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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 27 Oct 2026 Covers 21–27 Oct 2026 Issued Tue 27 Oct 2026 Cadence Weekly · Tuesdays
Three that matter most
  • G-BA widens new-method assessment (Section 137h). A procedural-rules change dated 15 October drops the “high-risk device” limit and makes manufacturers fund trials they apply for. It applies from 3 November 2026 at the earliest.
  • Hilfsmittel tenders: the fight moves to the Bundesrat. The emergency-care reform needs the Länder’s consent; BVMed and patient groups ask them to call the mediation committee to strike the tenders.
  • Switzerland: eCTD v4.0 moves closer. On 26 October Swissmedic published version 2.0 of the Swiss implementation guide package; the EMA SMS duty for active substances starts 15 November.

No new binding Austrian rule in this window. The lead German item is a G-BA decision of 15 October that was published after our last edition; everything else is dated 20–26 October.

DE

Germany

Market-entry rules for new hospital methods change; the tender question goes to the Länder.

From 3 Nov 2026Medtech · §137h / §137eTransition

G-BA: Section 137h no longer limited to high-risk devices; manufacturers pay for trials

Implementing the GKV contribution-stabilisation act (BStabG), the G-BA amended its procedural rules. The early benefit assessment of new hospital methods (Section 137h SGB V) now covers any new method that is not based solely on a drug, triggered by a hospital’s first NUB request — not only methods using high-risk-class devices. Manufacturers that apply for a trial under Section 137e(7) must commission and pay an independent institution, including compensation for participating hospitals; if they do not commit to the costs within two months, the procedure stops. The change takes effect on the day after publication in the Federal Gazette, but not before 3 November 2026.

Why it matters: Lower-class devices behind a new hospital method can now be pulled into a G-BA assessment the first time a hospital files a NUB request. Plan evidence and budget for a possible manufacturer-funded trial before you encourage hospitals to request NUB funding. See how a NUB application works.

Sources: G-BA decision, 15 Oct 2026 (PDF)

20 Oct 2026Hilfsmittel · TendersIn ratification

Hilfsmittel tenders: industry asks the Bundesrat to call the mediation committee

The emergency-care reform passed by the Bundestag on 15 October needs Bundesrat consent. BVMed’s patient initiative “Faktor Lebensqualität” asks the Länder to call the mediation committee and strike the reintroduced tenders in Section 127(1c) and (1d) SGB V, or at least exempt sensitive care areas. The same carrier law also makes DiGA manufacturers carry more financial responsibility.

Why it matters: If the Bundesrat consents, statutory insurers can tender Hilfsmittel again. Keep tender pricing scenarios ready and watch the Bundesrat plenary agenda; DiGA makers should check the new cost rules in the final text.

Sources: PZ, 20 Oct 2026

AT

Austria

Quiet for market access; the EUDAMED deadline is one month away.

Around 28 Nov 2026Medtech · EUDAMEDTransition

EUDAMED transition ends in about a month

The six-month transition after Commission Decision (EU) 2025/2371 ends around the end of November 2026, according to our reading of the BASG notice.

Why it matters: Austrian manufacturers and authorised representatives: complete EUDAMED actor and UDI/device registration now and confirm the exact date with BASG.

Sources: BASG notice

CH

Switzerland

Electronic submissions and the SMS duty move closer.

26 Oct 2026Submissions · eCTD v4.0Transition

Swissmedic publishes version 2.0 of the eCTD v4.0 implementation package

Swissmedic released version 2.0 of the package for the Swiss Implementation Guide for eCTD v4.0. In July it said technical implementation should finish by the end of 2026, with go-live expected in 2027 after pilot testing.

Why it matters: Companies filing in Switzerland should get their publishing tools and vendors ready for eCTD v4.0 in 2027.

Sources: Swissmedic, 26 Oct 2026

From 15 Nov 2026APIs · EMA SMSTransition

Reminder: active substances must be in EMA SMS

From 15 November 2026, active substances must be registered in the EMA SMS database before they can be included in Swiss establishment licences and GMP certificates.

Why it matters: Check SMS entries for every active substance listed in your Swiss licences now.

Sources: Swissmedic, 1 Oct 2026

EU

EU-wide — direct effect in DE & AT

Council: 28 Sep 2026Pharma packageIn ratification

Pharma package: Parliament plenary still expected in November

No plenary date has been confirmed; a law-firm update points to November as the indicative month for Parliament’s vote on the Council position.

Why it matters: No change to plans: keep the gap analysis on data protection and orphan exclusivity running.

Sources: CMS: what the Council's revised texts mean

Proposal: 16 Dec 2025MDR / IVDR revisionWatch

MDR/IVDR targeted revision: no Council position yet

We found no Council general approach on the Commission’s December 2025 proposal (broader clinical evidence, a larger EMA role); Parliament’s committee work continues.

Why it matters: Current MDR/IVDR transition deadlines (2027–2029) still apply; do not plan on relief until a text is agreed.

Sources: Osborne Clarke: EU progresses targeted revision

What we're tracking
  • Section 137h / 137e. G-BA rules apply from 3 November at the earliest; first assessments of lower-class device methods to follow NUB requests.
  • Notfallreform. Bundesrat consent or mediation committee; decides whether Hilfsmittel tenders return.
  • EU pharma package. Parliament plenary, indicatively November.
  • Deadlines. EMA SMS duty in CH from 15 November; EUDAMED transition about 28 November; swissdamed 31 December.
  • Mammography 45–49. BMG legal review; in force 1 August 2027 if not objected to.
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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 21–27 October 2026 and was issued on 27 October 2026.