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EU Joint Clinical Assessment vs AMNOG: what changes for Germany

Since January 2025 new cancer drugs and advanced therapies get an EU-level clinical assessment. Germany still runs AMNOG, still sets the price and still wants its own dossier. Here is how the two fit — and where the timing can bite.

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

The EU HTA Regulation (2021/2282) adds a Joint Clinical Assessment (JCA) of relative clinical effectiveness — no value judgement, no price. It covers new oncology medicines and ATMPs since 12 January 2025, orphan medicines from 2028 and all new centrally authorised medicines from 2030, plus selected high-risk devices. In Germany AMNOG continues: a national dossier is still due at launch, the G-BA still judges added benefit against its own comparator, and the price is still negotiated from month 7. The JCA report is taken into account only if it is published in time — for the first case, tovorafenib, it was not.

What the JCA is — and is not

The JCA answers one question for the whole EU: how does a new medicine compare clinically with the alternatives that matter in each Member State?

It assesses relative effectiveness and safety for the populations, comparators and outcomes Member States ask for (PICOs). It does not rate the size of the added benefit, judge value or say anything about price or reimbursement. Member States must give the report “due consideration” and annex it to their national assessments — but pricing and reimbursement stay national. For how the German side works, start with AMNOG explained.

The JCA process for medicines

  1. Trigger: filing the marketing authorisation application with EMA; the company sends the draft SmPC and clinical overview to the HTA secretariat.
  2. Assessors: an assessor and co-assessor from different Member States are appointed.
  3. PICO scoping: Member States state their needs; the subgroup consolidates the PICOs, fixed within about 10 days after the CHMP list of questions.
  4. Dossier: due within 100 days of the request (60 in accelerated procedures), no later than 45 days before the CHMP opinion.
  5. Report: endorsed no later than 30 days after marketing authorisation, then published after a short Commission review.

A dossier that does not meet the requirements can lead to the JCA being discontinued — one was, in September 2026.

How Germany’s AMNOG uses the JCA

AMNOG continues, normally starting after the EU procedure. The G-BA supplies Germany’s PICO input, and the rules were updated in 2025 (AM-NutzenV in March, G-BA procedures and IQWiG commission in July).

  • A German dossier is still required at launch.
  • EU evidence can be referenced precisely, down to section and table, for indication, benefit and added benefit versus the German comparator (zVT).
  • National items stay national: patient numbers, therapy costs, quality-assured use and anything missing for the German comparator.
  • What counts: the referenced EU evidence, JCA reports published before the German dossier deadline, and other information on the EU platform. A report published later, but before the G-BA assessment is out, enters the hearing.
  • Standards and categories unchanged: the extent (major to lesser) and certainty (proof, indication, hint) of added benefit remain German judgements.

The timing trap

The German dossier is due at launch; the JCA report can arrive up to roughly 40 days after marketing authorisation. Launch early in Germany and the report may not count. That is exactly what happened with tovorafenib: the German procedure started on 15 May 2026, the JCA report was published on 9 June 2026, so the G-BA did not consider it as a dossier basis. And if a JCA is discontinued for a non-compliant dossier, no EU references are allowed in the German dossier at all.

One evidence package, two filters — and the German one still decides the price.

Common questions

EU Joint Clinical Assessment vs AMNOG, answered

What is an EU Joint Clinical Assessment?

An EU-level assessment of a new medicine’s relative clinical effectiveness under Regulation (EU) 2021/2282, run in parallel with the EMA procedure. It makes no value judgement and has no bearing on price; Member States must give it due consideration.

Does the JCA replace AMNOG?

No. In Germany a national AMNOG dossier is still required at launch, the G-BA still assesses added benefit against its own comparator, and the price is still negotiated nationally. The JCA can be referenced and taken into account.

Which medicines need a JCA?

New oncology active substances and ATMPs since 12 January 2025, orphan medicines from 13 January 2028 and all new centrally authorised medicines from 13 January 2030. Selected high-risk devices are also assessed.

When does the G-BA take the JCA report into account?

If the report is published before the German dossier deadline, it is part of the assessment basis. If it comes later but before the G-BA assessment is published, it enters the hearing. Reports published after that may not count.

What was the first JCA?

Tovorafenib (Ojemda), a paediatric cancer medicine, published on 9 June 2026. Its German AMNOG procedure started earlier, on 15 May 2026, so the report was not part of the German dossier basis.

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