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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 15 Sep 2026 Covers 8–15 Sep 2026 Issued Tue 15 Sep 2026 Cadence Weekly · Tuesdays
Three that matter most
  • EU Joint Clinical Assessment output starts meeting Germany's AMNOG track for gene therapy. The Commission published a JCA report on an advanced therapy for spinal muscular atrophy on 7 September, while the G-BA's own benefit assessment for Novartis's Itvisma (onasemnogene abeparvovec, extended SMA population) runs in parallel, with a decision expected end of January 2027.
  • Swissmedic's medical-device registration fee is now live — CHF 200 for a first product, CHF 20 per additional device, capped at CHF 10,000 a year, payable for anything registered in swissdamed, with a transitional window to 31 December 2026.
  • The G-BA opened a comment procedure on full cochlear-implant reimbursement on 10 September — a live look at how it treats a high-risk implanted device in the Section 137h corridor. Written statements are due 12 October, oral hearing 12 November.
DE

Germany

A device-reimbursement comment window, an ATMP benefit assessment running alongside EU JCA output, a critical cardiology shortage and a BfArM process change.

10 Sep 2026Medtech · HTATransition

G-BA opens comment procedure on cochlear-implant reimbursement

The G-BA issued a resolution opening the formal statement procedure on a draft decision covering full implantation of a cochlear implant for sensorineural severe-to-profound hearing loss. Written statements are due by 12 October 2026, with an oral hearing scheduled for 12 November 2026.

Why it matters: This is the live window to shape the reimbursement corridor for a high-risk implanted device (Section 137h-adjacent) before the G-BA finalises its position — statements filed after 12 October will not be considered.

Sources: G-BA Beschluss 8007 (10.09.2026)

Since 1 Aug 2026AMNOG · ATMPWatch

Itvisma (SMA gene therapy): G-BA benefit assessment running alongside new EU JCA output

The G-BA's early benefit assessment for onasemnogene abeparvovec (Itvisma, Novartis) in the extended SMA population (patients aged 2+ with ≥4 SMN2 gene copies, types 2/3/4) began on 1 August 2026. The dossier assessment is due on 2 November 2026, with a G-BA decision expected end of January 2027. In parallel the Commission published a JCA report on an SMA advanced therapy on 7 September and refreshed its list of ongoing JCAs on 10 September.

Why it matters: One of the first visible cases of EU-level JCA evidence running concurrently with a German AMNOG procedure for an ATMP — a template for how JCA clinical conclusions will feed (or not feed) national dossiers once JCA becomes the standard reference.

Sources: G-BA Nutzenbewertungsverfahren 1383 · EC — JCA report on SMA ATMP · EC — updated JCA list

8 Sep 2026Supply shortageTransition

BMG declares a critical digoxin/digitoxin shortage

The Federal Ministry of Health notified a supply shortage for digoxin- and digitoxin-containing medicines on 8 September 2026, after Teva reported packaging-related delays for Digitoxin AWD 0.07 expected to last into late January 2027. The German Cardiac Society (DGK) classifies the shortage as critical: there is no aut-idem alternative, and switching patients to digoxin requires a dose adjustment for renal clearance.

Why it matters: Companies with cardiology or hospital-supply portfolios should check BfArM's shortage list before assuming continuity for these substances into Q1 2027, and flag the DGK position paper to prescribing customers.

Sources: BfArM — Lieferengpässe · DGK position paper

Since 1 Sep 2026Marketing authorisationWatch

BfArM slot allocation reportedly extends to purely national procedures

Secondary reporting indicates that, from 1 September 2026, BfArM's slot-allocation regime for assessment capacity also applies to purely national marketing-authorisation procedures, alongside a new digital PharmNet.Bund form for ENR/EUV applications. We have not yet located BfArM's own notice confirming the exact scope.

Why it matters: If confirmed, this changes timeline planning for purely national (non-CP, non-MRP/DCP) filings in Germany. Confirm current slot requirements directly with BfArM before committing to a Q4 2026 filing date.

Sources: BfArM — Aktualisierungen im Überblick

AT

Austria

A quiet week in Vienna: routine market surveillance only.

Week of 8–15 SepMarket surveillanceRoutine

No new Austrian pharma or device rule this week

We found no new Austrian legislation, BASG/AGES policy change or Erstattungskodex development dated to this window. BASG activity was limited to scheduled eServices maintenance (8 September) and routine market-surveillance notices; the most recent Erstattungskodex amendment on record (the 257th) dates to late January 2026.

Why it matters: Nothing to action for Austria specifically. The items to carry forward — the EU pharma package and the MDR/IVDR revision — apply to Austria once adopted.

Sources: BASG — home / official announcements

CH

Switzerland

A new device-registration fee in force and an eSubmission change on the horizon.

Since 1 Jul 2026 · to 31 DecDevices · FeesIn force

Revised Fees Ordinance now charges for swissdamed device registration

Following the Federal Council's approval of the revised Swissmedic Fees Ordinance, a registration fee applies in swissdamed: CHF 200 for a manufacturer's first product and CHF 20 for each additional product with "on the market" status, capped at CHF 10,000 per calendar year. The ordinance also raised Swissmedic's hourly rate to CHF 270 (unchanged since 2002), effective 1 July 2026. A transitional period for existing registrations runs to 31 December 2026.

Why it matters: Device and IVD companies selling in Switzerland should add the fee to their Swiss compliance budget now, and confirm which products still need registering before the window closes on 31 December.

Sources: Swissmedic — Fees Ordinance revision · swissdamed registration obligation

Target end 2026eSubmissionWatch

Swissmedic on track to complete eCTD v4.0 by end of 2026

Swissmedic confirmed it intends to complete technical implementation of eCTD v4.0 by the end of 2026, with go-live during 2027 after pilot testing. It also announced a re-election of the full Agency Council for 2026–2029 and a federal funding increase tied to performance-improvement targets.

Why it matters: Sponsors planning Swiss submissions on a 2027 timeline should prepare for eCTD v4.0 rather than the legacy format.

Sources: Swissmedic — federal contribution increase

EU

EU-wide — direct effect in DE & AT

7 & 10 Sep 2026HTA · JCAIn force

Commission publishes an SMA advanced-therapy JCA report and refreshes the JCA tracker

The Commission published a Joint Clinical Assessment report on an advanced therapy for spinal muscular atrophy on 7 September 2026, and an updated list of ongoing and completed JCAs on 10 September: 15 JCAs initiated to date under the 2026 HTACG work programme, which for the first time brings selected high-risk medical devices into scope.

Why it matters: See the Itvisma item above for how this JCA output lands on a German dossier in real time — a useful precedent for any ATMP or oncology asset entering JCA scope.

Sources: EC — JCA report on SMA ATMP · EC — updated JCA list

What we're tracking
  • EU pharma package (in ratification). COREPER endorsed the trilogue texts on 6 March 2026; final Parliament and Council approval is targeted for autumn 2026, with entry into force 20 days after Official Journal publication.
  • MDR/IVDR targeted revision (in ratification). The Commission's December 2025 proposal to simplify MDR/IVDR and delay select deadlines is moving through accelerated co-decision; no final adoption yet.
  • EU–Switzerland MRA (in ratification). Signed 2 March 2026 to restore mutual recognition of MDR/IVDR certificates; not in force until both sides ratify.
  • GKV-BStabG phase-in (transition). Published 29 July 2026; most operative measures phase in from 1 January 2027 — worth calendaring now for GKV-facing products.
  • Cochlear-implant statements due 12 October, oral hearing 12 November.
  • Itvisma dossier assessment due 2 November, G-BA decision expected end of January 2027.
  • swissdamed transition close, 31 December 2026.
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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 8–15 September 2026 and was issued on 15 September 2026.