Why It Is Needed

Gaps in Existing Standards

MHTS was created because no safety standard set specific design safeguards for digital mental-health technology. Mental-health apps have been described as severely under-governed, with existing standards largely general, applying to health apps, digital health or AI systems broadly rather than to mental-health technology specifically.¹

Even Australia's National Safety and Quality Digital Mental Health Standards, which apply to digital mental-health services, are high-level and process-based: they set governance requirements for service providers, not how the technology itself must be designed.² None of these frameworks sets out how mental-health technology must protect people using it while emotionally vulnerable.

The closest available alternatives, and how they compare:

MHTS fills this gap with safeguards centred on the design of technologies that influence emotional and mental states. Its distinctive focus includes:

• Prohibiting identity collection as a condition of stabilisation.
• Prohibiting behavioural surveillance.
• Removing access barriers during distress.
• Prioritising stabilisation before interpretation.
• Preventing dependency-generating engagement systems.
• Preserving immediate pathways to human assistance.
• Making non-identifiable effectiveness and impact data publicly accessible.

MHTS is intended to complement relevant existing frameworks rather than duplicate or replace them. See Relationship to Existing Frameworks.

The sections below set out the risks these safeguards address.

Psychological Vulnerability During Distress

People experiencing intense emotional distress, such as anxiety, panic, grief or despair, can be particularly vulnerable to psychological manipulation and exploitation.

During periods of emotional vulnerability, the desire for relief, reassurance or safety can make individuals more susceptible to persuasion, especially when messages appeal to their fears, insecurities or immediate emotional needs. Research has demonstrated that acute stress can impair decision-making⁶ and that fear-based messaging can increase susceptibility to persuasion.⁷

This vulnerability creates significant ethical responsibilities for mental-health technology providers. A person seeking emotional support should never have their distress exploited for commercial gain, behavioural influence or increased engagement.

For example, a service could exploit someone's fear of worsening mental health to encourage unnecessary purchases, cultivate emotional dependency to increase continued usage, or use sensitive emotional disclosures to deliver highly personalised persuasive messages.⁸

Unlike many other technologies, mental-health services may interact with people precisely when they are at their most emotionally vulnerable. The relationship between provider and user therefore carries a heightened responsibility to protect individuals from manipulation, coercion and exploitation.

Mental-health technology must be designed to support users' wellbeing, never to take advantage of the emotional circumstances that led them to seek help.

The Risk of Psychological Exploitation

Digital products can influence behaviour through their presentation, timing, language and underlying systems. Examples include:

• Artificial urgency encouraging immediate action.
• Fear-based language intended to influence decisions.
• Emotional pressure to continue using a service.
• Misleading claims about the consequences of leaving.
• Interfaces that conceal important choices.
• Personalised messaging based on behavioural profiles.
• Commercial offers that exploit emotional distress to pressure purchases.

These techniques are related to what consumer-protection authorities commonly describe as deceptive or manipulative design patterns. The US Federal Trade Commission has documented how interface design can influence consumer decisions through practices that obscure information, manipulate choices or encourage unwanted actions.⁹ Such practices raise additional ethical concerns when the person being influenced is seeking help for an emotionally difficult experience.

Similarly, an application that uses emotionally charged notifications can use a person's heightened vulnerability to build dependence on the product, benefiting commercially from the very difficulty it claims to address, at the expense of the user's mental health.

MHTS establishes requirements intended to prevent these conflicts. The objective is not simply to discourage unethical behaviour. It is to prevent certain forms of exploitation through the structure and operation of the technology.

Commercial Incentives vs User Wellbeing

Many digital businesses measure success through engagement. Common indicators include:

• Daily active users.
• Session duration.
• Frequency of return visits.
• Retention rates.
• Notification engagement.
• Subscription renewals.
• Revenue generated per user.

These measurements can be useful in conventional digital products. However, the objectives of mental-health support may be fundamentally different.

For a person using a stabilisation tool, a successful experience might involve using the service briefly, regaining composure and not needing to return. An application designed to maximise daily engagement could therefore pursue a commercial objective that conflicts with the intended outcome of the intervention.

This conflict becomes more serious when engagement mechanisms depend on emotional recurrence. For example, a product might use streaks to encourage daily interaction, reward users for repeatedly reporting distress or send reminders that create anxiety about losing progress. Such features take advantage of a person's recurring vulnerability to build dependence, rather than supporting the development of independent coping skills, serving the provider rather than the user's mental health.

MHTS Standard 5 addresses this issue directly through its prohibition on dependency engineering.

The distinction is not between commercial and non-commercial technology. A commercial mental-health product can operate responsibly. The distinction is between generating revenue from a useful service and deliberately structuring that service to exploit or prolong vulnerability.

Privacy & Emotional Data

Mental-health technologies may interact with information that is considerably more sensitive than ordinary application activity. Examples include:

• Emotional difficulties.
• Experiences of grief or trauma.
• Anxiety and panic.
• Personal relationships.
• Feelings of isolation.
• Psychological vulnerabilities.
• Patterns of emotional distress.

When such information can be associated with an identifiable person, its collection can create significant privacy risks. These risks may arise through direct requests for personal information or through less visible technical mechanisms, such as cookies, device identifiers, cross-site tracking, behavioural profiling and transfers of information to third-party services.

Even apparently anonymous data can become identifying when combined with other information. A technology may never ask for a user's name yet still create a behavioural profile capable of distinguishing that person from others.

Mental-health applications should therefore be examined for their actual data flows, not merely for the information requested through visible forms. MHTS establishes two complementary requirements:

• Anonymous access without identifiable personal information.
• No behavioural surveillance or undisclosed data flows.

The objective is to prevent the technology from turning psychological vulnerability into an identifiable or commercially exploitable data asset.

Safety During Emotional Distress

A conventional digital interface may assume that users have sufficient time, attention and cognitive capacity to navigate its features. That assumption may be unsuitable for an application intended to provide immediate stabilisation. Potential obstacles include:

• Mandatory login.
• Account registration.
• Long onboarding sequences.
• Excessive instructions.
• Complex navigation.
• Unnecessary questionnaires.
• Interruptive notifications.
• Promotional messages.
• Delayed access to support.

These obstacles may prevent someone from reaching assistance at the moment they need it.

Safety also depends on what the technology does after access is provided. A system designed for acute distress should consider whether its first instructions are appropriate for someone who is already overwhelmed. Introducing complex psychological interpretation before attempting stabilisation may increase cognitive demands at an unsuitable moment.

MHTS addresses this through its requirements for frictionless access and stabilisation before interpretation. The standards also require clear access to real human support and emergency services.

Establishing Trust Through Design

A privacy policy may explain what information a company collects. A statement of ethics may describe how a company intends to treat its users. A product description may promise that a service is safe, supportive or confidential.

These statements can be useful, but they do not necessarily establish how a technology actually operates. For example, an application may describe itself as privacy-focused while loading third-party services that collect behavioural information. Another may claim to promote independence while using rewards and notifications designed to build dependence.

MHTS focuses on requirements that can be examined through actual product behaviour. A technology should be able to demonstrate, for example, that:

• Stabilisation is accessible without identification.
• Cookies and behavioural profiling are absent.
• Support does not require registration.
• Engagement mechanisms do not cultivate dependency.
• Human assistance remains accessible.
• Anonymous effectiveness data and measurement methods are publicly available.

This approach makes ethical commitments more concrete and open to scrutiny.