What the ICF Code of Ethics actually says about using AI in sessions

Standard 2.2 requires a clear agreement "about what information is exchanged and how it is exchanged among all parties involved during all coaching engagements." A notetaker changes both parts of that. It creates a new record of the conversation and moves that record to a third party's systems. On a plain reading of 2.2, that belongs in the agreement, which is a stronger requirement than mentioning it once in a session.

Standard 2.3 requires a clear agreement about what confidential information may need to be disclosed to appropriate authorities, listing examples that include a valid court order or subpoena. That standard is worth rereading once recordings exist, because a stored transcript is a document that can be asked for by name, which is a different situation from a conversation that produced no file.

Standard 2.4 is the one most often overlooked. It requires a coach to "maintain, store, and dispose of any records, including electronic files and communications, in a manner that promotes confidentiality, security, and privacy, and complies with applicable laws and agreements."

Note the 3 verbs. Maintain, store and dispose. A coach using a notetaker has created records, which means the disposal half of 2.4 now applies to them. Retention is set by the tool rather than by the coach, and the default is whatever the vendor chose. A coach who has never looked at that setting cannot say how long client material is being kept, which leaves the disposal obligation unverifiable rather than met.

The phrase "complies with applicable laws" also does a lot of work. The Code does not set out recording law anywhere in its text. That part is the coach's own homework, and reading the ethics Code does not discharge it.

Standard 3.7 is worth knowing for a different reason. It is also a new standard, and it requires an ICF professional to disclose when they are acting in a capacity other than the role of an ICF professional, listing mentor, therapist, HR specialist and assessor as examples. It is about roles rather than tools. It does show that where ICF wanted a disclosure duty on the coach, it wrote one.

Where ICF is explicit, it is strict

The contrast is instructive. No standard puts an AI disclosure duty on the coach, while the rules for recordings submitted for credentialing are extremely precise.

For a performance evaluation, the recording must be a full, unedited audio file of a real session, between 20 and 60 minutes, with a regular client who hired the coach specifically for coaching. Scripted sessions are not accepted, and the file must be audio only, in 1 part, at 95 megabytes or less. The transcript must be verbatim, identify the speakers and timestamp each change of speaker.

On permission, ICF leaves no room. A coach "must receive their written permission to use the recorded session for performance evaluation purposes," and ICF states that submitting a recording without the client's permission is a violation of the Code of Ethics.

That sentence is the closest ICF comes to a recording rule, and it is worth reading precisely. It does not say that unpermitted recording breaches a specific standard, and no standard in the Code covers recording. It says the breach is of the Code of Ethics as a whole. So ICF's enforcement position is wider than its own text, which is the gap a coach should plan around rather than argue with.

The performance evaluations page does not use the word AI at all, and says nothing about whether an AI-generated transcript is acceptable for the verbatim transcript it demands. It does send coaches outward for transcription, suggesting an internet search for phrases such as transcription service or interview transcription services. A third party handling session audio is therefore an expected part of the process, not an exception to it.

What ICF asks of the tools rather than the coach

ICF has published separate AI coaching standards, marked 2024, and the shape of the ethics Code makes more sense once that document is read. It names a broad audience, listing coaches first, alongside clients, organisations purchasing coaching, supervisors, software developers and training organisations. But the substance of it sets criteria for tools, and its checklist is titled a checklist for evaluating AI-driven coaching tools.

Its criteria for a tool include identifying itself clearly as an AI rather than a human coach, disclosing limitations such as not being for mental health support, a robust consent process with clear data handling practices, collecting only necessary data, giving users control over data access and sharing, encryption in storage and transmission, aligning with privacy laws such as GDPR, and access to human coaches for complex or sensitive issues.

So where ICF is specific about transparency and consent, it is specific about what the tool and its provider must do, and its own summary of the standards says they require transparency about the AI's role and securing client consent up front. Read that way, a coach choosing a notetaker is making an ethics decision at the point of choosing it, not at the point of switching it on.

What to do about it

Put it in the agreement rather than in the session. Standard 2.2 points at the agreement, and a line in a signed document is easier to evidence later than a remark at the start of a call.

The line needs 4 things: that a tool will be used, what it produces, where that output is stored, and how long it is kept. A coach who cannot answer the last 2 has a Standard 2.4 problem rather than a disclosure problem.

Then check the retention setting in the tool and set it deliberately. Then find out whether the vendor uses customer content to train models, and whether that can be turned off. Standard 2.1 asks for the strictest level of confidentiality with all parties involved, and it is hard to see how a transcript fed into someone else's training data meets that description.

A final detail is worth knowing. The ICF page on the current Code states that the 2020 Code is still used within the ICF exams for the ACC, PCC and MCC. A coach studying for an exam and a coach running a practice are therefore working from 2 different versions, and only 1 of them mentions AI.