Global Transparency Reporting Laws & Deadlines

Self-regulatory / member-code disclosure obligations.

Farmindustria Code of Conduct for pharmaceutical companies and Confindustria Dispositivi Medici Code of Ethics for medical device companies.

Usually company websites. Confindustria Dispositivi Medici also provides a public transparency section for member-company documentation.

Member companies subject to the relevant industry code.

Transfers of value to healthcare professionals, healthcare organisations and other covered healthcare-sector recipients, depending on the applicable code.

Thresholds and disclosure categories depend on the applicable industry code and sector.

Generally within the first six months of the year following the year in which the transfers of value occurred.

Typically published annually on the company’s website, often with a methodological note. For medical device companies, Confindustria Dispositivi Medici provides a public transparency section containing documentation from associated companies.

Non-compliance with the Farmindustria Code may result in disciplinary measures, including warnings, financial sanctions, suspension or expulsion from the association.

These industry-code disclosures are separate from, and do not replace, future statutory reporting under Law No. 62/2022 once Sanità Trasparente becomes operational.

Self-regulatory / member-code disclosure obligations.

Pharmaceutical companies may be subject to the SFEE Code, which reflects EFPIA disclosure principles. Medical device companies may be subject to SEIV and MedTech Europe code-based transparency requirements.

Disclosures are generally made through company websites or the applicable industry-code disclosure process.

Member companies subject to the applicable SFEE, EFPIA, SEIV or MedTech Europe transparency framework.

Transfers of value to healthcare professionals, healthcare organisations, patient organisations and other covered healthcare-sector recipients, depending on the applicable code.

Thresholds, categories and exclusions depend on the applicable industry code and sector.

Generally within six months from the end of the reporting year, unless the applicable code or association guidance provides a different timeline.

Disclosures are typically published on company websites or through the applicable industry-code transparency process.

Non-compliance with the SFEE Code may result in disciplinary measures, including corrective actions, financial sanctions, suspension or expulsion from the association.

These industry-code disclosures are separate from the statutory EOF pharmaceutical disclosure regime. They do not replace any statutory disclosure obligation where one applies.

The UK does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the ABPI Code of Practice, administered by the Prescription Medicines Code of Practice Authority. Medical-device and health technology companies may be subject to the ABHI Code of Ethical Business Practice, aligned with broader MedTech Europe transparency principles.

For pharmaceutical companies abiding by the ABPI Code, disclosure is made through Disclosure UK, operated by the ABPI. For device and health technology companies, disclosures are generally made through company websites or the applicable industry-code process rather than a single central UK device database.

Pharmaceutical companies that abide by the ABPI Code of Practice, and ABHI member companies or other device/health technology companies subject to the applicable industry-code framework.

For ABPI disclosure, transfers of value to healthcare professionals, other relevant decision makers, healthcare organisations, patient organisations and certain members of the public, depending on the disclosure category. For device and health technology companies, the relevant scope depends on the ABHI or MedTech Europe-aligned framework.

Reportable transfers of value are disclosed according to the applicable code rules and disclosure categories. The UK self-regulatory frameworks should not be presented as simple statutory monetary-threshold regimes.

For ABPI / Disclosure UK, companies submit disclosure data for the previous calendar year by 31 March, with publication by 30 June. Gateway links for patient organisations and members of the public are submitted closer to the June publication date. For device and health technology disclosures, publication is generally annual and within six months after the end of the relevant reporting period, depending on the applicable industry-code framework.

ABPI pharmaceutical disclosures are published on Disclosure UK, a publicly searchable database. Device and health technology disclosures are generally published through company websites or the applicable industry-code disclosure process.

Non-compliance with the ABPI Code may result in complaints procedures, public reprimands, corrective statements, audits, financial sanctions and suspension or expulsion from ABPI membership.

The UK transparency system is self-regulatory. Disclosure UK is the central ABPI pharmaceutical disclosure database, while device and health technology disclosures do not operate through a single equivalent UK central database.

Self-regulatory requirement.

Germany does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the FSA Transparency Code, which reflects EFPIA transparency principles. Medical-device disclosure may follow the BVMed Code and broader MedTech Europe transparency principles.

For pharmaceutical companies, disclosures are generally published by companies, with FSA providing a transparency overview or access point for member-company disclosures. For medical-device companies, disclosures are generally made through company websites or the applicable industry-code process.

FSA member pharmaceutical companies and companies subject to the applicable BVMed or MedTech Europe-aligned medical-device transparency framework.

Transfers of value to healthcare professionals and healthcare organisations, depending on the applicable code. For medical-device companies, the relevant scope depends on the BVMed or MedTech Europe-aligned framework.

Individual disclosure of transfers of value to healthcare professionals generally depends on consent. Where consent is not available, disclosure is made in aggregate form. Transfers to healthcare organisations are generally disclosed according to the applicable code rules.

Disclosure takes place annually and must be made no later than six months after the end of the reporting period. FSA guidance indicates publication should generally take place between 20 June and 30 June of the following year.

Disclosures are generally published on company websites. FSA provides transparency information and access to member-company disclosures; device disclosures are generally published through company websites or the applicable industry-code process.

Non-compliance with the FSA Transparency Code may result in disciplinary proceedings, financial sanctions and other measures under the FSA Code of Conduct.

Germany’s transparency disclosure framework is self-regulatory. Individual-level HCP disclosure is consent-based, so aggregate disclosure is used where individual consent is not available.

Self-regulatory requirement.

Spain does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the Farmaindustria Code of Practice, which reflects EFPIA transparency principles. Medical-device disclosure is governed by the Fenin Code of Ethics and broader MedTech Europe transparency principles.

For pharmaceutical companies subject to the Farmaindustria Code, disclosures are made through the Farmaindustria transparency framework and company websites. For medical-device companies subject to the Fenin Code or MedTech Europe-aligned framework, disclosures are generally made through company websites or the applicable industry-code disclosure process.

Pharmaceutical companies subject to the Farmaindustria Code, and medical-device companies subject to the Fenin Code or applicable MedTech Europe-aligned transparency framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals, healthcare organisations and patient organisations are covered, depending on the disclosure category. For medical-device disclosure, the Fenin / MedTech Europe-aligned framework focuses mainly on educational grants and other permitted support to healthcare organisations or third parties. Direct sponsorship of individual healthcare professionals to attend third-party educational events is generally restricted under the MedTech Europe model.

Pharmaceutical transfers of value are disclosed according to the Farmaindustria Code categories. Medical-device disclosures are made according to the Fenin / MedTech Europe-aligned categories, particularly educational grants and permitted support. Spain should not be presented as a statutory monetary-threshold Sunshine regime.

Disclosure is annual and generally takes place within six months after the end of the reporting year, usually by 30 June for transfers made in the previous calendar year. This timing applies broadly to both Farmaindustria pharma disclosure and Fenin / MedTech Europe-aligned device disclosure, unless the applicable code or guidance provides otherwise.

Pharmaceutical disclosures are published through the Farmaindustria transparency framework and company websites. Medical-device disclosures are generally published through company websites or the applicable Fenin / MedTech Europe-aligned disclosure process.

Non-compliance with the Farmaindustria Code may result in disciplinary measures, including financial sanctions and publication of decisions by the Code of Practice bodies.

For pharmaceutical disclosure under the Farmaindustria Code, individual HCP disclosure is generally made without requiring prior HCP consent, based on the public-interest / legitimate-interest approach accepted by the Spanish Data Protection Agency. Medical-device disclosure follows a separate Fenin / MedTech Europe-aligned framework, with a stronger focus on educational grants and support to organisations rather than direct individual HCP sponsorship.

Self-regulatory / member-code disclosure obligations.

Pharmaceutical industry disclosure may be governed by Lif / ENLI rules and EFPIA-aligned transparency principles. Medical-device disclosure may be governed by Medicoindustrien and the MedTech Europe Code of Ethical Business Practice.

Industry-code disclosure is generally handled through company websites or the applicable industry-code process, rather than through the Danish Medicines Agency statutory relationship register.

Member companies or companies otherwise subject to the applicable Lif / ENLI, EFPIA, Medicoindustrien or MedTech Europe-aligned framework.

For pharmaceutical companies, disclosure may cover transfers of value to healthcare professionals, healthcare organisations and patient organisations, depending on the applicable code. For medical-device companies, disclosure is generally focused on educational grants and other support covered by the MedTech Europe-aligned framework.

Thresholds, categories and exclusions depend on the applicable industry code and sector.

Industry-code disclosure is generally annual and made within six months after the end of the reporting year, usually by 30 June for transfers or support from the previous calendar year.

Disclosures are generally made through company websites or the relevant industry-code disclosure process.

Non-compliance with ENLI's ethical rules may result in disciplinary measures, financial sanctions and publication of decisions.

Self-regulatory requirement.

Austria does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the PHARMIG Code of Conduct, which reflects EFPIA transparency principles. Medical-device interactions are governed by the AUSTROMED Code and broader MedTech Europe-aligned principles.

Pharmaceutical disclosures are generally published on company-controlled public websites in line with the PHARMIG Code. Medical-device disclosures are generally handled through company websites or the applicable AUSTROMED / MedTech Europe-aligned industry-code process.

Pharmaceutical companies subject to the PHARMIG Code, and medical-device companies subject to the AUSTROMED Code or applicable MedTech Europe-aligned transparency framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals and healthcare organisations are covered, including categories such as research and development, donations and grants, events, and fees for services or consultancy. Patient-organisation support is also subject to PHARMIG transparency requirements. For medical-device companies, the relevant scope depends on the AUSTROMED or MedTech Europe-aligned framework.

Reportable transfers of value are disclosed according to the applicable industry-code rules and disclosure categories. Austria should not be presented as a statutory monetary-threshold Sunshine regime.

Disclosure is annual and must be made no later than six months after the end of the reporting period, generally by 30 June for transfers made in the previous calendar year.

PHARMIG disclosures are generally published on public company-controlled websites and must remain publicly available for at least three years, unless a shorter period is required by law. Medical-device disclosures are generally published through company websites or the applicable AUSTROMED / MedTech Europe-aligned disclosure process.

Non-compliance with the Pharmig Code may result in disciplinary proceedings, financial sanctions and publication of decisions by the Pharmig Code Committee.

Austria’s transparency framework is self-regulatory. Legal anti-corruption, advertising and healthcare-interaction rules may also apply, but they are separate from the industry-code transparency disclosure process.

Self-regulatory requirement.

Swiss pharmaceutical disclosure is governed by the scienceindustries Pharma Cooperation Code, which is based on EFPIA transparency principles.

Disclosure is made by PCC signatory companies, generally through publicly accessible company websites. scienceindustries provides information and overview materials relating to the Pharma Cooperation Code.

Pharmaceutical companies that are signatories to the Pharma Cooperation Code.

Pecuniary benefits granted directly or indirectly in connection with prescription-only human medicines to healthcare professionals, mainly physicians and pharmacists, and healthcare organisations, including hospitals and research institutes. Patient-organisation support is disclosed separately.

Reportable pecuniary benefits are disclosed according to the PCC categories. Individual disclosure requires the consent of the relevant healthcare professional or organisation. Where consent is not available, disclosure is made in aggregate form.

Disclosure is annual and generally made within six months after the end of the reporting year, usually by 30 June for benefits granted in the previous calendar year.

Disclosures are generally published on company websites. scienceindustries also publishes overview information on cooperation grants disclosed by PCC signatory companies.

Non-compliance with the Pharma Cooperation Code may result in disciplinary measures, including corrective actions and publication of decisions by the Code Secretariat.

Self-regulatory requirement.

Ireland does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the Irish Pharmaceutical Healthcare Association Code, which reflects EFPIA transparency principles. Medical-device and health technology companies may be subject to the Irish Medtech Association framework and the MedTech Europe Code of Ethical Business Practice.

For pharmaceutical companies subject to the IPHA Code, disclosures are made through the IPHA Transfers of Value database. For medical-device and health technology companies, disclosures are generally made through company websites or the applicable MedTech Europe-aligned industry-code process.

Pharmaceutical companies subject to the IPHA Code, and medical-device or health technology companies subject to the applicable Irish Medtech or MedTech Europe-aligned transparency framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals and healthcare organisations are covered, including research and development, donations and sponsorship, consultancy fees, speaker fees, conference registration fees, travel costs, data analysis, medical writing and advisory-board participation. For medical-device and health technology companies, the relevant scope depends on the Irish Medtech or MedTech Europe-aligned framework, including educational grants and permitted support to healthcare organisations or third parties.

Reportable transfers of value are disclosed according to the applicable code rules and disclosure categories. Ireland should not be presented as a statutory monetary-threshold Sunshine regime.

Disclosure is annual and generally takes place within six months after the end of the reporting year, usually by 30 June for transfers or support from the previous calendar year.

Pharmaceutical disclosures are published through the IPHA Transfers of Value database. Medical-device and health technology disclosures are generally published through company websites or the applicable industry-code disclosure process.

Non-compliance with the IPHA Code may result in complaints proceedings, corrective actions, financial sanctions and publication of decisions.

Self-regulatory requirement.

Sweden does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by Lif’s Ethical Rules for the Pharmaceutical Industry in Sweden, which transpose EFPIA transparency principles. Medical-device disclosure may follow Swedish Medtech and MedTech Europe-aligned transparency rules. The Swedish healthcare-sector ethics agreement also governs interactions between industry, healthcare and other relevant parties.

For pharmaceutical companies subject to the Lif framework, disclosures are made through the Lif transparency database and/or company websites. Medical-device disclosures are generally handled through company websites or the applicable Swedish Medtech / MedTech Europe-aligned industry-code process.

Pharmaceutical companies subject to Lif’s Ethical Rules, and medical-device companies subject to the applicable Swedish Medtech or MedTech Europe-aligned transparency framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals and healthcare organisations are covered, depending on the disclosure category. For medical-device companies, disclosure generally focuses on educational grants and other permitted support to healthcare organisations or third parties under the Swedish Medtech / MedTech Europe-aligned framework.

Reportable transfers of value are disclosed according to the applicable industry-code rules and disclosure categories. Sweden should not be presented as a statutory monetary-threshold Sunshine regime.

Disclosure is annual and generally made within six months after the end of the reporting year, usually by 30 June for transfers or support from the previous calendar year.

Pharmaceutical disclosures are published through the Lif transparency database and/or company websites. Medical-device disclosures are generally published through company websites or the applicable Swedish Medtech / MedTech Europe-aligned disclosure process.

Non-compliance with the LER Ethical Rules may result in disciplinary measures, financial sanctions and publication of decisions.

Sweden’s transparency framework is self-regulatory. Lif’s pharmaceutical disclosure route follows EFPIA principles, while the Swedish Medtech / MedTech Europe-aligned device route focuses more on educational grants and permitted organisational support.

Self-regulatory requirement.

Norway does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by LMI rules, which reflect EFPIA transparency principles. Medical-device disclosure may follow Melanor and MedTech Europe-aligned transparency principles. Statutory medicines rules also apply to advertising and promotion, but they are separate from the industry-code transfer-of-value disclosure framework.

Disclosures are generally made through company websites or the applicable industry-code disclosure process. LMI provides the pharmaceutical industry framework, while Melanor is the relevant Norwegian industry association for medical-device, laboratory-equipment and assistive-technology companies.

Pharmaceutical companies subject to the LMI rules, and medical-device or health-technology companies subject to the applicable Melanor or MedTech Europe-aligned transparency framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals, healthcare organisations and patient organisations are covered, depending on the applicable disclosure category. For medical-device companies, disclosure generally focuses on educational grants and other permitted support to healthcare organisations or third parties under the MedTech Europe-aligned framework.

Reportable transfers of value are disclosed according to the applicable industry-code rules and disclosure categories. Norway should not be presented as a statutory monetary-threshold Sunshine regime.

Disclosure is annual and generally made within six months after the end of the reporting year, usually by 30 June for transfers or support from the previous calendar year.

Disclosures are generally published on company websites or through the applicable industry-code disclosure process.

Non-compliance with the LMI Code may result in disciplinary measures, financial sanctions and publication of decisions.

Self-regulatory requirement.

Pharmaceutical transfer-of-value disclosure is governed by the Pharma Industry Finland Code of Ethics, which implements EFPIA disclosure principles.

Disclosures are generally published through company websites or the applicable PIF / EFPIA-aligned disclosure process.

Pharmaceutical companies subject to the Pharma Industry Finland Code of Ethics.

Transfers of value to healthcare professionals, healthcare organisations and patient organisations, depending on the applicable disclosure category.

Reportable transfers of value are disclosed according to the PIF Code of Ethics and EFPIA-aligned disclosure categories.

Disclosure is annual and generally made within six months after the end of the reporting year, usually by 30 June for transfers made in the previous calendar year.

Disclosures are generally published on company websites or through the applicable company disclosure process.

Non-compliance with the Pharma Industry Finland Code may result in disciplinary measures, financial sanctions and publication of decisions.

Self-regulatory requirement.

Poland does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the INFARMA Transparency Code, which reflects EFPIA disclosure principles. Additional pharmaceutical industry-code frameworks may apply depending on company membership. Medical-device disclosure may follow POLMED and MedTech Europe-aligned transparency principles.

Disclosures are generally made through company websites or the applicable industry-code disclosure process. INFARMA provides the pharmaceutical transparency framework, while POLMED is the relevant medical-device industry association framework.

Pharmaceutical companies subject to the INFARMA Transparency Code or another applicable pharmaceutical industry-code framework, and medical-device companies subject to the applicable POLMED or MedTech Europe-aligned framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals, healthcare organisations and patient organisations are covered, depending on the applicable disclosure category. For medical-device companies, disclosure generally focuses on educational grants and other permitted support to healthcare organisations or third parties under the MedTech Europe-aligned framework.

Reportable transfers of value are disclosed according to the applicable industry-code rules and disclosure categories. Poland should not be presented as a statutory monetary-threshold Sunshine regime.

Disclosure is annual and generally made within six months after the end of the reporting year, usually by 30 June for transfers or support from the previous calendar year.

Disclosures are generally published on company websites or through the applicable industry-code disclosure process.

Non-compliance with the INFARMA Code may result in disciplinary proceedings, financial sanctions and publication of decisions.

Self-regulatory requirement.

The Czech Republic does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the AIFP Code and AIFP transparency methodology, which reflect EFPIA disclosure principles. Medical-device disclosure may follow CzechMed and MedTech Europe-aligned transparency principles.

For pharmaceutical companies subject to the AIFP framework, disclosures are made through the AIFP transparency process. Medical-device disclosures are generally handled through company websites or the applicable CzechMed / MedTech Europe-aligned industry-code process.

Pharmaceutical companies subject to the AIFP Code, and medical-device companies subject to the applicable CzechMed or MedTech Europe-aligned transparency framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals, healthcare organisations, patient organisations and professional congress organisers may be covered, depending on the applicable disclosure category. For medical-device companies, disclosure generally focuses on educational grants and other permitted support to healthcare organisations or third parties under the MedTech Europe-aligned framework.

Reportable transfers of value are disclosed according to the applicable industry-code rules and disclosure categories. The Czech Republic should not be presented as a statutory monetary-threshold Sunshine regime.

Disclosure is annual and generally made within six months after the end of the reporting year, usually by 30 June for transfers or support from the previous calendar year.

Pharmaceutical disclosures are published through the AIFP transparency process. Medical-device disclosures are generally published through company websites or the applicable CzechMed / MedTech Europe-aligned disclosure process.

Non-compliance with the AIFP Code may result in disciplinary measures, financial sanctions and publication of decisions.

Self-regulatory requirement.

Hungary does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the AIPM Code of Practice, which reflects EFPIA transparency principles. Medical-device disclosure may follow the applicable MedTech Europe-aligned industry-code framework. Hungarian statutory rules also restrict gifts, hospitality and other benefits connected with the promotion of medicinal products and medical aids, but those rules are separate from the self-regulatory transfer-of-value disclosure framework.

For pharmaceutical companies subject to the AIPM Code, disclosures are generally made through company websites or the applicable AIPM disclosure process. Medical-device disclosures are generally handled through company websites or the applicable MedTech Europe-aligned industry-code process.

Pharmaceutical companies subject to the AIPM Code, and medical-device companies subject to the applicable MedTech Europe-aligned transparency framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals and healthcare organisations are covered, depending on the applicable disclosure category. For medical-device companies, disclosure generally focuses on educational grants and other permitted support to healthcare organisations or third parties under the MedTech Europe-aligned framework.

Reportable transfers of value are disclosed according to the applicable industry-code rules and disclosure categories. Hungary should not be presented as a statutory monetary-threshold Sunshine regime.

Disclosure is annual and generally made within six months after the end of the reporting year, usually by 30 June for transfers or support from the previous calendar year.

Disclosures are generally published on company websites or through the applicable industry-code disclosure process.

Failure to comply with statutory transparency requirements may result in administrative sanctions and financial penalties imposed by the competent authorities.

Hungary’s statutory promotion rules restrict gifts, hospitality and other benefits to healthcare professionals, but these rules are separate from the self-regulatory transparency disclosure process.

Pharma self-regulation via AIFD (Association of Research-Based Pharmaceutical Companies); devices via ARTED or national MedTech Europe partner. Additionally, the Turkish Medicines and Medical Devices Agency (TITCK) has regulatory oversight. Transfers of value data are typically gathered and shared with the Ministry of Health on request.

Annual, within 6 months after the end of the reporting period.

Individual company websites or the AIFD platform, depending on membership.

Lithuania operates a hybrid transparency framework comprising statutory disclosure requirements under the Law on Pharmacy (Article 51¹) and implementing regulations, together with the Healthcare Professionals (HCP) and Healthcare Organisations (HCO) Disclosure Code adopted by the Innovative Pharmaceutical Industry Association (IFPA) and the Pharmaceutical Manufacturers Association (PMA), aligned with the EFPIA Disclosure Code.

State Medicines Control Agency (SMCA) for statutory reporting. Self-regulatory disclosures are administered by IFPA/PMA and published by participating companies.

The statutory framework requires pharmaceutical companies and their representatives to report sponsorship of healthcare professionals participating in scientific and promotional events, including registration fees, travel, accommodation and related support. The Disclosure Code additionally requires disclosure of transfers of value to healthcare professionals and healthcare organisations, including consultancy fees, speaker fees, donations, grants, sponsorships and research and development payments.

Annual.

Statutory reports must be submitted to the State Medicines Control Agency by 1 February for the preceding calendar year. Under the Disclosure Code, participating companies must publish disclosures within six months after the end of the reporting period.

State Medicines Control Agency (SMCA) portal (statutory reporting) and participating company websites (Disclosure Code).

Statutory disclosures are published by the State Medicines Control Agency. Self-regulatory disclosures are published annually by participating companies and remain publicly available for at least three years.

Failure to comply with the statutory reporting obligations may result in administrative sanctions under the Law on Pharmacy. Non-compliance with the Disclosure Code may result in disciplinary proceedings and sanctions under the applicable IFPA/PMA Codes.

Since 2020, individual disclosure of transfers of value to healthcare professionals is required by Lithuanian law, meaning recipient consent is no longer required for statutory disclosures. The self-regulatory Disclosure Code continues to supplement the statutory framework for participating companies.

The APME Code of Ethics, administered by the Association of Pharmaceutical Manufacturers in Estonia (APME), is based on and implements the EFPIA Code of Practice. The Code governs the promotion of medicinal products and the disclosure of transfers of value to healthcare professionals (HCPs), healthcare organisations (HCOs) and patient organisations by member companies.

Association of Pharmaceutical Manufacturers in Estonia (APME).

Transfers of value to healthcare professionals, healthcare organisations and patient organisations, including consultancy and speaker fees, sponsorships, educational support, donations, grants, event-related expenses and research and development payments disclosed in accordance with the APME Code.

Annual.

Disclosures must be published within six months after the end of the reporting period, in line with the EFPIA Disclosure Code.

Member company websites.

Participating companies publish annual disclosures on their websites. The EFPIA European Disclosure Gateway provides links to participating company disclosures.

Non-compliance with the APME Code may result in disciplinary proceedings, corrective measures and sanctions under the APME Code Enforcement Procedure.

Estonia does not currently operate a statutory Sunshine Act. Transparency reporting is based on the APME Code of Ethics, which aligns with the EFPIA Disclosure Code and applies to APME member companies.

The Code of Ethics of the Innovative Pharmaceutical Initiative (iF!) implements the EFPIA Code of Practice in Croatia and establishes the requirements for the disclosure of transfers of value between member pharmaceutical companies and healthcare professionals (HCPs), healthcare organisations (HCOs) and patient organisations.

Innovative Pharmaceutical Initiative (iF!).

Transfers of value to healthcare professionals, healthcare organisations and patient organisations, including consultancy and speaker fees, advisory services, sponsorships, educational support, donations, grants, event-related expenses and research and development payments.

Annual.

Disclosures must be published within six months after the end of the reporting period, in accordance with the EFPIA Disclosure Code.

Member company websites.

Participating member companies publish annual disclosure reports on their websites. The EFPIA European Disclosure Gateway provides links to participating company disclosures.

Non-compliance with the iF! Code of Ethics may result in disciplinary proceedings, corrective measures and sanctions under the association's Code Enforcement Procedure.

Croatia does not currently operate a statutory Sunshine Act. Transparency reporting is based on the iF! Code of Ethics, which is aligned with the EFPIA Disclosure Code and applies to member pharmaceutical companies.

The INOVIA Code of Practice, administered by the Association of Innovative Drug Manufacturers (INOVIA), implements the EFPIA Code of Practice in Serbia and governs the disclosure of transfers of value between member pharmaceutical companies and healthcare professionals (HCPs), healthcare organisations (HCOs) and patient organisations.

INOVIA – Association of Innovative Drug Manufacturers.

Transfers of value to healthcare professionals, healthcare organisations and patient organisations, including consultancy and speaker fees, advisory services, sponsorships, educational support, donations, grants, event-related expenses and research and development payments.

Annual.

Disclosures must be published within six months after the end of the reporting period, in accordance with the INOVIA Code and EFPIA Disclosure Code.

Member company websites. Companies may also disclose through a central platform where available, provided it complies with the INOVIA Code.

Participating member companies publish annual disclosure reports on their websites. The EFPIA European Disclosure Gateway provides links to participating company disclosures.

Non-compliance with the INOVIA Code may result in disciplinary proceedings, corrective measures and sanctions under the INOVIA Code Enforcement Procedure.

Serbia does not currently operate a statutory Sunshine Act. Transparency reporting is based on the INOVIA Code of Practice, which aligns with the EFPIA Disclosure Code and applies to INOVIA member companies.

Self-regulatory requirement.

The Russian Federation does not have a single statutory Sunshine Act. Pharmaceutical disclosure is governed by the AIPM Code of Practice, which includes transparency provisions for transfers of value to healthcare professionals and healthcare organisations. Medical-device disclosure may follow the IMEDA Code of Ethical Business Practice and MedTech Europe-aligned transparency principles.

Disclosures are generally made through company websites or the applicable industry-code disclosure process. AIPM provides the pharmaceutical industry-code framework, while IMEDA provides the medical-device industry-code framework.

Pharmaceutical companies subject to the AIPM Code, and medical-device companies subject to the applicable IMEDA or MedTech Europe-aligned transparency framework.

For pharmaceutical disclosure, transfers of value to healthcare professionals and healthcare organisations are covered, depending on the applicable disclosure category. For medical-device companies, disclosure generally focuses on educational grants and other permitted support to healthcare organisations under the IMEDA / MedTech Europe-aligned framework.

Reportable transfers of value or educational grants are disclosed according to the applicable industry-code rules. Individual-level disclosure involving healthcare professionals is subject to Russian personal-data requirements, including appropriate consent where required.

Disclosure is annual and generally made by 30 June of the year following the reporting year.

Disclosures are generally published on company websites or through the applicable industry-code disclosure process.

Non-compliance with the AIPM Code may result in disciplinary measures under the association's Code of Practice, including corrective actions and sanctions against member companies.

Engagement with the Russian market may be affected by international sanctions, export controls and company-specific restrictions. These issues are separate from the industry-code transparency framework and should be assessed independently.

Mecomed Code of Ethical Business Practice (first enacted 2007, updated 2017), administered by Mecomed - the medical devices, imaging and diagnostics trade association for the Middle East and Africa.

Currently disclosing entities cover GCC countries excluding KSA - i.e. United Arab Emirates, Kuwait, Qatar, Bahrain, Oman. The wider Mecomed Code of Ethics has been trained and applied across UAE, KSA, Lebanon, Jordan, Iraq, Kuwait, Syria, Palestine, Morocco, Tunisia and Egypt.

Educational Grants (Type A: to support Third-Party Organised Educational Events, including attendance, faculty support and event running; Type B: scholarships, fellowships, grants for public awareness campaigns).

Annual, each reporting period covering a full calendar year.

Not later than 6 months after the end of the reporting period (webpage notes: 'Annually, not later than 6 months after the end of the reporting period. Each reporting period covers full calendar year, starting on 1 January and ending 31 December.')

Transparent Mecomed (disclosure.mecomed.com) - data published for access by Mecomed members, with a view to broader public access over time.

Medicines Australia Code of Conduct - Edition 20, formally adopted at the Medicines Australia AGM on 30 October 2024 and in effect from 30 March 2025. The Code is underpinned by the Therapeutic Goods Act 1989 and Therapeutic Goods Regulations 1990.

Medicines Australia (for pharma). Devices are covered by MTAA (Medical Technology Association of Australia) under a separate but similar code.

Transparency reports cover payments and transfers of value to healthcare professionals (speaker fees, consultancy, advisory boards, educational sponsorships). Edition 20 expanded transparency reporting to include grants and donations to healthcare organisations, aligning Australia more closely with international norms.

Two reporting periods per year. Under Edition 20, the standard periods are 1 January–30 June and 1 July–31 December, with submissions due 31 October and 30 April respectively. Check Medicines Australia’s current timetable for any Edition 20 transition-period exceptions.

Public reports on the Medicines Australia website.

Code breaches can lead to monetary fines and corrective action. The Code lists fines by breach category, and Medicines Australia states companies found to have breached the Code can be fined up to AUD 300,000.

Japan operates a dual transparency framework comprising: (i) the Japan Pharmaceutical Manufacturers Association (JPMA) Transparency Guideline for the Relation between Corporate Activities and Medical Institutions (originally issued in 2011 and most recently revised in March 2025); (ii) the Japan Federation of Medical Device Associations (JFMDA) Transparency Guidelines for the Medical Device Industry; and (iii) Article 33 of the Clinical Research Act, effective from 1 April 2018, which establishes statutory disclosure requirements for Specified Clinical Research.

JPMA (pharmaceutical companies) and JFMDA (medical device companies). Disclosures are published individually by member companies rather than through a central reporting authority.

Disclosures generally include research and development expenses, academic research support, donations, manuscript and writing fees, lecture fees, consulting fees, information provision-related expenses and other transfers of value. Transparency relating to patient organisations is governed by separate JPMA guidance.

Annual, aligned with each company's fiscal year.

Each member company's website.

Disclosure reports are published annually on the websites of participating member companies.

The Clinical Research Act establishes separate statutory disclosure obligations for Specified Clinical Research, while broader transparency reporting continues to be governed primarily through the JPMA and JFMDA industry guidelines.

Medicines New Zealand Code of Practice - self-regulatory for pharma and devices. Supplemented by general medicines regulation under Medsafe.

Medicines New Zealand.

Annual disclosure - due by 30 June each year for the preceding reporting period.

Individual company disclosures and Medicines New Zealand central resources.

Event-centred; wider Sunshine-style disclosure framework pending

Department of Health (DOH) Administrative Orders and Food and Drug Administration (FDA) regulations governing industry-sponsored meetings and interactions with healthcare professionals, supplemented by the Pharmaceutical and Healthcare Association of the Philippines (PHAP) Code of Practice.

Department of Health (DOH), through the Office of the Secretary, and the Food and Drug Administration (FDA).

Notification and disclosure requirements primarily relate to company-sponsored scientific meetings, educational events, sponsorships and similar interactions involving healthcare professionals and healthcare organisations.

Notice of Meetings must generally be submitted one month prior to the scheduled event.

Failure to comply with applicable DOH and FDA requirements may result in administrative sanctions under Philippine healthcare regulations. Non-compliance with the PHAP Code may also result in disciplinary measures against member companies.

The current framework is event-centred rather than a comprehensive annual Sunshine-style disclosure regime. Broader transparency reporting requirements continue to be considered through ongoing regulatory developments.

Health Sector Payment Transparency Act, 2017 (HSPTA), part of the Strengthening Quality and Accountability for Patients Act, 2017. Ontario is the first Canadian province to adopt mandatory Sunshine-style legislation.

The statute is law but operational implementation has been repeatedly delayed since 2018. Draft regulations have been consulted on but have not been finalised or enforced; as a result, the HSPTA is not yet actively operative for industry reporting. Companies should continue to monitor the Ontario Ministry of Health's publications and engagement.

Ontario Ministry of Health.

Transfers of value from 'payors' (pharmaceutical and medical device companies and related entities) to 'recipients' (regulated health professionals, their colleges and associations, patient groups, and other broadly defined categories).

Transactions below CAD 10 and employment-related salaries/benefits were proposed to be exempt.

End of June.

Public, searchable database to be maintained by the Ministry of Health.

Fines of up to CAD 10,000 per day of non-compliance for individuals and up to CAD 100,000 per day for corporations.