EHDS Implementation Timeline: The Dates That Matter

EHDS obligations are phased over a decade under Article 105 of Regulation (EU) 2025/327. Compliance programmes must plan against specific milestones rather than a single deadline. This timeline lays out every legally binding date that affects healthcare providers, EHR vendors, and health data holders. Dates verified against the consolidated text of the Regulation as published in the Official Journal of the European Union on 5 March 2025.

5 March 2025 — Published in Official Journal

Regulation (EU) 2025/327 published in the Official Journal of the European Union (OJ L, 2025/327, 5.3.2025). Signed at Strasbourg on 11 February 2025.

25 March 2025 — Regulation enters into force

Per Article 105, the Regulation enters into force on the twentieth day following publication. No immediate operational obligations on providers, but the clock starts for Member States to begin transposition and designation of national bodies.

26 March 2027 — General application begins

Article 105: "This Regulation shall apply from 26 March 2027." Most provisions start applying on this date, including Member State obligations to designate digital health authorities, establish national contact points for digital health, establish health data access bodies, and join MyHealth@EU. This is also the deadline by which the Commission must publish implementing acts laying down technical specifications for the European electronic health record exchange format, common specifications for essential requirements in Annex II, and operational rules for MyHealth@EU.

26 March 2029 — Priority Category 1 mandatory + secondary use live

Per Article 105(3)(a), Articles 3–15 apply from this date to the Priority Category 1 data in Article 14(1): (a) Patient Summary, (b) electronic prescriptions, (c) electronic dispensations — and to EHR systems intended by the manufacturer to process those categories. In parallel, Chapter IV (secondary use) starts applying: National Health Data Access Bodies begin accepting and processing data access requests. This is the first hard compliance deadline for the patient-facing obligations most healthcare providers associate with EHDS.

26 March 2031 — Priority Category 2 mandatory + Chapter III live

Per Article 105(3)(b), Articles 3–15 apply from this date to the Priority Category 2 data in Article 14(1): (d) medical imaging studies and related imaging reports, (e) medical test results including laboratory results, (f) discharge reports — and to EHR systems intended to process those categories. Chapter III (EHR systems put into service in the Union per Article 26(2)) also starts applying on this date.

26 March 2035 — Final transitional provisions

Final remaining transitional provisions under Article 75(5) apply. The Commission is also required by this date to complete an overall evaluation of the Regulation and submit a report to the European Parliament, Council, EESC, and Committee of the Regions with any proposed amendments (Article 102(2)).

Spain-specific dates

In addition to EU-level EHDS deadlines, Spanish providers must plan against Spain-specific milestones:

  • 2025-2026: Ley de Salud Digital draft legislation moving through Congress. Final form expected late 2026.
  • 2026-2028: Autonomous community certification programmes begin. Each of the 17 regional health services defines its own integration and testing requirements.
  • 2027-2028: Ministry of Health national contact point accepting production connections from private healthcare providers. Earlier connection slots expected to be more available.
  • March 2029: National go-live alongside EHDS Priority Category 1 mandatory deadline.