Dear Mind,
I know, I know I’m the last person you want sending in yet another submission to one of your commissions, but this time it’s on Mental Health in the Age of AI and it’s been ages since we spoke. I appreciate you might be triggered by me wading into your Commission like this uninvited after we fell out over me getting rude about how it came to be that 4% of therapists use foodbanks. I’m like that Auntie who turns up on Xmas day with subscriptions to radical feminist book clubs for the kids, I promise you’ll look back and wonder why you didn’t at least hear me out.
So, let’s start with the observation that you’re asking the wrong questions if you want to understand how big an existential threat to therapy AI actually is. You’ve managed to hold onto a unique local structure of local Mind associations and you’ve really done the hours of local governance that mean you’re not even in the Tech Titan universe. But your reach and collective role as one of the biggest employers and providers of therapy in the UK means that you doing an informed job here on your approach to AI really matters.
I appreciate you might be tired of me banging on about money and the wages and working conditions of therapists but you know, you shouldn’t be so defensive. I’m just trying to help you accept that you do have commercial skin in the game of what comes out of your own commission. Don’t feel bad, your chums at the Partnership of Counselling & Psychotherapy Bodies produced a report about the future of therapy including a shabby section on AI without consulting with their own memberships. Turkeys and Christmas and all that.
One of the good things about therapy is that it helps you articulate things that have been pushed down resentfully during our relationship. So, letm e just put it into words here - I know that you have read my weekly blog Surviving Work over the last fourteen years about whether that’s possible for therapists, I know you have downloaded my academic research about the gig economy of therapy and have probably even read my recent book UberTherapy about the business model behind platformization and AI technologies in therapy. You’ve probably slipped on our podcast series Stories of UberTherapy on the drive home from work to understand why we’re now asking seriously whether Claude would do a better job than you?
So, let’s cut to the chase.
Theme 1: Help-seeking behaviour and AI
The orientation of this submission is to focus on the likely future scenarios for AI and mental health from the perspective of the mental health workforce. This includes psychotherapists and counsellors many of whom are or have been employed by Mind, as well as the growing body of non-clinical and general mental health roles within the public and private sectors. Evidence is presented that to address the likely impact of AI technologies on mental health services the experience of other sectors and in the US where they have already been introduced should be considered. This requires engaging meaningfully with the actors and research, including social justice campaigns, trade unions and platform worker campaigns that are leading regulatory responses to the impact of AI.
The speed with which digital and AI technologies are being adopted means that in order for the mental health sector to regulate and address the inequalities that lie ahead it needs to learn from the experience of other sectors such as the emergence of dynamic pricing and pay models in the app driving and courier sector (Wray/WIE, 2026), as well as the ‘uberization’ of the Behavioural Health sector in the US (Garofalo, 2024).
This submission urges the Mind Commission to look at the US mental health sector and other platformized sectors to understand future scenarios for regulating AI. This includes the existing collective and regulatory actions around AI such as the legal mobilizations carried out by the National Union of Healthcare Workers’ SB 903 campaign, as well as in other sectors such as the dynamic pay campaign for Uber drivers. It also means addressing the shift in access to mental health services via private companies, often direct to consumer on-demand therapy platforms which fundamentally shifts the nature of the therapeutic relationship.
This submission also encourages the Mind Commission to understand the business model that underpins the expansion of digital and AI technologies in mental health (Cotton, 2025) as well as the growth of practice management companies linked to the private medical insurance sector (PsiAN, 2025). This requires engaging with the broader political economy and critical research about the inequalities within the digital tech sector (Bender & Hanna, 2025) as well as the cultural literature around the impact of AI technologies on our relationships and more broadly within society (Tuckle, 2026).
This submission proposes that the use of AI technologies in the UK mental health sector is part of a trajectory of uberization in the standardization and manualisation of mental health services within the NHS and more broadly in the sector (Dalal, 2020). The NHS has provided a strategic opportunity for digital providers to supply digital services while data mining patient data and developing AI tools. What is about to happen now as a result of this process of datafication and uberization is the subsequent automation of therapeutic labour (Cotton, 2025).
A specific part of the uberization process in the UK is the adoption of the ScoPEd framework, introduced in 2024 as a key part of the standardization of the therapy sector. Research carried out by Dr Cotton in collaboration with Counsellors Together UK (CTUK) in 2020/21 (1500 respondents) and 2023 (750 respondents) looking at the financial and professional landscape and the implications of SCoPEd found:
65% earn less than £600 per week (gross income) which is the median earning for employed people in the UK
9% of respondents earn their main income in counselling and psychotherapy
23% increasing work outside of therapy to cover costs
16% (14% in 2020/21) of respondents receive income based welfare benefits with 4% accessing food banks while training and 3% while working as counsellors/psychotherapists, the same figures for 2020/21
Only 3% of 2023 survey respondents felt that SCoPEd offered them higher opportunities for paid work and 1% felt it would lead to income increase, rising to 13% responding they anticipated a fall in income.
As a result of these financial realities, a high level of 33% (30% in 2020/21) of respondents cannot see a future earning a living as a counsellor or psychotherapist.
Our key concern is that the platformization, digitalization and automation of mental health services is likely to reduce even further the earnings and job security of therapists and counsellors. The experience of platform work outside of our sector indicates that as AI technologies are introduced, we will see dynamic pricing and pay models operationalised. This stands to reduce the industry standard hourly rate even lower, away from an already unsustainable rate of £40 per hour, to much lower rates as we already see in therapy platforms such as BetterHelp (Cotton, 2025).
Consequently, actors in the mental health sector must take a position on the introduction of AI technologies on therapeutic labour and the automation of therapeutic work before it happens in order to maintain a safe baseline for both practitioners and consumers.
Theme 2: Keeping people safe
There needs to be an acknowledgement by the Mind Commission that safety around AI in mental health needs to be applied to the people providing services, as well as those consuming them.
In addition to the international legal mobilizations around safety and social media use, there are multiple national and international regulatory programmes underway in relation to platformization and the use of AI technologies in mental health. Good formulations of AI regulatory tools exist, including the important social justice and labour rights campaigns around AI such as the DAIR institute and Data & Society in the US and the Ada Lovelace Institute in the UK.
In relation to AI in workplaces, there are multiple frameworks relating to data and algorithmic transparency for workers such as the EU Directive on Platform Work, including protections from ‘robofiring’, surveillance and systems of redress for discrimination in algorithmic decision making. One example is the TUC’s response to the regulation of AI in work around workplace monitoring technologies that calls for legislation to:
introduce a statutory duty to consult and negotiate on key monitoring tech;
strengthen transparency and information rights;
embed collective representation;
strengthen data protection and enforcement mechanisms;
match emerging international standards in UK law;
prohibit dynamic pay.
Based on the experience of the US what we will see is a rise in legal cases being taken against digital therapy providers. These include consumer actions (via Advertising Standards Agencies), professional standards and accreditation of digital therapy platforms. In the UK we have already started to see legal redress in relation to professional standards within Employee Assistance Programmes (EAPs). The 2024 complaint made against Health Assured (now Wisdom Wellbeing) to the BACP and NCPS by the BBC is an important indication of the implications of digitalization and the range of actors involved in attempts to regulate psychotherapy.
In the future, we will see collective actions taken through worker networks and trade unions on behalf of platform workers around algorithmic harms and the emergence of dynamic pay systems (Worker Info Exchange, 2026). We will continue to see campaigns demanding data transparency and algorithmic transparency in relation to both patients and therapists within the NHS as the ongoing campaigns against Palantir underline (Medact, 2025).
The professional bodies and key employers involved in regulating mental health work will need to develop a clear and informed set of principles and practices to defend the profession and professional standards. This requires a much greater engagement outside of the therapy sector, to understand the potential campaigns, legal cases and organising strategies adopted to protect mental health workers such as the work of the National Union of Healthcare Workers and the Psychotherapy Action Network in the US.
Theme 3: Inequalities in Access
This submission urges the Mind Commission to look carefully at the pre-existing and deepening social inequalities as they relate to the mental health workforce as a key element to addressing inequalities to access. This includes looking critically at the quality of mental health support that people have access to as well as the quality of jobs of the mental health workforce delivering that support.
Within the psychotherapy and counselling profession there is a two tier labour market which is based on pre-existing inequalities in terms of class, race, gender and disability. The SCoPEd framework will entrench those inequalities already inherent in the profession by formalizing a system of unwaged work (450 unwaged clinical hours) tied to professional accreditation and associated costs of accredited trainings required to progress from category A to C and the raised cost of monthly professional membership fees. In our survey, of those respondents who had a view on SCoPEd 10% felt they would fail to get accredited under this new system and 19% felt it would lead to lower diversity within the profession. Only 1% felt SCoPEd would lead to higher diversity in the profession.
Given the rapid rise in associate and non-clinical roles within the NHS Talking Therapies and more widely within the privatized and digitalized therapy sector the introduction of AI technologies into mental health fundamentally stands to undermine quality services and consumer safety further.
Psychotherapists and counsellors have for a long time been calling for greater investment in diverse and person centred therapy both in the public and private sector and the following policy lines of action both within and outside of the NHS, much of it raising concerns about austerity and the linking of mental health services with welfare reform (Mills, 2026; Pring, 2024).
Rather than addressing these pre-exiting systemic inequalities in mental health the introduction of AI stands to deepen them. Inequalities are embedded within the AI architecture (Bender & Hanna, 2025) including the eugenicist basis of the predictive technologies that underpin LLMs and AI technologies. Research of platform work evidences that this bias is linked to discrimination in relation to pricing, pay and working conditions of platform workers. As the therapy sector is increasingly platformized, including algorithmic management and dynamic pay systems, we can safely anticipate that the pre-existing workforce inequalities within the SCoPEd framework will be deepened.
If the professional bodies and key employers such as Mind are intentional in addressing inequalities mental health the likely impact of AI technologies must be both understood through the experience of other sectors and in the US where they have already been implemented. This requires engaging meaningfully with the actors and research, including social justice campaigns, trade unions and platform worker campaigns that are leading regulatory responses to the impact of AI.
To continue to consult and design policy within a professional vacuum will not allow the mental health sector to anticipate and respond to the threat to mental health services that AI and the key tech companies currently represent.
Evidence
BBC File on 4 (2024) Investigating EAPs [ Available at https://www.bbc.co.uk/programmes/m001x4lk]
Bender E & Hanna A (2025) The AI Con: How to Fight Big Tech’s Hype and Create the Future We Want. Penguin.
EAPA (2026) BBC File on 4 Allegations – Outcome [Available at https://www.eapa.org.uk/bbc-file-on-4-allegations-outcome/]
Cotton E (2025) UberTherapy: The new business of mental health. BUP [Available at www.bristoluniversitypress.co.uk/ubertherapy]
CTUK/Surviving Work Submission to the PSA [Available at https://www.survivingwork.org/surviving-work-blog/psascoped?rq=CTUK]
Garofalo L (2024) Doing the Work: Therapeutic Labour, Teletherapy and the platformization of mental health. Data & Society.
Medact (2026) Briefing: Concerns regarding Palantir Technologies in NHS Data Systems.
Michaels LM, Wooldridge T, Burke and Muhr (eds) (2024) Advancing Psychotherapy for the Next Generation: Humanizing Mental Health Policy and Practice. Routledge.
Mills C (2026) No more deaths by welfare. Pluto Press.
Pring J (2024) The Department: How a Violent Government Bureaucracy Killed Hundreds and Hid the Evidence. Pluto Press.
PsiAN (2025) Practice Management Companies [Available at https://www.psian.org/practice-management-companies#compreport]
Rizq R (2014) Perversion, neoliberalism and therapy: the audit culture in mental health services. Psychoanalysis, Culture & Society 19: 209– 218.
Scott MJ (2018) Improving Access to Psychological Therapies (IAPT): the need for radical reform. Journal of Health Psychology 23(9): 1136– 1147.
Tuckle S (2026) Artificial Intimacy: Who we become when we talk to machines. Little, Brown & Company.
Wray B (2026) “The right trip, at the right time, to the right driver” Understanding Uber’s dynamic pay systems in European. Worker Info Exchange/ETUC [Available here https://www.etuc.org/sites/default/files/publication/file/2026-09/Uber-dynamic-pay-Europe-report_final_updated.pdf]
If you’re an UberTherapist do this:
Listen to our podcast series Stories of UberTherapy here
Join our network of UberTherapists here
Read UberTherapy: The New Business of Mental Health here
Follow the story of MuchBetter.Help here