We welcome the Draft Commission Implementing Regulation on HealthData@EU. This infrastructure is a vital step toward realizing the European Health Data Space (EHDS). However, to ensure the infrastructure truly enables cross-border research and is valuable for all European citizens, we submit three key recommendations regarding Chapter II (Architecture, technical documentation and interoperability).
HBV
The Hyve B.V.
Company · Netherlands
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
2
positions filed
in the 655 files tracked
2
legislative files
of 655 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 655 consultation files tracked so far (56,999 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
The Hyve B.V. filed 2 positions between 11 May 2026 and 22 Sept 2026, across 2 of the 655 legislative files tracked here.
What they argued
The current EHDS proposal focuses heavily on National Health Data Access Bodies (HDABs). However, a purely centralized national model is inefficient for specialized research. For rare diseases, requesting access through multiple national points is a barrier; instead, access should be facilitated through disease-specific access points.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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