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European Health Data Space (EHDS)

Enacted European Union · In force Mar 25, 2025 · next deadline Mar 26, 2027 (in 6 months)

Deadlines

DateWhat happens
Mar 25, 2025EHDS enters into force18 months ago
Mar 26, 2027EHDS general application datein 6 months
Mar 26, 2029Primary use for first data categories; secondary use framework appliesin 2.5 years
Mar 26, 2031Primary use for second data categories; EHR systems in service; extra secondary-use categoriesin 4.5 years
Mar 26, 2035Third-country participation in secondary usein 8.5 years

Summaries for reference, not legal advice. Check the official text.

What it does

Gives individuals electronic access to, and control over, their health data across the EU (primary use), with a cross-border MyHealth@EU infrastructure and mandatory requirements for electronic health record (EHR) systems. It also creates a permit-based framework for secondary use of health data (research, innovation, policy) through national Health Data Access Bodies, with data holders required to make data available.

Who it applies to
Health data holders (healthcare providers, researchers, companies holding electronic health data; micro-enterprises largely exempt as data holders), manufacturers and distributors of EHR systems and wellness apps claiming interoperability, health data users seeking secondary use, and Member State digital health authorities.
Penalties
Secondary-use infringements by data holders/users: up to EUR 10M or 2% of worldwide annual turnover, and up to EUR 20M or 4% for the most serious infringements, e.g. unlawful re-identification or use outside a data permit (Art 64). Member States set other penalties.
Enforced by
National digital health authorities, Health Data Access Bodies, market surveillance authorities (EHR systems), data protection authorities; EHDS Board and European Commission
Official name
Regulation (EU) 2025/327 on the European Health Data Space
Citation
OJ L, 2025/327, 5.3.2025
Topics
health, privacy, data-access
Verified 2026-09-22
Research notes

Some provisions (e.g. Art 55(6), 70, 73(5), 75(1),(12), 77(4), 78(6)) apply from 26 Mar 2027. Many details depend on implementing acts still being adopted. The effective date is computed as the twentieth day after the 5 Mar 2025 OJ publication.

Related

Questions about European Health Data Space (EHDS)
What are the European Health Data Space (EHDS) compliance deadlines?
Mar 25, 2025: EHDS enters into force. Mar 26, 2027: EHDS general application date. Mar 26, 2029: Primary use for first data categories; secondary use framework applies. Mar 26, 2031: Primary use for second data categories; EHR systems in service; extra secondary-use categories. Mar 26, 2035: Third-country participation in secondary use.
When does European Health Data Space (EHDS) take effect?
European Health Data Space (EHDS) took effect on Mar 25, 2025. The next milestone is Mar 26, 2027: EHDS general application date.
Who does European Health Data Space (EHDS) apply to?
Health data holders (healthcare providers, researchers, companies holding electronic health data; micro-enterprises largely exempt as data holders), manufacturers and distributors of EHR systems and wellness apps claiming interoperability, health data users seeking secondary use, and Member State digital health authorities.
What are the penalties under European Health Data Space (EHDS)?
Secondary-use infringements by data holders/users: up to EUR 10M or 2% of worldwide annual turnover, and up to EUR 20M or 4% for the most serious infringements, e.g. unlawful re-identification or use outside a data permit (Art 64). Member States set other penalties.

When the rules change: new data, privacy and AI laws and deadlines, the next morning.