Helpdesk
Helpdesk
Adopting EHRxF – Helpdesk
The Helpdesk, set up by the xShare project, serves as a dedicated support resource on the EHDS and the European EHRxF. It provides guidance on technical, regulatory, and implementation aspects to facilitate the effective adoption and integration of interoperability assets across the EU.
Frequently Asked Questions
A FAQ section is available below to address common questions and offer clarity on key topics. If your question cannot be answered via the FAQ or information on this website, feel free to submit your question via the button below.
Questions on the Helpdesk
What questions is the helpdesk prepared to answer?
We answer questions related to the Helpdesk itself, the EHRxF, the EHRxF Standards and Policy Hub and ESHIA, the xShare industry label, the Yellow Button and the Open Calls.
How long will it take for the Helpdesk to get back to me?
The Helpdesk will acknowledge the receipt of your question within 5 working days. We will give you an answer via email within 20 working days.
Who will answer my question to the Helpdesk?
An internal expert team within the xShare project will answer your question. Occasionally, we might direct you to experts from other EU projects related to the EHRxF, if their expertise fits more.
Questions on the European EHRxF
What is the European Electronic Health Record Exchange Format (EHRxF)?
The European Electronic Health Record Exchange Format (EHRxF) aims to ensure secure, interoperable, cross-border access to electronic health data across the EU. It establishes guidelines for cross-border data access and exchange, sets common technical standards, and supports ongoing development of a standardised format improving care quality for EU citizens.
The EHRxF is crucial for transforming digital health and care in the European Union (EU). This transformation is based on three main goals outlined by the European Commission:
- Secure data access and sharing.
- Connecting and sharing health data for research, quicker diagnoses, and improved healthcare.
- Empowering citizens and improving individual care through digital services.
You can find the official definition of the EHRxF in Article 15 of the EHDS Regulation.
For non-technical people:
The European Electronic Health Record Exchange Format (EHRxF) is a set of rules and standards designed to help European countries share health data safely and efficiently. It is like agreeing on a common format for digital health records, so that healthcare professionals in different European countries can understand and use each other’s patient information when needed.
What is the European EHRxF not?
The EHRxF is not a platform, central repository, or piece of software.
Is the EEHRxF's standard data format FHIR?
The EEHRxF does not mandate one single standard, rather, a set of common standards is envisioned (including HL7 FHIR) to encompass a broad range of applications, usages and practices, and to avoid creating a new standard on top of the numerous existing ones.
The exact specifications around the EEHRxF are still in development (e.g., in Joint Action Xt-EHR) and are expected to be published as Implementing Acts in 2027. The documents prepared by the Joint Action Xt-EHR which are meant to prepare the implementing acts are however pointing to HL7 FHIR as the key reference standard.
Why do we need a new standard/format?
The EEHRxF mandates not one new standard, but a set of common standards to encompass a broad range of applications, usages and practices. For example, HL7 FHIR is expected to play a pivotal role in the EEHRxF.
The EEHRxF’s requirements will evolve to permit adaptation to evolving landscapes of standards, healthcare practices, health systems and of digital health solutions including with the integration of new technologies. At the level of data, the use of controlled vocabularies such as SNOMED-CT, LOINC, UCUM or ICD need also to be considered. Those standards will increasingly need to be able to ‘talk” to each other.
Note also that standards are created at various points in time to serve different purposes and use cases. As part of their lifecycle, all data standards undergo continuous maintenance, which involves collecting items for review, updating existing frameworks, and extending their capabilities. Over time, advancements in technology and evolving use cases, may require the development of new standards and may make it necessary to align with other standards, driving updates to existing standards to ensure that published standards remain relevant and adaptable to these new conditions.
What types of health data must comply with the European EHRxF?
According to Article 14(1) EHDS, the format applies to the following priority categories of personal electronic health data:
- a) Patient summaries;
- b) Electronic prescriptions;
- c) Electronic dispensations;
- c) Medical imaging studies and related imaging reports;
- d) Medical test results, including laboratory and other diagnostic results and related reports; and
- e) Discharge reports
These categories must be exchanged in compliance with EHRxF when shared within or across Member States.
For non-technical people:
The EHRxF covers health data types that help you get adequate treatment when you are not with your main doctor and avoid repetitive exams, testing etc.
- Patient Summary: Think of it as a medical “snapshot” of your most important health information. It helps doctors quickly understand your health situation – in your country and abroad.
It includes:
- Your current health problems (like diabetes, asthma),
- Allergies, to avoid dangerous reactions,
- Medications you are taking,
- Recent surgeries or treatments,
- And more.
Who must implement and use the European EHRxF?
The following actors are required to implement and support the format:
- Healthcare providers and facilities
- EHR system manufacturers, who must ensure their products are compliant with the common specifications in Art. 36, EHDS
- Digital health authorities in Member States, responsible for supervision and certification
How does the European EHRxF support (cross-border) health data exchange?
The format enables semantic and technical interoperability across systems and Member States. This ensures that data generated in one country can be understood and used in another, improving continuity of care for mobile EU citizens and cross-border treatment scenarios.
Is the European EHRxF only for cross-border exchange?
No – the EHRxF is also for national level health-data exchange.
Is the EEHRxF also relevant for the secondary use of data?
The EEHRxF is first of all meant to support continuity and quality of care. However, the capacity to reuse those structured data for other finalities is also of major importance. The core data supported by the five priority categories of health data are also present in the vast majority of datasets for secondary use. Both public health analysts and clinical research officers can build on the EHRxF to define their data collection process paving the way to very innovative new use cases (see the Business Use Case Repository)
Are the standards used for secondary use compatible with those used for primary use?
In the past, each (health) data ecosystem has been working in silos and has selected or even developed its own standards, without taking into consideration other initiatives working on similar standards or terminologies. . This is true for the data models and the controlled vocabularies. Simplification and better alignment is possible and beneficial. SDOs have already taken major initiatives to create governance and mappings between major international resources. By referring to a common standard for describing datasets, HealthDCAT-AP, the EHDS greatly facilitates the capacity to identify and reuse existing datasets. HealthDCAT-AP is not a data standard itself, but a way to describe datasets and their metadata. It does not replace medical terminologies like SNOMED CT or ICD-10, or data standards such as FHIR, CDISC, or OMOP CDM. Those are still needed to label, organise, and structure the actual data, and should be referenced in the metadata. HealthDCAT-AP’s role is to make datasets easier to find and describe in a consistent way, without defining how the data itself is stored or formatted. The EEHRxF provide a first robust reference to be used by all actors of the healthcare value chain.
Does the EDHS require hospitals to make retrospective data available through this format or just data collected since the application of the EHDS Regulation?
The European Health Data Space (EHDS) Regulation does not require hospitals or healthcare providers to make all retrospective (past) data available by default. However, it does allow and encourage Member States to include historical data if they wish — under certain conditions.
Article 8 of the EHDS Regulation refers to the mandatory use of the European Electronic Health Record Exchange Format (EEHRxF) for newly generated data.
How challenging will EEHRxF implementation be due to the need for training overworked health professionals?
Without strong support for infrastructure and workforce training, smaller hospitals will struggle to implement FHIR. The EHDS directly mandates both national and EU-level assistance to prevent these gaps from widening. It explicitly addresses training in Articles 83 and 84.
On this topic, check out the EU-co-funded project XiA which aims to build capacity comprehensively in the health workforce for adopting the EEHRxF.
What are the main new secondary use cases which can be implemented thanks to the EEHRxF?
The use of the EEHRxF and of the proposed extension of the International Patient Summary (IPS+R) will have a direct impact on the following use cases:
- Administrative simplification (avoidance of data duplication),
- Real time monitoring of key variables,
Patient discovery (identification of patients meeting specific criteria),
- Improved knowledge consolidation.
xShare’s work has identified that the clinical domains of infectious diseases, cancer monitoring and control of antimicrobial resistance are the ones that could mostly benefit from the implementation of the EEHRxF.
What is the IPS+R?
The Patient summary is one of the five priority categories of personal electronic health data listed by the EHDS. The IPS, International Patient Summary, has been defined at an international level and is aligned with the EU specifications. xShare has studied how the IPS could support critical use cases related to clinical research and public health and created a new specification called the IPS+R (International Patient Summary + Research). Only adding a few variables to the existing ones would make a huge difference and would allow an extended use of the data produced. EHR Systems which have implemented IPS+R facilitate planning of clinical studies (e.g. eligibility criteria, assumption testing), sparing both time and resources. This fosters innovative use cases.
Are all requirements and specifications of the European EHRxF already defined?
Not yet. By 26 March 2027, the European Commission is expected to define via Implementing Acts the requirements and specifications that various stakeholders must comply with to meet the interoperability requirements that the EHDS Regulation demands. The use of the EHRxF will be mandatory for patient summaries, electronic prescription and dispensation from 2029 onwards, and for medical images, test results and discharge reports from 2031 onwards.
Will the European EHRxF evolve over time?
Yes. The European Commission, assisted by EU agencies and stakeholders, may update and extend the EHRxF specifications to incorporate new data categories or technical standards. These updates will be done via new Implementing Acts.
What can I expect the Implementing Acts related to the European EHRxF to look like?
To get a better idea of the upcoming Implementing Acts, check out the Joint Action Xt-EHR (2023-2026). It develops guidelines, implementation guides, and a conformity assessment framework for EHR systems. You can find out about their ongoing work and stakeholder engagement activities on the project website. The Deadline for the final Implementing Acts is 26 March 2027.
Questions on EHR systems
Are there requirements for EHR systems regarding the European EHRxF?
Yes. Detailed requirements are laid out in Art. 30 and Annex II of the EHDS Regulation
What requirements do EHR manufacturers need to observe?
EHR manufacturers shall ensure that EHR systems satisfy the essential requirements laid down in Annex II and conform with the common specifications (Article 36, EHDS Regulation).
What specifications do EHR systems need to comply with?
EHR systems need to comply with software components and specifications.
The requirements for software components relate to a logging and an interoperability component. They are outlined in Chapter III, Section 1, EHDS Regulation.
The specifications for the conformity of the harmonised software components of EHR systems are outlined in Chapter III, Section 3, EHDS Regulation.
Both components and specifications will be further defined via Implementing Acts.
Questions on X-Bundles
What is an X-Bundle?
An X-Bundle is a targeted aggregation of assets and artefacts that support the interoperability within and between health systems in different ways, based on European EHRxF specifications. An asset is a standardised specification, tool or supporting material that strengthens the deployment of an interoperability scenario in a real-world implementation. Artefact is the form in which one or more assets are being made available by any organisation contributing to the European EHRxF, whether a project, an SDO, a government agency or other organisation
An X-Bundle provides a coherent set of assets that are targeted toward the specific business use case and interoperability requirements to be implemented in support of digital transformation in real-world healthcare practice.
Where can I find the X-Bundles?
In the X-Bundle Registry, you can find examples of X-Bundles for the EHRxF priority categories and the business use cases identified by the xShare project, including the Yellow Button. Please note that these resources are under development and are kept continuously updated.
How do the X-Bundles relate to the EHDS Regulation?
The X-Bundles are and artefact of xShare and not part of the Implementing Acts. Yet, they provide a mean for better supporting the EHRxF adoption.
Questions on the European EHRxF Standards and Policy Hub
What is the European EHRxF Standards and Policy Hub?
The European EHRxF Standards and Policy Hub is a an platform established under the xShare project (2023–2026) to support the European Health Data Space (EHDS). It brings together standards development organizations (SDOs), digital health industry stakeholders, policymakers, regulators, and researchers. It aims to develop, harmonize, maintain, and promote the adoption of the European Electronic Health Record Exchange Format (EHRxF) and its defining standards.
What are the main functions of the Hub?
The Hub serves three principal functions:
- Managing and supporting users of interoperability assets relevant to their business use cases.
- Co-Creation Environment: Providing a neutral space for collaborative design and innovation.
- Adoption Promotion: Facilitating and encouraging the adoption of the European EHRxF across various stakeholders.
With its work, it supports Member States, organisations and vendors in the implementation of EHDS-ready and compliant solutions.
What kind of services does the Hub offer?
The Hub sees itself as a one-stop-shop providing the following services:
- interoperability specifications and tools, adoption and implementation kits;
- a Community of Excellence;
- the xShare Industry Label as a mark of EHDS readiness.
Who are the key stakeholders involved in the Hub?
The Hub is a joint initiative involving Standards Development Organizations (SDOs) (e.g. CDISC, CEN/TC 251, HL7 Europe, IEEE, IHE-Europe, and SNOMED International), industry representatives, policymakers and regulators, research organisations and others. The European Commission and other international organizations are invited as observers to ensure broad alignment and oversight.
How can stakeholders engage with the Hub?
Stakeholders can engage with the Hub through:
- Participating in co-creation and design-thinking activities.
- Utilizing the Hub’s resources and interoperability assets for their specific use cases.
- Contributing to the development and maintenance of EHRxF specifications.
- Collaborating with other stakeholders to promote the adoption of European EHRxF
Where can I find more information or get involved?
For more information or to get involved with the European EHRxF Standards and Policy Hub contact the Hub’s coordinators: Robert Stegwee (robert[at]trace-health.nl) and Catherine Chronaki (chronaki[at]hl7europe.org).
Questions on ESHIA
What is the European Standards for Health Interoperability Alliance (ESHIA)?
The European Standards for Health Interoperability Alliance (ESHIA) is a newly established organisation accelerating Europe’s journey towards a connected health ecosystem. Founded in Brussels and backed by Europe’s leading standards development organisations, stakeholder groups, and innovation centres, ESHIA exists to turn the promise of the European Health Data Space (EHDS) into reality.
ESHIA is building the trusted home for interoperability standards – a platform where policy, innovation and implementation come together to make health data flow securely and effectively across borders.
ESHIA’s mission is to:
- support the development and implementation of the European EHR Exchange Format (EHRxF)
- provide a single point of access for interoperability specifications, tools, and guidance
- continue the work of the EHRxF Standards and Policy Hub beyond the lifetime of the xShare project
- ensure global alignment and practical support for EHDS implementation across Europe.
Interoperability is no longer optional; It’s the foundation of digital health in Europe. ESHIA is here to help Member States, health providers, vendors, and industry adopt EHDS-compliant solutions – with clarity, collaboration and confidence.
How can I join the European Standards for Health Interoperability Alliance (ESHIA)?
In the coming months we develop the legal entity, business model and membership conditions. Then, we will welcome SDOs, interoperability competence centres, stakeholder associations and other organisations to join ESHIA. More information will be available soon.
Who are the founding members and directors of ESHIA?
The seventeen founding members (in alphabetical order) are: CEN/TC 251, Berlin Institute of Health @ Charité (DE), Datawizard (IT), DNV AS (NO), ECHAlliance – The Global Health Connector (IE), EHTEL (BE), empirica (DE), Fondazione Toscana Gabriele Monasterio (IT), Foundation for Research and Technology FORTH (GR), Fundació TIC Salut Social (ES), Gnomon (GR), HL7 Europe, IEEE, IHE-Europe, IHE Catalyst, MedCom (DK), and Uninova (PT)
The members of the inaugural ESHIA Board of Directors are: Carla Alvarez Costa (Fundació TIC Salut Social), Giorgio Cangioli (HL7 Europe), Marc Lange (EHTEL), Karolina Mackiewicz (ECHAlliance – The Global Health Connector), Maria Palombini (IEEE), Claudio Saccavini (IHE Catalyst), Robert Stegwee (CEN/TC 251), Sylvia Thun (Charité), and Janos Vincze (IHE-Europe)
How can I find out more about ESHIA?
To find out more about ESHIA, check out our press release and the ESHIA website: http://www.eshia.eu/
For specific inquiries, contact Karolina Mackiewicz, xShare Communications Lead, and ESHIA Vice President: karolina[at]echalliance.com
Questions on the xShare Industry Label
What is the xShare Industry Label?
The xShare Industry Label is a voluntary, non-regulatory certification scheme designed to support digital health solution providers as they prepare for alignment with the European Health Data Space (EHDS). It offers a structured pathway for organisations to assess and improve their technical maturity and interoperability readiness.
Who can benefit from the xShare Industry Label?
The label is designed for:
- Digital health manufacturers and solution providers;
- Stakeholders across the healthcare data ecosystem;
- Policy and technical decision-makers who want to demonstrate or evaluate EHDS readiness.
What are the different levels of certification?
There are three progressive levels in the xShare Industry Label system:
- Bronze: Entry-level recognition, typically following a self-assessment
- Silver: Mid-level recognition, may involve more structured evaluation
- Gold: Advanced recognition, typically based on independent third-party validation
These levels allow organisations to evolve over time and prepare for full EHDS compliance by 2029/2031.
Questions on the xShare Yellow Button
What is the xShare Yellow Button?
The xShare Yellow Button is a tool that allows individuals to obtain and share their personal health data in a structured, secure, and interoperable format (HL7 FHIR). It will be used in health portals and patient-facing apps to effortlessly share personal health data in compliance with the GDPR in the EHDS. It empowers users to exercise their data portability rights under GDPR and contributes to standardized data flows across the EU. The accompanying xShare Industry Label certifies that a solution can handle health data using the European EHR Exchange Format (EHRxF).
Is the Yellow Button already being used?
Yes. xShare’s eight adoption sites in Cyprus, Denmark, France, Greece, Ireland, Italy, Portugal and Spain already use the Yellow Button. Via the xShare Open Calls, we aspire that the Yellow Button is featured in close to 100 settings by the end of 2026. Ultimately, our vision is to bring the button to all citizens in the EU.
How are xShare and the Yellow Button related to the EHDS Regulation?
xShare is an EC-funded project that supports the implementation of the EHDS, particularly the EHRxF. It helps develop standards, tools, and guidance and provides early pilots (like the Yellow Button) to test interoperability in real-world settings.
How does xShare ensure that patient consent is consistently tracked, enforced, and auditable? How can I revoke access to my health data?
xShare’s focus is to make data available to the patient and enable a smooth reuse of those data for different purposes, via its Yellow Button. The project paves the way to implementing consent mechanisms for health data sharing as foreseen in the EHDS Regulation. Under the EHDS regulation, consent is considered to be granted a priori. Under certain circumstances, citizens may opt out. For primary use, the EHDS regulation also foresees the right of patients to restrict access to specific data. Beyond this right, it is up to each Member State to pass national law to allow total opt-out. As a result, health data of people who have opted out will not be accessible by third parties, other than the healthcare provider who provided the treatment.
For secondary use, the EHDS Regulation (Art. 71) gives all individuals the right to opt out from secondary use of their personal electronic health data – i.e. without specific legislation from Member States. Member States need to provide easily understandable information about the opt-out process.
Both opt out mechanisms are thus enforced by each Member State which develops all components required for their tracking and auditing.
How is the healthcare provider authenticated?
The Yellow Button is to be coupled with a secure authentication method.
Health professionals (like doctors or nurses) will use trusted national ID systems that are recognized across Europe to access patient data. Many countries in the EU already provide such digital IDs to licensed health professionals. These IDs are usually the same ones people already use to log into public or private services online (like government websites or banking apps). They can keep using them as long as they meet common EU standards, which will be officially set in the near future.
However, just using a digital ID is not enough to confirm that someone is a qualified health professional. These IDs usually only confirm someone’s identity – like proving that a person is really “Jacques Durand.” But they don’t always confirm that Jacques Durand is a nurse or works at a specific hospital.
To solve this, more advanced ID systems – like the EU Digital Identity Wallet – may also include details such as a person’s professional role and qualifications. Countries may choose to use this feature to help confirm that a user is not only who they say they are, but also that they are truly qualified to access health data. This requires that Member States have implemented a digital registry of healthcare professionals operating in the country.
The yellow button is to be coupled with a secure authentication method.
Can I give an app I trust continuous, real-time access to my lab results?
There are quite a few trustable apps which can already retrieve lab results on real time in different EU Member States. But in order to do this, the App must be able to communicate seamlessly either with each Lab or with the Regional/National EHR to which all the labs are connected. This is not specific to xShare. But thanks to the Yellow Button, the lab results can be retrieved in a structured way following the specifications of the EEHRxF. This will allow the App to show the information to the patient in a more comprehensive, intuitive and dynamic way and possibly also to support the “translation” of the results in lay language
As an example: I want to share parts of my health data to the army or vaccination records for travel purposes — is this feasible?
The EHDS does not automatically authorise sharing your health data with non-healthcare entities like the army or border control officers. But the EHDS Regulation guarantees a right to data portability. This means that the citizen can download his/her data and can share them with third parties if he/she wishes so. You as a natural person remain in full control.
The xShare Yellow button has precisely this objective in mind. The EU digital identity wallet will also be a very convenient tool to store essential and certified data that need to be shared with third parties.
To download data from different providers/hospitals, do I need to click on the "Yellow Button" each time?
The maturity of national digital health infrastructure can be very different from country to country in the EU. In some countries, the documents and data produced by each professional or hospital are already shared via a regional or national EHR. In this case, downloading data with the yellow button can be done easily through an App or a web portal leaving the patient select the download criteria (e.g. all lab reports for a selected period).
If the infrastructure is not yet mature, then indeed the patient might have to download data from each individual hospital or professional via a secured data processing environment or protocol (such as e.g. Bluetooth for simple transactions such as prescriptions or dispensations).
Is the Yellow Button’s idea using a link as a reference to download my data via a file? How long should such a link be valid?
When the data sharing is made via a secured unique link, the person (data owner) clicks on the xShare Yellow Button and selects the one-time share functionality. He/she visualises and selects the health data available to share and indeed creates a static document. The xShare Yellow Button might suggest several options such as data transformation: anonymisation, translation, and digital signature. The data are then visible both in EEHRxF and the original data in human readable format. The person requests then a shareable link and provides the shareable link to the Authorised Data Recipient. The period of validity of the link can be customised.
Another option foreseen by the Yellow Button is the “linked option” where the person can share selected data during a selected period of time. All data which meet the set criteria are then shared with the external party during this period.
As I am working on a digital health start-up, how to integrate the Yellow Button functionality, and is there any cost?
Start-Up are most welcome to integrate the Yellow Button functionality. This is also the purpose of the Open Call organised by xShare. The Yellow Button FHIR implementation guideline has been published and a first plugathon has been successfully organised in Vienna in June 2025. There is no cost of access to the specifications but using the testing environment might be subject to limited fees.
Is the Yellow Button also for wellness apps/medical devices to insert data into EHR Systems?
The xShare Yellow Button also includes an upload functionality which can thus allow to insert data into specific EHR systems. The Yellow Button is however for now only covering the data included in the EEHRxF; other types of data such as those provided by wellness app might also be shared but this might lead to interoperability issues.
Some Member States already have a similar functionality automated (e.g., the Netherlands, using MedMij standards). Should this be replaced by the Yellow Button?
The Yellow Button is closely connected to the EEHRxF while Medmij relies on its own national specifications. The Yellow Button might thus not replace Medmij but Medmij might integrate the Yellow Button specifications to cover an extended number of use cases – in particular in a cross-border context.
Questions on the Open Calls
What is the xShare Open Call 2025?
The xShare Open Call 2025 is an invitation for early adopters to pilot the xShare “Yellow Button” — a one-click solution enabling individuals to share their health data securely and in an interoperable manner across systems in Europe. The initiative aligns with EHDS objectives by promoting citizen-centric health data exchange based on Health Level Seven (HL7) Fast Healthcare Interoperability Resources (FHIR), the standard format behind the European Electronic Health Record exchange Format (EHRxF). Find more information on the xShare website.
What are the objectives of this Open Call?
The open call aims to support real-world integration of the Yellow Button in healthcare and wellness scenarios. Proposals should demonstrate how one-time health data sharing can enhance care delivery, personal health management, or research. Proposals must utilize the HL7 FHIR xShare Implementation Guide and are expected to prioritize EHDS Regulation categories such as:
- Patient summaries
- ePrescriptions and eDispensations
- Laboratory results
- Medical imaging and reports
- Hospital discharge summaries
Additional categories proposed by xShare include:
- IPS+R (an extension of the International Patient Summary for research)
- Care Plans
Who can apply?
The call is open to a wide range of actors in the digital health ecosystem, including:
- Health tech startups
- Electronic Health Record (EHR) or Personal Health Record (PHR) vendors
- Digital therapeutics and wellness app developers
- Healthcare providers and system integrators
- Patient associations
- Hospitals
- National agencies and public authorities
Applicants may apply individually or as part of a consortium and should be capable of delivering a working demonstrator or Minimum Viable Product (MVP) during the call period.
What kind of use cases is xShare looking for?
Proposals should focus on:
- Enhancing patient control over their data
- Demonstrating clear real-world value
- Improving productivity for providers or systems
Examples include:
- Personal health apps that combine official records and wearable data
- EHR portals offering FHIR-based data downloads
- Tools to facilitate research data contributions directly from patients
- Services enabling patients to match with clinical trials using their own data
Creative combinations of official health data, patient-generated data, and other sources are encouraged.
Questions on individual rights
What data can I personally insert into my electronic health record?
Under the EHDS, as an individual, you are allowed to insert different types of data into your electronic health record (EHR), with the following boundaries and safeguards in mind:
- You can add information
You have the right to add personal electronic health data into your EHR or store additional information in your separate personal health record which could be accessed by health professionals.
However:
- Your inserted data is clearly marked
The data you add must be clearly distinguishable from data entered and verified by health professionals. This ensures that healthcare providers know which data was self-entered and which was clinically validated. - No modification of professional data
You cannot modify or alter electronic health data entered by healthcare professionals. You are allowed to complement, but not change, data provided by them. - No explicit limitations on content, but indirect limits apply
The EHDS does not impose a specific list of data types you may or may not add, but clinical value, quality, reliability, and ethical considerations indirectly limit what is meaningful or useful to add. For instance:- lifestyle data (e.g. diet, sleep, exercise)
- wellness app outputs (if interoperable)
- patient-reported symptoms
- over-the-counter medications
The entries above may all be examples of valid personal entries, as long as they are clearly flagged as self-reported.
- Not legally equivalent to professional data
Data you add may not carry the same clinical or legal value as data entered by a healthcare professional. Health professionals will make their own judgment on whether and how to take your self-reported data into account. - Technical channel
The insertion must happen through the officially provided electronic health data access services (or apps linked to them), which EU Member States are obliged to make available free of charge. - Additional safeguard: Right to rectification
Although you cannot directly modify professional data, you can request rectifications if you identify mistakes
In summary:
You have broad rights to complement your EHR with your own data, but you cannot overwrite professional entries and your added data will be clearly marked as patient generated.
There might be some limitations on the types and volume of data which can be entered by the citizen depending on the system used. Personal Health Records are usually designed to collect a wider range of structured data, including data produced by devices under the control of the patient while regional or national EHR often limit themselves to a narrower range of data.
For reference: Articles 4(1), 5 and 6; Recital 12.
Which is the health record I can insert my data into? A health record maintained by a specific healthcare organisation? By me? By the European Health Data Space?
Under the European Health Data Space (EHDS), the health record you can insert your data into is your Electronic Health Record (EHR), maintained within the healthcare system by healthcare providers, but accessible to you via official national or regional electronic health data access services established by your Member State
More precisely:
- The health record is not directly maintained by you, nor by the EHDS itself.
It remains operated by healthcare providers (hospitals, clinics, doctors, etc.) who register and update your personal electronic health data when delivering care. - The EHDS sets common EU rules and technical standards for how these EHR systems work and interoperate.
The EHDS creates the legal and technical framework, but does not itself host or own your health record. - You can insert data into your EHR via national electronic health data access services or apps linked to them.
Article 5 gives you the right to insert information into your own EHR through these official access services or connected applications. This data will be clearly marked as “provided by you”, and you cannot directly modify the information entered by health professionals. - In addition, you may also keep personal health records that are separate from the EHR.
Recital (12) explains that citizens may store additional health information in personal health records, but these have a different legal status than the official EHR maintained by healthcare providers
In summary:
- You insert your data into your official EHR via authorised national electronic health data access services.
- You do not manage the EHR directly.
- The EHDS does not maintain or host your record but regulates the system.
For reference: Articles 1(1), 5 and Recitals 1, 7, 11 and 12.
Can I opt out of a country?
Under the European Health Data Space (EHDS), you cannot directly “opt out of a country.” The regulation doesn’t allow an individual to selectively exclude a specific Member State or third country from having access to their data.
However, you have multiple rights to limit access in general:
- Right to restrict access for primary use (care purposes)
You can restrict which health professionals and healthcare providers see parts of your data (e.g. specific treatments, diagnoses) — but this applies to any professional regardless of country, not country-specific - Right to opt-out entirely from primary use sharing (if your country allows it)
Some Member States may allow you to fully opt-out of sharing your data beyond the healthcare provider that originally treated you. This means no cross-border sharing at all — but again, not selectively by country - Right to opt-out from secondary use (research, policy, public health, etc.)
You can fully opt out of having your data used for secondary purposes (like research, statistics, public health monitoring). This opt-out applies generally — again, not selectively by country. - International transfers to third countries
Transfers to non-EU countries are strictly regulated under international agreements and GDPR rules. These are not something you as an individual can directly control, but there are high legal safeguards in place.
For reference: Articles 8, 10, 71, 90-91; Recitals 17, 18, 54