Independent intelligence for the European Health Data Space

Tracking what 27 Member States are actually building — not what they promised.

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EHDS Readiness Tracker

27 countries. 6 dimensions. Updated March 2026

France

85A

Lithuania

84A

Finland

79A

Denmark

73B

Germany

73B

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ANALYSIS

The two-speed EHDS

“The EHDS was designed as one space. What we are building, so far, is two.”

Health Edge·8 min

Latest

INFRASTRUCTURE31 Mar 2026

HL7 Europe and IHE-Europe open ballot on two EHDS FHIR Implementation Guides

HL7 Europe and IHE-Europe opened coordinated ballots for two Fast Healthcare Interoperability Resources (FHIR) Implementation Guides built under their EURIDICE collaboration: the Imaging Study Report IG and the EU Health Data API IG. Both define electronic health record (EHR) functionalities meeting the interoperability requirements of the EHDS Regulation (EU) 2025/327, with comments and votes due by 30 April 2026. Both organisations are offering the specifications to the European Commission for reference in EHDS Implementing Acts, positioning them as the technical baseline for interoperability compliance when the regulation applies from March 2027. EHR vendors and national implementation teams should track these ballots closely: the outcome will shape how imaging data exchange and health data API standards are defined across the 27 Member States.

Source: HL7 Europe

COMMISSION26 Mar 2026

Commission updates EHDS FAQ to 67 questions on regulation's first anniversary

DG SANTE published version 1.1 of the EHDS Frequently Asked Questions, a 61-page guidance document now covering 67 questions across primary use, secondary use, EHR requirements, HDABs, governance, and international aspects. The update adds six new questions — on EHR product scope, future data access extractions, HDAB appeal procedures, and the EHDS relationship with the Cyber Resilience Act and social security coordination — and expands three existing entries on EHR definitions and territorial scope. This is the first update since the original FAQ was published in March 2025, landing exactly one year after the regulation entered into force. For EHR vendors, the new Q24 clarifies which products fall within the regulation's scope — a definition that determines certification obligations under Chapter III. Member States preparing national implementing measures now have Commission guidance on HDAB appeal procedures and cross-regulation interplay ahead of the March 2027 deadline for implementing acts.

Source: European Commission

COMMISSION25 Mar 2026

Commission comitology committee begins work on approximately 20 EHDS implementing acts

The comitology committee responsible for the EHDS implementing acts has started its work. Composed of Member State representatives and chaired by the Commission, the committee must adopt approximately 20 implementing acts covering technical specifications for EHR exchange formats, EHR system requirements, and secure processing environment standards by 26 March 2027. Until these acts are finalised, EHR vendors and health data holders face regulatory uncertainty on the exact technical requirements they must meet. One year to adopt 20 acts is an ambitious timeline — any slippage here delays everything downstream, from the 2029 primary use deadline to the 2031 full operational date.