Have difficulties with the HDS certification requirements to host healthcare data in France? Besides, do you ask yourself how penetration testing is a key factor in attaining and ensuring compliance? HDS certification (Hebergement des Donnees de Sante) has become obligatory for all organisations that store personal health data that were gathered in France, and its demands must be known to ensure it is used in compliance with the requirements. Moreover, the framework also received substantial changes in 2024, which makes it more important than ever before to understand these changes.
Consequently, this guide will take you through the HDS certification process, describe why penetration testing is important to do so, and give you an understanding of cloud-specific certifications such as AWS HDS certification and Azure HDS certification. Moreover, we will discuss the reasons why real-life security testing is imperative in organisations that are working in the HDS certification in the French landscape.
What Are the Core HDS Certification Requirements?
The initial step towards successful compliance is to understand the HDS certification requirements. As a result, organisations should ensure that they are introduced to the overall outline set by the French Ministry of Health.
Mandatory Framework Components
The HDS certification system requires mandatory security and privacy requirements in safeguarding health information. Hence, these strict requirements must be met by all parties accommodating healthcare information gathered in France. The certification is also provided to cloud service providers, data centre providers, as well as third-party service providers.
The core components include:
- Physical security controls that protect data centre facilities from unauthorised access.
- Data encryption mechanisms, both at rest and in transit, to safeguard sensitive information.
- Access control systems that ensure only authorised personnel can access health data.
- Incident response procedures, including mandatory data breach notification protocols.
- Regular security audits are conducted by accredited certification bodies.
- Documentation of security policies and procedures aligned with ISO 27001 standards
The 2024 Framework Updates
In May 2024, the HDS certification requirements were changed dramatically. This therefore means that organisations will need to change to the restructured framework by November 2024. In addition, the existing certified ones have until May 2026 to migrate to the new version.
The new structure brought down 44 requirements to 31, which were arranged under four chapters with added integration with the ISO 27001 information security management systems. Also, the new structure puts more focus on transparency and contractual duties.
| Chapter | Focus Area | Requirements | Key Changes |
| Chapter 4 | Certification Conditions | 1 requirement | Summarizes certification pathway |
| Chapter 5 | ISMS Integration | 15 requirements | Deeper ISO 27001 integration required |
| Chapter 6 | Contractual Relationships | 11 requirements | Explicit customer obligations now mandated |
| Chapter 7 | Data Localization | 4 requirements | EEA hosting requirement clarified |
| Chapter 8 | Transparency | 1 table | Third-party involvement disclosure |
Talk with Our Experts to understand how these changes affect your organisation’s compliance strategy.
Cloud-Specific Certification Paths
Companies that use the services of HDS cloud should make sure that their providers are certified. Thus, it is essential to grasp the pathways of AWS HDS certification and the pathways of Azure HDS certification to comply.
AWS HDS certification obligates the organisations to adopt certain security settings of their Amazon Web Services infrastructure. Equally, the Azure HDS certification requires adherence to the framework of Microsoft cloud security and fulfilling the standards of the French regulations. Moreover, the two platforms should show compliance with data localisation standards in the European Economic Area.
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How Does Penetration Testing Support HDS Compliance?

Penetration testing is an important validation tool for HDS certification requirements. Therefore, it fills the gap between the recorded policies and actual security effectiveness.
Identifying Vulnerabilities Before Attackers Do
Penetration testing is a real-world method of testing security that provides insights on vulnerabilities that cannot be achieved by automated tools. Thus, companies are able to close security gaps before they are used by their bad actors. Also, this is an ideal method in accordance with the risk assessment requirements, which are presented in Chapter 5 of the HDS certification framework.
As per the current cybersecurity statistics in the United States, the average number of cyberattacks on healthcare organisations is 1,463 per week. Furthermore, healthcare data breaches were costing 10.93 million dollars per occurrence in 2023. This also makes penetration testing more than a compliance tool and a business necessity.
The testing process evaluates:
- Network infrastructure security to identify potential entry points for attackers
- Application security vulnerabilities in systems processing health data
- Authentication and authorisation mechanisms protecting sensitive information
- Data encryption implementation across all storage and transmission channels
- Access control effectiveness in preventing unauthorised data access
- Incident detection and response capabilities when breaches occur
Validating Security Controls
Penetration testing confirms that the controls on security documented against HDS certification in France are indeed working as intended. Moreover, it presents the certification authorities with the fact that your organisation is strongly secured. Furthermore, periodic penetration tests are used to show continuous dedication to security even after the initial certification.
The organisations should be subjected to frequent audits that verify that their security is healthy and effective and that it is within the standards demanded by the framework during the three-year certification. Hence, penetration testing services will be a vital part of the ongoing compliance exercise.
Meeting Contractual Obligations
The new HDS certification stipulations are very explicit about the contractual duties to the customers in Chapter 6. As a result, the organizations have to prove their security measures by providing real evidence. Hence, penetration testing reports are the tangible evidence of security due diligence to the customers and stakeholders.
Download our sample security testing report to see how comprehensive security testing addresses HDS compliance requirements.
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What Is the Difference Between Automated Tools and Penetration Testing for HDS?
It is important for the HDS certification to understand the difference between automated compliance tools and penetration testing. In addition, the two approaches have varying uses in the compliance journey.
Automated Compliance Tools: Speed vs Depth
Automated tools scan the systems rapidly, searching for vulnerable points and configuration errors. Hence, they give quick feedback about security hygiene fundamentals. Nevertheless, the tools are unable to match the innovative thinking of the experienced penetration testers.
Automated scanning offers:
- Quick vulnerability identification across large infrastructure environments.
- Consistent baseline assessments for ongoing security monitoring.
- Compliance checklist verification against HDS certification requirements.
- Cost-effective initial screening of security posture.
- Continuous monitoring capabilities for configuration drift detection.
However, automated tools are limited to a great extent. They therefore tend to generate false positives that must be manually verified. They are also unable to test complex business logic vulnerabilities and combine multiple weaknesses. Moreover, automated tools have problems with context-specific security concerns, which are specific to healthcare settings.
Penetration Testing: Real-World Attack Simulation
Penetration testing attempts to mimic the actions of real attackers to discover vulnerabilities that can be exploited. Thus, it gives more information about your security posture. Furthermore, competent testers will reason as opponents, and they will find innovative avenues of attack that an automated tool will not identify.
The advantages include:
- Business logic vulnerability discovery specific to healthcare applications.
- Chained attack scenario testing demonstrating real-world risk exposure.
- Manual verification, eliminating false positive noise from results.
- Contextual risk assessment considering your specific healthcare environment.
- Exploitation validation proving vulnerabilities are genuinely exploitable.
- Remediation guidance tailored to your infrastructure and applications.
The Optimal Approach: Combining Both Methods
To have a holistic HDS cloud security, an organisation must use automated tools as well as penetration testing. As a result, automated tools will offer continuous checks, even as periodic deep validation will be availed through the penetration tests. Moreover, the hybrid strategy will guarantee solid security in line with HDS certification France requirements.
The research of the U.S. cybersecurity claims that implementing automated scanning and the regular use of penetration testing by organisations mitigates their risk of breach by 73 per cent as compared to organisations that use only automated tools. In addition, the median time to identify breaches reduces to 73 days with all-encompassing testing programs as compared to 207 days.
Take a look at Qualysec’s ratings and reviews on Clutch to see how we help businesses secure their data. Book a free live consultation to learn more.
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Why Is Qualysec the Best Partner for HDS Certification Compliance?
The appropriate security partner is different when it comes to the need to satisfy the requirements of the HDS certification. As such, organisations require the service of a type of expertise, that is, the technical excellence in conjunction with regulation.
Comprehensive Penetration Testing Services

Qualysec can be recognised as the leading cybersecurity company in terms of penetration testing services, which directly assist with the HDS certification compliance. In addition, we have a team of qualified ethical hackers who have worked in numerous healthcare data protection systems in the global market, such as France and Europe.
Our services specifically address HDS certification requirements through:
Web Application Penetration Testing: We test our applications that process patient data and find the weak points that may jeopardise HDS cloud security. Also, our testing includes authentication, data processing, and API security essential to the cloud setting.
Network Penetration Testing: Our team analyses network infrastructure that supports the hosting of health data, and ensures that the physical security and access control requirements are met. In addition, we also test the segmentation strategies that separate healthcare data and other systems.
Cloud Security Testing: We focus on AWS HDS certification and Azure HDS certification tests. We have the knowledge of the special security concerns of cloud healthcare settings. Therefore, our tests confirm the compliance of cloud arrangements with French regulations.
API Security Testing: APIs are becoming more essential in healthcare systems to provide data exchange, and thus API security is a critical factor in HDS certification and France compliance. Thus, we exhaustively test the API authentication, authorisation and data protection mechanisms.
Mobile Application Testing: As the healthcare service becomes more and more available on mobile phones, our testing assures that mobile applications are HDS certified to protect data and transmit it securely.
Why Choose Qualysec?
Location: Headquartered in India, Qualysec has clients all over the world, such as France and Europe, and is aware of compliance requirements by region and its cultural setting.
Expertise: The team has internationally recognised qualifications such as CEH, OSCP and CISSP, in addition to which it has world-renowned expertise when it comes to HDS certification projects.
Methodology: We adhere to the industry-best practices such as OWASP, PTES, and NIST, which makes our approach cover all the HDS certification requirements.
Reporting: We offer actionable remediation advice based on the HDS cloud security standards, and therefore, it is easy to comply with our detailed reports.
Support: We do not simply point out vulnerabilities but collaborate with you during remediation, which guarantees successful certification of HDS.
Track Record: Our customers have been able to obtain and sustain different certifications of compliance, such as the ISO 27001, which forms the core of HDS certification.
Our prices are affordable so that organisations can have access to enterprise-level security testing irrespective of their scale. Moreover, our turnaround times can meet serious deadlines when it comes to certification and do not sacrifice quality. Also, we offer continuous monitoring that would guarantee compliance even after initial certification.
Our experts at Qualysec have helped secure fintech, SaaS, and enterprise systems across 25+ countries. Manual + Automated Pentesting. No false positives. Actionable reports.
Proven Results in Healthcare Security
Qualysec has assisted many health institutions in improving their security position. Furthermore, our penetration testing has revealed some vulnerable barriers in advance, before they could be used. As a result, our customers have strong cybersecurity against the constantly changing threats.
The most recent engagements have found an average of 23 vulnerabilities in every healthcare application, with 6 of them being critical. Also, our guidance on remediation has made it possible to resolve 94 per cent of the vulnerabilities in 60 days. Our retesting services also ensure that fixes can successfully remove security threats in healthcare.
Learn how we helped our clients to achieve compliance and prevent data breaches — View Case Studies
Conclusion
Knowledge and application of HDS certification requirements constitute a big task for healthcare organisations. Nevertheless, compliance investment has enormous advantages such as increased data security, customer confidence, and decreased risk of breach. Besides, penetration testing can be defined as an indispensable method of testing the security measures and achieving true security of the health data.
Updates of the 2024 framework have enhanced the current standards of HDS certification in France and made it more integrated with ISO 27001 and more open about data handling. Therefore, organisations are to implement the full security testing methods that involve automated tools and real-life penetration testing. Moreover, Cloud providers who are seeking AWS certification of HDS or Azure certification of HDS encounter extra complexity, which demands special expertise.
Through collaboration with qualified security experts such as Qualysec, organisations will sail through the HDS certification process with ease. Thus, they can gain compliance effectively and establish actual strong security programs that secure patient information. Also, compliance and security effectiveness are maintained due to continuous penetration testing in the certification lifecycle.
It is important to remember that HDS certification is not about just filling out compliance boxes; rather, it is about truly securing sensitive health data against advanced cyber threats. Therefore, security testing is an investment worth making today, which saves money on breaches in the long run.
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FAQ
1. How to get HDS certification?
To achieve certification in HDS, organisations are required to present themselves to accredited certification organisations, provide extensive paperwork of security controls, and well as local audits. Moreover, they have to portray that they have met all the 31 requirements in the four chapters of the framework, such as integration of ISMS and contractual obligations.
2. What is the HDS standard?
The HDS standard is a compulsory French framework that guarantees the security and privacy of the health information that is stored in France and is maintained under the supervision of the French Ministry of Health. In addition, it demands that organisations have strict security controls such as encryption, access controls, and regular compliance security audits within the three years of certification.
3. How to be HDS certified?
To be certified HDS, one must have in place strong security control measures in line with ISO 27001, there must be detailed documentation, and the audits must be done by certified bodies. Moreover, companies are required to store data in the European Economic Area as well as provide open communication regarding third-party intervention.
4. Who is HDS certified in France?
The HDS certification is required to be done on the cloud service providers, data centre operators, and third-party service providers hosting the healthcare data gathered in France. Also, there are big clouds, such as AWS and Azure, that provide HDS certification to their French healthcare clients who have all the standards required by regulations.
5. Is HDS certification mandatory?
Yes, the French Public Health Code (Article L.1111-8) mandates HDS certification on any entity where the personal health data is hosted in France. Therefore, the risks of legal fines and liability in case of breach of patient information expose organisations to operating without certification.
6. How to get HDS certification?
To become certified in the area of HDS, organisations may use the activities of accredited certification bodies and required security controls in their implementation, such as penetration testing, as well as show their continued compliance. In addition, collaborating with proven cybersecurity companies such as Qualysec will speed up the certification process due to specialised counsel and full security testing.
Ready to achieve HDS certification with confidence? Contact Qualysec’s expert team today for a comprehensive security assessment that ensures your organization meets all HDS certification requirements while building genuinely robust defenses against cyber threats.

























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