Using an AI scribe in Québec: what is required

The Collège des médecins du Québec requires that « tout médecin utilisant un scribe IA opte pour un outil certifié par le Bureau de certification de Santé Québec » — that every physician using an AI scribe choose a tool certified by the Santé Québec certification bureau.

That is where the decision starts, before any comparison of features or price. A vendor who cannot answer this question yes or no has not yet answered the first question.

Both are required, but they do not fall on the same party — and that is the most common confusion.

• TGV certification is the vendor’s responsibility. It covers the software itself: security, protection of personal information, interoperability. You cannot obtain it on your vendor’s behalf.
• The ÉFVP is the responsibility of the institution or clinic deploying the tool. It covers your use: who sees what, in what context, with which data. It remains to be done even when the product is certified.

In short: your vendor’s certification does not discharge yours, and your ÉFVP does not rescue an uncertified tool.

Canada Health Infoway’s pan-Canadian AI transcription programme (2025-2026) offers free licences to roughly 2,000 front-line professionals in Québec, for up to 12 consecutive months, until 31 December 2026. Nine products were selected for it.

• With TGV certification: CoeurWay, AutoScribe, Tali AI.
• Without TGV certification: Autochart AI, Empathia AI, Mika AI, Nexus AI, Pippen, Scribeberry.

Two cautions when reading this. The list is one programme’s selection, not the exhaustive registry of certified products in Québec. And being selected is not the same as being certified: six of the nine are not. Check the source before drawing a conclusion.

The Collège is explicit: the physician has a duty to obtain free and informed consent, covering « la capture de la conversation et aux risques associés à la sécurité et à la confidentialité » — the capture of the conversation, and the risks to security and confidentiality.

Consent therefore covers more than the recording. It covers the risks, which presumes you know them — and so that you know what your vendor does with the data.

It must be obtained again in two situations: when a more sensitive subject is to be discussed, and on any major technological change to the software affecting data protection.

This is the most precise requirement, and the most often misread. Recordings and transcriptions « doivent être détruits dès que le médecin a révisé et signé la note produite » — must be destroyed as soon as the physician has reviewed and signed the resulting note.

The test is not a duration, it is an event: the signature. A retention policy expressed in hours — 24, 48, seven days — describes something other than what is being asked here. Put the question to a vendor in those terms: what is left, and at exactly which moment does it go?

Where a company uses captured data to improve its software, the physician « doit faire preuve de prudence » — must exercise caution — particularly where that involves transferring and storing data outside the country.

Three questions to ask, and to have answered in writing: are my patients’ conversations used to train the model? Can I decline without losing the product? Does the data leave Canada, and if so, for where?

Every physician using such software must satisfy themselves, before signing, that the content of a note written by an AI scribe is accurate and meets record-keeping standards.

No certification moves that responsibility. A scribe that makes the review faster helps you; a scribe that makes the review feel unnecessary exposes you.

Sylvia Scribe^™ is not out yet. It will arrive certified.

What already runs in clinics is the Intake Assistant. The patient writes their story before arriving; Sylvia structures it and puts the pre-note in your EMR. The source material is text the patient wrote and can re-read. The requirements described here govern capturing a conversation — a different act, under a different regime.