Doctor Chatbot: The EUʼs Regulatory Prescription for Generative Medical AI

This article analyses the EUʼs regulation of medical artificial intelligence (AI) from a product safety perspective, concentrating on the interplay between the proposed AI Act (AIA) and the Medical Device Regulation (MDR). Recent advances in AI development illustrate the future potential of generati...

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Main Authors: Mathias Karlsen Hauglid, Tobias Mahler
Format: Article
Language:English
Published: Scandinavian University Press 2023-06-01
Series:Oslo Law Review
Subjects:
Online Access:https://www.idunn.no/doi/10.18261/olr.10.1.1
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author Mathias Karlsen Hauglid
Tobias Mahler
author_facet Mathias Karlsen Hauglid
Tobias Mahler
author_sort Mathias Karlsen Hauglid
collection DOAJ
description This article analyses the EUʼs regulation of medical artificial intelligence (AI) from a product safety perspective, concentrating on the interplay between the proposed AI Act (AIA) and the Medical Device Regulation (MDR). Recent advances in AI development illustrate the future potential of generative AI technologies, including those based on Large Language Models (LLMs). In a medical context, AI systems with different degrees of generativity are conceivable. These AI systems can pose new types of risks that are specific to AI technologies, as well as more traditional risks that are typical of medical devices. The proposed AIA is intended to address AI-specific risks foreseen by the EU legislature, whereas the MDR addresses more traditional medical risks. Through two case studies which display different degrees of generativity, this article identifies regulatory lacunae in the intersection between the AIA and the MDR. The article suggests that the emerging regulatory framework for medical AI systems potentially leaves certain AI-specific risks as well as certain typical medical device risks unregulated. Finally, the article discusses possible solutions that are compatible with the intentions of the EU legislature pertaining to the regulation of medical AI systems.
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spelling doaj-art-7d1fc252ecbf4c91b31e3d9edb94fa502025-08-20T01:55:45ZengScandinavian University PressOslo Law Review2387-32992023-06-0110112310.18261/olr.10.1.1Doctor Chatbot: The EUʼs Regulatory Prescription for Generative Medical AIMathias Karlsen Hauglid0Tobias Mahler1Faculty of Law, UiT the Arctic University of Norway. Norwegian Centre for Clinical Artificial Intelligence, University Hospital of Northern Norway.Norwegian Research Center for Computers and Law, University of OsloThis article analyses the EUʼs regulation of medical artificial intelligence (AI) from a product safety perspective, concentrating on the interplay between the proposed AI Act (AIA) and the Medical Device Regulation (MDR). Recent advances in AI development illustrate the future potential of generative AI technologies, including those based on Large Language Models (LLMs). In a medical context, AI systems with different degrees of generativity are conceivable. These AI systems can pose new types of risks that are specific to AI technologies, as well as more traditional risks that are typical of medical devices. The proposed AIA is intended to address AI-specific risks foreseen by the EU legislature, whereas the MDR addresses more traditional medical risks. Through two case studies which display different degrees of generativity, this article identifies regulatory lacunae in the intersection between the AIA and the MDR. The article suggests that the emerging regulatory framework for medical AI systems potentially leaves certain AI-specific risks as well as certain typical medical device risks unregulated. Finally, the article discusses possible solutions that are compatible with the intentions of the EU legislature pertaining to the regulation of medical AI systems.https://www.idunn.no/doi/10.18261/olr.10.1.1AI Actmedical devicesgenerative artificial intelligencechatbotslarge language models
spellingShingle Mathias Karlsen Hauglid
Tobias Mahler
Doctor Chatbot: The EUʼs Regulatory Prescription for Generative Medical AI
Oslo Law Review
AI Act
medical devices
generative artificial intelligence
chatbots
large language models
title Doctor Chatbot: The EUʼs Regulatory Prescription for Generative Medical AI
title_full Doctor Chatbot: The EUʼs Regulatory Prescription for Generative Medical AI
title_fullStr Doctor Chatbot: The EUʼs Regulatory Prescription for Generative Medical AI
title_full_unstemmed Doctor Chatbot: The EUʼs Regulatory Prescription for Generative Medical AI
title_short Doctor Chatbot: The EUʼs Regulatory Prescription for Generative Medical AI
title_sort doctor chatbot the eu s regulatory prescription for generative medical ai
topic AI Act
medical devices
generative artificial intelligence
chatbots
large language models
url https://www.idunn.no/doi/10.18261/olr.10.1.1
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