← All editions  /  Summer 2026
Regulatory Digest

Pharma & medical devices: what changed in Germany, Austria & Switzerland

A weekly scan of regulatory changes and news across DE, AT and CH — pricing, reimbursement, clinical trials and device rules — with what each means for market access.

Edition Summer 2026 Covers Jun–Aug 2026 Issued Tue 1 Sep 2026 Cadence Weekly · Tuesdays
The three that matter most this summer
  • Germany — GKV-BStabG in force 30 Jul 2026. A cost-containment package that tightens AMNOG evidence, compresses free pricing and restructures DiGA reimbursement.
  • Switzerland — swissdamed device registration mandatory from 1 Jul 2026 (transition to 31 Dec 2026). The EU–Swiss device MRA, signed March 2026, is still not in force — third-country rules continue.
  • EU-wide — Joint Clinical Assessment reaches high-risk devices in 2026 (Implementing Reg. (EU) 2025/2086), on top of the pharma pharma-package revision — affecting DE and AT directly.
DE

Germany

In force 30 Jul 2026Pharma · PricingIn force

GKV-BStabG: the summer's big pricing & reimbursement shake-up

The GKV-Beitragssatzstabilisierungsgesetz (GKV Stabilization Act) was adopted by the Bundestag on 10 July 2026, cleared the Bundesrat the same day, and entered into force on 30 July 2026. It bundles cost-containment measures across statutory health insurance: compressing free-pricing windows, tightening AMNOG early-benefit evidence thresholds, restructuring DiGA reimbursement, and adding transparency and reporting obligations for pharma and medtech. Reporting also points to relief on certain pricing "guardrails" for combination therapies, notably in oncology.

Why it mattersAnyone modelling German revenue on the old AMNOG rules needs to re-check evidence requirements, the free-pricing window and DiGA economics now — the negotiated price just got harder to defend.
Ongoing 2026Pharma · Medtech · PolicyWatch

Pharma & MedTech Dialogue continues under the new Health Minister

The federal government's Pharma & MedTech Dialogue, launched in January 2026, remained active through the summer, with a broad agenda spanning pricing, research incentives and manufacturing. Commentary flags both high hopes and unclear prospects, and further reform steps are expected beyond the GKV-BStabG.

Why it mattersThe direction of travel — not just the current law — shapes launch sequencing decisions. Expect more pricing and DiGA changes to follow.
In effectClinical trials · ATMPIn effect

Medical Research Act (MFG) reshaping trials and agencies

The Medizinforschungsgesetz continues to bed in: it simplifies clinical-trial and approval processes for medicines and devices, adjusts rules for advanced therapy medicinal products (ATMPs), touches AMNOG, and reorganises BfArM, the Paul-Ehrlich-Institut and ethics committees.

Why it mattersFaster, more centralised trial pathways are a genuine plus for sponsors planning German or EU studies — worth factoring into evidence timelines.
AT

Austria

Jun 2026Pharma · VariationsWatch

CMDh signals guidance updates for the new pharmaceutical legislation

At its June 2026 meeting, the CMDh (with Austria's BASG participating) discussed the new pharmaceutical legislation (NPL), its multi-annual workplan, variations, safety-label variations, multilingual packs and trade-name challenges. Updates to several variation guidance documents and templates are due to align with new European Commission guidelines.

Why it mattersVariation and labelling rules are about to shift for anyone holding or planning an Austrian/EU authorisation — template changes mean process changes.
Live 10 Feb 2026Pharma · InformationLive

New BASG medicines information portal

BASG's new medicines information system went live on 10 February 2026, merging the former medicinal-product index, shortages index, announcements and votes into a single portal at medikamente.basg.gv.at.

Why it mattersA single source for Austrian product status, shortages and official notices — update any internal monitoring that pointed at the old registers.
Source: BASG
OngoingMedtech · EUDAMEDWatch

Device registration runs in parallel: EUDAMED + national obligations

BASG (through AGES) remains the competent authority for devices in Austria. Manufacturers, authorised representatives and importers register via EUDAMED and the competent authority where established — but until the relevant EUDAMED modules are fully mandatory, Austrian national obligations continue in parallel.

Why it mattersDon't assume EUDAMED alone covers you in Austria yet — national registration duties still apply during the transition.
CH

Switzerland

From 1 Jul 2026Medtech · RegistrationTransition to 31 Dec 2026

swissdamed device registration becomes mandatory

From 1 July 2026, registration of medical devices, systems, procedure packs and IVDs in the swissdamed UDI/Devices module is mandatory, with a transition period until 31 December 2026. From 31 December 2026, a device must be registered in swissdamed to be legally marketed in Switzerland.

Why it mattersAny manufacturer selling devices into Switzerland must get into swissdamed before year-end — a hard gate, alongside the existing CH-REP requirement.
Signed 2 Mar 2026Medtech · Market accessIn ratification

EU–Swiss device MRA: signed, but still not in force

The updated EU–Switzerland mutual recognition agreement for medical devices, signed on 2 March 2026, remains in the ratification process. Until it enters into force, Switzerland is treated as a third country: non-Swiss manufacturers still need a Swiss Authorised Representative (CH-REP), importer duties, economic-operator registration, and swissdamed registration.

Why it mattersDon't plan entry timing around the MRA yet — build for third-country rules today; treat the returning MRA as future upside, not a current fact.
EU

EU-wide — affecting DE & AT directly

From 2026Pharma · Medtech · HTAPhasing in

Joint Clinical Assessment reaches high-risk medical devices

Under the EU HTA Regulation (applying since 12 January 2025 for oncology medicines and ATMPs), Implementing Regulation (EU) 2025/2086 — adopted 17 October 2025 — finalised the framework for Joint Clinical Assessment (JCA) of selected high-risk devices and IVDs, starting in 2026. The system aligns evidence requirements across member states.

Why it mattersFor medicines already, and now high-risk devices, a single EU-level clinical assessment feeds national pricing — align your evidence, comparators and launch sequencing to it early.
Ongoing 2026Pharma · LegislationWatch

EU pharmaceutical package revision advancing

The overhaul of EU pharmaceutical legislation — the "pharma package" — continued through 2026. Notable for market access: a broadened Bolar exemption that expressly covers HTA activities, creating a direct link between the pharma package and the EU's joint clinical assessment framework.

Why it mattersData-protection periods, incentives and the Bolar/HTA interface will reshape launch and lifecycle strategy across the EU, including Germany and Austria.
On the radar for next editions

What we're tracking

  • Germany: GKV-BStabG implementing detail and any follow-on measures from the Pharma & MedTech Dialogue; DiGA reimbursement restructuring specifics.
  • Switzerland: progress on EU–Swiss MRA ratification; swissdamed registration ahead of the 31 Dec 2026 hard deadline.
  • Austria: CMDh variation-guidance updates and new pharmaceutical legislation transposition.
  • EU: first JCA outcomes for devices; pharma-package trilogue milestones.
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This digest is a general, non-exhaustive summary of publicly reported regulatory developments as at early September 2026 and is not legal or regulatory advice. Dates, scope and in-force status change; several items are in transition or ratification. Confirm the current position with the relevant authority (BfArM/PEI, G-BA, BASG/AGES, Swissmedic, the European Commission/EMA) and qualified counsel before acting.