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From Policy to Practice: Implementing the EHDS for Responsible Data Sharing

From Policy to Practice: Implementing the EHDS for Responsible Data Sharing

In May 2022, the European Commission introduced the proposal for the European Health Data Space (EHDS) to establish a unified framework for the secure and standardized sharing of electronic health data across all EU member states. The EHDS Regulation, finalized and entered into force for implementation on March 26, 2025, is the inaugural initiative among nine planned European sector-specific data spaces. As a new regulatory framework, EHDS introduces significant opportunities that encompass two core components: (1) patient rights regarding access and control of their electronic health data, supported by the necessary infrastructure; (2) provisions for access and secondary use of health data for research, innovation, policy development, and other approved uses. The implementation of these components requires harmonization of data governance mechanisms across diverse health systems of EU member states.

The MRCT Center has partnered with Vivli to co-host a series of online, invitation-only forums for interested pharmaceutical and biotechnology companies to support stakeholders in understanding and navigating this evolving landscape. A range of issues, including the implementation of EHDS, the importance of harmonizing data governance, data protection, and compliance, have been discussed to date, with additional topics slated for presentation and discussion at upcoming forums. Additionally, commentary and responses to the EHDS draft guidelines are presented and discussed in the forums. Through this collaborative approach, we aim to identify and address opportunities and challenges, ensuring that EHDS fulfills its promise of advancing personal health, innovation, and clinical research across Europe.

OBJECTIVES

  • Convene and engage global stakeholders to collaborate on EHDS developments, coordinate efforts, and foster dialogue on data sharing and governance.
  • Guide policy and framework development toward a harmonized system for secondary use of health data, ensuring alignment with ethical, regulatory, and compliance standards that advance innovation in clinical research and healthcare.

KeY MILESTONES

  • November 30, 2025: Submitted three comments to the second wave of TEHDAS2 Public Consultations, specifically (1) M7.2 Draft guideline on data minimisation, pseudonymisation, anonymisation and synthetic data, (2) M8.1 Draft Guideline to Health Data Access Bodies how to implement opt-out from secondary use of electronic health data, (3) M8.2 Draft Guideline to Health Data Access Bodies on implementing the obligation of notifying the natural person on a significant finding from the secondary use of health data.
  • November 4, 2025: Held the sixth EHDS workgroup forum, discussing insights gathered by attendees of the TEHDAS2 and HL7 Vulcan Stakeholder Forum on October 9, 2025, in Copenhagen, and an open discussion of the second wave of TEHDAS2 guidance documents with highlights on topics such as data linkage, data minimization, and trusted data holders and central data repositories.
  • September 30, 2025: Held the fifth EHDS Workgroup forum, where members (1) discussed an earlier meeting with Sitra, and (2) identified which TEHDAS2 draft guideline documents to prioritize for comments, including a potential strategy and process for submitting comments.
  • September 9, 2025: Held the EHDS Workgroup forum, where Elina Drakvik, a Senior Lead at Sitra, provided an overview of EHDS rules relating to the secondary use of health data, Finland’s groundwork for EHDS implementation, and the ongoing work of the TEHDAS2 project, which is creating guidelines to harmonize practices across Europe and directly inform the Commission’s implementing acts.
  • July 17, 2025: Held the third EHDS Workgroup forum, where Aneta Tyszkiewicz, Associate Director, Digital & Data for the Science Policy and Regulatory Affairs team at EFPIA, provided an overview of the EHDS regulation and EFPIA’s active engagement in this area.
  • May 15, 2025: The second EHDS Workgroup Forum convened industry members to discuss the practical implications of EHDS for industry and research organizations and how to transform uncertainty into actionable, pragmatic next steps.
  • March 19, 2025: Launch of Workgroup Webinar Series “From Policy to Practice: Implementing the EHDS for Responsible Data Sharing.” The forum convened experts from industry, legal, and regulatory backgrounds to discuss the European Health Data Space (EHDS) and its implications for the sharing of clinical trial data.

project Leadership & sTAFF

  • Barbara E. Bierer, MD, Faculty Director, MRCT Center
  • Lisa Koppelman, MSW, LICSW, MPH, Team & Program Director, MRCT Center
  • Rebecca Li, PhD, CEO Vivli
  • Olchey Tchavyntchak, Research Assistant, MRCT Center

Project Resources