Beyond NHI: Why e-Impilo Makes Health Data Readiness Urgent in South Africa
While National Health Insurance waits on the courts, South Africa's national electronic medical record is quietly scaling. For provinces, hospitals, schemes and laboratories, the data work it demands is needed whatever the courts decide.
Suhina Singh
Founder & CEO, Jonda Health
October 16, 2026
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7 min read
Key takeaways
The NHI Act is law, but the state has undertaken not to implement it until the Constitutional Court rules; judgment may come in early 2027.
e-Impilo, the national electronic medical record for primary care, went live in March 2025 and was in use at 55 facilities by late 2025.
Expansion to 3,300 more facilities is planned over two years.
Provinces start from very different places: five use a mix of hospital systems, while four reported none in 2025.
Consistent, structured patient records are needed for e-Impilo, provincial systems, schemes and any future financing model.
In South Africa, conversations about health reform often begin and end with National Health Insurance. It is an understandable focus: NHI is ambitious, contested and now before the Constitutional Court. But while that debate continues, something more practical is happening in clinics across the country.
A government-owned electronic medical record, e-Impilo, has moved from a handful of pilot clinics to a formal national rollout, with thousands more facilities planned. It links patients through a national registration system and uses international standards for exchange. For anyone who works with patient records, this is where the near-term change is.
This guide sets out where NHI stands, what e-Impilo is building, how different provinces are starting, and what data work is needed either way. It draws on our experience at Jonda Health, where our work is turning health records from many different sources into structured, standardised information that clinicians and systems can actually use.
Key takeaways
The NHI Act is law, but the state has undertaken not to implement it until the Constitutional Court rules; judgment may come in early 2027.
e-Impilo, the national electronic medical record for primary care, went live in March 2025 and was in use at 55 facilities by late 2025.
Expansion to 3,300 more facilities is planned over two years.
Provinces start from very different places: five use a mix of hospital systems, while four reported none in 2025.
Consistent, structured patient records are needed for e-Impilo, provincial systems, schemes and any future financing model.
Figure 1. Two tracks: one paused, one moving.
Where NHI stands
The NHI Act was signed into law on 15 May 2024, but further implementing legislation, including on funding, is still needed before it takes effect. In February 2026, in the Pretoria High Court, the state undertook that the Minister of Health and the President would not proclaim or implement any provision of the Act until the Constitutional Court has ruled on challenges to the public participation process (Sakeliga).
The Constitutional Court heard those challenges in May 2026 and reserved judgment, which may be delivered in early 2027. More than ten further cases challenging specific clauses are paused until then (Bhekisisa). We take no position on the outcome here. What matters for this article is that NHI's timing is uncertain, while the need for good patient data is not.
What e-Impilo is building
e-Impilo is the National Department of Health's electronic medical record for public primary health care. After a beta in 36 clinics and one GP practice across the Free State, KwaZulu-Natal, the Northern Cape, Mpumalanga and North West, its first phase went formally live on 28 March 2025, with scale-up in primary care planned from January 2026 (Parliamentary reply NW4495).
By November 2025 it was in use at 55 facilities, with expansion planned to 3,300 more over the following two years. It uses FHIR standards for exchange, takes a modular approach that links to existing registries, and relies on the Health Patient Registration System, which verifies patients biometrically against the Department of Home Affairs database to create unique identifiers and reduce duplicate records (Global Fund).
A varied starting point
Hospitals are a different picture. In August 2025, the Department reported a range of provincial hospital systems, and four provinces with no hospital patient information system being implemented (Parliamentary reply NW4495).
Figure 2. A varied starting point across provinces.
This matters for data. Where provinces run different hospital systems, records need reconciling before they can be shared or compared. Where hospitals are still largely on paper, years of history will need to be structured if it is to be useful in any electronic system.
The data work, whatever happens next
In the records we work with across Africa and Asia, the same patterns appear again and again, and South Africa has its own versions of each.
Patient identity. Matching historical records to the national registration system, and resolving duplicates across clinics and hospitals.
Different systems. Reconciling records between provincial hospital systems, primary care, private providers and laboratories.
Laboratory results. Tests named and coded differently between laboratories and facilities, with different units and ranges.
Medicines. Brand, generic and formulary names for the same medicine, including long-term treatment histories.
Paper and documents. Patient files, referral letters and discharge summaries that exist only on paper or as scans.
Health information is special personal information under the Protection of Personal Information Act (POPIA), so any project that moves or processes records should be planned with that in mind. Where records are reused beyond direct care, the right protections matter, which we explain in this guide. AI can do much of the heavy lifting at speed, and we use it extensively ourselves, but it needs clinical review and quality checks behind it. That is why we argue that healthcare AI will not work without trusted data infrastructure.
Who this affects
Organisation
Where to focus
Provincial health departments
Reconciling hospital systems with e-Impilo, and structuring paper history where there is no hospital system.
Private hospital groups
Consistent records across sites, POPIA compliance, and readiness for future exchange.
Medical schemes and administrators
Structured clinical data behind claims and care management.
Laboratories
Results that map cleanly to shared standards and can be compared across facilities.
Implementing partners
Programme data that feeds national systems in a consistent, reusable form.
List every system and paper store holding patient records in your organisation.
Check how patients are identified, and how records will match to the national registration system.
Review naming and units for your most common laboratory tests and medicines.
Identify which historical records matter most for continuity of care, and plan to structure those first.
Confirm your POPIA obligations for any project that moves or processes patient records.
Build clinical review into data cleaning and conversion.
Follow e-Impilo's rollout and the Constitutional Court's NHI judgment, without waiting for either to begin.
How Jonda Health can support you
At Jonda Health, we have spent years working with health records across formats, languages and health systems in Africa and Asia, and we know how much of this work only becomes visible once real data starts to move. Depending on where your organisation is today, there are three ways we can help.
If you are not sure how ready your records are
A data readiness assessment
Through Jonda Health Services, we look at a sample of your records and give you a clear picture of the gaps, with a practical plan that holds whatever happens with NHI.
If much of your history is on paper or in PDFs
JondaX
JondaX turns paper records, scans and PDFs, as well as HL7 and CSV files, into structured, standardised data ready to map to FHIR. It reconciles variant test names and units, maps local codes to medical coding standards, and puts clinical review and quality assurance behind the output. JondaX is ISO 27001 certified.
If you are moving systems or joining e-Impilo
Migration support
We work alongside your vendor or provincial team to check, clean and move patient history, and agree with you at the outset where data is processed, in line with POPIA.
Frequently asked questions
What is e-Impilo?
e-Impilo is the National Department of Health's electronic medical record for public primary health care. Its first phase went formally live on 28 March 2025 after a beta in 36 clinics and one GP practice across five provinces. It uses FHIR standards and links to the Health Patient Registration System, which uses biometric verification to establish unique patient identifiers.
How many facilities use e-Impilo?
A Global Fund case study published in November 2025 reported e-Impilo in use at 55 health facilities, with expansion planned to 3,300 more facilities over the following two years.
What is the status of NHI?
The NHI Act was signed into law in May 2024. In February 2026, the state undertook in the Pretoria High Court not to proclaim or implement any provision of the Act until the Constitutional Court rules on challenges to the public participation process. The Constitutional Court heard those challenges in May 2026 and reserved judgment, which may be delivered in early 2027.
Do all provinces have hospital information systems?
No. A parliamentary reply in August 2025 reported hospital patient information systems in the Western Cape, KwaZulu-Natal, Eastern Cape, Free State and Gauteng, using several different systems, and none being implemented in Mpumalanga, North West, Limpopo or the Northern Cape.
Why prepare data now if NHI is paused?
Consistent, well-structured patient records are needed for e-Impilo, for provincial hospital systems, for medical schemes and laboratories, and for any future financing model. The data work is useful whatever the courts decide.
Book a free 30-minute data readiness conversation
Tell us about your province, hospital group, scheme or laboratory, your systems and where your records sit today, and we will talk through where your data stands and the most sensible next step. There is no obligation, and you will leave with a clearer picture either way.
Sources: Sakeliga (February 2026); Bhekisisa (6 July 2026); Parliamentary reply NW4495 (1 August 2025); The Global Fund, South Africa digital health case study (November 2025). This article is for general information and is not legal advice, and takes no position on the NHI litigation.
