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Regulatory Digest

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

Market-access intelligence for life sciences — a weekly scan of DE, AT and CH regulatory changes, with what each means for pricing, reimbursement and getting paid.

Edition Week of 6 Oct 2026 Covers 29 Sep–6 Oct 2026 Issued Tue 6 Oct 2026 Cadence Weekly · Tuesdays
Three that matter most
  • EU pharma package: what is left. After Council adoption on 28 September, the remaining steps are Parliament approval and Official Journal publication; application is expected around 2028.
  • AI-enabled devices: the TUeV-Verband (30 Sep) warns against moving medical devices from Annex I Section A to Section B of the AI Act, which would remove direct application of the high-risk AI requirements.
  • Three deadlines close in: the Swiss HMG consultation ends 16 October, the EUDAMED six-month transition ends around 28 November, and swissdamed closes 31 December.

A quiet week for formal legal changes: no new binding DE, AT or CH rules with a verifiable date in this window. The items below are news from 29 September–6 October plus still-pending deadlines, each with its date.

DE

Germany

EUDAMED obligations are running, and the AMNOG reform is still waiting for a draft bill.

Since 28 May 2026Medtech · EUDAMEDTransition

BfArM: first four EUDAMED modules mandatory

Use of the Actor Registration, UDI/Devices, Notified Bodies and Market Surveillance modules became mandatory on 28 May 2026. In Germany, registration runs through BfArM's DMIDS.

Why it matters: Manufacturers and authorised representatives need EUDAMED actor and UDI/device data in place. The six-month transition triggered by Commission Decision (EU) 2025/2371 implies roughly the end of November 2026 — our reading; confirm with BfArM.

Sources: BfArM: EUDAMED becomes mandatory · BfArM DMIDS FAQ

Since 16–18 Sep 2026AMNOG · ReformWatch

AMNOG reform: still no draft bill

No new official step this week after the G-BA (16 Sep) and GKV-SV (18 Sep) statements on the Health Ministry's proposals. A draft bill text is still pending.

Why it matters: Keep dossier and negotiation planning flexible for orphan and conditionally approved products until a draft appears.

Sources: G-BA statement, 16 Sep 2026 (PDF)

AT

Austria

BASG confirms the EUDAMED timeline for Austrian operators.

Since 28 May 2026Medtech · EUDAMEDTransition

BASG: EUDAMED modules mandatory, six-month transition running

BASG confirms the first EUDAMED modules became mandatory on 28 May 2026, following Commission Decision (EU) 2025/2371 of 26 November 2025, which triggered a six-month transition under Regulation (EU) 2024/1860.

Why it matters: Austrian manufacturers and authorised representatives face the same end-of-transition date as in Germany. Confirm the exact deadline with BASG.

Sources: BASG notice

CH

Switzerland

The HMG consultation enters its final days; the MRA is still a 2027-plus story.

Closes 16 Oct 2026Therapeutic Products ActWatch

HMG consultation closes in ten days

The consultation on the Therapeutic Products Act (HMG) revision, opened on 19 June, ends on 16 October 2026. It includes a supervision fee on manufacturers and importers of medical devices.

Why it matters: Last chance to submit input, directly or through industry associations.

Sources: Federal Council press release, 19 Jun 2026

Signed 2 Mar 2026Devices · EU–CH MRAIn ratification

EU–Switzerland MRA update signed, not yet in force

An industry source reports the updated MRA package, signed on 2 March 2026, needs consent from the European Parliament and Council and Swiss parliamentary approval — likely with a referendum — so entry into force is not expected before late 2027. Until then, CH-REP and EU authorised-representative requirements remain.

Why it matters: Do not drop CH-REP or EU-REP arrangements yet. Single secondary source — verify with the Federal Council or SERI.

Sources: MedDeviceGuide, 9 Jun 2026

EU

EU-wide — direct effect in DE & AT

28–30 Sep 2026Pharma packageIn ratification

Pharma package: what is left after Council adoption

A law-firm report of 30 September says the Council adopted the package on 28 September; Parliament adoption and Official Journal publication are pending, with entry into force after that. Application is expected around 2028.

Why it matters: Start the gap analysis on regulatory data protection, orphan exclusivity and supply obligations now — timing may shift. Confirm the stage on EUR-Lex.

Sources: Matheson: EU Council adopts new EU Pharma Package (30 Sep 2026)

30 Sep 2026MDR · AI ActWatch

TUeV-Verband warns on an AI Act carve-out for medical devices

The TUeV-Verband warned that moving medical devices from Annex I Section A to Section B of the AI Act would remove the direct application of high-risk AI requirements, and urged member states to keep full coverage.

Why it matters: AI-enabled devices and software could face a different compliance path. The question sits in the AI omnibus and the MDR reform talks and is unresolved.

Sources: Pharmazeutische Zeitung, 30 Sep 2026

9 Jun 2026HTA · JCAIn force

First Joint Clinical Assessment published; 18 initiated so far

The Commission published the first JCA report (Ojemda/tovorafenib, Ipsen) on 9 June 2026; 18 JCAs have been initiated since January 2025, mainly in oncology and ATMPs.

Why it matters: Member states are expected to use JCAs without adding their own requirements — align G-BA dossiers with JCA submissions.

Sources: European Commission news, 9 Jun 2026

What we're tracking
  • EU pharma package. Council adopted on 28 September; European Parliament final approval and Official Journal publication still to be confirmed.
  • MDR/IVDR targeted revision and the AI Act question. Parliament ENVI position targeted end-2026, entry into force early 2028 (unconfirmed); the Annex I Section A/B debate is open.
  • AMNOG reform. Statements filed; waiting for a draft bill.
  • GKV-BStabG. Manufacturer rebate rises to 15.5% from 1 January 2027.
  • EUDAMED. Six-month transition to about 28 November 2026 — confirm with BfArM/BASG.
  • Switzerland. HMG consultation closes 16 October; swissdamed full compliance 31 December; EU–CH MRA not before late 2027.
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Disclaimer. This digest is prepared by BCA (bcaun.de) for general information only and is not legal advice. Regulatory positions change quickly: every item marked Transition, Watch or In ratification is not settled law, and dates, scope and entry-into-force can shift. Confirm any such item directly with the competent regulator — BfArM, PEI, G-BA or GKV-Spitzenverband in Germany; BASG/AGES in Austria; Swissmedic in Switzerland; the European Commission or EMA at EU level — before acting. This edition covers 29 September–6 October 2026 and was issued on 6 October 2026.