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Are you sure? Just tested it and it works locally and offline
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I believe you're correct as of the last few iPhone generations. iOS 27 (with newer models of device required) have even better transcription coming as well, all on device.
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It says right on it when you enable it:

> Dictation sends information like your voice input, contacts, and location to Apple when necessary for processing your requests.

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Oh my, this is the first time I read about it ever. Thanks for sharing it! I'll stop using the built-in dictation now.
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