transparency obligations overview

Latest update: 26 September 2019 | Important Notes

Pharmaceutical Companies

What is reported:

“Pecuniary benefits”

The pharmaceutical companies which are required to comply with this Code shall disclose pecuniary benefits which they grant to healthcare professionals or healthcare organisations in compliance with the following rules.

The PCC defines the term “pecuniary benefits” as remuneration granted either directly or indirectly in connection with pharmaceuticals for human medicine available by prescription only. The disclosure includes payments made for consultancy and the provision of services, financial support for research and development in the healthcare sector, and cost contributions for the attendance of professionals at events.

There are a few exceptions from the obligation to disclose pecuniary benefits, e.g.:

  • Normal commercial compensation for professionals when pharmaceuticals are ordered and delivered
  • Delivery of pharmaceutical samples without payment to professionals within the limits of the official recommendations
  • Information and training materials of modest value
  • Payment for meals (including beverages)
Authority Details:

Science Industries

Self-regulatory Pharma Cooperation Code (PCC) followed by the Associations of the Pharmaceutical Industry in Switzerland:

  • scienceindustries (Business Association Chemistry Pharma Biotech)
  • Intergenerika (Association of the Generic Medicines Manufacturers in Switzerland)
  • Interpharma (Association of the Research Based Pharmaceutical Companies in Switzerland)
  • vips (Association of Pharmaceutical Companies in Switzerland)

Medical Device Companies

What is reported:

According to the code: transfers of value related to educational grants on a yearly basis.


We understand from MedTech Europe that – for reporting in Switzerland – it  may be required to collect legal entity’s consent, before data can be published.

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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