03/07 · Essay
By the government’s own count, the Ayushman Bharat Digital Mission has issued health identifiers to over ninety crore people, linked more than a hundred crore records, and registered over five lakh facilities. Whatever one thinks of the figures, the architecture behind them is the most consequential AI policy decision India has made, and it does not mention AI.
The decision is sequencing. The ministry’s stated position, repeated at a regional digital health summit last year, is that identifiers, registries, and consent frameworks are prerequisites for AI at scale, not afterthoughts. Build the rails first. Decide who can see what, and on whose say-so, before anyone trains a model on it.
Why the consent manager matters more than the model
In the hepatitis work I contributed to, the single largest improvement in program monitoring did not come from a better analytical tool. It came from redesigning the forms so that a screening result, a referral, and a treatment initiation were recorded as linked events rather than three separate tallies. The data flow was the intervention. The dashboard was a view of it.
ABDM’s consent manager is the same idea at national scale. It separates the question of whether data exists from the question of who may use it, and it makes the second question answerable by the person the data describes. For AI, this is the whole game. Every proposal to train a model on health records eventually runs into the secondary-use problem: the data was collected for care, and the model is not care. A consent architecture that can express “my records may be used to treat me but not to train your model” is a policy instrument. A model governance framework that assumes the data is already available is a press release.
What is still missing
I do not want to be naive about this. The consent manager is a specification, and specifications are not the same as practice. Consent in an overcrowded outpatient department is often a thumbprint on a form nobody read. The ministry is rolling out a clinical decision support system built at a national institute to tens of thousands of hospitals, and I have not seen a public evaluation plan, a model-version policy, or an account of how a wrong suggestion in a district hospital gets reported and fixed. The WHO’s guidance on large multimodal models asks for exactly those things, including mandatory post-release audits, and it notes something that rarely appears in Indian policy discussion: the compute and water costs of these models fall disproportionately on countries that did not build them.
There is also no linkage, in the published literature, between ABDM and disease surveillance in the way people sometimes assume. Hepatitis A and E outbreaks are still detected the way they were before: through the integrated disease surveillance program’s water-outbreak reports. The rails exist. The trains, for surveillance at least, have not been built.
The argument
My argument is narrow. If you want to know whether a country is serious about AI in health, do not read its AI strategy. Read its consent architecture, its registry quality, and its facility-level data flows. India has made an unusual and defensible bet that those come first. The test, over the next few years, is whether the models that arrive on the rails are held to the same standard of accountability that the rails themselves were designed to make possible.
Sources
- Ministry of Health and Family Welfare. Regional Open Digital Health Summit press release. 2025. https://mohfw.gov.in/?q=en/pressrelease-349
- World Health Organization. Ethics and governance of artificial intelligence for health: guidance on large multi-modal models. 2024. https://www.who.int/publications/i/item/9789240084759
- Global Initiative on AI for Health: priorities for ethical, regulatory, implementation, and operational work. npj Digital Medicine, 2025. https://www.nature.com/articles/s41746-025-01618-x
- Artificial intelligence in public health: a research and policy agenda. The Lancet Public Health, 2025. https://www.thelancet.com/journals/lanpub/article/PIIS2468-2667(25)00036-2/fulltext