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 .
XP
xShare Project
Other · Belgium
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 665 files tracked
2
legislative files
of 665 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
xShare Project filed 2 positions between 6 Jan 2026 and 7 May 2026, across 2 of the 665 legislative files tracked here, attaching a full position paper 2 times.
What they argued
The xShare project recommends the following amendments in the draft requirements for cross-border exchange of personal health data (MyHealth@EU) 1. Section Cross-border data exchange and central interoperability platform for digital health (Art.3-13) o In Article 4, include a standalone point on the Commission and Steering Groups responsibility to set up end-to-end testing assets.
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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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