Overview

• Doctors, pharmacists and hospitals must begin uploading treatment data to insurer-created records on Oct. 1, with sanctions for non‑use starting in 2026, including fee cuts for outpatient doctors from January and for hospitals from March.
• Insurers have auto‑created records for roughly 70–74 million people, yet active use remains limited, with 1.37 million self‑activations at TK, AOK and Barmer combined and 800,000 active users at TK; opt‑out rates reported at about 4–6 percent.
• Technical readiness is uneven: Gematik projects over 90 percent of practices can start, KBV earlier warned about one fifth not ready, and Thüringen reports 96 percent module coverage; only 9 percent of clinics are prepared by Oct. 1, rising to 42 percent by year‑end.
• Providers can populate records even if patients have not registered, with 90‑day access granted via health card; patients need eID or eGK PIN to manage permissions, and special rules limit entries for those under 15 or where child welfare could be at risk.
• Security holes flagged by the Chaos Computer Club were addressed, according to the Federal Data Protection Officer, though fine‑grained access controls and the handling of billing data remain contested and many practices still report workflow and software issues.