Financial transparency in the healthcare industry is not only nice-to-have, it's a legal and ethical imperative.
You might be asking: "Does this apply to my company if we’re not based in the U.S.?"
Around the world, pharmaceutical, biotech, and medical device companies are required to disclose financial interactions with healthcare professionals (HCPs) and organisations (HCOs).
While local requirements vary, the growing emphasis on Global HCP Transparency reflects a wider shift toward ethical standards, public trust, and compliance.
One of the most well-known regulations, the US Sunshine Act, has inspired similar frameworks across Europe and beyond.
Healthcare Professional (HCP) Transparency refers to the disclosure of financial relationships between healthcare companies and medical professionals or organisations.
These relationships must often be reported to public authorities or industry bodies to promote integrity and prevent conflicts of interest.
The rationale is clear: when a doctor receives payments from a drug manufacturer, the public deserves to know. Transparency builds trust, ensures accountability, and enables regulatory oversight.
Over the last decade, an increasing number of countries have adopted their own rules or voluntary codes to regulate these disclosures. However, companies do face several challenges:
These factors make compliance resource-intensive, especially for multinational organisations with a wide geographic footprint.
Here are some of the most prominent frameworks shaping global compliance:
A voluntary code requiring pharmaceutical companies to disclose payments or transfers of value (ToVs) made to HCPs and HCOs. Members must name recipients and specify the nature and value of each ToV.
One of the most stringent laws in Europe, requiring disclosure of any ToV above €10. Disclosures must be submitted to a central public platform and include detailed contractual information.
Governed by the Japan Pharmaceutical Manufacturers Association, this code promotes fair marketing and requires disclosure of payments to healthcare professionals.
Other examples of voluntary industry-led codes that encourage transparency and responsible interactions with HCPs.Together, these frameworks highlight a global movement toward disclosure, and demonstrate just how complex the regulatory landscape can be.
The Sunshine Act, officially known as the Physician Payments Sunshine Act, was enacted in 2010 as part of the U.S. Affordable Care Act. It mandates that manufacturers of drugs, medical devices, and biological products report most payments or transfers of value made to physicians and teaching hospitals.
These payments fall into three categories:
Non-compliance can be costly. Penalties for knowingly failing to report range from $10,000 to $100,000 per payment, with an annual cap of $1 million.
The data is made publicly available through the Open Payments Program, aiming to shine a light on industry-provider relationships.
The Sunshine Act has served as a blueprint for transparency legislation around the world. But with each country introducing its own flavour of regulation, multinational companies now face a complex compliance puzzle.
Some key contrasts:
Staying ahead of transparency regulations requires a robust and scalable compliance strategy. Here’s what the most successful companies are doing:
If you need to know which systems you should use to track payments globally, you've come to the right place.
Manual tracking is slow, error-prone, and risky. Tools like Declaree and MXP by Mobilexpense let users log expenses on the go, attach receipts, and link them to HCP profiles with minimal effort.
Using approved HCP databases (e.g. MediSpend, MedPro, IQVIA), employees can pull accurate details for each contact.
Mobilexpense supports both list-based and manual entry workflows.
With preconfigured templates, companies can generate disclosure reports aligned with local requirements. These reports are formatted for submission to authorities or associations.
Automated systems create a digital audit trail, reducing fraud and simplifying investigations.
Teams must understand how regulations vary. Embedding compliance into travel and expense workflows ensures that nothing is overlooked.
The world of HCP transparency is evolving rapidly, and compliance is no longer a burden. On the contrary, it’s an opportunity to build trust and demonstrate integrity.
Whether you're dealing with the Sunshine Act, or EFPIA’s Disclosure Code, the core challenge remains the same: managing complex, high-volume data in a consistent and auditable way.
Mobilexpense empowers healthcare companies to meet this challenge with ease. Our HCP transparency module helps you record, track, and report every relevant payment or transfer of value. All within a single, automated platform. Resulting in better compliance, less admin, fewer errors, and total peace of mind.
Ready to start? Download our free guide to HCP Sunshine Act Compliance in the pharma industry.