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United Kingdom
transparency obligations overview

Latest update: 31 October 2018 | Important Notes
PHARMACUETICAL

Report Due Date

Submission is required by 29 March each year for publication on 28 June

Authority

ABPI

Who Must Report

ABPI member companies

Covered Recipients

Healthcare professionals (HCPs) and healthcare organisations (HCOs) located in Europe
MEDICAL DEVICE

Report Due Date

Annually within 6 months after the end of the relevant reporting period

Authority

Association of British Healthcare industries (ABHI)

Who Must Report

Members of ABHI

Covered Recipients

Healthcare organizations (HCOs)

Pharmaceutical Companies

What is reported:

  • Joint working
  • Donations, grants and benefits
  • Contracts between companies and institutions, organizations and associations
  • Sponsorship of attendance by HCPs and other relevant decision makers at meetings
  • Fees and expenses paid to HCPs and other relevant decision makers, or to their employers on their behalf
  • Contributions towards the costs of meetings paid to HCOs or to third parties managing events on their behalf, which may include sponsorship of HCPs by way of registration fees and accommodation and travel

Meals are not included.

How to Report

Via the industry association’s website.
See UK disclosure template here: pmcpa.org.uk/Disclosure.
Companies must publish a summary of the methodologies used to prepare the disclosure.

Medical Device Companies

What is reported:

Aggregate spend regarding educational grants

How to Report

An example of the template can be found in annex II of the following source: abhicodeofpractice.org.uk Code of Business Practice May 2017.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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