EU Health Data API
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EU Health Data API, published by HL7 Europe. This guide is not an authorized publication; it is the continuous build for version 0.1.0 built by the FHIR (HL7® FHIR® Standard) CI Build. This version is based on the current content of https://github.com/euridice-org/eu-health-data-api/ and changes regularly. See the Directory of published versions

EHDS Annex II - Essential Requirements

EHDS Regulation (EU) 2025/327 - ANNEX II

Essential Requirements for EHR Systems

Source: EUR-Lex Regulation (EU) 2025/327

Published: 5 March 2025 Entered into force: 26 March 2025

Note: The essential requirements laid down in this Annex shall apply mutatis mutandis to medical devices, in vitro diagnostic medical devices, AI systems and wellness applications claiming interoperability with EHR systems.


Section 1: General Requirements

1.1 Performance and Safety

The harmonised software components must achieve their intended performance and be designed such that during normal use, they support patient safety and fulfill their designated purpose.

1.2 Installation and Supply

The harmonised software components of the EHR system shall be designed and developed in such a way that the EHR system can be supplied and installed, taking into account the instructions and information provided by the manufacturer, without adversely affecting its characteristics and performance during its intended use.

1.3 Rights Protection

Systems must be designed to uphold individual rights according to their intended purpose under Chapter II, maintaining interoperability, safety, and security features.

1.4 Compatibility with Other Products

Where an EHR system operates with other products including medical devices, it must ensure reliable and secure interoperability with compatible sharing of personal health data through the harmonised components.


Section 2: Requirements for Interoperability

2.1 Data Access Interface

Where an EHR system is designed to store or intermediate personal electronic health data, it shall provide an interface enabling access to the personal electronic health data processed by it in the European electronic health record exchange format.

2.2 Data Reception Capability

Systems must be able to receive personal electronic health data in the European electronic health record exchange format through the interoperability component.

2.3 Data Access Reception

Where an EHR system is designed to provide access to personal electronic health data, it shall be able to receive personal electronic health data in the European electronic health record exchange format, by means of the European interoperability software component for EHR systems.

2.4 Data Entry Granularity

Systems enabling structured data entry must support sufficient detail levels to enable provision of entered data in the required exchange format.

2.5 Anti-Restriction Provisions

The harmonised software components of an EHR system shall not include features that prohibit, restrict or place an undue burden on authorised access, personal electronic health data sharing or use of personal electronic health data for permitted purposes.

2.6 Data Export Capability

Systems must not include features that prohibit, restrict, or unduly burden the authorised exporting of personal electronic health data when replacing one EHR system with another.


Section 3: Requirements for Security and Logging

3.1 Professional Authentication

An EHR system designed to be used by health professionals shall provide reliable mechanisms for the identification and authentication of health professionals.

3.2 Logging Mechanisms

The logging component must record sufficient information for every access event, including:

  • Healthcare provider or individual identification
  • Specific individual accessing the data
  • Categories of accessed data
  • Date and time of access
  • Data origin or origins

3.3 Log Analysis Tools

The harmonised software components of an EHR system shall include tools or mechanisms to review and analyse the log data, or it shall support the connection and use of external software for the same purposes.

3.4 Retention and Access Differentiation

Components storing personal health data must support varying retention periods and access rights accounting for data origins and categories.