Five Years of Switzerland’s Revised Integrity, Transparency and Discounts Framework: Current Status and Emerging Enforcement Trends

Reviews Legal Industry, 2025, S. 16 - 17, Five Years of Switzerland's Revised Integrity, Transparency and Discounts Framework: Current Status and Emerging, Zürich 2025, Journal

In this article, Dr. Oliver M. Brupbacher and Prof. Dr. Markus Schott summarize the Swiss integrity, transparency, and discounts (ITD) regime in the therapeutic products sector.

The revision, which came into force on January 1, 2020, aims to ensure that the prescription and supply of medical products are not influenced by transfers of value (ToVs) to healthcare professionals (HCPs) and organizations (HCOs).

The article highlights the introduction of a whistleblowing platform by the Federal Office of Public Health (FOPH) in February 2025 and emphasizes the need to reassess ITD standards and processes to prepare for potentially increased enforcement.

Additionally, it highlights mentions that the general anti-bribery provisions of the Swiss Penal Code still apply to auxiliaries in a principal-agent relationship.