EHDS and ePA: What Is Coming for Your Department's Documentation

Thursday, outpatient consultation. The patient puts his phone on the table, the app open: "It says here I had a hypertensive derailment. What does that mean?" The physician letter the department wrote three weeks ago has acquired a reader nobody reckoned with at the time of writing. Around 73 million accounts now exist for the elektronische Patientenakte (ePA) — Germany's national electronic patient record, run on an opt-out model, which means an account for nearly every person with statutory insurance [1].

What a department documents was long a text for the general practitioner, the insurer, the Medizinischer Dienst — the statutory insurers' medical review service — and, in a dispute, a court. That circle of addressees is currently growing in two pushes: first by the patients, then by Europe. Both pushes have dates.

What already applies

The "ePA für alle" ("ePA for all") started on January 15, 2025 in three model regions and has been usable nationwide since April 29, 2025 [2]. Since October 1, 2025, healthcare providers including hospitals have been obliged to fill the record — with data from the current treatment that exists electronically, unless the patient has objected (§§ 347 ff. SGB V) [3]. For practices, fee reductions have applied since January 1, 2026; hospitals, according to insurers and consultancies, face a cut of the telematics-infrastructure surcharge if the ePA has not been filled since April 1, 2026 [4].

Usage is real but unevenly distributed. According to gematik — the national agency for Germany's digital health infrastructure — over 100 million documents sat in the ePA in April 2026, and by June it was around 130 million; hospital uploads rose from about 2,000 per week in October 2025 to over 90,000 per week [1]. At the same time, fewer than 900 hospitals — just under half — were actively using the ePA in June 2026 [5]. Whoever uploads today still belongs to the first half.

For 2026 and 2027, gematik has announced further functions, among them the expansion of the digitally supported medication process with structured dosage information, full-text search and a data export for research purposes — all of it to be read as planning; dates can slip [1].

The European timetable

The second wave comes from Brussels. Regulation (EU) 2025/327 on the European Health Data Space (EHDS) was published in the Official Journal on March 5, 2025 and entered into force on March 26, 2025 [6]. Its obligations take hold in stages:

• March 26, 2027: general date of application of the regulation.
• March 26, 2029: first priority data category of primary use — patient summary, electronic prescription and dispensation.
• March 26, 2031: second category — medical imaging including reports, laboratory results and discharge reports.

The sentence that counts for hospital departments stands at the end of the staggering: discharge reports become a European mandatory category from March 26, 2031 — structured, interoperable, retrievable across borders [7]. The staggering follows from the regulation's transitional provisions; the technical formats will be specified by implementing acts expected over the coming years.

What this means at department altitude

The circle of addressees grows

The patient from the consultation is already reading. From 2031 it can be the emergency department in Lisbon retrieving the discharge report. Comprehensibility and clean structure used to be a quality mark of good letters; they are becoming a precondition of access. Practically, this means: resolve in-house abbreviations, note medication changes with their reasons, separate the essential from what gets dragged along. A letter only your own hospital can decode will in future serve its purpose only in part.

The prose PDF becomes a legacy burden

What travels into the ePA today as a scanned PDF satisfies the filling obligation. The category-2 requirements of 2031, by contrast, aim at structured, interoperable documents. The difference between the two is work — and it is smallest at the moment the information comes into being: at admission, at the finding, on the ward round. Whoever reconstructs structure only on the day of discharge pays for it twice. Separate rules of evidence also apply to digital records — what § 630f BGB requires of electronic documentation (in German) is worth a look of its own.

Timeliness is already an obligation

Independently of Brussels, the Rahmenvertrag Entlassmanagement — Germany's framework agreement on discharge management — has applied since 2017: patients must be given at least a preliminary discharge letter no later than the day of discharge [8]. The ePA filling comes on top. The letter is thus no longer a trailing task running after the stay — why the same-day discharge letter is in truth an admission problem (in German), we have described separately.

Five questions for the next leadership meeting

1. Is our hospital already uploading to the ePA — and which document types exactly?
2. Would our discharge letter stand in 2031 as a structured category-2 document, or is it a formatted PDF?
3. Does a patient without a medical degree understand what we write about her — and do we want to leave that to chance?
4. How often is our preliminary letter actually ready on the day of discharge? Measured, not estimated.
5. Who in our hospital tracks the EHDS implementing acts — and reports to the department what they mean for documentation?

None of these questions demands a project. Each demands an owner. The difference between hospitals that reach 2031 calmly and those that reach it frantically is made in the leadership meetings of 2026 and 2027.

If you want to keep the timelines of the ePA, the EHDS and everything in between in view: our weekly briefing Visite (German; English edition Grand Rounds is in preparation) tracks them — brief, sourced and at department altitude.

Sources

1. gematik. Ein Jahr „ePA für alle“: Mehr als 100 Millionen hinterlegte Dokumente. April 2026. https://www.gematik.de/newsroom/news-detail/ein-jahr-epa-fuer-alle-mehr-als-100-millionen-hinterlegte-dokumente-verbessern-behandlung-und-versorgung-in-deutschland
2. gematik. „ePA für alle“ startet in drei Modellregionen. Januar 2025. https://www.gematik.de/newsroom/news-detail/epa-fuer-alle-startet-in-drei-modellregionen
3. Ärzteblatt. Ab Anfang Oktober ePA-Nutzung für Praxen verpflichtend. 2025. https://www.aerzteblatt.de/news/ab-anfang-oktober-epa-nutzung-fur-praxen-verpflichtend-13f0e40a-c05e-4417-9c90-521f93730fb7
4. AOK. Sanktionen bei Nicht-Nutzung der ePA ab 2026. https://www.aok.de/gp/news-allgemein/newsdetail/sanktionen-nicht-nutzung-epa-2026
5. Ärzteblatt. Nutzung der elektronischen Patientenakte nimmt zu. Juni 2026. https://www.aerzteblatt.de/news/nutzung-der-elektronischen-patientenakte-nimmt-zu-802ce6cc-169b-4634-9a91-c86e132d5b03
6. Verordnung (EU) 2025/327 über den europäischen Raum für Gesundheitsdaten (EHDS). Amtsblatt der EU, 5. März 2025. https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX:32025R0327
7. Noerr. Der European Health Data Space kommt — ein Überblick. https://www.noerr.com/de/insights/der-european-health-data-space-kommt-ein-ueberblick
8. Rahmenvertrag Entlassmanagement (§ 39 Abs. 1a SGB V), Lesefassung. GKV-Spitzenverband. https://www.gkv-spitzenverband.de/media/dokumente/krankenversicherung_1/amb_stat_vers/entlassmanagement/12._AendVb_Rahmenvertrag_Entlassmanagement_03.06.2024_Lesefassung_ohne_Anlagen.pdf