i~HD co-publishes White Paper on EHDS implementation in Greece

The policy paper, entitled “European Health Data Space (EHDS) in Greece: Establishing a Health Data Space Ecosystem”, is the result of two co-creation workshops held in 2025 as well as European experience in developing similar frameworks. It proposes a roadmap for transitioning from regulatory compliance towards leveraging the opportunity created by the European Health Data Space framework, with the aim of generating real value for patients, healthcare professionals, and the health system as a whole.

The European Health Data Space (EHDS) is a strategic European initiative that creates a unified regulatory framework both for the primary use of data (for the provision of care) and for its secondary use (for research, innovation, public health, and policy-making). The EHDS regulation represents a structural reform for the European health landscape, aiming to establish a secure and interoperable framework for health data utilisation that operates through interconnected systems enabling the exchange of insights at both European and national levels.

A central conclusion of the joint initiative is that institutional regulations and technical infrastructures, while necessary, are not sufficient on their own for the successful development of a Health Data Space in Greece.

Effective use of data requires coordination, trust, and the active participation of all stakeholders. Therefore, the creation of a structured stakeholder ecosystem is proposed, operating in complementarity and full alignment with the official institutional framework of the Ministry of Health. This ecosystem will focus on addressing practical challenges not covered by legislation, such as ensuring semantic consistency of data and building trust between citizens and the health system.

The White Paper sets out six strategic recommendations to the State:
Primarily, it proposes the official recognition of an autonomous and representative ecosystem, supported by a neutral coordinating body that ensures transparency and the participation of all stakeholders, with patients at its core. Strategic alignment with the State is deemed necessary, but without direct governmental operational control, in order to preserve the flexibility of the initiative. Furthermore, it proposes the establishment of formal communication channels for the transmission of national priorities, as well as an explicit commitment by the State to leverage the technical expertise of stakeholders in the design of future policies. The framework is completed by the establishment of transparency mechanisms that ensure the ethical use of data, transforming it into social value and guaranteeing that its secondary use serves exclusively the improvement of patient care and safety.

Primarily, it proposes the official recognition of an autonomous and representative ecosystem, supported by a neutral coordinating body that ensures transparency and the participation of all stakeholders, with patients at its core. Strategic alignment with the State is deemed necessary, but without direct governmental operational control, in order to preserve the flexibility of the initiative. Furthermore, it proposes the establishment of formal communication channels for the transmission of national priorities, as well as an explicit commitment by the State to leverage the technical expertise of stakeholders in the design of future policies. The framework is completed by the establishment of transparency mechanisms that ensure the ethical use of data, transforming it into social value and guaranteeing that its secondary use serves exclusively the improvement of patient care and safety.

The importance of the initiative is reflected in the positions of the three organisations. ELLOK emphasises that health data must remain inextricably linked to the patient experience, without revealing patient identity, as trust is the foundation of any reform. The PhARMA Innovation Forum underlines that secondary use of data is a critical driver for the development of new therapies and precision medicine, while also enhancing strategic planning and predictability of the health system. i-HD highlights that without strict standards of interoperability and data quality, the EHDS will remain an unfulfilled promise.

The White Paper concludes with a practical 180-day action plan, including the establishment of thematic working groups on key issues such as data quality, secure access protocols, and transparency mechanisms. Through this coordinated effort, Greece can ensure that the digital transformation of health places the citizen at its centre, while simultaneously strengthening the resilience and competitiveness of the national health system.