The recent ruling of the European Court of Justice in the case Smits-Peerbooms explicitly mentions undue delay as a legitimisation for cross-border care within the EU. In the Netherlands, waiting times are well above the norm set by several health care parties as well as maximally acceptable waiting times elicited in patients. This might indicate that Dutch patients are often entitled to care in other Member States, in the sense that insurers cannot withhold reimbursement of cross-border care in the present situation. However, experiments clearly demonstrate that few Dutch patients are willing to travel abroad. Patients seem to prefer longer waiting in the Netherlands over shorter waiting by going abroad, even those living in border regions. In addition, mobility of patients within the Netherlands is very modest. Given this inertia in patient mobility, in the short run, cross-border care will probably remain an insignificant phenomenon in terms of quantities of patients travelling abroad and therefore the impact of the Smits-Peerbooms rulings is limited.