The COVID-19 pandemic has laid bare structural weaknesses in the domestic public health systems in place in the US and EU member states. In the US the debate and implementation on Patient Protection and Affordable Care Act (‘Obamacare’) will undoubtedly continue. In the EU there will be an intense debate on how to shape a European Health Union, including an increased mandate at the European level to govern essential public health functions and the response to the public health crisis.At the same time there will be discussion to what extent there should also be a shared European mandate to govern and finance health systems, which remains up to now a member states’ competence.