Czech healthcare 2026
The year 2026 does not represent just another set of partial amendments for the Czech healthcare sector. We stand on the threshold of a fundamental transformation that will fundamentally change the way you provide care, manage finances, and protect data. This article is not a mere list of sections; it is a strategic guide for the management of healthcare facilities, providing specific answers on how to prepare for the legislative updates in Czech healthcare for 2026.

Do you need advice on this topic? Contact our Prague-based law firm ARROWS at office@arws.cz or by phone at +420 245 007 740. Your inquiry will be handled by "Mgr. MUDr. Veronika Králíková", our expert on Czech medical law.
Article Content
- Digital transformation is a mandate, not a choice: What does the Act on the Digitalization of Healthcare bring?
- Cybersecurity under NIS2: Is company management facing personal liability?
- Our specialists:
- Expanded preventive check-ups: How to adjust documentation and reporting?
- Artificial Intelligence (AI) as a medical device: Who bears responsibility for algorithm errors?
Digital transformation is a mandate, not a choice: What does the Act on the Digitalization of Healthcare bring?
The era of gradual and voluntary digital innovation is definitively ending. From January 1, 2026, an amendment to Act No. 325/2021 Coll., on the Digitalization of Healthcare, enters into full nationwide effect in the Czech Republic. This step marks the end of fragmented and individual IT solutions. It introduces centrally defined rules, standards, and security protocols to which all healthcare service providers must adapt without exception.
This change is not just a technological modernization, but primarily a new legal framework that brings new obligations and high risks in case of non-compliance. Preparing for this digital mandate is crucial for management to ensure smooth operations and legal protection of facilities after 2026. If you need to analyze the impact of these changes on your organization, our Prague-based attorneys are ready to assist you – write to office@arws.cz.
From eVouchers to eRequests: What new processes must you implement?
The amendment to Czech law introduces several key digital tools that will become a daily part of your practice. Their implementation requires not only technical readiness but also the adjustment of internal processes and staff training.
- eVoucher (ePoukaz): From January 1, 2026, it will be mandatory to issue vouchers for medical devices (glasses, wheelchairs, incontinence aids, etc.) exclusively electronically. The paper form is ending, except for legal exceptions. This means your facility must ensure functional access to the eRecept system and apply for access credentials for all relevant staff in time, including non-medical professions such as opticians or dispensary workers.
- eRequest (eŽádanka): Paper requests for laboratory, imaging, or specialized examinations will be replaced by an electronic system. The doctor issues an eRequest, the patient receives a unique identifier, and the target facility downloads the request electronically. Even if a patient may request a paper version, the primary process must be digital.
- Shared Health Record: This is one of the most fundamental elements of the entire reform. This central record will be divided into two parts: emergency record (vital data such as blood type, allergies, key medication) and a record of preventive and screening examination results. Your facility will be obliged to contribute to this system and simultaneously draw information from it, which fundamentally changes the rules for sharing medical documentation in the Czech Republic.
Cybersecurity under NIS2: Is company management facing personal liability?
In parallel with digitalization, the new European NIS2 directive is coming into force, implemented into the new Czech Cybersecurity Act. This dramatically expands the range of regulated entities in the healthcare sector and significantly tightens requirements for the protection of networks and information systems. It is no longer just about the IT department – NIS2 introduces direct and personal liability for statutory bodies and top management for ensuring cybersecurity.
New obligations include conducting regular risk analyses, implementing robust security measures, mandatory incident reporting, and, above all, securing the entire supply chain. This means you will have to legally and technically verify the security standards of your IT system and medical device suppliers. The attorneys at ARROWS specialize in preparing supply contracts and internal directives that reflect NIS2 requirements. For an immediate solution to your situation, write to us at office@arws.cz.
Sanctions for non-compliance are unprecedented. Fines of up to EUR 10 million or 2% of total global annual turnover are possible, and in extreme cases, a ban on exercising functions for responsible management members. Management thus finds itself under double pressure: they must invest significant resources into technology and processes, while simultaneously being personally liable for their functionality.
FAQ – Legal tips for protecting healthcare data
1. Do we need to hire a new cybersecurity manager because of NIS2?
Not necessarily, but you must clearly designate a person with this responsibility and ensure their training. To assess your situation and set up the correct organizational structure, contact our Czech legal team at office@arws.cz.
2. What is the first step to ensure compliance with NIS2?
The first step is conducting a risk analysis and an audit of existing measures. Our Prague-based attorneys and cooperating experts will help you identify key assets and design an action plan. Get in touch with us at office@arws.cz.
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Risks and Sanctions |
How ARROWS assists |
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Fines up to EUR 10 million (or 2% of turnover) and personal liability of management for non-compliance with NIS2 requirements under Czech law. |
Preparation of complete documentation and internal policies for NIS2 compliance – do you need to protect your company's management? Contact our Prague-based attorneys at office@arws.cz. |
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Financial penalties for GDPR violations during data sharing within new eHealth systems in the Czech Republic (e.g., Shared Health Record). |
Legal audit (DPIA) and process review for data handling to comply with both GDPR and the Czech Act on Electronic Healthcare. Want to be certain? Contact our Czech legal team at office@arws.cz. |
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Operational collapse and reputational damage resulting from a cyberattack (average data breach costs in healthcare are USD 7.42 million). |
Professional training for employees and management focused on cybersecurity and legal obligations under Czech legislation. To immediately strengthen your defense, write to us at office@arws.cz. |
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Contractual disputes with IT system or medical device suppliers who fail to meet new security standards required in the Czech Republic. |
Preparation and review of supplier contracts with emphasis on cybersecurity guarantees and liability under the Czech Civil Code. Secure your supply chain – write to office@arws.cz. |
Financial Shocks in 2026: How to Prepare for the New Reimbursement Decree and Care Reorganization in the Czech Republic?
In addition to the technological revolution, healthcare facilities in the Czech Republic face a fundamental reset of financial flows in 2026. The draft of the new Reimbursement Decree and the reorganization of emergency care present serious strategic challenges for management that could directly threaten the economic stability and operational capabilities of your organization.
"Liquidating" Reimbursement Decree: What are the real threats to your budget?
Professional unions and hospital associations describe the draft Reimbursement Decree for 2026 as "liquidating". The reason lies in planned changes intended to save the Czech healthcare system approximately CZK 2 billion, but at the expense of providers. For management, it is crucial to understand the specific impacts of these changes and proactively prepare for them.
Among the riskiest measures is the reduction of the CZ-DRG base rate, which means less funding for standard hospitalizations. A major threat is also the financial pressure on short-term hospitalizations, where some procedures will only be reimbursed as day surgery, regardless of the patient's actual health condition. This could have a fatal impact on the financing of care for polymorbid and chronic patients requiring longer post-operative care.
Furthermore, the introduction of price competitions, for example in orthopedics, brings the risk that price, rather than quality of care, will become the main criterion for reimbursement. These changes come at a time when many facilities are still dealing with insufficient cost coverage from previous years. ARROWS provides legal impact analyses of the Reimbursement Decree and represents clients in negotiations with Czech health insurance companies. Do you need legal assistance? Contact our Prague-based law firm at office@arws.cz.
Our Specialists:
Reorganization of Emergency Services and New Contracts with Insurance Companies: What to Watch Out For?
From January 1, 2026, a fundamental systemic change will occur in the Czech Republic: the responsibility for ensuring the network and availability of emergency services will transfer from the regions directly to the health insurance companies. For providers, especially hospitals with emergency departments and pediatric wards, this means the necessity to negotiate entirely new contractual relationships and define the scope of services provided.
Emergency care will now be divided into four segments (adult, pediatric, dental, and pharmaceutical) and financed through a flat-rate-performance reimbursement model. Precise parameters will be set by the Reimbursement Decree, but the key will be the contractual terms you negotiate with the insurance companies. A passive approach and acceptance of standard proposals may lead to disadvantageous settings and insufficient cost coverage.
In this new situation, legal support becomes a strategic tool for defending financial stability. It is no longer just about a formal review of contracts, but about active negotiation, preparation for administrative proceedings, and protection of your economic interests. Our attorneys in Prague are ready to represent you in these key negotiations. Connect with us at office@arws.cz to obtain a tailored legal solution.
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Risks and Sanctions |
How ARROWS Assists |
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Significant drop in income due to reduced reimbursements for hospitalizations and the introduction of price competitions. |
Legal analysis of Reimbursement Decree impacts and preparation of materials for negotiations with Czech health insurance companies. Want to know your legal options? Write to office@arws.cz. |
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Disadvantageous contractual terms with insurance companies for providing emergency services, leading to uncovered costs. |
Representation during contract negotiations with health insurance companies and review of contractual amendments. Need to negotiate better terms? Contact our Czech legal team at office@arws.cz. |
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Sanctions for incorrect care reporting under new, more complex rules for reimbursements and preventive programs in the Czech Republic. |
Legal opinions and professional training for management and care reporting departments. Gain certainty in reporting – write to office@arws.cz. |
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Risk of reimbursement denial for care provided beyond the scope of one-day surgery for high-risk patients under Czech health insurance regulations. |
Representation in administrative proceedings with health insurance companies in disputes over reimbursement for care provided in the Czech Republic. Do you need representation? Contact our Czech legal team at office@arws.cz. |
A new era of patient rights and provider obligations in the Czech Republic
Legislative changes for 2026 do not only concern technology and finance but also affect the very core of the doctor-patient relationship under Czech law. New obligations in the field of prevention and payment transparency require the adjustment of daily processes, precise documentation, and increase the legal risks associated with the human factor.
Expanded preventive check-ups: How to adjust documentation and reporting?
The amendment to the Decree on Preventive Check-ups (No. 70/2012 Coll.) will significantly expand their scope starting January 1, 2026. Physicians in the Czech Republic will now perform ECG examinations from the age of 30, take blood for cholesterol tests more frequently, and regular liver and kidney tests as well as heart failure risk screening are being introduced. Emphasis is also placed on mental health in family history and the creation of an individual treatment-preventive plan for every patient.
For healthcare providers, this results in a fundamental task: adjusting internal procedures and medical documentation systems so that all these new procedures are properly recorded and reported to Czech health insurers. Particularly important is the new active obligation of the physician to verify the patient's participation in oncological screening programs (mammography, colonoscopy, etc.). If the patient refuses the examination, the physician must demonstrably advise them of the risks and carefully record this advice.
This change increases the administrative burden but, above all, creates a new field for potential disputes. Insufficient documentation can lead not only to problems with insurance reimbursement but, in extreme cases, to liability disputes in Czech courts. Our Prague-based attorneys can help you prepare internal guidelines and template forms to ensure legal certainty. Do not hesitate to contact our office – office@arws.cz.
Ban on hidden fees and mandatory price lists: How to avoid million-koruna fines?
Another significant change is the amendment to the Czech Act on Healthcare Services, which from 2026 explicitly prohibits the collection of any fees for services fully covered by public health insurance. This also applies to previously tolerated practices such as registration fees, fees for booking a specific time, or sponsorship donations conditional on acceptance into care.
At the same time, the law introduces an obligation to have a visibly published, transparent, and binding price list for all premium and non-covered services. If the patient is not informed of the price in advance and does not agree to it, the provider has no legal right to demand payment under Czech legislation. Sanctions for violating these rules are strict: unauthorized fees can result in a fine of up to CZK 1 million, and formal errors in the price list up to CZK 50,000.
Successfully managing these changes lies not only in the technical setup of systems but primarily in working with people. The human factor – overworked and insufficiently trained staff – is the most common source of errors that can lead to high sanctions. Therefore, it is essential to invest in quality internal regulations and certified training to minimize the risk of error.
FAQ – Legal tips for communicating with patients in the Czech Republic
1. How to correctly document that a patient refused a recommended screening?
It is necessary to make a demonstrable record in the medical documentation, ideally with the patient's signature, stating that they were advised of the risks. Our Czech legal team can prepare template forms and internal guidelines for this process. Write to us at office@arws.cz.
2. Can we charge a fee for the use of disposable material not covered by the insurance company?
Yes, but only if this item is clearly and understandably listed in your publicly accessible price list and the patient is informed of the price in advance. For a review of your price list, do not hesitate to contact our Prague-based attorneys at office@arws.cz.
International impact: European Health Data Space (EHDS) and AI in healthcare
The legislative changes of 2026 do not only have a local impact. They are part of a broader European trend towards creating a single digital market in healthcare. For the management of Czech facilities, it is crucial to understand the two main pillars of this transformation: the European Health Data Space (EHDS) and the regulation of Artificial Intelligence (AI). The EHDS is at the beginning of its journey, and by 2027, the Commission must adopt important implementing acts so that the EHDS and its key parts can fully enter into force in 2029.
Data sharing within the EU: What does the European Health Data Space (EHDS) bring?
The EHDS is an ambitious European Union project aimed at creating a single space for the secure sharing of health data. It has two main levels: primary use, intended to facilitate the provision of healthcare to EU citizens across borders, and secondary use, intended to open anonymized and pseudonymized data for the purposes of science, research, innovation, and healthcare policy-making.
For Czech hospitals and clinics, this means they are becoming "data holders" with a new obligation. They will have to provide access to data upon request and under strictly defined conditions through newly established national access points. This brings enormous opportunities for involvement in international research projects, but also new legal risks, especially in the area of protection of intellectual property and trade secrets contained within your datasets.
Artificial Intelligence (AI) as a medical device: Who bears responsibility for an algorithm error?
The use of Artificial Intelligence in medicine, for example for diagnostics from imaging examinations or predicting disease progression, is no longer science fiction. However, the legal framework for these technologies is rapidly tightening. Software using AI is regulated as a medical device (under the MDR regulation) and, if classified as "high-risk," it also falls under the new, very strict European regulation – the AI Act.
A key question for every facility deploying AI in the Czech Republic is liability for damages in the event of an erroneous algorithmic decision. The legal reality is complex and liability is shared: the AI manufacturer is liable for product defects, the hospital as the user is responsible for correct deployment and ensuring human oversight, and finally, the physician bears professional responsibility for the final clinical decision, as they must not blindly accept AI outputs. ARROWS specializes in drafting contracts with AI suppliers and setting up internal processes that clearly define this complex liability and minimize your risks under Czech law. For a consultation, please write to us at office@arws.cz.
By hospitals providing their data for training AI models, their role changes from a mere "data controller" (under GDPR) to a "data curator." This brings new responsibility not only for data protection but also for data quality and relevance. Providing low-quality data that leads to AI malfunction can establish the hospital's joint liability for subsequent damages under the Czech legal system.
Do you provide care with an international element? Rely on the ARROWS International network
The complexity of regulations such as EHDS, the AI Act, and GDPR in the context of cross-border care requires deep knowledge of not only Czech law but also European legislation. This is where the unique strength of our law firm in Prague becomes evident. Thanks to the ARROWS International network built over ten years, we handle cases with international elements practically every day and can ensure legal certainty across EU jurisdictions.
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Risks and Sanctions |
How ARROWS Assists |
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Loss of trade secrets or intellectual property when providing data for research within the EHDS framework. |
Drafting Data Sharing Agreements and licensing agreements that protect your intellectual property. Do you want to use your data safely for research? Write to office@arws.cz. |
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Joint liability for damage caused to a patient by an erroneous decision of an AI system. |
Legal analysis and setup of contracts with AI suppliers, which clearly define liability relationships. Do you need a review of a contract for purchasing AI technology? Contact us at office@arws.cz. |
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Fines for violating the EU AI Act for high-risk systems (up to EUR 35 million or 7% of turnover). |
Drafting internal directives and processes for the safe and legal deployment of AI in clinical practice. Want to avoid sanctions? Connect with us at office@arws.cz. |
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Legal uncertainty when providing care to foreign patients and sharing their data across borders within the EHDS. |
Legal advisory using the ARROWS International network to ensure compliance with the legislation of multiple EU states. Are you dealing with cases involving an international element? Write to office@arws.cz. |
How ARROWS turns legislative threats into your competitive advantage
The year 2026 brings a wave of legislative changes affecting all areas of healthcare facility operations – from IT and finance to daily patient care and strategic planning. Managing this transformation requires an integrated legal approach that connects technical law, finance, employment law, and intellectual property protection in the Czech Republic.
At ARROWS, we understand that it's not just about paragraphs. Thanks to our long-term experience and a portfolio that includes more than 150 joint-stock companies, 250 LLCs, and dozens of municipalities and regions, we also understand the business and operational reality of our clients. Our job is not just to point out risks, but to provide practical solutions that protect your organization and allow it to grow.
For our healthcare clients, our Czech legal team provides comprehensive legal services covering all key challenges of 2026:
- Drafting internal directives to ensure compliance with NIS2, GDPR, the AI Act, and new rules for price lists and informed consent.
- Preparation and review of contracts with IT and medical technology suppliers, health insurance companies, AI developers, and research partners.
- Professional training for employees and management, which is crucial for managing the human factor, minimizing errors, and proving due care in the event of an audit or dispute.
- Representation in Czech courts and before administrative authorities in reimbursement disputes, during regulatory inspections, or in liability cases.
We pride ourselves on speed, high quality, and added value. We actively connect our clients if we see interesting business or investment opportunities and are always open to discussing new entrepreneurial ideas.
Who you can contact:
Your strategic partner for certainty in 2026
Legislative changes in 2026 are inevitable, complex, and ignoring them is not an option. For the unprepared, they represent a serious threat; for those prepared, they are an opportunity to gain an edge. Correctly set processes, watertight contracts, and trained personnel will not only save you millions in fines but also streamline operations and strengthen your position in the market.
Do not wait for problems to arise. Gain a strategic advantage and legal certainty today. Arrange a non-binding consultation and let us discuss how we can prepare your facility for a successful entry into 2026. Contact our Czech legal team at office@arws.cz.
FAQ – Most frequent legal questions regarding legislative changes in the Czech healthcare sector 2026
1. What is the single largest financial risk that the 2026 changes represent for us?
The greatest threat is the combination of reduced reimbursements under the new Czech decree and simultaneously high penalties for non-compliance with new obligations, particularly in cybersecurity (NIS2). This convergence can represent an existential risk for some facilities. Thorough legal preparation and strategic planning under Czech law can minimize these risks. If you are addressing financial planning for 2026, contact us at office@arws.cz.
2. Our hospital is a contributory organization of the region. Does personal liability under NIS2 apply to our management?
Yes, the NIS2 directive and the new Czech Cybersecurity Act do not distinguish between the legal forms of providers. Responsibility for implementing and supervising security measures lies with the organization's top management. Our Prague-based attorneys will help you set up processes and internal regulations that legally address this responsibility. For more information, write to us at office@arws.cz.
3. We have dozens of IT and medical technology suppliers. How do we ensure that everyone will meet the new security requirements?
The key is an immediate revision and adjustment of all supplier contracts so that they contain new security guarantees and clearly defined liability in accordance with NIS2 and Czech commercial law. It is essential to start this process as soon as possible to protect your operations. Our Czech legal team will assist you with the audit and preparation of contracts; get in touch at office@arws.cz.
4. What is the return on investment for legal preparation for 2026?
This is not a classic investment with a direct return, but rather strategic risk management. The costs of prevention (legal audit, preparation of directives, revision of contracts) are a fraction of the potential damages that can arise from multi-million fines, lost disputes with insurance companies, or cybersecurity incidents in the Czech Republic. It is about protecting your financial stability and business continuity. For a specific tailored solution, contact us at office@arws.cz.
5. We are planning to participate in a research project using our patient data. What should we look out for in the context of EHDS?
It is crucial to correctly set up the data sharing agreement, which will protect your trade secrets and intellectual property while remaining in full compliance with GDPR and the future EHDS framework. Incorrect setup can lead to the loss of valuable data or a breach of personal data protection. Our experts in Prague specialize in this area. For a consultation, write to us at office@arws.cz.
6. What is the best way to train hundreds of employees on all the new digital processes and legal obligations?
We recommend a combination of e-learning for basic familiarization and targeted in-person workshops focused on specific roles (doctors, nurses, administration, management). ARROWS provides certified tailored training that is practical, understandable, and legally sound under the Czech legal system, helping to effectively manage the risk of human error. To prepare a training program, contact us at office@arws.cz.
Disclaimer: The information contained in this article is for general informational purposes only and serves as a basic orientation to the issue. Although we ensure maximum accuracy of the content, legal regulations and their interpretation evolve over time. To verify the current wording of regulations and their application to your specific situation, it is therefore necessary to contact ARROWS law firm in Prague directly (office@arws.cz). We bear no responsibility for any damages or complications arising from the independent use of information from this article without our prior individual legal consultation and professional assessment. Every case requires a tailored solution, so do not hesitate to contact us.
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