What should pharmaceutical companies do if cross-border payments have not been provided by affiliates by end of March?

  • 24.1

    24.1 Companies must document and publicly disclose certain transfers of value made directly or indirectly to health professionals and healthcare organisations located in Europe.

Disclosures must be made in the first six months after the end of the calendar year in which the transfers of value were made (Clause 24.4). This means a company should have a full disclosure published by the end of June annually.

In order to ensure that disclosures are made on the central platform, Disclosure UK, transfer of value data needs to be submitted to the ABPI by the end of March annually. If a full disclosure is not made by the end of March the ABPI cannot guarantee that a full disclosure will be made within the timeframe required.