Executive Summary

In February 2026, the Federal Ministry of Health (BMG) released the "Further Development of the Digitalization Strategy," setting a definitive roadmap for the next four years. Moving beyond basic infrastructure like the Telematics Infrastructure (TI), the strategy declares a new era of "utilization-oriented technologies".

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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".
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This is not merely a suggestion; it is a strategic objective embedded in the BMG’s "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 key drivers for this aggressive push toward AI:

• Relief from Administration: The strategy highlights that AI can automate documentation and administrative processes to a certain degree, freeing up time for direct patient care.‍
• Structuring the Unstructured: A major hurdle in the current system is that data is often unstructured. The strategy notes that AI applications can specifically support the processing of unstructured data (e.g., spoken doctor-patient conversations) into structured formats.‍
• Interoperability: To make data usable for the electronic patient record (ePA) and research (FDZ), it must be interoperable. AI is viewed as the bridge to convert clinical input into these interoperable 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 regarding 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: The strategy aims for clinical data profiles (e.g., for diabetes or heart failure) to 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).‍

Recommendation: Medical practices should begin implementing AI scribing solutions now to align with the "Digital by Default" trajectory of the German healthcare system.