The European Commission has criticized the German government’s plans to reorganize how medical appointment scheduling is handled. According to a report from the “Politico” health newsletter, citing a letter from the Commission directly to the German government, Brussels is concerned that the proposed Law for Data and Digital Innovation in Healthcare (GeDIG) could unfairly disadvantage private appointment booking platforms.
Under the new Digital Law, the Federal Association of Statutory Health Physicians (KBV) and the GKV-Spitzenverband are mandated to establish rules for platforms like Doctolib and Jameda, including technical requirements. However, since the KBV currently operates its own appointment service, “116117,” the Commission has raised warnings about potential conflicts of interest.
The Commission stated that the regulations governing these platforms should be set by the KBV and the GKV-Spitzenverband in a way that is impartial and transparent. Furthermore, the letter insists that adequate safeguards must be put in place to prevent any such conflicts of interest.
The cabinet draft of the GeDIG specifies that patients will eventually be able to book doctor’s appointments through the app associated with their electronic health records-a process termed “Digital Care Entry.” The draft intends to utilize the KBV’s existing system for this purpose. Critics, including the Commission, note that private providers are not mentioned in the draft, which drew further criticism from Brussels.
The Commission contends that the law draft fails to concretize the inclusion of private digital booking platforms within the digital care entry system. Instead, it appears to focus exclusively on the KBV’s appointment booking system, even though the draft allegedly calls for open and competitive frameworks.
The debate over appointment scheduling has been highly contentious this year as political leaders aim to reduce patient waiting times. The GeDIG is currently moving through the parliamentary process. For context, the KBV’s “116117” service reported facilitating roughly two million appointments last year, while company figures show Doctolib is used by 30 million people in Germany.


