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Shared Medical Record: What Independent Practitioners Must Anticipate

Markus Team20 May 20266 min read

France's shared medical record obligation dates back to 2022. Financial penalties were struck down in December 2025 — but the underlying obligation stands. Here is what independent practitioners need to anticipate.

Shared Medical Record: What Independent Practitioners Must Anticipate

Shared Medical Record: What Independent Practitioners Need to Anticipate Now

Introduction

Your practice software may already indicate it: every consultation should, in theory, result in a document being deposited in Mon Espace Santé (MES — France's national patient health portal). In practice, many independent practitioners have rarely used it, or only feed the Shared Medical Record (DMP) occasionally.

This is changing. There is still time to organise. Not because of an imminent overhaul, but because the legal framework is tightening, automatic document uploads have accelerated since March 2026, and certain practitioners, physiotherapists with direct patient access at the forefront, already have an explicit statutory obligation to feed the DMP.

This article sets out what is mandatory today, what is being prepared for independent nurses (IDEL — Infirmières et infirmiers diplômés d'État libéraux), and three concrete questions to put to your software vendor to be ready.

Mon Espace Santé in 2026: A Deployment Gaining Speed

Mon Espace Santé is no longer the pilot platform launched in a few French departments in 2022. In January 2026, the French National Health Insurance (Assurance Maladie) published its four-year assessment:

97% of the French population has a Mon Espace Santé profile
24 million profiles have been activated
420 million documents were deposited in 2025, up 40% from 2024
2.5 million people log in monthly to access their health data

The scale is significant. Yet a gap remains on the practitioner side: around 150,000 independent practitioners feed the DMP, out of approximately 250,000 independent healthcare professionals in France. And only 38,000 independent doctors consult their patients' files each month.

(Source: Assurance Maladie, press release "Four years of Mon Espace Santé", 29 January 2026)

Since 24 March 2026, a concrete shift has occurred: sick leave certificates and occupational accident certificates generated in Amelipro are now automatically deposited into the DMP and visible in Mon Espace Santé. Since 1 April 2025, dental examination reports follow the same logic. Automation is progressing without waiting for each practitioner's manual input.

What the Law Says: The Obligation That Already Exists

An Obligation in the Public Health Code Since 2022

The obligation to feed the DMP is not a creation of the 2026 Social Security Financing Bill (PLFSS — Projet de loi de financement de la Sécurité sociale). It is enshrined in Article L. 1111-15 of the French Public Health Code, clarified by the ministerial order of 26 April 2022. This text specifies the list of documents that healthcare professionals must upload to the DMP at each appointment or consultation — unless the patient objects on legitimate grounds.

In plain terms: the obligation exists. It applies to you today.

The 2026 Social Security Bill and the Constitutional Council's Ruling

The 2026 Social Security Financing Bill generated considerable debate. Articles 30 and 31 proposed financial penalties for non-compliance: up to €2,500 per breach, capped at €10,000 per practitioner per year.

On 30 December 2025, the Constitutional Council struck down the relevant article. Its ruling: the measure constituted a "social rider", a provision without sufficient connection to Social Security financing. The censure was procedural, not substantive.

The key point: this decision does not invalidate the obligation to feed the DMP. It simply delays the introduction of financial penalties, which can be reintroduced through standard legislation. The French government has not abandoned mandatory enforcement. It has been forced to use a different legislative vehicle.

What Changes Depending on Your Profile

Empty physiotherapy room with treatment table and a tablet on a stand — digital traceability in a prescription-free practice

General Practitioners

For doctors, the obligation is already in force. Consultation reports, medical summaries, prescriptions, health assessments: these documents fall within the scope defined by the order of 26 April 2022. Your software must allow them to be uploaded to the patient's DMP, provided it holds Ségur numérique certification (see the next section).

The 2026 Social Security Bill also reinforces a second obligation, independent of any penalties: consulting the patient's DMP before prescribing particularly expensive procedures or products. This is a substantive development that stands regardless of the penalty question.

Physiotherapists with Direct Access: A Statutory Obligation

This is where the link between direct access and the DMP becomes unavoidable.

The Rist Law (Law no. 2023-379 of 19 May 2023) opened direct access to physiotherapists within coordinated care structures. Multiprofessional health centres (MSP — Maisons de santé pluriprofessionnelles), primary care teams, territorial professional health communities (CPTS — Communautés professionnelles territoriales de santé): since 28 August 2024, around twenty French departments have been taking part in the experiment, for a period of five years.

The law is explicit on the DMP:

"An initial assessment and a report of the care provided by the physiotherapist shall be systematically sent to the patient's GP and to the patient, and recorded in the patient's shared medical record."

— Law no. 2023-379 of 19 May 2023, article on direct access to physiotherapists

This is not a recommendation. It is a statutory obligation, written into the law itself.

Why this requirement? Because without a medical prescription, the DMP becomes the traceability record for the care pathway. It is the evidence that the patient was treated, that the GP was informed, and that coordination was maintained. Without this record, direct access loses part of its legitimacy within coordinated care.

→ Direct access to physiotherapists: how the experiment works and what to do (Markus Santé)

For Independent Nurses (IDEL): What Is Being Prepared

Independent nurses (IDEL) are not yet subject to a generalised direct access scheme, with the exception of advanced practice nurses (IPA — Infirmières en pratique avancée), whose direct access was established by decree no. 2025-55 of 20 January 2025.

But the competency framework is evolving. The nursing law of 27 June 2025 and decree no. 2025-1306 of 24 December 2025 broadened nursing competencies. Nursing consultation, nursing diagnosis, and the ability to prescribe certain health products and complementary examinations within a multiprofessional framework: these new competencies come into force no later than 30 June 2026. Implementing orders are still expected to specify procedural details.

Amendment 11 (Avenant 11) to the national IDEL convention, signed on 31 March 2026 and in force since 6 May 2026, created two reimbursed nursing consultations: type II diabetes follow-up and preventive health assessments at key life stages.

As independent nurses take on autonomous consultation and follow-up responsibilities, the DMP will become a central traceability and coordination tool, as it already is for physiotherapists under direct access. The direction of travel is clear, even if implementing texts are still pending.

Is Your Software Ready? Three Questions to Ask Your Vendor

Hands resting on a laptop keyboard, three blank sticky notes on the screen bezel — checklist before contacting your software vendor

Feeding the DMP is not a manual task. It goes through your practice management software. Not all software is at the same level. Here are the three questions to raise without delay.

1. Is your software certified under Ségur numérique? The Ségur du numérique en santé programme, led by the Agence du Numérique en Santé (ANS — France's health digital agency), makes access to financial incentives and the digital care allowance (forfait numérique, which replaces the previous forfait structure from 2026) conditional on using certified software. Without this certification, your software sits outside the Mon Espace Santé ecosystem. You can check the list of certified software directly on the ANS website (esante.gouv.fr). For physiotherapists, our physiotherapy software comparison can help you choose.

2. Does it natively handle the DMP workflow? Software can hold Ségur certification without having implemented all DMP functions. Ask your vendor whether uploading documents to Mon Espace Santé is natively integrated into your usual workflow, or whether an additional manual step is required at each consultation. In practice, the difference between the two is the difference between a habit that holds and an obligation that falls away.

3. What is the update roadmap for new obligations? DMP feeding obligations are expanding progressively: new document types, new practitioner profiles. Your vendor must have a clear update roadmap. If they cannot answer this question, treat it as a warning sign.

Key Takeaways

The obligation has been in force since 2022. Article L. 1111-15 of the French Public Health Code requires DMP feeding. The financial penalties proposed in the 2026 Social Security Bill were struck down on procedural grounds. The underlying obligation stands.
For physiotherapists under direct access, it is an explicit statutory obligation. The Rist Law requires the initial assessment and care report to be recorded in the patient's DMP. No option, no exception.
Checking your software's compatibility is the first concrete step. Ségur certification, native DMP workflow, update roadmap: three questions to put to your vendor without delay.