WHITE PAPER — The 2028 Standard
Why AI documentation is no longer optional in German healthcare.
- Source: Bundesministerium für Gesundheit (BMG)
- Publication: Weiterentwicklung der Digitalisierungsstrategie
- Date: February 2026
- Mandate: 70% AI adoption by 2028
- Target: all healthcare and nursing facilities
Executive summary
In February 2026, the Federal Ministry of Health (BMG) released the Weiterentwicklung der Digitalisierungsstrategie — a definitive roadmap for the next four years. Moving beyond baseline infrastructure like the Telematics Infrastructure (TI), the strategy declares a new era of "utilization-oriented technologies".
The most critical takeaway for medical practices is a specific, quantifiable goal. Practices that cling to manual typing face the risk of falling behind in "digital maturity" — a metric the Ministry explicitly expects to increase by 35% across hospitals and facilities starting now.
| Metric | Target |
|---|---|
| AI documentation adoption (facilities) | 70% by 2028 |
| Digital-maturity increase (hospitals) | +35% |
| ePA active users | 20M+ by 2030 |
| Strategy publication | Feb 2026 |
Source: BMG, Weiterentwicklung der Digitalisierungsstrategie (Feb 2026).
1. The core mandate: 70% adoption by 2028
The era of manual data entry is officially ending. The strategy explicitly states:
"AI-supported documentation is to become the standard in healthcare and nursing care; more than 70 percent of facilities are expected to use this actively by 2028."
This is not a suggestion — it is a strategic objective embedded in "Action Field 2" (Data Generation) and "Action Field 3" (Technologies). The goal is to move away from isolated data silos and unstructured notes toward structured, high-quality data that improves care quality and research capabilities.
2. Why the shift? The strategic drivers
The Ministry identifies several drivers for this aggressive push toward AI:
- Administrative relief. The strategy highlights that AI can automate documentation and administrative processes, freeing up time for direct patient care.
- Structuring the unstructured. A major hurdle in the current system is that data is often unstructured. AI applications can specifically help transform unstructured data (e.g. spoken doctor–patient conversations) into structured formats.
- Interoperability. To make data usable for the electronic patient record (ePA) and the research data center (FDZ), it must be interoperable. AI is the bridge that converts clinical input into these standards.
3. Legal certainty and "blueprints"
A common hesitation for practices has been legal uncertainty regarding AI. The 2026 strategy addresses this directly with short-term measures starting immediately:
- Legal clarity. Providers will receive legal certainty about which AI applications they can use and for what purposes.
- Conformity blueprints. By the end of 2028, the government will provide blueprints for the creation of conformity-assessment documents for AI applications in healthcare.
- AI real-world labs (Reallabore). The Ministry is establishing testing environments to provide regulatory advice on the development and use of AI, ensuring data-privacy compliance.
4. The role of the ePA (electronic patient record)
The AI documentation push is inextricably linked to the ePA. The strategy targets that more than 20 million insured persons will actively use the ePA by 2030.
- Standardization. Clinical data profiles (e.g. for diabetes or heart failure) will be defined so that AI can generate care instructions based on structured data points.
- Data flow. The vision is for structured data to flow from the point of care (the doctor's voice / AI) into the ePA and subsequently into research databases (FDZ).
Conclusion — action required
The publication of the 2026 strategy signals that AI documentation is transitioning from an "early adopter" advantage to a regulatory expectation. With the clear target that 70% of facilities must actively use AI documentation by 2028, practices that cling to manual typing face the risk of falling behind in "digital maturity" — a metric the Ministry expects to increase by 35% across hospitals and facilities.
Sources
- Weiterentwicklung der Digitalisierungsstrategie für das Gesundheitswesen und die Pflege — Bundesministerium für Gesundheit (BMG) (2026)