TABLE 2.

Implementing access to electronic personal health data.

Implementation model	Advantages	Implications	Stakeholders impacted
Option 1: Decentralized. Local EHR portals implement EEHRxF directly. Each healthcare provider (e.g., hospital, clinic) ensures that their EHR system includes the interoperability and logging components required by Article 25. Patients access their health data and exercise their EHDS rights directly through provider-level portals.	Gives patients direct access to the point of care and encourages wider, system-level integration. It also allows for local flexibility and innovation.	This places a high burden on individual providers, particularly in less digitally mature settings, and may lead to uneven implementation across regions, confusion for European citizens and lack of interoperability. Regular testing and certification are necessary.	Healthcare providers, patients, EHR system vendors, regulatory authorities
Option 2: Centralized. Member States provide a single platform. The national or regional health authority implements a central portal that interfaces with local EHR systems. Patients access, download, and share their EEHRxF-compliant data through this centralized service.	Easier to manage in countries with fragmented systems or fewer digital resources. Creates a more consistent national experience for patients.	Can slow down adoption at the provider level to fit the one-size-fits-all approach and risks creating dependence on national timelines and infrastructure. Natural persons may have access to a limited part of their health data.	National health authorities, patients, healthcare providers
Option 3: Hybrid approach. Mixed model depending on context. Combines centralized national services with decentralized provider-level implementations. Suitable for countries with regionalized healthcare systems or varying provider readiness.	Offers flexibility and stepwise implementation while allowing countries to scale gradually based on local readiness. A good balance between control and customization.	Needs strong coordination to ensure consistency. Without it, patient experience and technical standards may vary widely. Regular testing and certification are necessary.	National and regional health authorities, healthcare providers, patients