Germany begins financial sanctions for ePA non-compliance

From 1 January 2026, German physicians who do not use software certified for the elektronische Patientenakte (ePA) or who fail to populate it with mandatory data face up to a 2.5% reduction in service billing and a halved TI-Pauschale (telematics infrastructure allowance). The sanctions follow the October 2025 mandatory-use requirement and the January 2025 opt-out launch that created records for nearly all 74 million statutory health insurance members. Hospital sanctions begin on a staggered schedule from April 2026. Germany is now the largest Member State to enforce electronic health record use through financial penalty rather than mandate alone — the strongest signal yet that the patient data infrastructure required for EHDS cross-border exchange in 2029 is being built whether providers want it or not.