Hospitals Lag: Only 40% Pilot Digital Records-Fines Start Soon
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75 million electronic patient records (ePA) have been created. Yet fewer than 4 % of insured individuals use them actively. In hospitals, only one in four institutions has even begun its pilot phase. At the same time, starting in 2026, digitalization discounts of up to 2 % per billed case will be applied. The ePA is the largest digitalization project in Germany’s healthcare system—and it’s stalled.
Key Takeaways
- 75 million ePAs created, fewer than 4 % used: Opt-out rates are just 5 %, yet almost no one opens their electronic record (borncity, AOK, KZV BW, 2026).
- 40 % of hospitals in pilot phase: This sounds like progress—back in September 2025 it was only 7 %. Still, 43 % don’t expect full hospital-wide rollout before Q3 2026 (DKI Quick Survey, March 2026).
- Up to 2 % discount per case: Five mandatory digital services must be contracted; otherwise, digitalization discounts apply to every inpatient case (§5 para. 3h KHEntgG).
- Germany ranks 16th of 17: In the Bertelsmann Foundation’s Digital Health Index, Germany sits just ahead of Poland. Estonia and Denmark show how it’s done.
- €7 billion savings potential: McKinsey estimates duplicated diagnostics and communication breakdowns could be cut—if the ePA were actually used. So far, almost nothing has changed.
75 million electronic patient records, 4 % of users: ePA by the numbers
Since nationwide rollout in April 2025, every mandatory insured person in Germany automatically receives an electronic patient record (ePA) unless they have explicitly opted out. The opt-out model is working: only about 5 % of insured persons have filed an objection; among AOK it’s 4.3 %, Techniker Krankenkasse 7 %, and KKH even 10 %.
The bottleneck isn’t the creation of records but their actual use. Recent data show that only between 4.2 and 4.6 million insured persons have activated a health ID (Gesundheits-ID)—roughly 6 % of public-sector policyholders (GKV). Active usage is even lower: an estimated 3.6 % access their ePA on a regular basis.
For hospitals and primary-care physicians this means the infrastructure exists on paper, yet in daily practice it rarely reaches the bedside. Today, when a patient is admitted, most encounters still rely on the familiar mix of paper forms, faxed reports and phone calls.
The federal government has earmarked €4 300 million under the Hospital Future Act (KHZG) precisely to change this. McKinsey estimates the ePA’s annual savings potential at €7 000 million—fewer duplicate tests, faster data exchange and more efficient communication between GPs, hospitals and specialists. Of the total digitalisation potential in the healthcare sector, valued at €42 000 million per year, only a fraction has been realised so far: €1 400 million (McKinsey eHealth Monitor, 2025).
Why hospital roll-outs stall: SIS updates, staffing and process hurdles
The DKI quick poll of March 2026, which drew responses from 489 hospitals, paints a nuanced picture. Ninety per cent of respondents have already started technical implementation. Forty per cent are already running pilot phases within their care processes—a notable leap from the seven per cent recorded in September 2025.
Yet eighteen per cent of hospitals are still waiting more than five months after the mandatory deadline for the required update to their hospital information system (SIS). Forty-three per cent do not expect nationwide hospital deployment of the electronic patient record (ePA) before the third quarter of 2026. The bottleneck is not merely technical—it is the underlying processes.
«Rolling out the ePA in hospitals is a genuine transformation project that demands numerous procedural and organisational adjustments. Hospitals cannot simply flip a switch and make it work».
—Prof. Dr Henriette Neumeyer, Vice-President of the DKG Board (DKG press release, March 2026)
Organisational obstacles weigh heavier than technical ones. The ePA must be woven into existing admission workflows, access rights defined, data-protection concepts adapted and medical staff trained. All of this takes time and staff capacity—two resources already in short supply across German hospitals.
Technical setbacks are further eroding confidence. In February 2026, a smoke-detector alarm in a Frankfurt data centre shut down the entire telematic infrastructure for eight hours—ePA, the electronic prescription (E-Rezept), the secure email service for healthcare professionals (KIM) and the discharge-summary document (VSDM) were all inaccessible. Also in February, a software glitch triggered the erroneous suspension and emptying of 6 400 ePAs at AOK Bavaria. In both cases no data were lost, yet the incidents confirmed the sceptics’ doubts.
One underestimated problem remains: the replacement of legacy TI connectors. Roughly 7 900 TI connectors using obsolete RSA encryption must be replaced before the end of 2026, because certificate renewal is technically impossible. At the same time, the transition to new eHBA cards ends on 30 June 2026. For hospitals that have not yet received their SIS update, the backlog is piling up.
Digitalization discount: what will it actually cost hospitals from 2026 onwards?
Definition
Digitalization discount refers to a percentage deduction applied to each fully or partially hospital-billed case when a hospital fails to contract or implement certain mandatory digital services in a timely manner. The legal basis is §5 paragraph 3h KHEntgG.
From 1 January 2026, discounts will apply to five mandatory digital services. If a hospital cannot demonstrate, by 31 December 2025, that at least these services have been contracted, it will incur a surcharge on every billed case:
| Mandatory service | Discount |
|---|---|
| Patient portals | 0.5 % |
| Digital documentation of care and treatment | 0.6 % |
| Clinical decision-support systems | 0.2 % |
| Digital medication management | 0.4 % |
| Digital benefit applications | 0.3 % |
| Total maximum discount | 2.0 % |
For a mid-sized hospital with 15 000 inpatient cases annually and an average case revenue of €5 000, the maximum 2 % discount equates to an annual loss of €1.5 million. These are not theoretical figures—this is the amount hospitals forfeit when they fail to contract the five mandatory services on time.
The pressure is rising: from late 2027, at least 60 % of hospital cases must be documented digitally; from late 2028, this threshold climbs to 70 %. Hospitals that can show they have contracted the services—but fail to meet minimum usage rates—will face penalties once again.
Estonia, Denmark, Germany: A Daunting Comparison
In the Bertelsmann Foundation’s Digital Health Index, which compares 17 OECD countries, Germany ranks 16th. Only Poland fares worse. Estonia and Denmark have led the way for more than a decade, showing how digital healthcare should work.
In Estonia, 99 % of the population has an electronic health record, and 100 % of doctors, hospitals, and pharmacies are connected to the national ENHIS system. The backbone is the X-Road infrastructure, which since 2002 has interoperably linked all public and private IT systems in the country.
Denmark achieves almost 100 % for electronic prescriptions and a usage rate of more than one-third of the population on its sundhed.dk health portal—with 1.7 million monthly logins. Family doctors and pharmacies are 100 % connected, while specialists reach 98 %.
What both countries share is centralized political leadership with binding targets, clear interoperability standards from the outset, and tangible benefits for citizens. The Bertelsmann Foundation identifies five key success factors: strong governance, centralized direction versus a federal patchwork, clear interoperability rules, a positive error culture, and visible added value for citizens.
Germany, by contrast, has 130 health insurance funds with different apps, a worn-out Gematik caught between ministerial direction and industry coordination, and 16 federal states with their own digitalization strategies. The result: not even the ambitious KHZG funding program has overcome this structural fragmentation. PwC estimates hospitals must shoulder roughly 16 % of digitalization costs and up to 50–100 % of recurring operating expenses (PwC, November 2023).
What IT Leaders Should Do Next
The situation is unsatisfactory, but not hopeless. Those who set the right priorities now can avoid penalties and, at the same time, lay the groundwork for genuine hospital digitalization.
1. Clarify and escalate the status of SIS updates. 18 % of hospitals are still waiting for theirs. If the SIS vendor fails to deliver, document this in writing—also as evidence to cost managers that the delay is not the hospital’s fault.
2. Define and launch a pilot unit. The jump from 7 % to 40 % in the pilot phase proves: whoever starts, moves forward. One unit is enough to begin. What matters is not just having the technology, but integrating the ePA into doctors’ and nurses’ workflows.
3. Secure procurement approvals for the five mandatory services. Penalties apply for lack of procurement—not for lack of implementation. A signed contract or project order can avert the penalty even if rollout is still underway.
4. Implement a training plan. The DKI survey clearly shows the bottleneck is not technology, but organization. Training for doctors, nurses, and administrative staff must run in parallel with technical rollout—not afterward.
5. Look ahead. The ePA is not an isolated IT project. It is the foundation for the European Health Data Space (EHDS), which from 2029 will enable cross-border patient data exchange. Those who build this foundation now will position their hospital for the next stage of interconnection. Those who wait will have to catch up within three years under even tighter time pressure.
Frequently Asked Questions
What is the opt-out rate for the ePA?
On average, approximately 5 % of mandatory insured individuals have filed an objection against the ePA. The rate varies by health insurance fund: 4.3 % for AOK, 7 % for Techniker Krankenkasse, and 10 % for KKH. Since its launch in April 2025, objection figures have plateaued.
What happens if a hospital fails to avoid the digitalization discount?
The discount applies to each fully or partially hospital-billed case and can reach up to 2 % of case revenue. For a hospital with 15,000 cases annually and an average revenue of €5,000 per case, this amounts to up to €1.5 million per year. From late 2027, minimum usage rates of 60 % will also be audited.
How does Germany rank in international comparison of electronic health records?
In the Bertelsmann Foundation’s Digital Health Index, Germany ranks 16th out of 17 OECD countries analyzed. Estonia (1st place) boasts 99 % coverage and 100 % physician connectivity for over a decade. Denmark achieves nearly 100 % for e-prescriptions, with 1.7 million monthly users of its national health portal.
What is the savings potential of the ePA?
According to the McKinsey eHealth Monitor 2025, the ePA alone could save around €7 billion—thanks to fewer duplicate diagnostic tests, more efficient provider communication, and faster patient data access. McKinsey estimates the total digitalization potential of the healthcare system at €42 billion annually.
Is the ePA secure?
At the end of 2024, the Chaos Computer Club identified theoretical possibilities for unauthorized access to third-party medical records; Gematik closed this gap before national rollout. In February 2026, two incidents occurred: an eight-hour outage of the telematics infrastructure (TI) due to a data-center failure and a data incident at AOK Bavaria, where 6,400 medical records were mistakenly blocked. No data was lost in either case, but the incidents highlight that the infrastructure is still maturing.
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