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Digital health · Before you buy

How long does a DiGA take, and what does it cost?

BfArM promises a decision in three months. The real clock starts much earlier — with CE marking, a security certificate and, above all, a study — and the real money question is what happens to your price after month twelve.

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

The BfArM review itself is short: a decision within 3 months of a complete application. Before that you need MDR CE marking, a BSI TR-03161 certificate and, for permanent listing, a study showing a positive care effect. A provisional listing adds a trial phase of up to 12 months, extendable to 24. Realistically, plan 1.5 to 3 years from a CE-ready product to permanent listing. Official BfArM fees are in the low thousands of euros; the large costs are the clinical study, notified-body work and security certification. You set your price freely in year one (2025 average: EUR 544 per prescription); from month 13 a negotiated price applies — on average about 59% lower, at least 20% of it outcome-based.

The short answer

StageTypical durationMain cost
MDR CE marking (class I, IIa or IIb)Often 12–18 months if not yet doneNotified body (class IIa+), QMS, technical documentation
BSI TR-03161 certificateSeveral months, plus fixesTest lab: five-digit euro amounts per run
Study for a positive care effectTrials ran 9–48 weeks, plus set-up and analysisUsually the largest single item
BfArM review3 months from a complete file (can be extended by 3)Fees in the low thousands
Provisional trial phase (class I/IIa only)Up to 12 months, extendable to 24Evaluation by an independent institution
Price negotiationNegotiated price applies from month 13Your revenue, not a fee

These stages overlap in practice. There is no official end-to-end figure, but adding up what manufacturers report gives roughly 1.5 to 3 years from a CE-ready product to permanent listing — longer if CE marking and the study start from zero.

Official fees

BfArM charges fees under the DiGA fee rules. According to the federal public-service description, the ranges are:

ProcedureFee range
Decision on listingEUR 1,500 – 9,000
Evidence for permanent listing after a trialEUR 1,500 – 6,600
Extension of the trial phaseEUR 1,500 – 4,900
Notified changesEUR 300 – 4,900
DelistingEUR 200

Fees can be reduced or waived where the economic value to the applicant is low. The BSI TR-03161 certificate is not a BfArM fee: it is paid to the testing lab and, by industry accounts, costs five-digit euro amounts per certification run. It is tied to a software version, so updates trigger maintenance procedures. A GDPR data-protection certificate is also required by law, but certification schemes have been late, and BfArM can set later deadlines.

What you earn: year one and after

  • Year one: your price. You set the price freely for the first 12 months (§134 SGB V). Manufacturer prices range from EUR 119 to over EUR 2,000; the 2025 average was EUR 544.
  • From month 13: the negotiated price. Agreed with the GKV-Spitzenverband; if there is no agreement within nine months of listing, the arbitration board sets it. The 40 negotiated prices so far average about EUR 227 — 59% below the launch prices they replaced.
  • Outcome-based share. Since 1 January 2026 at least 20% of the negotiated price must depend on outcomes.
  • Caps in year one. Framework-agreement maximum amounts per indication group apply once a DiGA passes 2,000 uses in year one; provisional DiGA take larger cuts. Below a threshold of EUR 77.40 per 90 days (and modest revenue), no negotiated price is needed.
  • Volume discounts. §134 now also provides for volume-related discounts from 2027.

Plan your business case on the negotiated price, not the launch price. For the patient and prescriber side, see DiGA: the app on prescription.

What changed in 2026

  • Second DiGAV amendment (in force 1 February 2026): outcome tracking during use for permanently listed DiGA, with quarterly data from Q3 2026 and a first report due 15 April 2027; new studies must also record how long and how often the app is used; applicants must state whether the EU AI Act applies.
  • 20% outcome-based price share mandatory from 1 January 2026.
  • GeDIG (the digital-health bill adopted by the federal cabinet on 15 July 2026) would, among other things, explicitly bring remote-monitoring DiGA into patients’ entitlement. It was not yet law when we published this.

We track each step in the weekly Regulatory Digest.

Common questions

DiGA cost and timeline, answered

How long does it take to get a DiGA listed?

BfArM decides within three months of a complete application. Before that you need CE marking, a BSI TR-03161 certificate and study evidence or an evaluation concept; a provisional listing then adds a trial phase of up to 12 months, extendable to 24. From a CE-ready product to permanent listing, plan roughly 1.5 to 3 years.

What are the BfArM fees for a DiGA?

According to the federal service description, the listing decision costs EUR 1,500 to 9,000, evidence for permanent listing EUR 1,500 to 6,600, a trial extension EUR 1,500 to 4,900 and notified changes EUR 300 to 4,900. Fees can be reduced or waived in some cases.

How much does a DiGA cost to develop and list in total?

There is no reliable published total. The largest items are the clinical study (usually an RCT), notified-body costs for class IIa and IIb (reported at roughly EUR 50,000 to 120,000 per device), BSI certification and ongoing outcome reporting. Official fees are a small share.

What price does a DiGA get?

The manufacturer sets the price for the first 12 months; the 2025 average was EUR 544. From month 13 a negotiated price applies; the negotiated prices so far average about EUR 227, and at least 20% must be outcome-based since January 2026.

Can a class IIb app become a DiGA?

Yes. The 2024 Digital Act opened DiGA to class IIb, but only via permanent listing: the positive care effect must be proven at application, with no provisional trial phase.

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