The evolution of Swiss policy on electronic health records: between public health and privacy rights

Issue

For years, Swiss public health authorities have struggled to implement electronic health records across the country. Although initial plans envisioned this digital health infrastructure becoming fully functional by 2015, as of March 2026 only 1% of the population has opened such a record, and an even smaller proportion actively uses it. To address this issue, the Swiss government presented, in November 2025, a comprehensive reform of the legislative architecture for the electronic patient dossier. A key element of this reform is the shift to an opt-out model, whereby an electronic health record will be created for each resident unless they actively choose to opt out.

Description

The planned reform of electronic health records is set to significantly reshape both the role of public health authorities and the framework of privacy rights in this field. In particular, the Federal Office of Public Health is expected to take on a more central role in developing and steering the technical infrastructure. Moreover, records will no longer be opened based on explicit individual consent, but rather created automatically. Public health authorities will therefore be responsible for establishing the technical and governance structures necessary to enable individuals to opt out.

Results

The proposed reform of the Swiss electronic patient dossier aligns with broader public health policies aimed at strengthening digital data infrastructure. Switzerland has recently introduced similar reforms in population cancer registries and rare disease registries, shifting to opt-out systems to improve data coverage and support public health planning and epidemiological research. However, these changes remain politically contested and pose significant implementation challenges, particularly in designing opt-out mechanisms.

Lessons

The Swiss experience highlights the difficulty of balancing effective public health data infrastructure with the protection of privacy rights.

Key messages

• Opt-out electronic health records can improve population health data coverage but require strong governance and trust to succeed.

• Swiss reforms show the challenge of balancing public health data use with individual privacy rights in modern health systems.