The Netherlands
transparency obligations overview

Latest update: 3 July 2019 | Important Notes

Pharmaceutical Companies

What is reported:

  • Service agreements
  • Agreements regarding hospitality
  • Sponsorship agreements
  • Agreements for the support of patient organisations
Authority Details

The Foundation for the Code for Pharmaceutical Advertising (CGR) followed by members of the following organizations:

  • Nefarma (Association for Innovative Medicines in The Netherlands)
  • Bogin (Association of the Dutch Generic Medicines Industry)
  • Neprofarm (Association of the Pharmaceutical Industry for Self-Care Medicines and Healthcare Products)
  • KNMG (The Royal Dutch Medical Association)
  • KNMP (The Royal Dutch Pharmacists Association)
  • V & VN (The Dutch Nurses Association)
  • NAPA (The Netherlands Association of Physician Assistants)
  • CBD (The Dutch Association of druggists)

Medical Device Companies

What is reported:

Companies must report financial relations with recipients who have a total TOV sum for the calendar year exceeding 500 euros:

  • Remuneration of services
  • Sponsorship of projects or activities other than meetings, between:
    • HCPs listed in the BIG Register in the category “doctor”(except general practitioners); including those in collaboration with institutions
    • Suppliers of medical devices

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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