TEHDAS2 second consultation draws 750 responses across 11 draft secondary use guidelines

The TEHDAS2 joint action closed its second public consultation in November 2025 with over 750 responses across 11 draft documents covering fees, penalties, data access procedures, data protection, secure processing environments, and citizens' rights under EHDS secondary use. Individual documents received between 40 and 99 responses, with representation from 12 to 16 European countries per document. Eastern and Southern European countries were underrepresented in submissions, raising the risk that the final guidance — due in the first half of 2026 — will not reflect the implementation realities of the Member States furthest from readiness. These documents will serve as the de facto operational playbook for Health Data Access Bodies and secure processing environments before the Commission's formal implementing acts arrive.