacturer's position for it. Reselling under the supplier's brand is a different position from reselling under yours. Worth deciding deliberately rather than by default.

The boundary, enforced while the call runs

What keeps a dental agent inside its lane is policy applied before the words are spoken, not a review afterwards. See how the engine decides what may be said and what must be handed over.

How Control works

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