European Health Data Space · For hospital data teams

What your first EHDS data request will actually take

3 months

to deliver requested data to your HDAB (Art. 60)

€10M or 2%

maximum fine for breaching data holder duties (Art. 64)

Every request

restarts the hardest work, unless your data is already mapped

From March 2029, once an HDAB approves a health data request, it asks your hospital for the data, and you have three months to deliver. Additional data categories, such as labs and genomic data, follow in 2031. The steps below show the work, who owns it, and what it costs when you have to repeat it with every request.

seE the seven steps
Calculate your repeat cost

The checklist

Seven steps between a data request and a delivered dataset

Download as PDF (PDF, 65 KB, opens in a new tab)
The seven steps a hospital takes to fulfil an EHDS data request, with the systems touched, who owns each step and whether it repeats per request
StepWhat happensSystems touchedWho owns itRepeats per request
1 Read the request. Scope, variables, and the deadline arrive from your national Health Data Access Body. HDAB portal Data office Yes
2 Find the data. Locate every requested variable across the systems that hold it, and work out how each was derived. EHR, lab, imaging, registries, trial systems Data office, IT Yes, unless mapped once
3 Cut to what’s in scope. Keep only the named variables. Remove national opted-out patients (Art. 71) and flag protected IP (Art. 52). Opt-out register, data warehouse DPO, data office Yes
4 Reshape and code it. Convert to the format the request names and map local codes to standard vocabularies. EHR, lab, imaging, registries Clinical informatics, IT Yes, unless mapped once
5 Anonymise or pseudonymise. Anonymised is the default. Under current draft guidance, the HDAB re-pseudonymises when pseudonymised data is approved. Data warehouse DPO, HDAB Yes
6 Deliver and keep proof. Put the data at the HDAB's disposal within three months of its request and keep a record of what left and when. HDAB portal, compliance system IT Yes
7 Estimate your costs. Send the HDAB an estimate of your compilation and preparation costs so you can obtain compensation. Finance system Finance Yes

Where the time goes

Steps 2 and 4 will carry most of the effort. Map your data once, and they stop repeating.

Cost calculator

What redoing the work costs you, today and from 2029

Most hospitals already rebuild extracts for research and registry requests. EHDS adds requests on a deadline. Enter your own numbers; we don’t pre-fill effort, because every data estate is different.

Research, registry and audit requests that need a fresh extract

Salary plus employer costs

Adjust for your country

Staff days per request today to find and reshape the data (steps 2 and 4)

Base it on your last few extracts: a quick one and a hard one.

Not set
Not set
Share of today’s requests that become EHDS requests

0% keeps them separate, so the work stacks. 100% means EHDS requests replace them entirely.

0%
EHDS requests you expect per year, from 2029

All requests, including any of today’s requests that move to the EHDS route. Nobody knows yet, so set a low and a high guess for 2029 and how fast volume grows each year.

3 requests
12 requests
0% a year

Set growth above 0% if you expect volume to rise after 2029.

Staff days per EHDS request (steps 2 and 4)

An EHDS request fixes the scope, the format, and a three-month deadline, so it may take longer than today’s extracts. Leave at 0 to use today’s figure.

Same as today
Same as today

Today

—

a year

Set staff days per request

In 2029

—

the first year: requests that stay outside EHDS, plus EHDS requests

Set staff days per request

Yearly staff days, 2027–2033

  • Today’s requests
  • EHDS requests
  • Lighter shade: up to your high estimate
Set staff days per request to draw your chart

Set staff days per request and add your hourly cost to see the totals.

Effort before any compensation. For EHDS requests, the HDAB fee may include compenstion for your documented preparation costs. The full-time share assumes about 220 working days a year.

Stop redoing the same work

Mapped once, steps 2 and 4 become a configured run on every request after the first, whether it arrives through the EHDS or your usual channels.

Share it internally

A one-page summary with your inputs, ranges and chart, ready for your CIO or finance lead.

Test it against your systems

In 30 minutes, we run these numbers against a map-once scenario for your most likely first request.

Bring these numbers

Your one-page summary. Choose “Save as PDF” in the print dialog.

RhinoFederated Computing

Prepared
Your inputs, not Rhino benchmarks

EHDS repeat-cost estimate

What redoing the extract work costs us, today and from 2029

Today, per year—
In 2029—
Total, 2029–2033—

Yearly staff days, 2027–2033

Set staff days per request and add your hourly cost to see the totals.

  • Today’s requests
  • EHDS requests
  • Lighter shade: up to your high estimate

Each bar stacks today’s requests and EHDS requests for that year. Solid blocks show your low estimate; the lighter blocks above them run to your high estimate.

Add staff days per request in the calculator to include the chart.

Our assumptions

The seven steps behind every request

  1. 1. Read the request
  2. 2. Find the data (repeats unless mapped once)
  3. 3. Cut to what’s requestted
  4. 4. Reshape and code it (repeats unless mapped once)
  5. 5. Anonymise or pseudonymise
  6. 6. Deliver and keep proof, within three months
  7. 7. Claim your costs through the HDAB fee

Figures are effort before compensation. For EHDS requests, Art. 62 of Regulation (EU) 2025/327 lets data holders claim documented preparation costs through the HDAB fee. Full-time share assumes about 220 working days a year. Not legal advice.

Walk your first request with us in 30 minutesrhinofcp.com
optional role
Three more steps, with costs recovered through fees

Member States may let hospitals apply for trusted health data holder status (Art. 72). Designation requires a secure processing environment that meets Art. 73, expertise to assess applications, and compliance guarantees. In return, three more steps move to your side, with fees to cover them.

Considering Trusted Data Holder status? Talk it through with us.

Assess applications

Review applications that cover only your data and send the HDAB an assessment with a proposed decision.

Run the environment

Researchers work inside your secure processing environment instead of receiving an extract.

Review every export

Only anonymised results leave. You can charge cost-based fees directly (Art. 62).

How hospitals shorten the repeat work
Map once. Run every permit after that.
Rhino’s Data Harmonization Engine maps your data to standard models once, inside your own infrastructure. Each request then runs as a configured job, with a record of what left and when. Mapping and preparation stay inside your boundary, and only the dataset the request permits goes to the HDAB.

A large academic medical centre that mapped its data once now harmonises new target profiles in one to two days.

Rhino deployment, anonymised

Walk your first request with us
In 30 minutes, we trace your hospital's most likely first EHDS request through your own systems and show which steps you only need to do once.
Prefer the regulatory detail? Read the EHDS white paper