1 de septiembre de 2026
The paradox of a system that looks exemplary on paper
Until 2016, Ukrainian healthcare was almost entirely paper-based: many public facilities had no IT at all and internet access was irregular. Today the electronic health system —eHealth— has run on the international HL7 FHIR standard from day one, connects dozens of private medical information systems to a state central database and has accumulated, according to the system itself, more than 5 billion medical records by the end of 2025. The patient register holds over 34.6 million entries.
On paper, it is a story of rapid success. But the report we have prepared at InnoHealth Academy applies an uncomfortable lens to these figures: “registered in the system” is not the same as “the data is complete and in use”. Seen through that lens, the picture changes.
34.6 million records are not 34.6 million people
This is the single most important check in the whole report. The population on territory controlled by Ukraine is estimated at around 29 million people (±1 million), according to the Institute of Demography of the National Academy of Sciences —an estimate, not a census, because the war makes one impossible. The register therefore holds several million more records than there are people in the country.
This is not an error: the register counts everyone ever registered —people who have left, the population of the occupied territories, and the deceased until their deactivation.
The practical consequence is often overlooked: this figure cannot be used as an indicator of population coverage, nor can any other value be divided by it to obtain a “share of Ukrainians”.
“A figure published with no snapshot date, no denominator and no definition cannot be reconciled —not by a reader, and not by us.”
Registered does not mean complete
The system has control mechanisms, and they work: they cross-check data against state registers to verify the patient’s identity, deactivate the records of the deceased, and require the professional’s electronic signature on every entry. But all these controls verify one thing —that a record was created by a real person about a real person— and do not verify another: whether the record contains a real clinical history or is a copy of the previous visit.
Put differently: nobody owns the clinical quality of the data.
Ukraine’s own health Strategy acknowledges that an institution responsible for this methodology is missing… and the operational plan contains no measure to create it. It is the only gap on the list that degrades all the others: analytics, secondary use, AI and cross-border exchange all inherit whatever quality the record has.
The patient still cannot see their own data
For years, access to the electronic medical chart was held only by the doctors treating the patient directly. February 2026 brought the turning point: the first state-level personal patient account. But it is worth distinguishing “the account has launched” from “the account works”: for now it only allows managing personal data and the family-doctor declaration. The medical data in the central database is not yet accessible through it; that is planned for later stages.
The real route to one’s own history remains asking the doctor or submitting a written request. It is the starkest gap between “exists” and “works” in the whole report.
Security: the risk is at the perimeter, not the centre
The architecture of the central database is sound: personal data and medical data are stored separately, in different clusters, so that a leak from a single cluster would yield either a list of people without diagnoses, or diagnoses without names.
But the security of the centre and that of the system as a whole are different things. Data reaches the central database through each facility’s systems, and it is the facilities that are the most vulnerable point: in 2023–2024, cases of data being encrypted by ransomware in hospitals and leaks from private clinics were publicly described. In response to the rise in attacks, requirements were tightened in May 2026 (two-factor authentication, a single login per worker, device control). The sectoral cybersecurity centre meant to shield the perimeter, however, has no deadline before 2027.
Ukraine and Spain: the comparison that inverts expectations
Here lies, for us, the most useful lesson. Spain has no single medical chart in the Ukrainian sense: it has 17 regional systems plus a layer of normalised document exchange (HCDSNS). On the technical standard, the expected order holds —Spain is now adapting its reports to FHIR to meet EU requirements, whereas Ukraine was born on it.
But on everything that concerns the patient, the order reverses. In Spain, a patient has been able to read their clinical reports since 2023, hide specific reports from professionals outside their usual care team, and audit who has consulted their history. In Ukraine, in 2026, the account still contains no medical data.
And the adoption gap runs the other way on another axis: Spain has built something citizens use (more than 5.5 million report consultations) and professionals still barely do; Ukraine has built something clinicians use every day and patients cannot reach. Neither gap shows up in an architecture diagram.
The conclusion is not that one country did it “better”.
The starting points are radically different: Spain is deploying its strategy with some €893 million, largely from EU recovery funds; Ukraine, under wartime conditions and with no published financing. What the comparison does establish is that these gaps are not inherent to health data systems, nor a consequence of centralisation: they have been closed in another European country under a comparable regulatory trajectory. And that removes “not yet feasible” from the list of available explanations.
What it means for us
You can build an impressive digital infrastructure and still not have data that serves the person. That is the lesson we take home, and it directly shapes how we work at Living Lab Pirineus.
The shift from repairing to anticipating —prediction, personalised prevention, support— depends entirely on three things that technology does not guarantee on its own: that the data is complete and of good quality, that the citizen owns it and can access it, and that the data lifecycle (consent, correction, portability, retention) is designed from day one. Without that, even the most sophisticated digital twin is trained on gaps.
“Having data is not governing it. A health system that digitises without putting the person at the centre of their own data does not advance: it merely accumulates.”
💬 I invite you to reflect:
→ In your own setting, who actually owns the clinical quality of the data? Does that role exist, or is it assumed to “depend on each person’s discipline”?
→ Can your patients or users see, move and audit their own health data? If not, what stands in the way: the technology or the governance?
→ When we think about AI and personalised prevention, are we investing enough in the foundation —data quality, access and lifecycle— or only in the visible layer?
InnoHealth Academy (IHA)
