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

Public Comments submitted to TEHDAS2 on targeted issues related to the European Health Data Space

Public Comment

Comments provided on: November 30, 2025

Comments provided to: TEHDAS2, coordinated by the Finnish Innovation Fund SITRA

Description:The MRCT Center and Vivli co-host an ongoing, invite-only forum focused on the European Health Data Space (EHDS), bringing together stakeholders to track developments and coordinate responses. The MRCT Center submitted responses to three TEHDAS2 guidance documents offered for public consultation to Health Data Access Bodies:

  1. GUIDELINE FOR HEALTH DATA ACCESS BODIES ON DATA MINIMISATION, PSEUDONYMISATION, ANONYMISATION AND SYNTHETIC DATA 
  2. DRAFT GUIDELINE FOR HEALTH DATA ACCESS BODIES ON IMPLEMENTING OPT-OUT FROM THE SECONDARY USE OF HEALTH DATA
  3. DRAFT GUIDELINE FOR HEALTH DATA ACCESS BODIES ON IMPLEMENTING THE OBLIGATION OF NOTIFYING THE NATURAL PERSON ON A SIGNIFICANT FINDING FROM THE SECONDARY USE OF HEALTH DATA

Medical Need or Market Opportunity: Setting Research Priorities

Meeting Summary

Presented on: March 10, 2025

This meeting was presented to the Bioethics Collaborative. The Bioethics Collaborative is a forum to propose, share, and discuss ethical challenges in multi-national clinical trials. Meetings convene individuals from academia, industry, patient/participant groups, ethics committees, government, and others.

Abstract: Since funding and other resources for clinical research are limited, decisions must be made about which research projects to pursue, which not to pursue, and how to prioritize among the studies that are chosen. The principle of “unmet medical need” is often acknowledged as a guiding consideration in this context, and there have been calls for community input into prioritization and the choice of the study question. Further, addressing unmet medical needs, particularly in the context of the global burden of disease, is important for public health but may not, and likely will not, maximize market opportunity or financial profits – a dynamic that is particularly salient for private industry sponsors. Should prioritization then rest solely or principally with the funder? How should such entities balance economic obligations toward shareholders with the public good?

One salient principle of distributive justice is “prioritarianism,” the idea that research that stands to benefit the worse-off or those who are already underprivileged should be given priority over research that stands to benefit people in better situations: the well-being of the most disadvantaged is prioritized. Even prior to this, however, questions arise over how to understand the expected goods of research, who the beneficiaries might be, and how the well-being of different possible beneficiary groups should be measured. Further downstream, issues arise over who should engage in prioritization decisions, and in particular, whether the research community should rely solely on high-level, centralized prioritization mechanisms (e.g., industry sponsors, NIH, non-profit funders), or whether individual institutions, local communities, and/or patients and their allies might have some role to play in ensuring that studies are appropriately prioritized at a local level. How should these various voices be heard, should they be represented, and how can—or should—balance be achieved, and if so, what processes should be considered? The March Bioethics Collaborative will seek to address these and other issues in connection with the ethics of research priority-setting.  

Therapeutic Misconception Revisited

Meeting Summary

Presented on: June 4, 2025

This meeting was presented to the Bioethics Collaborative. The Bioethics Collaborative is a forum to propose, share, and discuss ethical challenges in multi-national clinical trials. Meetings convene individuals from academia, industry, patient/participant groups, ethics committees, government, and others.

Abstract: The lines between research and care continue to blur. Pragmatic research studies comparing accepted therapies are increasingly embedded seamlessly into clinical practice. More and more, participation in research deemed promising is offered to patients before standard therapies are exhausted, sometimes as a first-line option. While the concept of “therapeutic misconception”—in very broad strokes, the tendency for individuals to misapply attributes of clinical care to research—has been a mainstay of research ethics for over 40 years, these developments provide an occasion, and perhaps even an urgent need, to revisit it and related topics. How exactly should we understand the therapeutic misconception and what it involves, particularly in cases where the line between research and care really is vague and hard to determine? Even more basically, how should we understand the relationship between research and care in the first place? Are concerns over therapeutic misconception still important, or do they perhaps reflect naïve understandings of research and care and the relation between them–particularly in cases where current options are limited? 

Mitigating Financial Toxicity for Participants in Clinical Trials: Best Practice Considerations & Recommendations for Sponsors

Webinar

Presented on: December 9, 2025

Hosted by the MRCT Center, in collaboration with Equitable Access to Clinical Trials (EACT), a project convened by LUNGevity Foundation.

Clinical trials are vital to advancing medical knowledge and care, yet participation can impose significant financial burdens on participants and their families—from travel and time away from work to uncovered medical and ancillary expenses.

This webinar examined the sources and impact of these costs and highlighted emerging strategies to reduce financial hardship for research volunteers. Presenters also introduced tools, checklists, and other resources developed through the EACT Project, a collaborative forum advancing financial neutrality in clinical research participation.

Panelists

Moderator
Dr. Barbara Bierer, Faculty Director, MRCT Center

A Framework for AI Adoption and Oversight in Clinical Research


EACT Project Resources

Joint Task Force for Clinical Trial Competency (JTF) Global Biannual Meeting

Meeting

June 15, 2026 @ 9:00 am 11:00 am

The Joint Task Force for Clinical Trial Competency (JTF), anchored at the MRCT Center, develops and disseminates standards and practices for the global clinical research workforce. By fostering a cohesive and collaborative approach, the JTF ensures that professionals have the competencies to conduct clinical trials ethically and effectively.

Our international team of investigators, educators, and clinical research professionals has developed and/or utilizes a framework that defines the knowledge, skills, and attitudes necessary for conducting safe, ethical, and high-quality clinical research.

Join us on June 15, 2026, 9:00-11:00 AM ET for the Joint Task Force for Clinical Trial Competency (JTF) Biannual Global Meeting to hear about global perspectives on implementing the JTF Framework. Agenda specifics will be posted soon.

To learn more about the JTF Framework: https://mrctcenter.org/clinical-trial-competency/framework/overview/

All registrants will receive slides and a meeting summary after the meeting. This event is free.

Meeting of The Research, Development, and Regulatory Roundtable (R3)

November 5, 2026 @ 1:00 pm 3:30 pm

The Research, Development, and Regulatory Roundtable (R3) is a forum to discuss pre-competitive issues in drug and device development, regulatory oversight of clinical trials, and human subjects research. Meetings convene policymakers, legal counsel, academicians, industry representatives, and global regulators. The R3 is a cooperative endeavor coordinated by the MRCT Center and Ropes & Gray LLP.

This hybrid meeting is open to sponsors of the Research, Development, and Regulatory Roundtable.

Topic: TBD

For more information, please email at MRCT@BWH.HARVARD.EDU

Deliverables

Meeting of The Research, Development, and Regulatory Roundtable (R3)

September 3, 2026 @ 1:00 pm 3:30 pm

The Research, Development, and Regulatory Roundtable (R3) is a forum to discuss pre-competitive issues in drug and device development, regulatory oversight of clinical trials, and human subjects research. Meetings convene policymakers, legal counsel, academicians, industry representatives, and global regulators. The R3 is a cooperative endeavor coordinated by the MRCT Center and Ropes & Gray LLP.

This hybrid meeting is open to sponsors of the Research, Development, and Regulatory Roundtable.

Topic: TBD

For more information, please email at MRCT@BWH.HARVARD.EDU

Deliverables

Meeting of The Research, Development, and Regulatory Roundtable (R3)

June 10, 2026 @ 1:30 pm 4:00 pm

The Research, Development, and Regulatory Roundtable (R3) is a forum to discuss pre-competitive issues in drug and device development, regulatory oversight of clinical trials, and human subjects research. Meetings convene policymakers, legal counsel, academicians, industry representatives, and global regulators. The R3 is a cooperative endeavor coordinated by the MRCT Center and Ropes & Gray LLP.

This hybrid meeting is open to sponsors of the Research, Development, and Regulatory Roundtable.

Topic: TBD

For more information, please email at MRCT@BWH.HARVARD.EDU

Deliverables