Sundheds- og Kirkeministeriet

Denmark · owned by Government of Denmark (Denmark) · www.ism.dk · 3 vendors

Sundheds- og Kirkeministeriet (the Danish Ministry of Health and Ecclesiastical Affairs) is a Danish government ministry responsible for contributing to the development of a healthy Denmark. It oversees health policy, patient rights, psychiatry, and church affairs, and supervises agencies such as the Danish Health Authority, the Danish Medicines Agency, and the Danish Patient Safety Authority. As of June 2026, it was formed following a reorganisation of the former Ministry of the Interior and Health.

Resilience scores

Technology vendors

Insights

Last updated 2026-09-01 · revision 3

3 direct vendors, 48 subvendors

Direct vendors by controlling owner country (sample)

Subvendors by controlling owner country (sample)

Migration Readiness: 4/10

Assessed by AI based on technology stack characteristics (cloud-native vs legacy, containerization, microservices), regulatory environment, data residency requirements, financial stability, and vendor lock-in risks. The score ranges from 0-10, where higher scores indicate better readiness for technology migration.

Sundheds- og Kirkeministeriet's migration readiness is assessed at 40, indicating a medium-low readiness due to several significant challenges. The most prominent hurdles are the stringent regulatory environment (GDPR, NIS2) and strict EU data residency requirements, which necessitate highly compliant and often localized cloud solutions, adding complexity and cost to any migration effort. The company's deep integration with national infrastructure, including 'Danish Government Shared IT Infrastructure (Statens IT)' and national digital identity systems (MitID / NemID), suggests a high degree of vendor or platform lock-in, making decoupling and migration difficult. The presence of 'National Health Data Registries' and 'Sundhedsdatabanken' implies large, sensitive, and potentially monolithic data systems that are inherently complex and risky to migrate. While the data indicates 'Total Services: 3' and 'Vendor Geographic Diversity: 3 unique countries', the rule of 'few vendors (1-3) indicates high lock-in risk' applies, further complicating migration. On the positive side, the use of Microsoft 365 indicates some existing SaaS adoption, and the 'Digital Health & eHealth Strategy' suggests a strategic drive towards digitalization, which could eventually encompass cloud migration, though specific plans are not detailed. Stable growth provides financial capacity, but the technical and regulatory complexities remain substantial.

Compliance

9 in-scope frameworks identified; showing 3.

Danish Public Administration Act — Compliant

As a Danish government ministry, compliance with Forvaltningsloven (Public Administration Act) and Offentlighedsloven (Freedom of Information Act) is a fundamental legal obligation. The ministry's data protection policy explicitly references Forvaltningsloven §7(2) (duty to guide and refer citizens) as a legal basis for processing citizen correspondence data. The ministry has documented procedures for handling aktindsigt (freedom of information) requests. Risk is rated Low because these are core administrative law obligations that the ministry, as a central government body, is structurally designed to fulfill.

Evidence: https://www.ism.dk/ministeriet/databeskyttelse-og-behandling-af-aktindsigt/behandling-af-aktindsigt, https://www.ism.dk/ministeriet/databeskyttelse-og-behandling-af-aktindsigt/departementets-databeskyttelsespolitik, https://www.ombudsmanden.dk, https://www.retsinformation.dk

Danish Archives Act — Compliant

The ministry explicitly references Arkivloven compliance in its data protection policy, documenting that records are transferred to Rigsarkivet (the Danish National Archives) after the relevant journal period. Retention schedules are documented. Risk is rated Low because the ministry has clearly integrated archival law requirements into its data governance framework.

Evidence: https://www.ism.dk/ministeriet/databeskyttelse-og-behandling-af-aktindsigt/departementets-databeskyttelsespolitik, https://www.rigsarkivet.dk

Danish Databeskyttelsesloven — Partially Compliant

The Danish Databeskyttelsesloven is the national implementation of GDPR in Denmark, adding sector-specific provisions for Danish public authorities. It is directly and mandatorily applicable to Sundheds- og Kirkeministeriet as a Danish public authority. The law includes specific provisions on CPR number processing (§11), sensitive data in public administration (§8), statistical and scientific research processing (§10), and employee data. The ministry explicitly references these provisions in its data protection policy. Risk is rated High for the same reasons as GDPR — the ministry processes special category health data, CPR numbers, and statistical data at scale, with Datatilsynet actively enforcing compliance against public authorities.

Evidence: https://www.ism.dk/ministeriet/databeskyttelse-og-behandling-af-aktindsigt/departementets-databeskyttelsespolitik, https://www.retsinformation.dk/eli/lta/2018/502, https://www.datatilsynet.dk

Financials

Three-year financials

Financial Resilience Score: 9/10

As a Danish government ministry, Sundheds- og Kirkeministeriet enjoys exceptional financial resilience backed by the Danish sovereign state. Approximately 94% of operating income comes from direct state appropriations (bevilling), providing extraordinarily stable and predictable funding shielded from market or counterparty risk. The ministry also maintains a substantial accumulated wage-sum savings buffer of DKK 416.8M at the end of 2025, and borrowing frame utilization is minimal at just 0.3% in 2025. However, the ministry has experienced persistent operating deficits over the past three years (DKK 21.9M in 2023, DKK 23.7M in 2024, DKK 20.6M in 2025), driven by rising costs for rent, building maintenance, Statens IT services following the 2023 relocation, and structural over-runs in the Lægemiddelskadeerstatningsordningen (pharmaceutical-injury compensation scheme). Equity has declined from DKK 163.5M in 2022 to DKK 110M in 2025, a one-third reduction over three years. Additional pressures include the recent 3 June 2026 reorganization splitting the predecessor ministry into two entities, which creates transition costs and potential short-term inefficiencies. Major exogenous cost drivers such as the Danish EU Council Presidency (H2 2025) and implementation of the Sundhedsreformen 2024, Kræftplan V, and 10-årsplan for psykiatrien impose heavy workload. Despite these pressures, sovereign backing and the massive scale of administered appropriations (~DKK 257.6B in 2025) ensure the ministry's fundamental financial stability.

Key strengths: 94% of operating income from stable state appropriations, Sovereign backing by the Danish state eliminates credit/counterparty risk, Substantial accumulated wage-sum savings buffer of DKK 416.8M (end 2025), Very low borrowing frame utilization (0.3% in 2025), Administers ~DKK 257.6B in block grants and transfers annually

Risk factors: Persistent operating deficits (DKK 20-24M annually 2023-2025), Equity declined by one-third over three years (DKK 163.5M to DKK 110M), Structural over-run in Lægemiddelskadeerstatningsordningen (DKK 11.3M deficit in 2025), Rising rent, building maintenance and IT services costs post-2023 relocation, Reorganization risk from 3 June 2026 split into two ministries, Heavy implementation workload from Sundhedsreformen, Kræftplan V, and psykiatri-plan, EU Council Presidency H2 2025 drove above-normal expenditure

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