Cross-Border Payment Complexity: Navigating Multi-Jurisdictional Transparency Requirements

Let’s break this down. And like all things complex, it helps to use a fictional case study to simplify what otherwise feels like chaos.

The Local Comfort Zone

In the U.S., transparency reporting has been in place for more than a decade, starting in 2013. By now, a mid-sized pharmaceutical company likely has its systems reasonably well-configured. Expense management and accounts payable systems are integrated to capture Healthcare Professional (HCP) details and categorize the “nature of payment” for downstream aggregate spend teams.

State requirements? Perhaps handled manually. After all, the volume of state-level activity is usually low, and manual workarounds seem sufficient. The mindset: we’re small, we don’t need extensive configurations.

And then, cue the record scratch, cross-border activities creep in.

Oops…Madrid?

Imagine this: The compliance team suddenly learns that a clinical trial steering committee meeting is scheduled in Europe. No problem, just a one-day event in Madrid. But the guest list? It includes investigators from France, Belgium, and Italy… and one Italian HCP who happens to be traveling in from South Korea.

What could possibly go wrong?

Plenty!

Systems Built for One Country, Not Many

The company’s expense reporting system is configured for the U.S., for example, NPIs (National Provider Identifiers), but France uses RPPS numbers, Belgium has its own unique identifiers, and Italy…well, before its new Sunshine Law rolls out, requires reporting via industry codes such as EFPIA or Confindustria, so basically no identifiers for now. None of these are set up in the system.

Currency? Another headache. In the system, Everything defaults to USD. But the Italian HCP’s reimbursement is in KWK, which must somehow be converted into Euros for EFPIA, while still being tracked in USD in the expense reporting system. If someone overlooks the manual conversion, suddenly the reimbursement appears inflated by several multiples.

What was meant to be a “simple” one-day meeting has morphed into a compliance nightmare.

The Three-Headed Monster: France, Belgium, and Italy

France (CNOM Authorization)

In France, if the contract value for an HCP exceeds €2,000, prior authorization from CNOM (the French Medical Council) is required. And not just a quick online filing, this must be done at least two months in advance.

Uh oh, too late for that now, the meeting in Madrid is only 15 days away. With airfare, hotels, and honoraria, the €2,000 threshold is already guaranteed to be crossed. Suddenly, the compliance team is scrambling to explain why the authorization wasn’t filed in time and whether the event can even proceed without risking non-compliance.

Belgium (Mdeon Visa)

Belgium raises the bar further. Any hospitality offered to Belgian HCPs requires a so-called Mdeon visa application. This isn’t about travel visas; it’s a regulatory pre-approval process for events. And again, this isn’t something you can whip up overnight; applications must be filed at least 15 days prior to the event.

Exception: less than 15 people (HCPs and company representatives) and participants of different nationalities, 6 working days prior are ok. So, with Belgium, our fictional company still has hope…

But, Belgium enforces some of the strictest hospitality caps in Europe:

• €45 for lunch
• €90 for dinner (including beverages)
• Daily maximum of €135
• Accommodation capped at €250 per night

Picture this: you’ve booked a hotel in central Madrid at €275 per night because nothing cheaper was available during conference week. Too late now, the HCP is already ticketed. One misstep, one slightly over-budget dinner, and suddenly the company has breached Belgian limits.

Italy (Pre-Sunshine Transition)

Before Italy’s Sunshine Law fully takes effect, reporting obligations exist under industry codes. This requires coordination with local industry associations, which often have different submission portals and formats.

And here’s the kicker: once the new law is enforced, companies must be ready to file structured data directly with the Ministry of Health. If systems aren’t updated in time, historical gaps could surface later. Imagine backfilling those gaps under regulatory scrutiny across borders. Not fun.

When Compliance Becomes Event Management

What started as a straightforward conference has ballooned into:

1. Three different reporting obligations (France, Belgium, Italy).
2. Multiple data collection requirements (NPI vs. RPPS vs. no identifier at all).
3. Currency conversions across four denominations (USD, EUR, KRW, and potentially other, if travel routes shift).
4. Regulatory pre-approvals (CNOM and MDEON) require foresight well before the event takes place.

And who’s handling all this? Compliance? Legal? The phantom affiliates that don’t even exist in these countries? Suddenly, the U.S. headquarters compliance officer is playing the role of global event coordinator, regulatory translator, and project manager, all for a single meeting.

Possible Solutions: Centralization and Standardization

The purpose of this blog isn’t to provide a one-size-fits-all answer, but it’s worth reflecting on what often works in practice.

Companies trying to juggle dozens of reporting requirements quickly learn that patching local systems together doesn’t scale. What tends to succeed is moving toward a single, global point of coordination, one source that can:

• Coordinate the setup and cadence of the capturing HCP data consistently across countries, with local identifiers built in.
• Apply currency conversions in a standardized way to avoid inflated or underreported values.
• Track jurisdiction-specific thresholds and pre-approval timelines before they become last-minute surprises.
• Produce outputs that match each market’s disclosure format, whether CSV, pipe-delimited, XML (wink wink, the Italians are smiling), EFPIA templates, or CNOM/MDEON approval filings.

This kind of approach isn’t about technology alone; it’s about having a partner who understands the nuances of cross-border reporting and can bring order to the patchwork.

Closing Thoughts

Cross-border transparency reporting is a classic example of complexity in motion. Each country’s rules may make sense locally, but together they create a patchwork quilt that’s nearly impossible to manage without foresight and infrastructure.

Our fictional Madrid meeting shows how a single event can trigger reporting obligations in four countries, highlight system gaps, and demand regulatory approvals that nobody flagged in time.

The real lesson? Global activities demand global systems. Local comfort zones won’t cut it anymore. For companies operating in multiple jurisdictions, centralization, and forward-planning aren’t luxuries; they’re necessities.

And while there may not be a simple fix, experience shows that working with the right global partner, one equipped to anticipate, translate, and standardize across borders, can mean the difference between firefighting and foresight.