transparency obligations overview

Latest update: 14 September 2018 | Important Notes

Report Due Date

Annually for a full calendar year. Pecuniary benefits are to be disclosed in each case within six months of the end of a reporting period.


Science Industries (see details in text)

Who Must Report

Pharmaceutical companies that are required to comply with the Pharma Cooperation Code (See: pharma cooperation code signatories)

Covered Recipients

Healthcare professionals (HCPs) or healthcare organizations (HCOs)

Report Due Date

No later than 31 August of the year following the reporting period. Companies wishing to publish on the Swiss Medtech website will send the template provided by Swiss Medtech (Annex 1) to the Swiss Medtech office no later than 30 June of the year following the reporting period.


Swiss MedTech

Who Must Report

Members of Swiss MedTech

Covered Recipients

Healthcare organisations (HCOs)

Pharmaceutical Companies

What is reported:

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)

How to Report

The pharmaceutical companies must satisfy their disclosure obligation on their corporate website, which is accessible to the public, either in Switzerland or internationally. In principle, disclosure must be made in the English and whenever possible in the German, French and Italian languages. To indicate the HCOs, use their name in the relevant language or languages.

Medical Device Companies

What is reported:

Spend related to educational grants on a yearly basis.

How to Report

Each company and its subsidiaries should disclose training grants per calendar year on an aggregated basis. Disclose for each of the following categories and name each individual recipient:

  • Grants to events organized by third parties, including support for HCPs’ participation in education events organized by third parties
  • Other grants to medical institutions, including scholarships, fellowship programs and/or education grants

Aggregate the amounts disclosed per category and recipient.

Disclosures must be made in accordance with the disclosure policy in an official language or English. Use the template in the appendix (Annex 1).

Disclosures should be made either on the company’s website or on the Swiss MedTech website.


MedTech Code:
Link to MedTech Code currently published on MedTech website:
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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