xShare has submitted its response to the European Commission’s open public consultation on the draft Implementing Regulation for the European Health Data Space (EHDS) Board. The contribution reflects an implementer’s perspective on how to make the European EHR Exchange Format (EEHRxF) work in practice, with a strong focus on the needs and rights of citizens.
Why xShare is contributing
xShare is engaging in this consultation to help advance the EEHRxF in a way that supports real-world deployment while remaining firmly citizen-centred. This comes at a critical moment, as the EHDS Board is expected to begin early work on the exchange of first-priority data categories and to provide written contributions on technical specifications and electronic health data exchange.
Based on its close collaboration with implementers and EHR stakeholders, xShare sees a clear and shared need for continuous, practical guidance on how to implement the EEHRxF. This need is particularly pressing in view of the planned start of cross-border exchange for Patient Summaries and ePrescription and eDispensation in 2029.
Key recommendations from xShare
In its submission, xShare proposes targeted amendments to ensure that the EHDS Board’s written contributions, such as implementation guides, deliver concrete added value for those responsible for putting the EEHRxF into practice.
The main recommendations include:
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Adding implementation guides per priority category of personal electronic health data under Article 2.1(a), explicitly aligned with existing eHealth Network Guidelines.
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Explicitly referencing, under Article 2.1(b), interoperability assets and best practices from open repositories, as well as best practices for mapping legacy standards and systems to the standards that make up the EEHRxF.
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Clarifying how the Stakeholder Forum will be involved when drafting written contributions under Article 2.1, and ensuring its involvement in providing feedback on EEHRxF implementation.
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Including a clear mandate under Article 2.1 for the EHDS Board to interact with relevant Standards Developing Organisations, so EHDS technical specifications are adopted and reflected in international standards.
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Ensuring that the bi-annual workplan under Article 2.2 foresees regular evaluation of technical specifications and their implementation, including the EEHRxF, so guidance evolves alongside market and standards developments.
Through this response, xShare aims to support a more practical, coherent, and citizen-focused implementation of the European Health Data Space and to contribute constructively to the EHDS Board’s future work.
Read the full response on the EC portal here.