transparency obligations overview

Latest update: 14 September 2018 | Important Notes

Report Due Date

End of February and end of August


Medicine Australia Medicines

Who Must Report

All member pharmaceutical companies of the Medicines Australia Code of Conduct

Covered Recipients

Healthcare professionals (HCPs) including medical practitioners, pharmacists, dentists, nurses, nutritionists/ dieticians, optometrists, physiotherapists, psychologists, podiatrists

Pharmaceutical Companies

What is reported:

Reportable payments and transfers of value to HCPs must be reported. These include:

  • Fees paid to HCPs for speaking at an educational meeting or event.
  • Sponsorship of HCPs to attend an educational event. Reportable sponsorships are any airfare, accommodation or registration fees for the event.
  • Fees paid to HCPs consultants, or to their employers on their behalf, for their services. This includes, all consultancy services provided in relation to educational meetings, preparation of promotional materials or product position papers, assistance with training or any other advice to the company. It includes any accommodation and/or airfares associated with providing the consulting service. This does not include payments to consultants in relation to research and development work, including the conduct of clinical trials.
  • Fees paid to HCPs as Advisory Board members. This includes all sitting fees, accommodation and airfares associated with the activities of the Advisory Board.
  • Fees paid to HCPs for the purpose of market research where the identity of the healthcare professional is known to the company that contracted the market research.

How to Report

Through the Medicine Australia Medicines member company website.
See template at https://medicinesaustralia.com.au/wp-content/uploads/sites/52/2009/12/Sample-payments-to-a-HCP.pdf
Important notes:
  • This information is provided for your convenience and should not be construed as legal advice. The applicability of these requirements to your organization depends on individual circumstances. The information is not exhaustive.
  • Kindly check with your legal department and do not depend solely on the information provided here. Moreover, the rules mentioned could be subject to interpretation of local authorities/courts in the applicable jurisdiction. Lastly, be mindful of the latest update mentioned above. These rules and regulations change frequently, so it is important to determine whether the information reflects that most recent changes and is still applicable.
  • Reporting dates are related to the transparency obligation regarding transfers of value by pharmaceutical companies and/or medical device companies (excluding suppliers of in vitro diagnostics) to HCPs and HCOs. These often are based on laws or rules in codes of conduct of industry associations. (In such cases, your company only needs to disclose the transfers of value on the mentioned due date if your company is a member of that association).
  • “Due date” means the date on which the transfers of value need to be published. For example, the deadline for submitting/sending the complete information to the authority could be before the due date to give HCPs/HCOs the opportunity to check the data that the pharmaceutical companies/medical device companies are going to disclose.
  • The information does not take into consideration:
    • Transparency related to clinical trials (unless it concerns transfers of value as mentioned above)
    • Transparency related to patient organizations (unless the patient organization is considered an HCO)
  • If your company is a member of MedTech/EFPIA (or if the industry association your company belongs to is a member of MedTech/EFPIA), the due dates are as mentioned above for MedTech/EFPIA (end of June), unless a law/regulation specifically states otherwise (e.g., the jurisdiction is suspended/exempted from following MedTech/EFPIA).


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