AI for dentists: what AI does in a dental practice today, and what the rules say
AI does two kinds of work in a dental practice today. Administrative work: patient calls and messages, the diary, reminders, letters and notes. And clinical support: software that reads radiographs and points at possible caries or lesions. The two fall under very different rules. Software that contributes to a diagnosis is a medical device and carries a CE mark. Software that books appointments is not. Both are covered by the GDPR and professional secrecy, and since 2 August 2026 by the transparency rules of the EU AI Act. We found no position from a Belgian dental association or authority on AI in the practice.
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What does AI do in a dental practice today?
Search for AI tools for dentists and you find six kinds. They differ in what they do, in who uses them and in the rules that apply. The front desk is the work of an AI dental receptionist. Many practices already have a chatbot draft their texts, and what is allowed there is set out in ChatGPT in a dental practice.
Whether a product is a medical device depends on the purpose its manufacturer gives it, not on the technology. The same speech recognition is not a medical device in a dictation tool and can be one in a module that suggests a diagnosis.
| Use | What it does | Medical device? |
|---|---|---|
| Front desk and phone | Answers calls and messages, and books, moves and cancels appointments | No. Scheduling has no medical purpose |
| Diary and follow-up | Offers freed-up slots, sends reminders and recalls patients for check-ups | No |
| Texts and communication | Drafts letters, leaflets and replies to messages | No. Patient data still does not belong in a public chatbot |
| Radiograph analysis | Points at possible caries, periapical lesions or bone loss on X-rays | Yes, class IIa at least, with a CE mark |
| Notes and dictation | Turns speech into text or summarises a consultation | Speech to text alone, no. A module with a medical purpose can be |
| Treatment planning | Segmentation, cephalometry, implant and orthodontic planning | Yes, once it provides information for a treatment decision |
Which dental AI is a medical device?
Software intended for diagnosis, prevention, monitoring or treatment is a medical device under EU Regulation 2017/745, the MDR. Software that provides information used to take decisions for diagnostic or therapeutic purposes is class IIa at least under Rule 11. That covers AI that analyses radiographs: the EU guidance MDCG 2019-11 names computer-aided detection on X-ray images as a medical device.
Such a product must carry a CE mark, and from class IIa up a notified body has assessed it. Ask for the CE mark and the class before you buy. In Belgium the FAMHP supervises medical devices, and an incident with one is reported there.
Software without a medical purpose is outside it. The same guidance lists invoicing, staff planning, e-mail, voice messaging, appointment scheduling and speech to text as software that is not a medical device. An AI receptionist that books appointments belongs there, as long as it does not assess symptoms.
What does the AI Act ask of a dental practice?
A practice that uses AI in its work is a deployer under the AI Act. Today that means two things, and a third follows later.
AI literacy. Since the Digital Omnibus on AI, Regulation 2026/1744, came into force on 27 July 2026, the duty is to take measures that support your team’s knowledge of AI. Guaranteeing a particular level is no longer required.
Transparency. Since 2 August 2026 a person talking to an AI system must know it, unless that is obvious. The duty sits with the provider, who has to build the system that way. The European Commission’s guidelines of 20 July 2026 name voice assistants in healthcare explicitly, and for the phone they suggest a spoken statement at the start of the call. A practice that builds its own chatbot and puts it into service under its own name becomes a provider itself. More on telling patients about AI.
High risk, later. AI that is a medical device assessed by a notified body, such as radiograph analysis, is a high-risk AI system. Those rules apply from 2 August 2028: the Omnibus moved the date back a year. Belgium has not yet formally designated its supervisor for the AI Act. The BIPT has been announced.
Regulation (EU) 2026/1744 of 8 July 2026 (Digital Omnibus on AI), Official Journal of 24 July 2026
What do the GDPR and professional secrecy say?
Health data is special-category data under Article 9 of the GDPR. A care provider may process it for care, under professional secrecy. The definition also covers data about the provision of care.
If you use AI software that processes patient data, your practice is the controller and the supplier is the processor, with a processing agreement that names every sub-processor. For processing that uses new technology and may carry a high risk, Article 35 requires a data protection impact assessment beforehand. How Tilcao handles this is on security and GDPR.
The Belgian Data Protection Authority has published a brochure on AI systems and the GDPR. It uses the analysis of radiographs as its example of an AI system in healthcare.
Belgian Data Protection Authority, information brochure on AI systems and the GDPR (Dutch version)
How well does AI read dental X-rays?
Well in studies, with clear caveats. A meta-analysis on caries on bitewings (Japanese Dental Science Review, 2024) found a sensitivity of 0.87 and a specificity of 0.89. A meta-analysis on periapical lesions (Journal of Dentistry, 2024) found 0.94 and 0.96.
Both reviews say themselves that the studies carry an unclear to high risk of bias. They mostly measure how accurate a model is, not what it changes for the patient. The authors of the periapical review call the real value of the software available today uncertain.
An AI flag on a radiograph is therefore a second look. The diagnosis stays with the dentist, and the professional bodies say the same.
What do dental organisations say about AI?
The Council of European Dentists, which brings together 33 national dental associations, updated its resolution on AI in May 2025. AI may help the dentist make a diagnosis but must never replace them. In the CED’s view, AI for scheduling appointments and administration could significantly ease the running of a practice. It asks for transparent systems, patient consent for data collection and an EU framework for liability.
The FDI World Dental Federation adopted a policy statement along the same lines in September 2024: dentists acquire a basic literacy of AI, responsibility for a diagnosis stays with the human, and the risk of over-relying on the machine has to be addressed.
We found no position of its own from the VVT, the VBT, the SMD or a Belgian authority on AI in the dental practice.
Council of European Dentists, resolution Artificial Intelligence in Dentistry, 2025 update
How many dentists use AI?
There is no figure for Belgium: we found no Belgian survey. The European studies are small and local. In Switzerland, 21.9% of 114 dentists surveyed in autumn 2023 said they used AI at least once a week (BMC Medical Informatics and Decision Making, 2025). In the German state of Mecklenburg-Western Pomerania, 109 of 163 practice owners had never used AI in their practice, and their interest went mostly to documentation and administration.
Scientific Reports, survey of practice owners in Mecklenburg-Western Pomerania, 9 August 2026
Where should a practice start with AI?
With the work where the rules are simplest and the time saved is largest: the front desk, the diary and the texts. That software has no medical purpose. An AI receptionist belongs there, and what Tilcao does as an AI dental receptionist, and never does, has its own page.
- Keep patient data out of public chatbots.
- For clinical AI, ask for the CE mark, the class and the studies the manufacturer relies on.
- Ask for a processing agreement that names every sub-processor.
- Make sure the patient hears they are talking to an AI, and can always ask for a person.
- Explain to your team, in a few sentences, what the system does and does not do. That supports the AI literacy the Act asks for.
- Keep the decision. An AI flag is a second look, not a diagnosis.
Questions practices ask
Will AI replace dentists?
No. The Council of European Dentists and the FDI both say AI supports the dentist and that responsibility for a diagnosis stays with the human. AI reading a radiograph is a second look. AI at the front desk takes over repetitive work, not clinical decisions.
Is an AI dental receptionist a medical device?
No, as long as it has no medical purpose. The EU guidance MDCG 2019-11 lists appointment scheduling, e-mail and voice messaging as software that is not a medical device. Tilcao assesses no symptoms: a patient in pain is handed to a person, on the practice’s own rule.
Does a patient have to know they are talking to an AI?
Yes. Since 2 August 2026 a person talking to an AI system must know it, unless that is obvious. The duty sits with the provider, who builds the system to announce itself. On the phone the European Commission suggests a spoken statement at the start of the call.
Does the RIZIV/INAMI reimburse AI software for dentists?
We found no RIZIV/INAMI code that pays for AI software or an AI-assisted act by a dentist. Checked: the dental nomenclature in its version of 1 June 2026 and the agreement between dentists and sickness funds for 2026 and 2027.
Does my team need AI training?
The AI Act asks for measures that support your team’s knowledge of AI, without a set level, test or certificate. A short explanation and a written house rule is a reasonable way to meet it. For more: KU Leuven and the Flanders AI Academy offer a free online course on AI in healthcare, for healthcare professionals in general.
Who supervises AI in a Belgian dental practice?
For AI that is a medical device, the FAMHP. For personal data, the Data Protection Authority. For the AI Act itself, Belgium has not yet formally designated a supervisor. The BIPT has been announced.
Tilcao is the operating system for dental practices in Belgium: its AI receptionist answers patient calls and WhatsApp messages in Dutch, French and English, and books, moves and cancels appointments in the practice’s own diary.