Who Holds the Record · country brief · data as of 2026-10-01Who holds the health record in Ukraine?
In 2026, Ukraine scores 49 of 100 on a person's right to see, control and share their own health record: rank 45= of 65 countries, in the Mixed band (45 to 64). Who holds the keys: Shared. Source: Who Holds the Record, SuperTruth, data as of 2026-10-01.
Ukraine's national e-health system holds records on 34.6 million people, but patients still cannot see their own medical data in the state portal.
Published · updated · data as of 2026-10-01 · research tool, not legal advice
Can I get my health records in Ukraine?
Access to the full record scores 46 of 100 in Ukraine, against a median of 62 across 65 countries. The law gives patients a right to see their medical documents and to get their personal data within 30 days, but the national patient cabinet shows only personal data and doctor declarations. Some private apps show part of the record.
Can I control who sees my health record in Ukraine?
Control and consent scores 50 of 100 in Ukraine, against a median of 52 across 65 countries. The law says access to a patient's e-health data needs consent, and patients approve other doctors by SMS code. But signing a family doctor declaration counts as blanket consent, and no patient-visible access log was found.
Eight rights, against Ireland, Russia, Switzerland and the EU
| Patient access to the full record20% | 46 | 55 · 60 · 55 | |
|---|---|---|---|
| Patient control and consent20% | 50 | 30 · 30 · 60 | |
| Privacy and security15% | 42 | 56 · 34 · 60 | |
| Connected care journey15% | 62 | 38 · 55 · 40 | |
| Protection from commercial use10% | 40 | 58 · 40 · 58 | |
| Clinician access at the point of care10% | 58 | 36 · 45 · 38 | |
| Research and trial consent5% | 44 | 70 · 42 · 66 | |
| Clinical AI governance5% | 40 | 50 · 55 · 56 |
Black dot: Ukraine. Hollow dots: Ireland, Russia, Switzerland (scores on the right, same order). Grey line: median of all 65 countries. Dashed teal line: EU median. Overall: Ukraine 49, EU median 61. Scores move in steps of about 5; gaps of 4 or less are ties.
What would Ukraine need to change to score higher?
Ukraine sits in Mixed (45 to 64); Strong starts at 65. The two rights furthest below the 65-country median, weighted, are patient access to the full record (46, median 62) and privacy and security (42, median 55). The published rubric reads:
- Patient access to the full record: A national portal showing at least part of the record (summary, prescriptions, labs) to most residents puts access at 60 to 75; a near-full record with export, long history and majority use, 76 to 90.
- Privacy and security: Health-sector enforcement on the record: an independent regulator deciding health-data cases, breach notification and penalties applied.
Which laws give health record rights in Ukraine?
- Fundamentals of Ukrainian Health Legislation (No. 2801-XII) (1992): Right to review medical documents, medical secrecy, consent rules for e-health access (Art. 24-2).
- Law on Personal Data Protection (No. 2297-VI) (2010): Health data is special category; access within 30 days; human rights commissioner oversees.
- Law No. 4497-IX (State Register of Servicemen; amends Art. 24-2 of the Fundamentals) (2025): Lets the defence ministry receive military medical exam results from the e-health system.
Strain and split context, not scored
- Doctors per 10,000
- 35.3 2023
- Nurses and midwives per 10,000
- 60.8 2023
- Private insurance + out-of-pocket
- 46.9% 2021
- Record reaches private care?
- partial
"Інші медичні записи можуть вноситись до ЕСОЗ за рішенням закладу."
Published stories
- 2026-08-17 · Sudovo-yurydychna hazeta (sud.ua) Court voids military fitness ruling after commission could not produce examination records
- 2026-02-02 · RBC-Ukraine National health service ends contracts with clinics that falsified patients' electronic records
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