European Health Data Space Board operations

The document promotes cross border interoperability of public services and health data access bodies. The nuances of interoperability of different platforms needs to be detailed to include privacy and security for patient information. Further collaboration and information exchange need to be defined at a high level. For example, who will upload the information, and where is it uploaded?

The Health Information and Quality Authority (HIQA) welcomes the opportunity to review and provide feedback on the Draft implementing regulation - Ares(2025)10870706 laying down the necessary measures for the establishment and operation of the European Health Data Space Board.

EUROCAM stresses that the European Health Data Space (EHDS) should strengthen healthcare delivery and research across the EU through a patient-centred and evidence-informed approach. The work of the EHDS Board in developing standards, technical specifications and guidance is essential to ensure digital solutions support clinical practice and continuity of care without imposing rigid approaches that limit…

Cancer Patients Europe (CPE) response to the Consultation on the Commission Implementing Regulation on the EHDS Board Cancer Patients Europe (CPE) welcomes the draft Commission Implementing Regulation establishing the European Health Data Space (EHDS) Board.

PUBLIC CONSULTATIONS & FEEDBACK Draft Commission Implementing Regulation establishing and operating the European Health Data Space Board: FEEDBACK Type of act Implementing regulation Committee C131500 Draft implementing regulation - Ares(2025)10870706 Commission adoption: Planned for First quarter 2026 We welcome the Commissions draft Implementing Regulation establishing the necessary measures for the operation of…

Founded in 2016, The Guild comprises 23 of Europe's most distinguished research-intensive universities across 17 countries and is dedicated to enhancing the voice of academic institutions, their researchers, and their students.

Thank you for inviting feedback to this draft implementing regulation for the EHDS Board. The Netherlands University Medical Centres support the establishment of the European Health Data Space and wish to contribute to valuable health data exchange that promotes the wellbeing of Europeans.

The xShare Project contributes to this consultation our perspective on advancing the EEHRxF in a way that is centred on the citizen. This is relevant to the EHDS Board since: a) exchange of first priority categories of health data will likely be one of its first work topics , and b) it will be tasked with providing written contributions on technical specifications and exchange of electronic health data .

We are submitting this feedback to the draft implementing act on the EHDS Board on behalf of the European Standards for Health Interoperability Alliance (ESHIA), a newly established nonprofit association backed by Europes leading standards development organisations, stakeholder groups, and interoperability competence centres with the mission to support EHDS implementation (www.eshia.eu).

Response on behalf of NVZ Dutch Hospital Association to the EU consultation on the Draft Implementing Regulation Ares(2025)10870706 NVZ recognizes the importance of the European Health Data Space (EHDS) as a foundation for better care, research, and innovation and welcomes the opportunity to provide comments on the proposed implementing regulation for the establishment and functioning of the EHDS Board.

The European Health Data Space (EHDS) represents a paradigm shift in the use of medical data. Our professional experience focuses mainly on laboratory medicine data. In this area, we are concerned about the traceability and interoperability of results between different centres.

Filed in Spanish · English published by the European Commission

We are submitting this feedback to the draft implementing act on the EHDS Board on behalf of EHTEL, the Digital Health and Care Stakeholder Forum representing Digital Policy Implementers working to advance digital health and care transformation (www.ehtel.eu).

AESGP welcomes the opportunity to comment on the draft Commission Implementing Act laying down the measures for the establishment and operation of the European Health Data Space (EHDS) Board. AESGP expresses its support for the establishment of the EHDS Board, recognizing it as a fundamental component for achieving a successful and harmonised implementation of the EHDS.

The European Health Data Space (EHDS) Regulation stands as a landmark initiative that has the potential to transform healthcare by improving access to and the use of electronic health data, fostering innovation, and strengthening Europes competitiveness in the health sector.

About EHA: The European Hematology Association (EHA) is the leading representative of hematology and hematology professionals in Europe. We are a notforprofit, public benefit organization with over 11,000 members.

SNOMED International welcomes the draft Implementing Act establishing the EHDS Board and considers it a solid and well-balanced proposal. The draft provides a clear governance framework that supports cooperation between Member States and the EC, while ensuring continuity with existing European digital health coordination mechanisms.

HOPE appreciates the opportunity to comment on the draft Implementing Regulation setting out measures on the establishment and operations of the EHDS Board. Recognising its key function as a forum for cooperation and exchange of information between the Member States and the Commission, HOPE backs its swift inception to steer the EHDS implementation.

Finnish Social and Health Data Permit Authority Findata welcomes the opportunity to comment on the draft Commission Implementing Act laying down the measures for the establishment and operation of the European Health Data Space (EHDS) Board.

I have read the implementing act of the EHDS Council and what is most striking is that it does not clarify the cooperation of the EHDS Council with the Stakeholder Forum (Article 93 of the EHDS Regulation) and the Steering Committees to be set up for MyHealth@EU and HealthData@EU (Article 95 of the EHDS Regulation). Cooperation with the stakeholder forum is completely absent from this implementing act.

Filed in Dutch · English published by the European Commission

EUROCAM stresses that the European Health Data Space (EHDS) should strengthen healthcare delivery and research across the EU through a patient-centred and evidence-informed approach. The work of the EHDS Board in developing standards, technical specifications and guidance is essential to ensure digital solutions support clinical practice and continuity of care without imposing rigid approaches that limit…

In the name of the European Traditional Chinese Medicine Association (ETCMA), representing over 11,000 professional members across Europe, we would like to formally express our support for the feedback submitted by EUROCAM to the European Health Data Space (EHDS) public consultation, as outlined in the attached document.

The objective of this contribution is to provide a strategic, scientific, and professional assessment of the proposed governance framework, with a view to supporting the effective, coherent, and evidence-based implementation of the European Health Data Space (EHDS) across the European Union.

Dedalus Group welcomes the publication of the draft implementing regulation on the European Health Data Space (EHDS) Board and appreciates the effort to establish a governance framework that promotes coordination and transparency. In this context, we would like to offer some recommendations aimed at strengthening inclusiveness, clarity, and moving to effective implementations.

As a member of the Practitioners Register, I fully support EUROCAM’s contribution to the European Health Data Space Board, supporting an inclusive, person-centred and evidence-based EHDS that reflects actual clinical practice, respects professional judgement, ensures data protection and recognises the personalised and preventive care models specific to MTCI and Natural Therapies.

Filed in Spanish · English published by the European Commission

As a Polish Chambers of Commerce of Naturopaths we endorse EUROCAM position. EUROCAM stresses that the European Health Data Space (EHDS) should strengthen healthcare delivery and research across the EU through a patient-centred and evidence-informed approach.

As a U.S-based biohealth stakeholder that has previously collaborated with other stakeholders on EU public health policy, Revitalised Medicine welcomes this ideas on strengthening the European Health Data Space (EHDS) through collaborations with public service institutions and advocating for interactions between the EHDS board and the eHealth Network.

The European Health Data Space (EHDS) Regulation aims to establish a common framework for the use and exchange of electronic health data across the EU. It does not regulate in detail all aspects of the EHDS Board’s activities. This initiative will set out in detail the measures necessary for the establishment and functioning of the EHDS Board.

Filed in Italian · English published by the European Commission

As a member of the Practitioners Register, I fully support EUROCAM’s contribution to the European Health Data Space Board, supporting an inclusive, person-centred and evidence-based EHDS that reflects actual clinical practice, respects professional judgement, ensures data protection and recognises the personalised and preventive care models specific to MTCI and Natural Therapies.

Filed in Spanish · English published by the European Commission

As a EUROCAM member ERG supports fully its declaration regarding EHDSB. "EUROCAM stresses that the European Health Data Space (EHDS) should strengthen healthcare delivery and research across the EU through a patient-centred and evidence-informed approach.

DIGITALEUROPE welcomes the establishment of the EHDS Board as a crucial element for the successful and harmonised implementation of the EHDS. While the draft Implementing Act provides some level of clarity on its operations, we believe that the areas outlined below should be further formalised in the Implementing Act: 1) Formal and meaningful stakeholder collaboration: the draft Implementing Act does not provide…

Bodies dealing with the EHDS should pay attention to the protection of trade secrets and promote research with the built-up data base in the least burdensome way. In this sense, the last sentence of Article 8 should be strengthened: Should EHDS Board members, invited experts and observers fail to respect these obligations, the Commission MUST take all appropriate measures.

Filed in German · English published by the European Commission

EFPIA welcomes the opportunity to comment on the draft Commission Implementing Act laying down the measures for the establishment and operation of the European Health Data Space (EHDS) Board. We support the Commissions efforts to develop a robust governance structure for the EHDS and recognise the importance of the Board in ensuring consistent implementation across Member States.

The International Federation of Anthroposophic Medical Associations endorses EUROCAM's response to the Public Consultation on EHDS Board operarations: EUROCAM stresses that the European Health Data Space (EHDS) should strengthen healthcare delivery and research across the EU through a patient-centred and evidence-informed approach.

EUROCAM stresses that the European Health Data Space (EHDS) should strengthen healthcare delivery and research across the EU through a patient-centred and evidence-informed approach. The work of the EHDS Board in developing standards, technical specifications and guidance is essential to ensure digital solutions support clinical practice and continuity of care without imposing rigid approaches that limit…

The PLATAFORMA DE ORGANIZACIONES DE PACIENTES (POP) welcomes the publication of the first draft Implementing Act (IA) under the European Health Data Space (EHDS) and acknowledges the key role of the EHDS Board in ensuring coherent, trustworthy and effective implementation of the Regulation across the EU.

It would be useful to include the following into the implementing act to ensure governance structures are clear and transparent: 1. Quorum for decision making, how many countries have to be in attendance to allow a decision to be taken. 2. Describe how a decision of the EDPB can be appealed or challenged. 3.

The Dutch Patients Federation (DPF) is the national umbrella organisation representing more than 200 patient organisations. It supports these organisations in strengthening their position within the Dutch health-care system.

This EU health data card is going to benefit patients , medical professionals, Hospitals, GP, Community Care. Deliver more precise target health, perhaps new medication , Clinical Trials if appropriate. Gather health data that may help others / researchers etc. It will be EU wide and it will be a consolidated approach for all Citizens in the EU. PPI participation is vital in the successful delivery of this project.

The European Association of Urology welcomes the publication of the implementing regulation on the EHDS Board. We particularly welcome the plans on transparency and the requirement to publish two year work plans. As the EHDS Board is noted as a key governance mechanism, we have noted the lack of provision on one of the key tools of governance - participation.

The European Patients Forum (EPF) welcomes the publication of the first draft Implementing Act (IA) under the European Health Data Space (EHDS) and acknowledges the key role of the EHDS Board in ensuring coherent, trustworthy and effective implementation of the Regulation across the EU.

Subject: Recognising care process and operational flow data as a necessary complement to clinical data within the EHDS. Feedback The draft Implementing Regulation on the establishment and operation of the European Health Data Space Board (EHDS Board) represents an important step towards strengthening the European governance framework for health data and supporting a consistent exchange of electronic health data…

To ensure that the European Health Data Space (EHDS) delivers its intended benefits for patients, research, and healthcare innovation, it is important that the EHDS Board includes or systematically consults stakeholders with expertise in data-driven biomedical research, diagnostics development, and patient-centred data governance.