Practitioner
An entity authorized by law to prescribe drugs.
How the laws define this
Both instruments connect the concept of a practitioner to artificial intelligence and legal oversight involving licensing. However, the frameworks fundamentally diverge on who or what holds practitioner status. Under the Healthy Technology Act of 2025, which references the FDCA's traditional view of a practitioner as a state-licensed human professional, the concept is expanded to directly include AI itself. In contrast, the Kenya Robotics and Artificial Intelligence Society Bill 2023 defines practitioners as the persons and undertakings engaged in the engineering, development, deployment, or provision of robotics and AI systems. Under the Kenya Robotics and Artificial Intelligence Society Bill 2023, these persons and undertakings fall within the regulatory regime and may be required to register, obtain licences, comply with codes of conduct, and adhere to standards and inspection regimes established by the Society, whereas the Healthy Technology Act of 2025 integrates AI itself into the practitioner role.
Synthesised from the 2 statutory definitions below. Each one is quoted in full, with its source.
How jurisdictions differ
What is distinctive in each definition, binding law in force first.
| Jurisdiction | Instrument | Status | What is distinctive |
|---|---|---|---|
| United States | Healthy Technology Act of 2025 | Proposed | This definition widens practitioner beyond traditional human professionals licensed by a state to include AI systems under specified conditions in the proposed bill. |
| Kenya | Kenya Robotics and Artificial Intelligence Society Bill 2023 | Under Review | This definition shifts practitioner to encompass persons and undertakings involved in engineering, developing, deploying, or providing robotics and AI systems subject to the bill's regulatory regime. |
What it triggers
- Under the Healthy Technology Act of 2025 if passed, AI systems would be recognized as practitioners authorized to prescribe drugs.source
- Under the Kenya Robotics and Artificial Intelligence Society Bill 2023 if passed, practitioners would be required to register, obtain licences, comply with codes of conduct and adhere to standards and inspection regimes established by the Society.source
Definitions (2)
Under the FDCA, a practitioner is traditionally a human professional licensed by a state; this bill expands that definition to include AI.
Practitioners are the persons and undertakings engaged in the engineering, development, deployment or provision of robotics and AI systems who are within the scope of the Bill’s regulatory regime and who may be required to register, obtain licences, comply with codes of conduct and adhere to standards and inspection regimes established by the Society.
Questions and answers
Can AI be a practitioner under US law?
The Healthy Technology Act of 2025 proposes to expand the definition of practitioner under the FDCA to include AI and machine learning systems authorized to prescribe drugs. It is currently a proposed bill.
What obligations do AI practitioners have in Kenya?
Under the Kenya Robotics and Artificial Intelligence Society Bill 2023, practitioners engaged in robotics and AI must register, obtain licences, comply with codes of conduct, and adhere to standards and inspections if the bill passes. The bill is under review.
How does the US bill change who can prescribe drugs?
The Healthy Technology Act of 2025 proposes to broaden the traditional FDCA definition of practitioner from human professionals licensed by a state to also include qualifying AI systems.