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Global Transparency Bulletin

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Get the most up-to-date information regarding the evolving nature of spend transparency in the pharmaceutical, life sciences, and health industries.

April 2021 Update


France is enhancing its submission portal with the goal of simplifying and streamlining the transparency reporting process. These enhancements are underway now with completion anticipated for this summer (2021). The key changes include:

  • Report Submissions:
    • Declarations using ‘csv’ flat files will no longer be accepted
    • Going forward, submissions may be made manually at the transaction level, or via a "web connection"
  • Reporting Fields:
    • Fewer fields will be required for submission and required field values will be simplified
    • Some fields will be auto-populated based on information such as RPPS and SIREN number
    • Avantage, remuneration, and convention reporting will no longer be separated

The authorities have indicated that the new database will be operational for reporting of data from the first half of 2021 (a testing period is planned for May 2021). We will continue to monitor these changes and will provide more information as it becomes available.

July 2020 Update

United Kingdom

In April, we notified you that the Association of the British Pharmaceutical Industry (ABPI) had released guidance that 2019 data would be submitted and disclosed in the aggregate in an effort to ease the burden on healthcare professionals to review the data during the initial stages of the COVID-19 pandemic.

ABPI has published the 2019 aggregated data, but is now requesting companies "disaggregate" their data and disclose at the individual level. Reports with disaggregated 2019 transfers of value are to be submitted by 31 July 2020. Disaggregated data refers to the individual disclosures for recipients who provided consent for standard disclosure.

The submission portal will be open for companies to submit from Monday 20 July to Friday 31 July at 14:00 GMT.

ABPI also asked companies to confirm that the already published 2019 aggregate data is up to date. The aggregate data will remain published until the official disaggregated data is made available to the public.

June 2020 Update


Recently the National Organization for Medicines (EOF) announced that the deadline for 2019 local EOF disclosure was moved up from September 30, 2020 to June 30, 2020. No change has been noted for the local submission process.


On May 29, 2020, the Colombia Ministry of Health and Social Protection announced that companies will now be able to submit data that was missed from the report due in March 2020. The Registry of Transfers of Value of the Health Sector (“RTVSS”) will be open from June 1-30, 2020 to submit the late data. 

How PwC can help:

  • Provide experienced resources to support transparency program
  • Deliver hands on, fast approach to tackle data quality issues
  • Generate automated transparency reports based on your company’s unique data inputs and customized business rules
  • Coordinate with Third Party Vendors and review accuracy/completeness of data
  • Strategize and implement process improvements to reduce cost and maximize efficiencies
  • Provide technology through our latest PwC product offering Transparency Hub - a true all-in-one, cloud-based solution for global transparency reporting.

Ready to learn more?

PwC has a team of experienced compliance professionals ready to support your transparency program needs!

Feeling overwhelmed with activities leading as we enter into the critical reporting season? We hear you! PwC has a global team of trusted advisors that can support you and your team navigate through the complexity of reporting. Please reach out to us to start the conversation.

This content is for general information purposes only and should not be used as a substitute for consultation with professional advisors.

Contact us

David Wysocky

Principal, Pharmaceutical and Life Sciences Transparency Leader, PwC US

Nate Lebowitz

Director, Requirements Lead, PwC US

Tim Canonico

Partner, Pharmaceutical & Life Sciences, PwC US

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