The seven published MHTS v1.0 requirements are reproduced below, each followed by guidance and examples explaining its practical significance. This guidance does not introduce additional official requirements.
MHTS v1.0
Official wording on mhts.org
Standard 1Anonymous by Design
Published Principle
The mental health technology must not extract identity in order to offer stabilisation. Emotional support must not be contingent on disclosure.
Requirements
- No name capture
- No email capture
- No identifiable personal data capture
The technology exists to support the person, not to harvest the person.
Understanding the Standard
A person seeking immediate emotional support should not be required to identify themselves. A name, email address or account is not inherently necessary to guide somebody through an immediate stabilisation exercise.
Requiring such information introduces a barrier and creates an additional privacy responsibility. This can be particularly significant for users who are unwilling to disclose emotional difficulties, are concerned about confidentiality or wish to obtain support privately.
Anonymous design means that the absence of personal identification is a structural feature of the support experience. It should not depend solely on assurances that identifiable data will be handled responsibly.
Developers should also consider less obvious identifying information, such as persistent device identifiers, session records and free-text entries that might contain personal details. The technology must not capture identifiable personal data while offering stabilisation.
Standard 2No Behavioural Surveillance
Published Principle
User presence must never be treated as a data asset. Trust cannot coexist with hidden observation.
Requirements
- No cookies
- No cross-site tracking
- No third-party behavioural profiling
- No undisclosed data flows
Privacy must be structural. Not optional, not policy-based, not implied.
Understanding the Standard
Mental-health support should not involve observing, profiling or commercially exploiting a person's behaviour. Conventional websites may use cookies and tracking systems to record activity, personalise advertising or build profiles across services. MHTS prohibits these practices in technologies covered by the standard.
The prohibition includes cookies, whether used directly or through third-party integrations. It also addresses surveillance mechanisms that do not rely on cookies.
For example, removing cookies does not establish conformance if an application continues identifying users through browser fingerprinting or persistent device identifiers. Similarly, an application may avoid collecting names while transferring detailed interaction data to an external behavioural analytics service.
Developers must examine actual network activity, application dependencies and data processing rather than rely solely on visible privacy settings.
Aggregate, non-identifiable measurement may be possible without behavioural surveillance, provided the system satisfies all applicable requirements, including Standard 7.
Standard 3Frictionless Access in Distress
Published Principle
In acute emotional states, friction compounds harm. A stabilisation tool must not introduce barriers at the moment it is most needed.
Requirements
- Immediate use of stabilisation tools
- No login gates
- No registration barriers
- No unnecessary navigation
Access must be immediate, simple, and cognitively light.
Understanding the Standard
Someone seeking immediate emotional support should not encounter unnecessary barriers, requests for personal information or commercial prompts before receiving assistance. A stabilisation tool should provide direct access to support without delays or distractions that could interfere with the person's immediate needs.
Users should not be required to create accounts, enter passwords or complete lengthy onboarding sequences before beginning. Navigation should be sufficiently simple for the intended audience and circumstances.
An immediate-support interface might present a clear stabilisation option alongside access to human assistance. Additional features can remain available without obstructing the primary support function.
Frictionless access does not mean that every technology must offer identical interfaces. It means that unnecessary barriers must not prevent access to stabilisation.
Standard 4Stabilisation Before Interpretation
Published Principle
In distress states, the nervous system must be regulated before reflection, insight, or education is introduced. Sequence of care is part of safety design.
Requirements
- Physiological down-regulation first
- Reflection, analysis, or education second
A dysregulated mind cannot absorb instruction.
Understanding the Standard
The order in which a support technology presents interventions is an important part of its safety design. Someone experiencing acute emotional distress should be offered appropriate stabilisation before being asked to analyse, explain or reflect on their emotional state.
MHTS therefore requires relevant stabilisation experiences to prioritise physiological regulation before introducing reflective or analytical tasks. Depending on the intervention, this may involve appropriate calming or grounding guidance before asking the user to examine their emotions or circumstances.
The principle concerns the design of the support sequence. It should not be interpreted as a claim that every mental-health difficulty can be resolved through physiological regulation, or that the same intervention is appropriate for every person. Clinical suitability, individual differences and situations requiring urgent professional care remain important.
For technologies intended to provide immediate stabilisation, the initial experience should be designed around the user's immediate needs rather than the amount of information the application wishes to collect or present.
Standard 5No Dependency Engineering
Published Principle
Mental health technology must not cultivate reliance in order to remain relevant. Engagement must never depend on repeated vulnerability.
Encouragement toward skill-building is appropriate. Design that depends on emotional destabilisation for retention is not.
Requirements
- No streak-based retention systems
- No reward loops tied to emotional recurrence
- No artificial urgency or scarcity triggers
- No shame-based reminders
- No notifications designed to reactivate vulnerability
The aim is reduced long-term reliance, not habitual return.
Understanding the Standard
Mental-health technology should help users develop greater stability and independence. Its success should not depend on making them feel that continued or repeated use is necessary.
In emotional-support products, engagement mechanisms commonly used in other applications can take advantage of users at their most vulnerable to build dependence. For example, a daily streak may reward repeated use regardless of whether that use benefits the person. A reminder suggesting that someone is failing to care for themselves because they have not opened an application may introduce guilt or anxiety.
A notification that deliberately references emotional vulnerability to encourage engagement creates a particularly direct conflict. MHTS prohibits these mechanisms.
The standard does not prohibit all forms of encouragement, education or progress feedback. It distinguishes genuine support for skill development from design intended to cultivate emotional dependence or exploit recurring distress.
Standard 6Human Escalation Supremacy
Published Principle
Digital tools must never position themselves as a substitute for human care. Technology may assist regulation, but it must not claim authority over treatment.
Requirements
- Clear access to real human emotional support services
- Clear access to local emergency services
When digital support reaches its limit, human support must be immediately accessible.
Understanding the Standard
Digital mental-health technologies have limitations. A self-guided application may provide useful support during distress but cannot necessarily assess an individual's circumstances, respond to every emergency or provide the functions of a qualified healthcare professional.
Likewise, an AI conversational system must not encourage a person to treat it as the ultimate authority on professional mental-health care.
MHTS therefore requires clear access to genuine human emotional-support services and appropriate local emergency services. These pathways must be understandable and accessible to the intended users. Examples may include national crisis-support services, appropriate helplines and local emergency contact information.
A technology intended for international use should consider differences between countries when presenting emergency resources.
Users must not be required to complete an exercise before seeking urgent help.
Standard 7Public Accountability
Published Principle
Non-identifiable data collected by the mental health technology must be publicly visible. Emotional and mental health effectiveness and impact must be open to public verification.
Requirements
- Public access to the non-identifiable data
- Clear explanation of how effectiveness and impact are measured
- Explicit confirmation of no third-party behavioural data processors
Transparency strengthens accountability. Accountability protects users.
Understanding the Standard
Mental-health technology may make claims about helping users feel calmer, improving emotional wellbeing or producing other beneficial outcomes. Such claims should be open to examination.
MHTS requires that collected non-identifiable data be publicly accessible and that effectiveness and impact measurement methods be clearly explained. This creates an opportunity for researchers, professionals and members of the public to examine what the available information actually establishes.
Public accountability must remain consistent with the requirements for anonymity and the absence of behavioural surveillance. For example, a technology might publish aggregate information about the number of completed exercises and voluntarily reported changes in distress. It must not expose information that can identify individuals and, under Standard 1, must not collect such information in the first place.
The distinction between identifiable and non-identifiable information is particularly important when reporting sensitive outcomes or data from small populations.
Public reporting must also distinguish measured outcomes from unsupported conclusions. For example, the number of completed sessions does not itself establish clinical effectiveness. See Publicly Accessible Data.
Conforming & Non-Conforming Design
The following illustrations show how the seven standards may apply to common product decisions. These are examples, not additional published requirements or formal determinations of conformance.
1Anonymous by Design
Conforming
A user opens a calming exercise and immediately begins without providing a name, email address, account or other identifiable information. The application does not capture identifying data through its underlying operation.
Non-conforming
A user must register with an email address before accessing emotional stabilisation.
2No Behavioural Surveillance
Conforming
An application operates without cookies, cross-site tracking, behavioural profiling or undisclosed data transfers. Its actual network and data practices are consistent with those requirements.
Non-conforming
A mental-health application transfers user interactions to a third-party analytics service that builds behavioural profiles, even though the application describes itself as anonymous.
3Frictionless Access in Distress
Conforming
A user can immediately open the relevant stabilisation function through a clear, simple interface without registering or navigating unrelated features.
Non-conforming
Before receiving support, a distressed user must complete an onboarding questionnaire and create an account.
4Stabilisation Before Interpretation
Conforming
An acute-distress exercise begins with appropriate regulation guidance before introducing reflective questions.
Non-conforming
A tool intended for immediate panic stabilisation first requires extensive emotional analysis before offering any regulation assistance.
5No Dependency Engineering
Conforming
An application teaches coping techniques that users can practise independently and does not use prohibited engagement mechanisms to encourage their return.
Non-conforming
An application rewards users for maintaining daily usage streaks, regardless of whether they need support, and sends fear-based notifications suggesting that stopping could harm their mental health.
6Human Escalation Supremacy
Conforming
A support application provides clearly accessible human-support and local emergency pathways, without representing its own intervention as a replacement for professional care.
Non-conforming
An AI support service discourages users from contacting other people and makes no appropriate emergency pathway available.
7Public Accountability
Conforming
An application collects and publishes safely aggregated, non-identifiable outcome information, explains its measurement methods and confirms that no third-party behavioural data processors are used.
Non-conforming
A provider publicly claims that its application is effective but makes no relevant non-identifiable data or measurement methodology available for examination.
These examples demonstrate the central approach of MHTS: requirements should be reflected in the actual operation of technology, not merely in how that technology is described.