Understanding the EHDS

The European Health Data Space

Advancing Health Research and Innovation Across Europe

The European Health Data Space (EHDS) is an important European Union initiative designed to support the exchange, access and responsible use of electronic health data.

It establishes a common framework for both the primary use of health data in healthcare and the secondary use of health data for purposes including scientific research, innovation, policymaking, public health and regulatory activities.

The EHDS creates opportunities to strengthen European collaboration, support research and generate new insights from health data while maintaining appropriate safeguards.

Secondary Use of Health Data

Enabling New Opportunities for Research

Secondary use refers to the use of existing health data for permitted purposes beyond those for which the data was originally collected.

Under the EHDS, eligible researchers and other authorised users will be able to request access to relevant electronic health data through structured procedures, subject to defined legal requirements and safeguards.

The framework will also establish responsibilities for health data holders concerning relevant datasets and their availability for permitted secondary use.

This approach supports the responsible reuse of valuable health information and offers opportunities for research across institutions, organisations and European borders.

Implementation Timeline

Preparing for the Transition

26 March 2025EHDS Regulation entered into forceThe Regulation establishes the legal framework for the European Health Data Space.
26 March 2029Key secondary-use provisions begin to applyThe secondary-use framework begins applying to specified categories of electronic health data, including relevant electronic health records, registries and administrative data.
26 March 2031Additional categories come into scopeThe framework extends to further categories, including clinical trial data and certain other research-related health data.

The phased implementation provides an opportunity for organisations to review their responsibilities, prepare governance and operational arrangements, and contribute to the development of effective secondary-use practices.

How EHDS Secondary Use Will Work

A Connected European Framework

The EHDS establishes a structured approach to secondary use that combines European connectivity with national implementation.

Health Data Access Bodies

Health Data Access Bodies (HDABs) will exercise defined statutory responsibilities, including the assessment of access applications, issuing data permits and overseeing relevant secondary-use arrangements.

HealthData@EU

HealthData@EU will provide the European cross-border infrastructure connecting participating authorities and supporting secondary-use activities across Member States.

Health Data Holders

Organisations falling within the EHDS definition of health data holders will have responsibilities concerning relevant electronic health data, including dataset descriptions and making data available in accordance with applicable requirements.

Health Data Users

Eligible researchers and other authorised applicants will be able to request access to relevant datasets for permitted purposes, subject to the applicable access procedures and safeguards.

Together, these arrangements establish a framework for responsible secondary use across Europe.

The Opportunity for International Data Holders

Supporting Research Across Borders

International pharmaceutical and biotechnology companies, academic institutions and research collaborations play an important role in generating and managing valuable health and clinical research data.

The EHDS provides an opportunity to support greater reuse of these resources for research and innovation through a common European framework.

As organisations prepare for implementation, effective governance, operational coordination and trusted access arrangements will be important in supporting secondary-use activities across multiple jurisdictions.

Vivli Europe is working with stakeholders to explore practical approaches that support these needs and contribute to successful implementation.

Vivli Europe’s Contribution

Supporting the Practical Implementation of the EHDS

Vivli Europe is developing operational approaches that complement the EHDS regulatory framework and European infrastructure.

Our work brings established clinical data-sharing expertise together with European stakeholder engagement to support readiness, coordinated workflows and trusted secondary-use arrangements.

We aim to contribute scalable solutions that help international data holders and researchers participate effectively in the emerging European health data ecosystem.