TEHDAS2 public consultations reflect active EHDS preparations in the European health ecosystem
Over 750 consultation responses were submitted, helping the development of key guidelines for the secondary use of health data under the European Health Data Space (EHDS).
The second wave of public consultations organised by TEHDAS2 gathered over 750 responses on EHDS implementation guidelines. The consultation ran from October to November 2025 and included 11 draft documents.
The draft guidelines and technical specifications covered different topics such as fees, penalties, data access, data protection, secure IT systems and citizens’ rights. The overall number of responses per document ranged from 40 to 99. Several respondents represented multiple organisations, granting the responses still broader legitimacy.
This strong response reflects a broad recognition that the upcoming EHDS implementation and TEHDAS2 results will significantly influence how health data is accessed, shared and reused across borders, and that stakeholders wish to contribute actively to making sure the resulting framework is both practical and impactful.
Broad participation across Europe and different sectors
As in the first TEHDAS2 consultation, public, private and academic organisations formed the majority of respondents. Geographical coverage was broad, responses varying from 12 to 16 European countries, although Eastern and Southern European countries remained underrepresented. Participation from international organisations saw a notable increase compared to the first consultation round.
Stakeholders call for clear and practical guidance for EHDS implementation
Many consultation responses revealed expectations for more specific operational guidance and called for clarity and examples on use cases. This reflects a desire by many stakeholders for actionable materials to support their EHDS-readiness.
Document authors are currently carefully reviewing all feedback received and improving the guidelines and technical specifications based on the comments. To help users navigate EHDS-related requirements better, forthcoming versions of TEHDAS2 guidelines will include a more thorough explanation on the role of TEHDAS2 materials as expert guidance developed within the project. This will further clarify the distinction from legal specifications in the form of implementing and delegated acts drafted by the European Commission.
The final versions of the documents will be published during the first half of 2026.
A strong signal of the need for user engagement
Taken together, the second TEHDAS2 public consultation shows strong, maturing engagement with the technical and operational details of secondary health data use. This momentum underscores how stakeholders across Europe are preparing for the opportunities and responsibilities that the EHDS will bring, and how user contributions on the supporting guidelines can play an important role in that transition.
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