This article examines the institutional output and preliminary outcome of the EU Patients' Rights Directive in two health care models: the Beveridge and Bismarck models in Denmark and Bulgaria, respectively. The study applies a most dissimilar system design to explain a similar transposition output through three explanatory variables, namely, institutional misfit, salience and administrative resources. We find that Denmark and Bulgaria have transposed the Directive in protectionist and minimalistic ways, thus far leading to a low outcome, i.e. low patient outflow. The encounter between the EU and the national health care models has not been enthusiastic but has instead been another example of reluctant and restrictive Europeanisation.