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Canada
transparency obligations overview

Latest update: 21 January 2019 | Important Notes

Pharmaceutical Companies

What is reported:

The Voluntary Framework on Disclosure of Payments provides members of Innovative Medicines Canada with a framework to publish aggregated sums of payments to Canadian healthcare professionals (HCP) and healthcare organizations (HCO).

As of June 2017, 10 Canadian pharmaceutical companies – all of them members of Innovative Medicines Canada – started publishing aggregated sums of their payments to Canadian healthcare professionals (HCP) and healthcare organizations (HCO) based on the following reporting framework:

  1. One sum total of the company’s payments to HCPs for services such as speaking and/or consulting.
  2. One sum total of the company’s funding to HCOs, which supports efforts such as philanthropic (charitable), educational and/or scientific activities.
  3. One sum total of the company’s funds provided to HCPs to support their travel to attend international congresses and/or global standalone meetings.

Details related to those categories could be found here: http://innovativemedicines.ca/ethics/voluntary-disclosure-of-payments/

See also: http://innovativemedicines.ca/wp-content/uploads/2018/06/Code-Formatted_Regular_EN-2.pdf under “ANNEX A INNOVATIVE MEDICINES CANADA GUIDELINES FOR TRANSPARENCY IN STAKEHOLDER FUNDING” e.g.:
“Members should regularly disclose, by means of their web sites and annual reports, a list of all stakeholders to which they provide direct funding.”

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 provided reflects the 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 – in most cases – 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 case it is based on codes of conduct, your company only needs to disclose the transfers of value on the mentioned due date if your company is a member of the association that follows that code.
  • Including a jurisdiction in the Legislative Watch does not guarantee that jurisdiction is available for reporting via the MediSpend Transparency Reporting Solution.
  • Reporting date normally means the date the transfers of value need to be published. The deadline for e.g. submission/sending the complete information to the authority could be before that date, for example to give HCPs and/or HCOs and/or the authority/association who publishes the information, the possibility to check the data the pharmaceutical companies/medical device companies are going to disclose.
  • The information does not take into consideration (unless explicitly mentioned):
    • 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)


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