Few pieces of Australian health infrastructure have been promised so much and delivered so unevenly as My Health Record (MHR). Launched in 2012 as the Personally Controlled Electronic Health Record (PCEHR), shifted to an opt-out model in 2018, and now the subject of a multi-year Modernisation Strategy, MHR sits at the centre of a louder-than-ever reform debate. The system has tens of millions of accounts, yet clinician usage remains patchy, hospital integration is fragmented, and consumer trust has been bruised by a series of high-profile data breaches outside the health system. As the Commonwealth pushes Sharing by Default mandates and FHIR-based interoperability through 2026 and 2027, the question is no longer whether MHR exists, but whether it can finally function as the connective tissue Australian healthcare needs.
What My Health Record Is — and How It Got Here
MHR is a national summary record system operated by the Australian Digital Health Agency (ADHA), holding clinical documents that follow a person through the health system. Its content typically includes shared health summaries authored by general practitioners, event summaries, hospital discharge summaries, pathology and diagnostic imaging reports, prescription and dispense records, immunisation history, and consumer-entered information such as advance care planning documents (ADHA, 2024).
Its origins lie in the 2010 PCEHR proposal, which assumed individuals would actively register and curate their records. Uptake under that opt-in model was modest, prompting the 2017 legislative shift to opt-out. By early 2019, after the opt-out window closed, more than 90% of eligible Australians had a record created automatically. The architecture itself is a centralised document repository rather than a true longitudinal clinical database — documents are uploaded as packaged Clinical Document Architecture (CDA) artefacts, indexed against an Individual Healthcare Identifier (IHI), and retrieved on request by authorised providers.
That architectural choice matters. MHR was designed as a record-of-records, not a live data exchange. It can show what was uploaded but cannot, in its original form, support real-time clinical workflows or granular data queries — limitations that drive much of the current reform agenda.
Uptake Reality Versus Official Statistics
Headline numbers are encouraging. More than 23 million Australians have an MHR, and the Agency reports billions of documents stored across pathology, prescriptions and clinical summaries (ADHA, 2024). But registration is not the same as use.
Three distinct measures matter:
- Account existence: near-universal after opt-out, but reflects automatic creation, not engagement.
- Active records: records with at least one clinical document uploaded in the past 12 months. This figure is materially lower than headline registration, and the gap is widest for working-age adults without chronic disease.
- Clinician access: the proportion of consultations in which a provider actually views or contributes to MHR. AIHW analysis and Productivity Commission work suggest this remains a minority of encounters, with substantial variation by setting and clinical software (AIHW, 2025).
The result is a system that exists for nearly everyone but is used routinely by relatively few. That asymmetry — high coverage, low utility — is the central problem reform must solve, and it cannot be solved by registration campaigns alone.
The Interoperability Problem
Australia's clinical information environment is a patchwork. General practice runs on a small number of dominant practice management systems. Public hospitals operate on a mixture of vendor electronic medical record (EMR) platforms, with significant variation between states and even within local health districts. Private hospitals, allied health, community pharmacy, residential aged care and mental health services each have their own software ecosystems, often with limited or no MHR connectivity.
The international standard for solving this kind of fragmentation is HL7 FHIR (Fast Healthcare Interoperability Resources), which models clinical concepts as discrete, queryable resources rather than monolithic documents. ADHA has committed to FHIR as the underpinning standard for the next generation of national digital health infrastructure, including the FHIR-based API gateway that supports newer MHR functions (ADHA, 2024). Adoption across vendors, however, is uneven. Some vendors have shipped FHIR endpoints; others remain document-centric. Without a coordinated mandate, conformance has been driven by procurement rather than regulation, which has produced inconsistent coverage of the resources that matter most for continuity of care — medications, allergies, problems and encounters.
Sharing by Default — The Reform Lever
The Strengthening Medicare Taskforce report (2023) and subsequent Commonwealth measures introduced the concept of Sharing by Default: rather than relying on clinicians to actively decide to upload, key clinical events should flow into MHR automatically unless the patient or provider explicitly opts out.
The most concrete expression of this is the mandate for pathology and diagnostic imaging providers to upload reports to MHR by default, supported by funding tied to compliance. Primary care is being pushed in the same direction, with practice incentive arrangements and software conformance requirements aligned to default upload of shared health summaries, event summaries and prescribing data. The pharmacy channel — already a strong contributor through dispense records — is being deepened with electronic prescriptions integrated into the same flow.
The reform logic is straightforward: if MHR is to act as a clinical safety net, the default state must be that information flows in. Optionality at every step produced exactly the patchy coverage that erodes clinician trust in the record. A clinician who finds MHR empty twice in a row stops checking it.
Secondary Use of MHR Data
Alongside primary clinical use, MHR data is increasingly relevant for research and health system planning. The Framework to guide the secondary use of My Health Record system data sets out the conditions under which de-identified data may be made available to approved researchers and government agencies (ADHA, 2024). Access is governed by an oversight board, with a separate opt-out register for individuals who do not want their data used for secondary purposes, even in de-identified form.
This is a sensitive area. Public support for research use of health data is generally high in principle but conditional in practice — contingent on de-identification quality, governance transparency, and the absence of commercial exploitation. Secondary use policy will need to evolve in parallel with the broader reform agenda; otherwise gains in clinical utility may be offset by trust losses if data flows are perceived as expanding without consent.
Consumer Trust and the Breach Hangover
The hardest variable to engineer is trust. The 2022 Optus and Medibank breaches — neither of which involved MHR — nonetheless reshaped the public conversation about health data security in Australia. Medibank in particular, where sensitive health claims information was exfiltrated and released, demonstrated that the threat model for health-adjacent data is real, attacker-driven, and not bounded by sector.
Survey work since then has consistently shown elevated concern about health data privacy, with a measurable, though not catastrophic, increase in MHR opt-out rates following the breaches. The opt-out share remains in the single digits nationally, but it is not evenly distributed: opt-out is higher among younger adults, among some culturally and linguistically diverse communities, and among people with stigmatised conditions such as mental illness or HIV.
Trust recovery is a function of three things: visible security posture (audit logs, access controls, breach response), governance that is independent and credible, and lived experience of the system providing benefit. Sharing by Default helps with the third — a record that is actually useful is easier to trust — but it raises the stakes on the first two, because more data flowing into a national system increases both the value of the asset and the consequences of failure.
For broader context on how trust intersects with access to care, see our analysis of the bulk billing crisis, which shapes how often Australians encounter the digital health system in the first place.
Where the System Still Breaks for Patients
Even with reform momentum, three transition points remain weak.
Hospital discharge. Discharge summaries are among the most clinically valuable documents in MHR, yet upload rates vary widely between jurisdictions and individual hospitals. Where summaries are uploaded, they are often delayed beyond the window in which they would be useful to the receiving GP. State-run EMR procurement cycles are slowly closing this gap, but progress is measured in years, not months.
Allied health and mental health. Psychologists, physiotherapists, dietitians and other allied health providers have historically had limited MHR integration, both technically and culturally. Mental health information attracts additional sensitivity, with legitimate concerns about who can view what. The current reforms are beginning to extend conformant software and consent tooling into these settings, but coverage remains thin. Our piece on Medicare-funded mental health reform explores the parallel funding levers.
Rural, remote and Indigenous health services. Connectivity, workforce stability and software fragmentation all amplify in non-metropolitan settings. Aboriginal Community Controlled Health Services have specific clinical and governance needs that off-the-shelf MHR workflows do not always accommodate. Reform that does not actively design for these settings will widen rather than narrow access gaps — a theme we develop further in our rural and remote health access policy analysis.
International Benchmarks
Australia is not reforming in a vacuum. Three comparators are routinely cited:
- Denmark (MedCom and Sundhed.dk): A long-running, FHIR-aligned national exchange with strong clinician adoption. Denmark's smaller population and centralised health system make direct comparison imperfect, but its experience demonstrates that mandatory standards, paired with clinician-facing portals that are genuinely useful, drive sustained use.
- United Kingdom (NHS Spine, Summary Care Record, Shared Care Records): A federated model with national identifiers and a summary record layered over regional shared care records. The UK experience illustrates both the value of strong identifier infrastructure and the political difficulty of consent and secondary use debates.
- United States (ONC interoperability rules, USCDI): Regulatory-driven interoperability through information blocking rules and a defined common data set. The US shows that mandates, including penalties for blocking, can shift vendor behaviour faster than voluntary frameworks — at the cost of significant compliance overhead.
Each model offers lessons. None is directly transposable. Australia's federated health system, with Commonwealth-funded primary care and state-run hospitals, has structural features that neither Denmark nor the UK nor the US fully share.
The 2026-2027 Reform Roadmap
The next two years are likely to determine whether MHR becomes genuinely useful infrastructure or remains a partial record of partial events. The reform agenda, as set out in successive ADHA strategies and Commonwealth budget measures, has several intersecting strands:
- Mandatory conformance to national standards for clinical software, anchored on FHIR and the Australian Core Data for Interoperability (AUCDI).
- Sharing by Default expansion across pathology, diagnostic imaging, primary care, pharmacy and, progressively, hospital discharge and allied health.
- Real-time and near-real-time data flows for high-value use cases such as medication reconciliation, allergies and adverse reactions, replacing the current document-centric model where it adds friction.
- Identity and consent infrastructure, including more granular access controls and improved audit visibility for consumers.
- Workforce and clinical change management, recognising that technology mandates without workflow redesign and education tend to underperform.
Funding mechanisms are also evolving. Practice Incentives Program (PIP) and equivalent levers are being aligned with conformance and upload behaviour, while procurement requirements at state level increasingly specify FHIR endpoints and national identifier integration.
The breadth of this agenda is also its risk. Concurrent reform across pathology, primary care, hospitals, allied health and consumer-facing tools is operationally demanding. Sequencing, vendor capacity and clinician change fatigue — already significant after several years of telehealth, electronic prescribing and MBS reform — will shape what actually lands. The trajectory of telehealth offers a useful comparison; see our telehealth permanency advocacy piece.
Key Takeaways
- MHR has near-universal coverage but uneven utility; the binding constraint is now clinical usefulness, not registration.
- The shift from a document repository to a FHIR-based, queryable data layer is the most important architectural change underway.
- Sharing by Default reforms address the chronic under-upload problem, but only if mandates are matched with software conformance, workflow integration and clinician trust.
- Consumer trust, shaped by the Medibank and Optus breach hangover, is a real and asymmetric risk: gains accrue slowly, losses occur suddenly.
- Hospital discharge, allied health, mental health, and rural and remote settings remain the weakest links and require explicit policy attention rather than incidental coverage.
- International benchmarks suggest mandates and standards work, but only when paired with clinician-facing utility and credible governance.
- The 2026-2027 window — Modernisation Strategy implementation, AUCDI rollout, expanded Sharing by Default — is decisive. The question is no longer whether to reform MHR, but whether the reform can be sequenced and resourced to actually change clinical experience on the ground.
Australian digital health has spent more than a decade building the scaffolding. The next phase is about whether that scaffolding can carry weight.