Transparency Reporting Enforcement: Lessons from Recent High-Profile Cases

Transparency reporting is no longer just a regulatory formality. Around the world, enforcement bodies, prosecutors, and self-regulatory authorities are treating disclosure data as evidence of culture, governance, and—in some cases—misconduct.

Recent years have produced headline cases that reveal a common story: when transparency reporting breaks down, the consequences reach far beyond technical non-compliance.

Examples below are drawn from publicly available cases and code-authority rulings; details and enforcement mechanisms vary by jurisdiction.

The UK: From Reporting Lapses to Public Reprimands

In July 2024, the U.K. ‘s Prescription Medicines Code of Practice Authority (PMCPA) reprimanded Novo Nordisk after finding that approximately £7.8 million in transfers of value to health-sector organisations had not been disclosed.

These omissions represented an estimated 10–14 % of annual reporting totals between 2020 and 2022. Academic researchers had previously highlighted apparent discrepancies, and once the regulator confirmed the failures, the reputational impact quickly outpaced any administrative penalty.

Shortly after, Moderna was publicly reprimanded for failing to provide complete and candid information during a prior investigation.
What could have remained a narrow compliance issue became a wider question of corporate culture and governance.

The Swiss drugmaker Novartis UK also faced rulings in 2025 for governance lapses and disguised promotion, reinforcing that reporting and disclosure quality are inseparable from broader compliance standards.

Together, these cases show how enforcement in the U.K. is evolving: it is no longer confined to financial disclosures but is extending into governance, transparency of process, and credibility with regulators.

The United States: Reporting Failures as Enforcement Leverage

Across the Atlantic, U.S. regulators and prosecutors continue to integrate transparency obligations into broader enforcement activity.
While the Sunshine Act’s Open Payments system may appear to be a technical disclosure exercise, it has become part of the prosecutable record.

In recent settlements, companies such as Medtronic and Medicrea paid multimillion-dollar sums that included allegations of kickback and False Claims Act violations, with reporting deficiencies under the Open Payments Program cited among the compliance concerns.

In large-scale cases such as Jazz Pharmaceuticals and Insys Therapeutics, speaker-program payments and disclosure failures were central elements in the government’s evidence, with penalties stretching into the tens and hundreds of millions.

Most recently, the 2025 National Healthcare Fraud Takedown in the U.S. underscored the government’s increasingly data-driven approach. The takedown involved 324 defendants and alleged fraud exceeding $14.6 billion. While much of this focused on telemedicine, opioids, and medical-equipment fraud, the message is unmistakable: federal agencies are mining datasets—including Open Payments—to detect patterns and escalate cases quickly.

In the U.S., transparency reporting failures rarely stand alone; they amplify broader misconduct cases, raising both financial exposure and reputational stakes.

Developments Shaping the Enforcement Landscape

The recent cases highlight several trends that compliance leaders should recognise globally:

• Public scrutiny is multiplying. Academic researchers, NGOs, and media outlets are cross-referencing disclosures with other public datasets, often identifying discrepancies before authorities act.
• Candour matters. As seen in the Moderna case, how a company engages with regulators during an investigation has become part of the compliance expectation. Transparency now extends beyond published numbers to how organisations respond under pressure.

Data is the backbone of enforcement. With regulators using analytics and AI, transparency data is increasingly combined with claims, finance, and whistle-blower reports to detect misconduct at speed.

Europe’s Position in This Global Trend

The U.K. cases show how self-regulatory regimes can have real impact. In other parts of Europe, the frameworks already exist for enforcement—even if the headline cases have yet to emerge.

• France has one of the most detailed statutory regimes, providing for administrative fines of up to €225 000 for non-disclosure. The system is mature and legally binding, making it a matter of when, not if, high-profile enforcement arrives.
• The Netherlands has operated its Transparantieregister Zorg for a decade. Disclosures above €500 per recipient are centralised and published annually. Even without statutory penalties, reputational risk is built in: discrepancies are visible to anyone who searches the register.
• Italy is rolling out its Sanità Trasparente telematic register under Law 62/2022. Once fully operational, its government-managed disclosures will place companies under direct public scrutiny. Early reporting issues are expected to attract heightened attention and may inform future enforcement practice.

The pattern is clear: Europe already has the legal and technical infrastructure in place, and the next enforcement headlines will likely emerge as these national registers mature.

Learning from Enforcement: Regulators Are Using AI Too

The lessons are not regional, they apply globally:

• Transparency reporting is enforcement-grade: treat disclosures with the same rigour as financial statements.
• Data quality is critical: validation should mirror regulator and portal checks, not just internal spreadsheets.
• Governance drives credibility: failures in oversight, reconciliation, and accountability almost always surface in enforcement.
• Public exposure is inevitable: whether through a regulator, journalist, or academic study, discrepancies will be found and amplified.

For boards, the real question is not whether enforcement will reach your jurisdiction, but whether your organisation is ready to withstand the same scrutiny faced by peers in the U.K. and U.S.

The Path Forward

A proactive stance is the only safeguard. Companies that invest in robust data integrations, clear accountability structures, and scenario planning for disclosures are not just avoiding penalties, they are protecting reputation, credibility, and market trust.

Transparency reporting has become a global compliance benchmark. The recent cases are a warning sign: weak systems don’t just fail audits, they create headlines.