Package deals in the pharmaceutical industry and Disclosure UK data

Alex Fell, Chief Executive at the PMCPA, talks about package deals in the pharmaceutical industry and why guidance from the Prescription Medicines Code of Practice Authority (PMCPA) on package deals may have contributed to an increase in ‘contracted services’ reported spend in disclosure data.  

If you work in pharmaceutical compliance, you will be familiar with ‘package deals’ and what they mean in the pharmaceutical industry. For those less familiar, a package deal is a commercial arrangement whereby the purchase of a particular medicine is linked to the provision of certain associated benefits as part of the purchase price.

These benefits might include homecare and administration services provided by a nurse, genetic or biomarker testing required before a medication can be prescribed, patient education delivered by a healthcare professional, or digital tools such as remote monitoring. Package deals can be beneficial to healthcare organisations and patients, however, they need good governance and transparency.

New PMCPA guidance published in January 2026

In 2025, the PMCPA conducted an analysis of package deals, with input from pharmaceutical companies, service providers, and healthcare organisations. What we found was that practices around package deals varied considerably across the industry, particularly in relation to disclosure of transfers of value and interpretation of the Code’s requirements.

The new guidance addresses this by setting out when package-deal transfers of value must be disclosed, when they are exempt, and how companies should make that determination. It also covers governance, including the need for cross-functional oversight, written agreements, appropriate certification of materials, and rigorous training of service providers, as well as rules on communication to healthcare professionals, and the prohibition on inducements.

The grace period for companies

Disclosure is an ABPI Code obligation, not a legal one, and we know the industry needs time to review its contractual arrangements and internal procedures against the new guidance. For those reasons, the PMCPA has decided not to adjudicate on complaints related to disclosure of package-deal transfers of value made between now and the end of June 2027.

We want companies to use the time to review all their package deals against the guidance and, where necessary, update their historical Disclosure UK entries and put enhanced governance in place for future arrangements. The normal complaints and adjudication process will apply from 01 July 2027.

The increase in ‘fees for contracted services’ and ‘event sponsorship’ data in Disclosure UK

While part of the increase in ‘fees for contracted services’ appears to be due to an increase in homecare service activity itself, some of it may be due to increased reporting following the publication of the guidance.

The package deals guidance refers to two disclosure category options in certain scenarios where there is a third party healthcare organisation service provider. However, the PMCPA’s preference is that companies disclose against the recipient healthcare organisation that ultimately benefits (e.g. an NHS Trust). As there is currently no dedicated package deals category on the disclosure template, the guidance states that disclosure against the recipient healthcare organisation can be made in the ‘contribution to costs of events’ column, which can include values that do not fit into any other category on the disclosure template. This may be one factor that resulted in the increase seen in company contributions to the cost of events.

The way that companies disclose package deal transfers of value will be consulted on when the ABPI Code is next updated, so that more transparency and consistency can be brought to this area.

Questions on the guidance should be emailed to: info@pmcpa.org.uk 

For an explanation of the overall Disclosure UK data for 2025, see the blog by Dr Amit Aggarwal (ABPI Executive Director of Medical Affairs).

Summary of Disclosure UK data for 2025

• Total disclosed value, including R&D and non-R&D, increased by 14.3 per cent to £929.6 million, from £813.3 million in 2024, and £692.5 million in 2023.
• Total R&D value was £647.3 million, up from £554.0 million in 2024, and £467.0 million in 2023. The percentage split of R&D vs non-R&D remains similar.
• Total non-R&D value was £282.3 million in 2025, up from £259.2 million in 2024, and £225.5 million in 2023. This value increase is mostly attributed to payments to organisations. The number of activities with healthcare professionals has also increased, but not the average amount paid per HCP.
• Of the total non-R&D value, 99 per cent is published against a named person or organisation, which is higher than the 98.5 per cent for 2024, and 95.8 per cent for 2023.
• The estimated percentage of healthcare professionals named against non-R&D values has increased to 93.6 per cent for 2025, from 91.9 per cent for 2024, and 80.8 per cent for 2023.
• More than 60 companies used the lawful basis of Legitimate Interests to publish information about healthcare professionals.
• Collaborative working between industry and the NHS has decreased - with £14.5 million invested by companies in 2025, down from £22.1 million and £24.9 million in 2024 and 2023 respectively. 
• Values for contracted services (fees and expenses) increased in 2025 to £139.6 million from £113.0 million in 2024, and £91.2 million in 2023. The majority of the increase in 2025 compared with 2024 is attributed to a greater number of fees for contracted service reported to organisations, specifically third-party service providers. (Contracted service fees make up the £134.2 million reported; the remaining £5.4 million are related expenses.)