The EHDS regulation inevitably contained some blind spots in the face of the complexity of Europe’s healthcare delivery. These blind spots are now emerging and causing pain points for implementers. This EHTEL Symposium session featured perspectives from healthcare providers, industry and Member States, and discussed policy recommendations to ensure a successful EHDS implementation.

An EHTEL working paper entitled "The EHDS regulation of EHR systems: Blind spots and pain points, and how to address them" lay at the heart of this session. If you didn’t yet read it, download it now.

Panellists

Moderator: Lars Hulbaek, MedCom, Denmark

Lars announced the plans for the establishment of Digital Health Denmark. This new organisation will strengthen digital development in healthcare.

Mariam Shokralla, HIMSS, The Netherlands

Mariam outlined the gap between theory and reality in terms of electronic health record systems (EHR systems), and the challenges that many healthcare institutions are facing today. She highlighted the trend towards merging/sharing different kinds of healthcare data.

Dr. Jörg Köpke, CompuGroup Medical (CGM), Germany

Jörg described electronic health records as a strategic resource. Some of the boundaries related to data use are becoming less clear with the introduction of artificial intelligence. It is therefore important to clarify the scope of EHR systems.

Dr. Juha Mykkänen, Finnish Institute for Health and Welfare (THL), Finland

Juha offered plenty of concrete information on Finland’s experience with health data, as well as background on EHRs, electronic medical records, and personal health records. He named some of the available major, commercial EHR systems. Examples cited of health data use cited came from outside Europe e.g., Singapore; others related to rare conditions. Juha’s major concluding messages were around “align now, deliver better, decide now, and execute better”.

Discussions

Throughout the session, discussions focused around the content of an EHTEL EHDS implementers’ task force working paper on "The EHDS regulation of EHR systems: Blind spots and pain points, and how to address them".  Attendees had been encouraged to read this Working Paper 1 and its details ahead of the Symposium.

Input from the audience zoomed in on:

• Finland: Expansion in 2026 of the MyKanta services data to include social welfare data.
• Nordic cooperation: Useful viewpoints published by the Nordic Council of Ministers on support for healthcare professionals’ data quality work.
• Data protection and data privacy: The relationship between concerns expressed in the EHDS and in the General Data Protection Regulation.
• Practicalities: “You cannot upgrade all at once!”. “The devil is in the detail.”
• “Must-haves”: Vital requirements include international collaboration; refinement of national initiatives; and the use/re-use of systems already in existence.

Short polls shared with attendees showed overall support for these four recommendations:

✅ Clarify the scope of EHR systems.

✅ Relax European Electronic Health Record exchange Format (EEHRxF – “the format”) compliance timelines for some types of EHR systems.

✅ Organise appropriate governance and processes for updating of the EEHRxF.

✅ Integrate EHDS governance and EEHRxF governance.

In conclusion

The session covered several key issues. They included: coverage of both large and small-scale information technology systems; standards and their governance; which organisations/entities have expertise in EHR systems (e.g., HL7, Integrating the Healthcare Enterprise); the use of “logic models” (theories of change); and the use of appropriate use cases.

Look out for more news in the short-term future on the work of EHTEL’s EHDS Implementers’ Task Force!

The working paper on "The EHDS regulation of EHR systems: Blind spots and pain points, and how to address them" lay at the heart of this session.