The European Health Data Space (EHDS) proposal aims to establish a set of rules and governance frameworks to promote the use of electronic health data for both primary and secondary purposes. This study aims at analysing the implementation status of the EHDS proposal in Portugal, particularly the points concerning the primary use of health data. The proposal was scanned for the points that gave member states a direct responsibility to implement actions, and a literature review and interviews were conducted to assess the implementation status of these policies in Portugal This study found that Portugal is well advanced in the implementation of policies concerning the rights of natural persons in relation to the primary use of their personal health data, but also identified challenges, which include the lack of a common interoperability framework for the exchange of electronic health data.