For the second year in a row, Belgium has achieved the maximum score (100%) in the European Union's eHealth Indicator Study. That sounds like a remarkable achievement, but although the country tops the list of EU member states, there is a clear caveat. According to ICT & eHealth expert Wil Rijnen of Domus Media, the study only highlights one side of the story.
In an expert analysis, Rijnen identifies several practical and structural obstacles that stand in the way of a sustainable digital transformation of healthcare. Incidentally, with a score of only 65%, the Netherlands is among the worst-performing countries in the EU study, surpassed only by Ireland (25%).
About the EU eHealth Indicator Study
The “Digital Decade 2025: eHealth Indicator Study” describes the situation on 31 December 2024, with the objective that by 2030 all EU citizens will have secure online access to their electronic patient records. The report confirms that digital access to medical records in Europe continues to grow. The EU-27 now averages 83% maturity, up 4 percentage points since 2023. All Member States offer some form of online access to records, with 16 countries taking further steps towards full coverage.
Access to basic data, such as identity and medication data, is almost universal (89–99%), but essential data such as radiology reports (26%) and implant information (55%) lag behind. eID-based authentication is gaining ground (78% of countries are EUDI-compliant) and technical coverage is above 80% in 23 countries.
A major bottleneck remains the connection of healthcare providers. Public institutions score much better than private players (79% vs. 59%), with sectors such as geriatrics, rehabilitation and mental health care being the least connected. Legal representatives can mostly gain additional access, but authorised representatives and user support lag behind, and seven Member States do not yet comply with WCAG standards.
The study emphasises that, as countries mature, the focus in the coming years must shift from technical availability to complete coverage. The goal is to achieve this for every citizen, with all data types, via secure channels and for eHealth applications by 2030. This is in line with the upcoming obligations of the European Health Data Space (EHDS), the digital framework that enforces cross-border interoperability and security.
Key findings at a glance:
- Increasing access: 16 Member States plus Iceland and Norway reported progress; all Member States now offer an access service.
- Data types: Strong availability of identification (99%), basic data (98%), e-prescription (89%) and dispensing history (87%). Medical imaging (26%) and implant information (55%) lag behind.
- Authentication & coverage: 21 countries (78%) use an eID system that complies with EUDI regulations; 23 countries (85%) have a technical reach of 80–100% of the population.
- Care providers: Public healthcare institutions have better connectivity (79%) than private ones (59%), with geriatricians and rehabilitation centres being the weakest links.

European ambitions for digital healthcare
The recognition for Belgium fits within the broader objectives of the Digital Decade Policy Programme (DDPP), the EU's strategic programme shaping Europe's digital transformation. One of the key priorities is to give all EU citizens access to their electronic health data. This goes hand in hand with high requirements in terms of data quality, interoperability, security and reuse, both for direct care and for research, innovation and policy.
To make this possible, numerous initiatives have been developed in the field of regulation and technical standards, from GDPR to the recently approved European Health Data Space (EHDS). The eHealth Indicator Study, published annually, monitors progress and assesses whether countries are technically ready to give citizens access to thirteen types of health data, including medication data, allergies and test results.
Belgian practice lags despite 100% score
According to Rijnen, Belgium's maximum score is due to its robust technical infrastructure. Thanks to systems such as regional primary care vaults, hospital hubs, Recip-e and Vaccinnet, health data is stored centrally and secured via the federal eHealth platform. Portals such as MijnGezondheid provide access to citizens.
However, this score mainly reflects the technical availability of data. In practice, healthcare providers and citizens encounter significant shortcomings. For example, the quality of Sumehrs, which contain problem lists and medication data, among other things, often leaves much to be desired. The functioning of eHealth functionalities such as medication schedules and BELRAI remains suboptimal due to poor interoperability and fragmented policy management.
Another structural problem is the exchange of data with residential care centres in Belgium, which is not considered in the score. Because the general practitioner formally remains the owner of the medical file, the lack of integration with residential care centre systems is not considered, even though this is a major bottleneck in practice.
In addition, the landscape of diverse patient portals in Belgium causes confusion among citizens. Not every portal provides access to all types of data, and user-friendliness varies. There is a lack of uniformity in terminology, which hinders participation and self-care.
Towards integrated care
The eHealth score shows that Belgium has a solid digital foundation, but if the country wants to maintain its lead, the next step is crucial: the transition from fragmented data to an integrated, dynamic care record.
In this context, there has been talk for some time about the Belgian Integrated Health Record (BIHR): a virtual record that allows healthcare providers and citizens to collaborate on health information, based on international standards such as FHIR and SNOMED-CT. However, this project is currently stuck in the conceptual phase. The necessary implementation is proving difficult, partly due to the complex Belgian policy structure.
At the same time, the recently approved EHDS Regulation is forcing all Member States to act. By 2029, summaries of patient records, medication data and dispensing histories must be available, with an extension to medical imaging and test results in 2031. The EHDS aims not only at national interoperability, but also at cross-border use of health data within the EU. This offers opportunities for economies of scale and quality gains but requires clear action plans at the national level.
From roadmap to reality
To realise the ambitions of BIHR and EHDS, more than technology alone is needed. Domus Medica and other stakeholders have been advocating for structural eHealth programme management for years. This should not only guide technical development, but also focus on change management, practical implementation and support for healthcare providers.
A joint approach, supported by federal and regional authorities, the RIZIV and the eHealth platform, is essential. The existing high-level roadmap for 2025-2027 must be translated into a concrete, feasible plan with clear timing and responsibilities. Only then, according to Rijnen, can Belgium make the leap from a solid score on paper to a future-proof digital healthcare system that really works for both patients and healthcare providers.