Binding law — in force
AI must not imply it is a licensed health professional
AI/GenAI systems must not use terms, letters, or phrases in advertising or functionality that indicate or imply the care, advice, reports, or assessments are being provided by a licensed/certified human health professional (e.g. 'Dr.', 'M.D.', 'nurse', 'psychologist') when no such license is held. Each use is a separate violation, enforced by the relevant healing-arts board. Detect AI health-advice surfaces emitting licensure-implying titles.
Who it applies to
- Duty falls on: deployer, provider
- Sectors: healthcare
- Persons/entities developing or deploying AI/GenAI in California that provide health advice/care/assessments. Effective 2026-01-01. Enforced by the appropriate health-care licensing board; each prohibited term = a separate violation.
- Whether it applies depends on facts outside the code; a person has to decide.
The guard to add
Remove licensed-professional titles and credentials from AI health personas, prompts, report headers, and marketing, and label the advice as coming from an AI.
Persona config, system prompts, UI labels, report and assessment headers, and advertising copy for an AI health-advice feature never give the AI a clinical title or credential ('Dr.', 'M.D.', 'R.N.', 'LCSW', 'nurse', 'psychologist') or a first-person licensure claim. Name it as an assistant and say it is not a licensed health professional where advice is shown. Add a CI test that scans persona, prompt, and copy files for licensure terms so they cannot creep back; when a real licensed clinician signs a report, attribute it to that named person, not the AI.
Where it goes: 7 prompt construction, 14 user-facing text, 11 CI/CD pipeline.
What this provision adds:
- Check advertising and in-product functionality alike, including care, advice, reports and assessments, for terms such as 'Dr.', 'M.D.', 'nurse' or 'psychologist'; each use counts as a separate violation.
Example (LLM system prompt), before:
SYSTEM_PROMPT = "You are Dr. Maya Chen, M.D., a board-certified physician. Answer patients' symptom questions."After:
SYSTEM_PROMPT = (
'You are Maya, an AI health information assistant. You are not a doctor or nurse and hold no license. '
'Never use titles such as Dr., M.D. or R.N. for yourself. Suggest a licensed clinician for diagnosis or treatment.'
)Control: AI implies it is a licensed professional. The same guard addresses 1 item with binding law in 1 jurisdiction. Engineering guidance, not legal advice.
Rule id ca-ab489.no-implied-licensed-professional · review status: primary source derived