The European Health Data Space (EHDS) will reshape how health data moves, who can use it, and under what conditions — for every patient, clinician, and researcher in Europe. So when the European Commission convened an Implementation Dialogue on the EHDS Regulation, chaired by Commissioner for Health and Animal Welfare Olivér Várhelyi, the question of who was in the room mattered. The European University Hospital Alliance, represented by Secretary-General Johan Van Eldere, was invited to the dialogue to bring the perspective of academic medicine and Europe’s university hospitals — the institutions that generate, curate, and safeguard much of the most valuable health data, and that will carry a substantial share of the work of making the EHDS real. For EUHA, this invitation is a milestone. It confirms what our members have argued since the first EHDS proposals: university hospitals are not passive data suppliers. They are data controllers, custodians, guarantors of data quality, and long-term custodians of public trust — and the implementation of the EHDS must be designed with them, not merely applied to them. 📘 What is the EHDS? The European Health Data Space (EHDS) is an EU Regulation, in force since March 2025, that creates a common European framework for health data. It rests on two pillars: Primary use — giving patients control over their electronic health data and making it available wherever they receive care, including across borders. Secondary use — allowing health data to be reused, under strict safeguards, for research, innovation, and policy-making, via national Health Data Access Bodies and Secure Processing Environments. Why This Dialogue Matters The Implementation Dialogues are the Commission’s instrument for gathering stakeholder input so that the EHDS delivers its intended benefits with minimal administrative burden — including exploring where the framework can be simplified. With the Regulation in force since March 2025 and key implementing acts due for adoption by March 2027, the decisions taken now will determine how the EHDS works in practice for decades. EUHA came to the table with a clear, published position. In our two position papers — the EUHA Consensus Positions on Artificial Intelligence (2025) and the EUHA Perspective on Secondary Use of Health Data and Intellectual Property under the EHDS (2026) — our eleven member hospitals set out a consistent vision: Federated Governance as the Default Model Access-based models within Secure Processing Environments, rather than centralised warehousing of raw data detached from the originating institutions. Data Controllership Stays with Healthcare Institutions. Healthcare providers must remain the primary custodians and controllers of patient data. The EHDS must preserve GDPR-aligned controllership at the institutional level. Openness and Protection Are Complements, Not Opponents. Open Science and academic intellectual property protection should not be framed as opposing paradigms; database rights, trade secrets in curated datasets, and legitimate confidentiality interests must be respected. Attribution, Recognition, and Compensation. Dataset creation and curation are research outputs. Originating institutions deserve mandatory attribution, provenance tracking, transparent reporting of secondary research outcomes, and compensation for the effort of preparing data for third parties. EHDS implementation must strengthen data stewardship culture, not commoditise hospital-generated data. Safeguards for AI Development. Reuse for AI must remain within a clear legal basis, in secure validated environments, with mandatory bias testing — and liability must not shift to data-originating hospitals when AI systems are built by third parties. “Hospitals are not upload points” — A conversation with Johan Van Eldere We sat down with Johan Van Eldere after the meeting to hear how this message landed. Q What was your overall impression of the meeting? A The meeting was a welcome opportunity for the different non-governmental stakeholders to present their remarks directly to the commissioner and his team. My impression was that the commissioner and his team were very much aware of many of the issues mentioned by the different stakeholders, but they nevertheless listened carefully to all remarks. What struck me was that, on the side of the stakeholders, the healthcare providers, that generate the bulk of the health data, were underrepresented compared to the industry. Q Is the Commission — and Commissioner Várhelyi personally — aware of the position of the university hospitals on the EHDS? A I hope they are. In any case, it remains of the utmost importance that we continue to argue for our points of view in regard to the EHDS. Not only because it is important for us but even more importantly because we are convinced that the success of the EHDS also depends on the active participation of university hospitals and the healthcare sector in general. Q Did the Commissioner agree with these positions? A The purpose of the dialogue was to gather input rather than to take positions, but I noted genuine attention to our main points that university hospitals and the healthcare sector in general are not only passive data upload points but active guarantors of data quality and that their efforts should result in data rights and attribution. Q What was the input from the other participants — industry, patients, other care providers? A Many different issues were raised. Issues that struck me were the need to avoid fragmentation in the implementation of the EHDS, the protection of IP, the need for EU-wide standards and interoperability of data, the need for trust from patients in the EHDS, the need for a collaboration between academia and industry, and the need for assistance in helping hospitals and other caregivers to implement the EHDS. Q One last question. If readers remember a single message from this dialogue, what should it be? A Hospitals must not be reduced to raw data providers, administrative upload points, or passive compliance entities. They are clinical knowledge institutions, guarantors of data quality, central actors in ethical oversight, and long-term custodians of public trust. To be successful, the European Health Data Space will need their active involvement and recognition. What Comes Next EUHA will continue to engage with the European Commission, Health Data Access Bodies, and fellow stakeholders as the implementing acts take shape between now and March 2027. Our members stand ready to contribute what they do best: real-world expertise from the institutions where Europe’s health data is created, curated, and turned into better care. Read Our Position Papers: EUHA Consensus Positions on Artificial Intelligence (2025) EUHA Perspective on Secondary Use of Health Data and Intellectual Property under the EHDS (2026)