Table 5

Accessibility and quality of drug company payment data disclosed via public regulation or a combination of self-regulation and public regulation

Country	Name of regulation	Overseeing authority and database web link2–4	Payment data accessibility*					Payment data quality*
Country	Name of regulation	Overseeing authority and database web link2–4	Document format	Single data template	Database searchable	Customisable summary statistics	Database downloadable	Characteristics included	Aggregation of payments	Payments with or without taxes	Unique identifiers
France	Law Number 2011–2012 (Law Bertrand)	Ministry of Social Affairs and Health	Webpage	Yes	Yes	No	Yes	Donors; donor categories; recipients; recipient categories; payment categories and amounts; date; recipient address	No	Inclusive of VAT	Donors (multiple entries for subsidiaries), recipients (partial)
Latvia	Regulation Number 378 (2014)	Health Inspectorate	XLS	Yes	No	No	Yes	Donors; recipients; recipient categories; payment name, description, category and amount; date; recipient address	No	Unclear	Donors, recipients
Belgium	Sunshine Act of 2016	Federal Agency for Medicines and Health Products	Webpage	Yes	Yes	No	No	Donors; recipients; recipient categories; payment categories and amounts; recipient address; years	Annually per payment type	Unclear	Donors, recipients
Lithuania	Law on Pharmacy (provisions from 2019), Ministerial Order Number V-1537 (2020)	State Medicines Control Agency	XLS	Yes	No	No	Yes	Donors; recipients; recipient categories; payment name; date; recipient address	No	Unclear	Donors (not publicly available), recipients (publicly available)
Portugal	Decree Law 20/2013 and 128/2013	National Authority of Medicines and Health Products	Webpage	Yes	Yes	No	No	Donors; donor categories; recipients; payment descriptions and amounts; years	No	Inclusive of VAT	No
Romania	Orders of the Minister of Health 194/2015 and 874/2015	National Agency for Medicines and Medical Devices	Webpage	Yes	Yes	No	No	Donors; recipients; recipient categories; payment descriptions, categories, and amounts; recipient address; date	No	Unclear	No
Slovakia	Act Number 362/2011 on Medicines and Medical Devices	National Health Information Center	XLS	Yes	No	No	Yes	Donors; recipients; recipient categories (only healthcare professionals); payment descriptions, categories and amounts; clinical trial numbers; product names; recipient address; date	No	Unclear	No
Denmark	Health Act of 2014, Executive Order Number 1153	Danish Medicines Agency Conferences abroad ; Professional affiliations	Webpage	Yes	Yes	No	No	Conferences abroad—donors; recipients; recipient categories; recipient address; Professional affiliations—donors; recipients; recipient categories; recipient address; payment amounts	Annually per payment type	Unclear	Recipients
Hungary	Act XCVIII of 2006 (provisions introduced in 2011)	National Institute of Pharmacy and Nutrition	Webpage	Yes	Yes	No	No	Donors; payment names, descriptions and amounts; date; recipient address	No	Unclear	No
The Nether- lands	Code of Conduct for Pharmaceutical Advertising (2012)	Foundation for the Code for Pharmaceutical Advertising	Webpage	Yes	Yes (recipient identifiers needed)	No	No	Donors; recipients; recipient categories; payment categories and amounts; year	Annually per payment type	Unclear	Recipients
Greece	Law 4316/2014; Opinion Number 5/2016 and 2/2017 of the Data Protection Authority; circular number 17770/2016 of the National Authority for Medicines	National Organisation for Medicines Payments to conference participants Payments to conference organisers; drug company websites	PDFs – image-based	Yes	No	No	Yes	Payments to conference participants—donors; recipients; payment categories (types of conference expenditure) and amounts; year; Payments to conference organisers—donors; payment amounts; year	Payments to conference participants—annually per recipient; Payments to conference organisers—donors	Unclear	Donors
Estonia	Medicinal Products Act of 2005 (provisions introduced in 2013)	State Agency of Medicines	XLS	Yes	No	No	Yes	Donors; payment categories and amounts; payment location (country); year	Annually per donor	Unclear	No
Turkey	Regulation on Promotional Activities of Medicinal Products for Human Use 2015	Ministry of Health (database not publicly available)	Unclear	Unclear	Unclear	Unclear	Unclear	Unclear	Unclear	Unclear	Unclear

*Lighter colours indicate, respectively, higher, and darker colours—lower, data accessibility and quality. The databases are presented in the descending order of their overall data accessibility and quality, that is, the greater overall number of lighter cells a database has the higher its position within the table. Databases with equal numbers of lighter and darker cells are sorted alphabetically.
†This column provides the dates when public regulation of payment disclosure was first introduced. If public regulation of payment disclosure forms part of a larger piece of government regulation, it is specified—where appropriate—whether the regulation of payment disclosure was introduced as a change already existing government regulation. The dates reported here do not cover changes to or refinements of provisions focusing on payment disclosure.
‡The disclosure requirements ordinarily cover both healthcare professionals and organisations. The exceptions are the Danish databases (only healthcare professionals) and the Turkish database (it is unclear whether disclosure requirements also cover healthcare organisations).
§Web links are accurate as of May 2021.
¶The recipient addresses ordinarily refer to the location of the payment recipient. In the case of Hungarian, Latvian and Lithuanian databases we considered that the event addresses were equivalent to recipient addresses.