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The AMNOG dossier: what it contains, how long it takes, what it costs

The dossier is due the day you launch in Germany, the negotiated price applies from month seven, and the industry puts the cost of one dossier at close to a million euros. The decisions that drive all three are made a year or more earlier.

11 min read By Alexander Baranov, Founder Updated October 2026
In one paragraph

A new medicine launched in Germany must submit a benefit dossier to the G-BA at market entry (§35a SGB V) — five modules, the core in German, filed through the G-BA portal. The assessment (usually by IQWiG) is published after 3 months, the G-BA decides after about 6 months, and the price negotiated with the statutory insurers applies from month 7. The G-BA charges for advice (EUR 3,200–16,000 per consultation), and early-advice slots are booked months ahead. The research-based industry association vfa puts a dossier at about EUR 800,000 and 12 months of work. About half of all procedures since 2011 found an added benefit, with a lower share in recent years.

What the dossier is

Since 2011, every new active substance launched in Germany goes through an early benefit assessment. The dossier is the company’s case for an added benefit over the appropriate comparator — and the burden of proof is on the company.

It is due at first market launch, and for a new indication within four weeks of its approval. Orphan drugs are treated as having an added benefit by law until their statutory-insurance revenue passes EUR 30 million in 12 months; above that, a full dossier is due within three months of the G-BA’s request. For how the assessment shapes the price, see AMNOG explained.

The timeline

StepWhenNotes
G-BA early advice12–24+ months before launchBy law within 8 weeks of a complete request — but slots are booked out months ahead
Dossier submissionDay of launchNew indication: within 4 weeks of approval
Benefit assessment publishedMonth 3Usually by IQWiG on behalf of the G-BA
Written and oral hearingMonths 3–5Company, experts and associations comment
G-BA decisionAbout month 6Extent of added benefit per patient group
Price negotiationWithin 6 months of the decisionWith the GKV-Spitzenverband; arbitration within 3 months if it fails
Negotiated price appliesFrom month 7 after launchSettled retroactively; free pricing only in months 1–6

In October 2026 the G-BA showed advice slots booked out until spring 2027: the next free submission week was calendar week 15 of 2027, with meetings from week 25. Plan advice a year ahead of when you need the answer.

What drives the cost

  • Indications and patient groups. Each needs its own Module 3 and 4 — and the G-BA often splits an indication into several subpopulations with different comparators.
  • The comparator gap. If your pivotal trial did not use the German comparator, you need indirect comparisons, which are only accepted when direct evidence is missing or insufficient — and are often rejected.
  • Analysis depth. Adverse-event analyses, data cuts, subgroup and sensitivity analyses multiply statistical work (the G-BA eased some of these requirements in July 2025).
  • Translation and medical writing into German to the G-BA’s standard.
  • The EU joint clinical assessment for oncology medicines and ATMPs since January 2025 — you can refer to the EU dossier, but timing and the PICO questions do not always match. See EU JCA vs AMNOG.

The cheapest dossier is the one whose comparator was fixed before Phase 3 started.

What changed in 2026

The GKV contribution-stabilisation act (BStabG), in force since late July 2026, changed the price side of AMNOG:

  • Price guardrails (Leitplanken) abolished from 30 July 2026; the basic rules remain — no added benefit means no higher annual therapy costs than the comparator.
  • Combination discount abolished from 29 July 2026.
  • Higher manufacturer rebate: an extra 8.5% on non-generic medicines from 1 January 2027, 15.5% in total. New active substances launched from 2027 can be exempted for three years if at least 5% of trial participants were at German sites.
  • Price-volume agreements become mandatory, with automatic price reductions from year four.
  • Confidential prices (since the 2024 Medical Research Act) remain an option until mid-2028, against a 9% discount and German research activity.

On 3 September 2026 the Health Ministry also floated an “AMNOG 2.0” concept for conditionally approved and orphan medicines, with mandatory re-assessment after three to four years. It is a proposal, not a bill. We follow it in the Regulatory Digest.

Common questions

The AMNOG dossier, answered

How much does an AMNOG dossier cost?

The vfa estimated about EUR 800,000 and 12 months of work per dossier in 2023. Costs rise with the number of indications and patient groups, indirect comparisons and statistical analyses. G-BA advice costs EUR 3,200 to 16,000 per consultation; we are not aware of a fee for the assessment itself.

When is the AMNOG dossier due?

At first market launch in Germany. For a new indication, within four weeks of its approval. Orphan drugs above EUR 30 million in statutory-insurance revenue must file a full dossier within three months of the G-BA’s request.

How long does the AMNOG process take?

The benefit assessment is published three months after the dossier deadline, and the G-BA decides about three months later. The price negotiated with the GKV-Spitzenverband applies from month seven after launch.

Does the AMNOG dossier have to be in German?

Modules 1 to 4 and the checklist must be in German. Study reports in Module 5 can be in German or English.

What changed in AMNOG in 2026?

The BStabG abolished the price guardrails and the combination discount in July 2026, raised the manufacturer rebate to 15.5% from January 2027 with an exemption for products with German trial sites, and made price-volume agreements mandatory.

AB
By Alexander Baranov
Founder, BCA Unternehmensberatung · market entry and market access in Germany since 2011
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