Recording Laws for Veterinary AI Scribes

U.S., Canada, Australia, New Zealand & European Countries

AI scribes rely on recorded conversations to generate accurate medical notes. But recording rules differ across jurisdictions, and penalties for getting it wrong can be serious. This guide provides an at-a-glance table for all U.S. states, Canada, Australia, New Zealand, and European countries to help clinics plan compliant workflows.

Important: This article is for informational purposes only and is not legal advice. Laws change and can be nuanced (different rules for in-person vs. phone/electronic, “private places,” cross-border calls, etc.). Always verify with local statutes and counsel before setting policy.


How to Read These Tables

  • One-party consent: A participant in the conversation can record without informing others (usage/disclosure may still be restricted).
  • All-party consent: Everyone must consent before recording a private conversation.
  • Mixed / special: Rules vary by context (e.g., in-person vs. telephone; “private place” definitions; notice requirements).
  • Best practice: When in doubt—especially for cross-border/telemedicine—follow the stricter jurisdiction and announce recording at the start.
Tip for clinics: add a short consent line to your intake workflow (verbal or written), post signage in exam rooms, and document your retention/deletion policy for recordings.

🇺🇸 United States — Recording Laws by State

The table below summarizes baseline consent rules for private conversations. Some states have nuanced exceptions. Use this as a starting point and confirm details locally.

State / D.C.Consent Rule (At-a-Glance)Notes (Nuances Vary)
AlabamaOne-party
AlaskaOne-party
ArizonaOne-party
ArkansasOne-party
CaliforniaAll-party“Confidential” conversations require all-party consent; cross-border risk.
ColoradoOne-party
ConnecticutMixedIn-person often one-party; telephone/electronic stricter/civil liability risk.
DelawareAll-party
District of ColumbiaOne-party
FloridaAll-party
GeorgiaOne-party
HawaiiMixedAll-party may apply in certain “private places.”
IdahoOne-party
IllinoisAll-party (private, in-person)Private conversations protected; nuances for electronic.
IndianaOne-party
IowaOne-party
KansasOne-party
KentuckyOne-party
LouisianaOne-party
MaineMixedStricter in certain contexts/locations.
MarylandAll-party
MassachusettsAll-partySecret recording of private speech prohibited.
MichiganAll-party (complex)Case law nuances; when unsure, obtain all-party consent.
MinnesotaOne-party
MississippiOne-party
MissouriOne-party
MontanaAll-party / noticeNotification/consent expected for private conversations.
NebraskaOne-party
NevadaOne-party
New HampshireAll-party
New JerseyOne-party
New MexicoOne-party
New YorkOne-party
North CarolinaOne-party
North DakotaOne-party
OhioOne-party
OklahomaOne-party
OregonMixedAll-party for many in-person private conversations; electronic often one-party.
PennsylvaniaAll-party
Rhode IslandOne-party
South CarolinaOne-party
South DakotaOne-party
TennesseeOne-party
TexasOne-party
UtahOne-party
VermontOne-party (federal default)No specific state statute; follow federal baseline.
VirginiaOne-party
WashingtonAll-party
West VirginiaOne-party
WisconsinOne-party (with nuances)Litigation use rules vary.
WyomingOne-party
Cross-border calls (e.g., your staff in one state calling a client in another): apply the stricter state’s rule and announce recording at the start.

🇨🇦 Canada — Recording Laws by Province/Territory

Canadian law generally allows one-party consent to record a conversation: if you are a participant, you may record without informing others. However, provincial privacy and health information laws may impose stricter requirements in clinical or professional contexts. As always, announce recording where possible.

Province / TerritoryConsent Rule (At-a-Glance)Notes (Nuances Vary)
AlbertaOne-partyHealth Information Act may require explicit consent for use/disclosure.
British ColumbiaOne-partyPersonal Information Protection Act (PIPA) governs storage/disclosure.
ManitobaOne-partyPHIA governs health info; obtain consent for records used in patient charts.
New BrunswickOne-party
Newfoundland & LabradorOne-partyPHIA obligations for medical contexts.
Nova ScotiaOne-party
OntarioOne-partyPersonal Health Information Protection Act (PHIPA) requires consent for health record use/disclosure.
Prince Edward IslandOne-party
QuébecAll-partyCivil Code and privacy law stricter: requires consent from all parties.
SaskatchewanOne-partyHealth Information Protection Act applies in clinics.
Northwest TerritoriesOne-party
NunavutOne-party
YukonOne-party
Note: Québec is the main outlier, requiring all-party consent. In other provinces, one-party consent applies, but clinics handling patient health information should also comply with provincial health privacy acts.

🇦🇺🇳🇿 Australia & New Zealand — Recording Laws

Australia and New Zealand have state/territory-specific laws that differ on whether one-party consent is enough or all-party consent is required. Clinics should pay close attention to local statutes and always announce recording in medical settings.

JurisdictionConsent Rule (At-a-Glance)Notes (Nuances Vary)
Australian Capital TerritoryOne-partySurveillance Devices Act allows participant recordings.
New South WalesAll-partySurveillance Devices Act requires consent of all parties.
Northern TerritoryOne-partyParticipant may record with consent of at least one party.
QueenslandOne-partyParticipant recordings permitted under Invasion of Privacy Act.
South AustraliaAll-partyListening and Surveillance Devices Act requires all-party consent.
TasmaniaOne-partyParticipant recordings generally permitted.
VictoriaOne-partyParticipant recordings allowed under Surveillance Devices Act.
Western AustraliaAll-partyRequires consent from all participants.
New ZealandOne-partyParticipant recordings allowed, but disclosure/use subject to Privacy Act and sector rules.
Note: In Australia, laws differ sharply by state — NSW, SA, and WA require all-party consent, while others allow one-party. In New Zealand, one-party consent is sufficient, but health privacy laws still govern storage and disclosure.

🇪🇺 Europe — Participant Recording by Country

European regimes layer national criminal/ePrivacy laws over GDPR. Many countries allow participant (one-party) recordings, but disclosure/use may be restricted. A few require all-party consent for private speech. Sector rules (e.g., health) and DPIA/notice obligations can also apply.

Country / RegionConsent Rule (At-a-Glance)Notes (GDPR/Data-Protection Duties Apply)
AustriaOne-party (participant)Usage/disclosure constrained by DP law.
BelgiumOne-partyParticipant recordings generally permitted; confirm usage limits.
BulgariaOne-partyCheck criminal code re: eavesdropping.
CroatiaOne-party
CyprusOne-party
CzechiaOne-partyAdmissibility/use can be context-specific.
DenmarkOne-partyBusiness recordings typically require notice.
EstoniaOne-party
FinlandOne-partyEmployers/businesses: inform parties.
FranceAll-partyPrivate speech recording without consent prohibited.
GermanyAll-partyUnauthorized recording is a criminal offense.
GreeceOne-partyUsage/disclosure restricted.
HungaryOne-party
IrelandOne-partyDP obligations apply for business use.
ItalyOne-partyParticipant recordings lawful; sharing restricted.
LatviaOne-party
LithuaniaOne-party
LuxembourgOne-party
MaltaOne-party
NetherlandsOne-party3rd-party interception illegal.
PolandOne-party
PortugalOne-party
RomaniaOne-party
SlovakiaOne-party
SloveniaOne-party
SpainOne-partyParticipant recordings allowed; DP limits.
SwedenOne-party
United Kingdom*One-party (for own use)Sharing with third parties triggers additional rules.
Norway*One-partyDP/sector rules apply.
Switzerland*All-partyConsent of all participants required.
Iceland*One-partyEAA/DP guidance applies.

*Non-EU countries shown for practical reference because many clinics interact with clients across these jurisdictions.


Practical Clinic Checklist

  • Consent line: “With your permission, we record this visit to create an accurate medical record.” Capture a verbal “OK.”
  • Signage: Post clear notice at the front desk and exam rooms where required.
  • Cross-border: Apply the stricter rule and always announce recording.
  • Data protection: Define retention, access controls, and deletion schedules for recordings and transcripts.
  • Documentation: Add consent and retention language to your intake forms and SOPs.