Table 1. Regulatory Approaches to Disclosure of R&D Payments in Europe .
| Countrya | Self-regulationb | Public Regulationc |
| Austria | ✓ | |
| Bosnia & Herzegovina | ✓ | |
| Belgium | ✓d,e | |
| Bulgaria | ✓ | |
| Croatia | ✓ | |
| Cyprus | ✓ | |
| Czech Republic | ✓ | |
| Denmark | ✓f | |
| Estonia | ✓d | |
| Finland | ✓d | |
| France | ✓ | |
| Germany | ✓ | |
| Greece | ✓d | |
| Hungary | ✓d | |
| Iceland | ✓ | |
| Ireland | ✓ | |
| Italy | ✓ | |
| Latvia | ✓d | |
| Lithuania | ✓d | |
| Luxembourg | ✓ | |
| North Macedonia | ✓ | |
| Malta | ✓ | |
| The Netherlands | ✓d,e | |
| Norway | ✓ | |
| Poland | ✓ | |
| Portugal | ✓ | |
| Romania | ✓d | |
| Russia | ✓ | |
| Serbia | ✓ | |
| Slovakia | ✓g | |
| Slovenia | ✓ | |
| Spain | ✓d,e | |
| Sweden | ✓ | |
| Switzerland | ✓ | |
| Turkey | ✓ | |
| UK | ✓ | |
| Ukraine | ✓ | |
| n = 37 | n = 32 | n = 5 |
Abbreviation: R&D, research and development.
a Countries excluded from analysis are Albania, Andorra, Belarus, Lichtenstein, Monaco, Montenegro, San Marino, and Vatican City.
b Self-regulation of R&D payment disclosure in all studied countries is based on the EFPIA Code. In the column listing countries with self-regulation, it applies to the disclosure of all R&D payments. Therefore, this column excludes Slovakia, where only some R&D payments are disclosed under self-regulation.
c Public regulation of payment disclosure in all studied countries is based on legislation.
d Countries with self-regulation of R&D payment disclosure and public regulation of non-R&D payments. In all these countries, the public regulation of non-R&D payments is based on legislation. In addition, Greece also has public regulation in the form of a clarification decision issued by the data protection agency.
e In addition to public regulation, the regulation of non-R&D payments in Belgium, Spain and the Netherlands is combined with elements of self-regulation. In Belgium and the Netherlands, the online disclosure platforms are managed by multi-stakeholder bodies, including the pharmaceutical industry. In Spain, payment disclosure is managed by individual drug companies, and overseen by the pharmaceutical industry trade group, without involvement from public authorities.
f In Denmark, R&D payments are part of individual-level payments called “professional affiliations,” which are disclosed, together with individual-level payments for conference participation abroad, based on public regulation taking the form of legislation. Separately, the Danish pharmaceutical industry trade group discloses non-R&D organisational-level grants to hospitals using its own self-regulatory code which is separate from the provisions of the EFPIA Code.
g In Slovakia, R&D and non-R&D payments made to individual-level “healthcare workers” and organisational-level healthcare providers are disclosed based on public regulation. However, R&D and non-R&D payments to organisational-level non-healthcare providers fall under self-regulation.