Jinish Rajan — healthcare technology consultant, from inside the health service

Most summaries of EHDS explain what the regulation says. The useful question is what it costs, and the answer is usually not in the software budget. Three consequences do most of the damage, and none of them is a licensing line item.

Structured is not the same as digital. A great deal of Irish healthcare data is already electronic and still fails the test, because a scanned letter, a PDF in a portal and a free-text field are all digital without being machine-readable. The obligation is to exchange data a receiving system can parse and act on: discrete fields, a stated format, coded terminology. The gap between "we have it in the system" and "we can emit it as a structured resource" is where most of the real work sits, and it is nearly always larger than it looks in a steering-group slide.

The obligation lands in two different places. Some of it falls on the systems — the manufacturers of the record software you buy, who face requirements about what their products can export and how. Some of it falls on you as a provider, in what you actually make available and to whom. That split matters commercially, because a supplier can be entirely compliant at the product level while your organisation is not, and the contract signed three years ago probably does not say which of you carries the cost of closing the difference. Read it before the deadline is near rather than after.

Secondary use is a governance design, not a pipeline. Making data available for research, innovation and policy under controlled access is a separate regime from day-to-day care, with its own permissions, its own gatekeeping and its own audit expectations. Organisations that treat it as a reporting problem — an extract, a spreadsheet, a data-sharing agreement drafted after the fact — build something they later have to take apart. It is far cheaper to answer the governance question before the pipeline exists than to retrofit it around one.

Put together, the practical readiness question is not "are we EHDS compliant". Nobody can answer that yet, and anybody who says otherwise is selling something. It is narrower and answerable today: for each clinical system we run, can we get our own data out of it, in a structured and coded form, without the supplier's permission and without paying for the privilege? Every organisation can start working that out this quarter, and the answer shapes almost everything that follows.