To systematically analyze the overall architecture, evolution, and core issues of medical data trading policies in China, identify deficiencies within the policy system, and to provide a basis for subsequent policy optimization.

Using NVivo 12 Plus software, we conducted content mining and thematic coding of 48 policy texts related to medical data trading issued at the national level between 2015 and 2025. A structural model of policy elements was constructed, and a combined qualitative and quantitative analysis was performed.

Medical data trading policies in China have formed a three-tier governance structure of “top level design-institutional mechanisms-development pathways.” However, the system exhibits significant structural imbalances, including a fragmented framework and lack of industry-specific legislation at the top-level design tier; a dual weakness in operational safety rules and supplier incentives at the institutional mechanism tier; and lagging development of infrastructure and the professional service ecosystem at the development pathway tier.

The policy system should be improved by strengthening top-level design through industry-specific legislation, improving institutional mechanisms with operational safety rules and incentive schemes, and bolstering development pathways by fostering a professional service ecosystem. These measures aim to enhance the efficiency and security of medical data factor market allocation, thereby supporting the deep integration of the “Healthy China” and “Digital China” strategies.