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DiGA: getting a health app prescribed, not just listed

Germany built one of the world's first reimbursement routes for digital health — the “app on prescription.” For a foreign company it's a rare open door. But getting listed and getting prescribed are two different things, and most teams learn that too late.

9 min read Reviewed by Ralf Müller, Market Access & Regulatory Lead Updated 2026
In one paragraph

A DiGA (Digitale Gesundheitsanwendung) is a low-risk digital medical device that physicians and psychotherapists can prescribe and statutory insurance reimburses. It's listed via the BfArM fast-track (about 90 days), either permanently (benefit proven) or provisionally (proven during a trial period). Reimbursement starts from day one of listing. The catch: a listing makes you reimbursable, not prescribed — and closing that gap is a commercial job, not a regulatory one.

What DiGA is

Through the DiGA framework, introduced by the Digitale-Versorgung-Gesetz (DVG) in 2019, a digital health application can be prescribed and reimbursed by Germany's statutory health insurance — which covers roughly 73 million people.

For an evidence-based product in chronic disease, mental health or prevention, that is unusual: a clear, explicit reimbursement pathway into a large paying market, rather than the improvised route digital health faces almost everywhere else. The market is small today but growing, and the door is genuinely open.

The framework solves access. It does not solve adoption — and that is where entry actually succeeds or quietly fails.

The route

Two ways onto the DiGA directory

Listing runs through the BfArM (Federal Institute for Drugs and Medical Devices), which maintains the official DiGA directory and runs a fast-track assessment of about 90 days.

Reimbursable from day one of listing
BfArM fast-track · ~90 days You can list one of two ways:
Permanent listing
Positive effect already proven If you can demonstrate a positive healthcare effect (positiver Versorgungseffekt) — a medical benefit, or a patient-relevant structural / procedural improvement — you list permanently.
Provisional (Erprobung)
Listed while you prove it Listed for a trial period (typically up to a year, extendable) during which you prove the effect through a study to German standards. Reimbursable throughout.

Either way, you earn from day one of inclusion — which is what makes the provisional route attractive: revenue while you generate the evidence.

What you have to clear

A DiGA is a regulated medical device before it is a reimbursable app. Four requirements decide whether you get listed — and one is routinely underestimated.

Requirement
What it means
Medical device (CE)
The app must be a CE-marked medical device under MDR — DiGA are lower-risk (class I or IIa).
Data protection
Full GDPR (DSGVO) compliance and contractual data-processing terms.
Data security & BSI
BfArM's data-security requirements plus a security certificate from the BSI (federal cyber-security office). For non-EU teams, usually the hardest and most underestimated hurdle.
Positive healthcare effect
Evidence German assessors accept — a study designed with the German reimbursement context in mind, not repurposed home-market data.

The data-security bar is high and rising: it's not a checkbox but a certified engineering programme, and it should start early because it gates the listing regardless of how good the clinical evidence is.

The part nobody tells you: listed vs prescribed

This is where most DiGA entries stall. Being in the directory does not put you in front of patients.

Regulatory — solved

Listed on the directory

You are reimbursable. BfArM listing, data security and evidence are cleared. The regulatory battle is won.

Commercial — the real work

Actually prescribed

Physician awareness of DiGA is uneven and prescribing habits are conservative. A listed app with no prescriptions earns nothing.

The work that turns a listing into revenue is commercial, not regulatory: physician awareness, the right specialist and association channels, patient pathways, and a credible local presence behind the product. Patients can also obtain a DiGA directly through their insurer's approval — a second demand channel most foreign teams overlook.

Getting listed is a project. Getting prescribed is a go-to-market campaign.

Where companies go wrong

  • Treating the listing as the finish line. Reimbursable is not the same as prescribed — the uptake plan should exist before you list.
  • Underestimating BSI / data security. For non-EU teams this is often the longest pole; start it first, not last.
  • Repurposing home-market evidence. The positive-effect study should be designed for German assessors and the German context.
  • Setting the year-one price by default. It anchors the GKV negotiation — a strategic decision, not an afterthought.
RM
Reviewed by Ralf Müller
Market Access & Regulatory Lead · 15 years in German pharma
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