Article 27

Relation to Union law governing medical devices, in vitro diagnostic medical devices and AI systems

In short: Medical devices, in vitro diagnostic medical devices and AI systems that claim interoperability with the interoperability component of EHR systems shall themselves prove compliance with with the EHR system requirements.

1. Manufacturers of medical devices or in vitro diagnostic medical devices, as defined in Article 2, point (1), of Regulation (EU) 2017/745 and Article 2, point (2), of Regulation (EU) 2017/746, respectively, that claim interoperability of those medical devices or in vitro diagnostic medical devices with the harmonised software components of EHR systems shall prove compliance with the essential requirements on the European interoperability software component for EHR systems and the European logging software component for EHR systems, laid down in Section 2 of Annex II to this Regulation. Article 36 of this Regulation shall apply to those medical devices and in vitro diagnostic medical devices.
2. Providers of AI systems considered to be high-risk in accordance with Article 6 of Regulation (EU) 2024/1689 (the 'high-risk AI system') and which do not fall within the scope of Regulation (EU) 2017/745 or Regulation (EU) 2017/746, that claim interoperability of those high-risk AI systems with the harmonised software components of EHR systems, shall prove compliance with the essential requirements on the European interoperability software component for EHR systems and the European logging software component for EHR systems, as laid down in Section 2 of Annex II to this Regulation. Article 36 of this Regulation shall apply to those high-risk AI systems.

Discussion

The EC has informally clarified (Dec.2025), and will note so in an upcoming EHDS FAQ, that the wording "in Section 2 of" in the 2 clauses above is erroneous. All of Annex II has to be supported.

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