Netherlands confirms opt-out for primary use and advances HDAB designation

Minister Bruijn sent a parliamentary letter detailing the Netherlands' EHDS implementation plans, confirming the country will introduce an opt-out right for primary use of health data — an optional provision under the regulation that reflects Dutch concerns about balancing medical confidentiality with data availability. Preparations for designating both the Digital Health Authority (Autoriteit Digitale Gezondheid) and the Health Data Access Body are underway, with the HDAB-NL programme now established across four partner organisations: RIVM, CBS, ICTU, and Health-RI. A legislative proposal for national EHDS implementation will go to public consultation in the first half of 2026, with parliamentary submission expected in Q1 2027. This is one of the most detailed national implementation roadmaps published by any Member State, and the four-organisation HDAB consortium signals institutional commitment to secondary use infrastructure that most countries have not yet matched.