A patient becomes acutely ill in Spain. The doctor there receives a patient summary from Norway, in Spanish. It sounds like a distant future – but the bill that is intended to make it possible has a deadline for public comment in a few days.

You may have seen the headlines about Norwegians soon being able to pick up prescriptions in other European countries. Behind this news lies a bill that is bigger than it sounds, and that hits something quite concrete in your everyday life: what you write in the journal, and how it is written.

On June 8, the Ministry of Health and Care sent for consultation proposals for a new law on the European Health Data Space, along with related amendments to the Patient Card Act, the Health Personnel Act, and the Health Register Act. The deadline for submitting comments is September 28, 2026. This is not a technical detail for the IT department – it is a change in the framework surrounding the documentation work of everyone who keeps records.

What the proposal actually entails

The bill implements the EU Health Data Regulation – Regulation (EU) 2025/327, often referred to as the EHDS – into Norwegian law. The regulation establishes common rules, standards, and infrastructure for health data in Europe, and divides its use into two tracks.

Primary use deals with health care for the individual patient: that necessary information is available where the patient actually is. Secondary use It is about research, public health work, innovation and policy-making.

For those who keep records, it is the primary use that is noticed first. Minister of Health and Care Jan Christian Vestre points to the practical: if you become ill in another European country, the healthcare staff there can more easily access the necessary health information, and it can be easier to obtain prescription medication.

The proposal calls for Norway to build on solutions we already have – Helsenorge, the national electronic health record and e-prescription – rather than building something new in addition. This is good news for everyone who has experienced what parallel systems do to a working day.

Timeline: what applies when

It is easy to imagine that this is far in the future. The Directorate of Health’s own timeline shows that it is both true and not true:

  • March 2025: The regulation came into force in the EU. Formal starting point for EEA proceedings.
  • March 2027: The regulations will become applicable in the EU – and in the EEA, provided that the treatment follows the plan.
  • March 2029: The first group of prioritized information shall be available in a common European format. The group includes Patient summaries, e-prescriptions and the issuance of e-prescriptions. From this point on, it is mandatory for the journal systems to meet the requirements for these categories.
  • March 2031: The second group follows – photo studies and photo reports, laboratory results and reports, and epics.

Note the last point below March 2029: the requirements apply to the journal systems, not just the national solutions. This means that work on adapting the systems begins long before the deadlines, and that the requirements are being formulated now – in the consultation rounds.

What it means for what you write

Here comes the point that is easy to overlook in a regulatory matter: A note that should be read in a different context must be written in such a way that it can be understood by someone other than you.

It's not a new principle. We recently wrote about how your journal entry is often read in a completely different place than where you wrote it – at the emergency room at three o’clock in the morning, by a colleague who has never met the patient. EHDS only widens the gap. The next reader may be in another country, in another medical record system, with a different language of instruction.

In practice, this means three things for the documentation work:

Structure counts more. When information is to be exchanged in a common format, it must be in the correct field – not hidden in a free text in the middle of a section. Medicines, allergies, diagnoses, and procedures must be recorded as they are.

Abbreviations and local jargon are bad for communication. Internal formats that colleagues in your office understand mean nothing to a doctor in Lisbon – or to a translation service.

Completeness becomes more important. A patient summary is only as good as the information it is based on. What is not documented does not go with it.

None of these three are new requirements. They are the same basic quality requirements for recordkeeping that have always applied – but the consequences of not meeting them become more visible when the note is to cross a national border.

Where documentation support comes in

The challenge with structured documentation is not that healthcare professionals don’t know how to do it; it’s that it takes time, and that time doesn’t exist.

This is where Medivox comes into its own: the tool transcribes what is said during the consultation and creates a draft of the journal note in the template you have created yourself. If you use a template with clear sections for history, findings, assessment, and plan, you get a draft that follows that structure – without you having to spend extra minutes sorting through free text later. You read through, correct, and approve.

We have also written about why Medical AI must speak Norwegian and be treated in Norway, And that point becomes even more important with EHDS. A framework for sharing health data across borders is not the same as allowing data to be processed anywhere – the requirements for where and how information is processed apply equally.

You can actually answer the hearing

The last one is perhaps the most important, and the one that most often goes unnoticed: The hearing is open to the public and anyone can submit their answers. You don't have to be on the consultation list, and you don't have to register.

The list of respondents is worth a look anyway. There you will find the Norwegian Nurses’ Association, the Norwegian Physiotherapist Association, the Norwegian Psychological Association, the Norwegian Dental Association, the Norwegian Dental Hygienist Association, the Norwegian Midwifery Association, the Norwegian Chiropractic Association, the Norwegian Logoped Association, the Norwegian Ergotherapist Association, the Pharmacy Association, the Optician Industry, and a long list of others. In other words: your professional group has been invited, and most associations accept input from members before delivering their response.

If you have experienced what actually happens when information does not follow the patient – in a transfer, an emergency admission, a referral that lacks something essential – then that experience is relevant to this hearing. Regulations that are designed without the practitioners’ input are rarely improved by that.

The deadline is September 28th. And regardless of whether you submit a response or not: the note you write today has gained a slightly larger readership.

Frequently Asked Questions

What is the European Health Data Space?
EHDS is the EU framework for secure sharing of health data across the EU and EEA – both for individual patient care and for research and public health work. The goal is to give patients better control over their own data, and to enable healthcare professionals to access necessary information across national borders.

When will this start to apply in Norway?
The regulations are scheduled to come into effect in the EU and EEA from March 2027. The specific requirements for what information can be exchanged are introduced in stages: patient summaries and e-prescriptions from March 2029, and image studies, laboratory results and epics from March 2031.

Does this mean that my journal will be read by foreign authorities?
No. Primary use is about healthcare professionals providing healthcare to you as a patient having access to the necessary information. The rules on confidentiality, access management and privacy still apply, and the proposal is currently out for consultation to clarify how this should be regulated in Norwegian law.

Do I need to change the way I record my data?
Not overnight. But the requirements for structure, completeness, and comprehensibility become more noticeable when the note is to be read in a different context. Good templates and clear sections make the job easier – regardless of the professional group.

Can a physiotherapist or dental practitioner answer the hearing?
Yes. The consultation is open to everyone, and you can submit your answers without registering. In addition, most professional associations are on the consultation list and are happy to accept input from their members.

Use Medivox for free – Get started completely free

Are you wondering how your templates can provide more structured notes without more work? Contact us – we are happy to show you how the builder works in your practice.

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