Orchestration and Small World Governance in the European Health Data Space

The European Health Data Space (EHDS) introduces a legally binding framework for sharing health data across the EU. While the Regulation provides hard control through obligations, institutions and standards, its effectiveness will likely depend on soft coordination among Member States and stakeholders. This paper interprets the EHDS through orchestration theory and network science, proposing that its mandated governance forms an "orchestrated small world". We argue that the EHDS represents a hybrid system combining legal authority and distributed agency, in which the European Commission orchestrates a networked ecosystem rather than managing a hierarchy. We map main bodies-the Commission, EHDS Board, Health Data Access Bodies (HDABs), Steering Groups and Stakeholder Forum-onto a multi-level network and hypothesise that intermediaries connect dense national or sectoral clusters, supporting diffusion and resilience. We foresee considering emerging ad-hoc structures such as the xShare Standards and Policy Hub (ESHIA in short). This paper adopts a conceptual-analytical approach and advances a conceptual mapping for applying network concepts such as clustering, path length, modularity and centrality as they offer a new analytical lens for EU digital-health governance. With this, it concludes by inviting quantitative validation by the biomedical-informatics community.