Each European country approaches
the pricing and reimbursement of medicines in its own way. The common objective
is to ensure access to medicines that meet EU-wide standards of quality, safety
and efficacy. However, differences in the design of national systems have a
direct impact not only on price levels, but also on the availability of
medicines, market structure and manufacturers’ behaviour. Number of Initiated
Proceedings: The Reality of the Czech Market
According to the European
Medicines Agency Annual Report (European Medicines Agency, 2025), a total of
114 medicines were authorised through the centralised procedure in 2024,
including 46 medicines containing a new active substance (the authorisation of
one product was subsequently withdrawn).
Our analysis, conducted as of 1
March 2026, confirms that among medicines containing a new active substance
approved by the European Medicines Agency in 2024:
✅ Price and reimbursement
have been determined for only 5 of the 45 medicines,
⏳ Administrative proceedings
on price and reimbursement determination are ongoing for 20 medicines,
🛑 For 20 medicinal products, the marketing authorisation holder has not yet submitted an application for inclusion in the List of Reimbursed Medicines,
🚚 Distribution has
been initiated for 16 medicines, regardless of whether reimbursement has
been established.
These figures suggest that the
path of new innovative medicines to the Czech market is often slow and
administratively demanding, which may have a direct impact on both patients and
manufacturers. The Question: Reasons for
Delays
The 2025 study Medicines:
Regulation versus Patient Needs, conducted by the Initiative for Efficient
Healthcare (Hlávka et al., 2025), points out that the strict and long-standing
rules governing reimbursement determination are primarily focused on limiting
the budgetary impact. Typical measures include:
reimbursement limited to only part of the indicated
patient population,
prescription restrictions limited to specific
medical specialties or specialised healthcare facilities.
Such restrictions directly affect
the availability of medicines and may reduce the attractiveness of the Czech
market for manufacturers, which can lead to delayed market entry of innovative
therapies. Recommendations: Flexibility
and Modern Financing Instruments
The authors of the study
recommend:
introducing a more flexible willingness-to-pay
(WTP) threshold, better reflecting disease severity, the level of
innovation and patient needs,
using modern financing mechanisms, such as coverage
with evidence development (CED) or risk-sharing arrangements,
further developing multi-criteria decision analysis
(MCDA) for very high-cost medicines.
The study also highlights
additional factors affecting the market, including dependence on imports, the
underutilised potential of pharmacists, the need to work with real-world data,
and the importance of supporting competitiveness and self-sufficiency in the
pharmaceutical sector. The patient perspective is not
overlooked either:
“For medicines to be
effective, it is essential that patients understand their disease and therapy,
and that they know why and how to use medicines correctly and safely.”
Source:
European
Medicines Agency. (2025). Annual report 2024. Publications Office.
https://data.europa.eu/doi/10.2809/6143038
Hlávka, J., Klimková, V., Brychtová, M., Selinger, E.,
Přecechtěl, Š., Milošič, A., Chadimová, K., Decker, B., Navrátil, M., Vaniš,
K., & Kučera, M. (2025, září). IEZ_Studie_Zdravotnictvi pro
budoucnost_4-Leciva.pdf. Studie 2025: Léčiva: regulace versus potřeby
pacientů.
https://www.efektivnizdravotnictvi.cz/post/studie-2025-leciva-regulace-versus-potreby-pacientu
Each European country approaches the pricing and reimbursement of medicines in its own way. The common objective, however, is to ensure that patients have access to medicines that meet EU-wide...
There is no
legal basis in the Public Health Insurance Act for excluding a medicinal
product from price
referencing on the grounds that its price is a tender price, nor does any other
legal provision allow such a procedure.
In
administrative proceedings concerning the determination of price and
reimbursement initiated from 1 January 2026, it is possible, beyond the
previously existing options, to exclude the manufacturer price in an EU Member
State where that state has introduced a market-wide measure affecting the
manufacturer price of the medicinal product. In such cases, however, SÚKL must
receive official information from the relevant foreign authorityor from the
Ministry of Health.
In the
determination of the maximum manufacturer price, a foreign price is also
excluded in cases where the lowest price deviates by more than 20% from the
average of the second and third lowest prices, or where more than three prices
are identified and the price associated with an exchange rate deviating by more
than 10% from the average exchange rate over the previous six calendar quarters
is excluded.
When determining the base reimbursement, a
foreign price may also be excluded if it is at least 20% lower than the average
of the second and third lowest prices. However, this rule does not apply to highly innovative and orphan medicinal products.
Are you interested in reading regular commentaries on decisions by
Pharmeca a.s.? Feel free to contact us.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
A continuously
updated overview of decisions issued by SÚKL and the Ministry of Health in the
field of pricing and reimbursement is available on the Pharmeca a.s. website.
In
2025, 12 decisions of the State Institute for Drug Control(SÚKL) became
legally effective in administrative proceedings relating to the determination
of price and reimbursement for orphan medicinal products. Although the system
introduced in 2022 is formally structured around SÚKL decisions, the Institute
may not deviate from the binding opinion of the Ministry of Health of the Czech Republic.
In 2025, SÚKL issued a total of 12 final decisions in proceedings concerning the determination of price and reimbursement for orphan medicinal products, based on binding opinions of the Ministry of...
The State Institute for Drug Control decided on the determination of the maximum price and reimbursement for a medicinal product containing the active substance tamoxifen citrate.
The proceedings were initiated upon the company’s application pursuant to Section 32d of the Public Health Insurance Act. The purpose of this specific procedure is to ensure the availability of irreplaceable medicinal products in situations where a supply disruption in the Czech Republic is imminent or has already occurred.
The primary reason for the decision was to ensure continued treatment availability for oncology patients, as supply of the previously registered medicinal products containing the above active substance had been interrupted for manufacturing reasons. As no other registered alternative for oral administration was available within the relevant group, the Ministry of Health approved a specific treatment programme for an unregistered medicinal product. The Institute subsequently determined its maximum price and reimbursement level, adopting the reimbursement conditions of the originally reimbursed product that had become unavailable.
The decision on the determination of price and reimbursement was issued 24 days after submission of the application.
Are you interested in reading regular commentaries on decisions by
Pharmeca a.s.? Feel free to contact us.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
A continuously
updated overview of decisions issued by SÚKL and the Ministry of Health in the
field of pricing and reimbursement is available on the Pharmeca a.s. website.
The State Institute for Drug Control (hereinafter the “Institute”) informs about current service outages of Verso and DSŘ (documents of CAU administrative proceedings). The reason for these outages is unforeseen technical issues on the side of an external supplier. Intensive work is underway to resolve the problem with the aim of restoring full system functionality as soon as possible. System adjustments have been implemented to eliminate the causes of the issues, along with improved monitoring and control of errors arising from this situation.
At this time, we can confirm that access to case files via the Verso application when logged in using the National Identification and Authentication Point (NIA), i.e. the so-called citizen identity, is functioning without limitations. Unfortunately, complications persist with access without login, which we are actively addressing.
We therefore recommend using login via citizen identity when accessing Verso.
Recommended Procedures for Affected Parties to Administrative Proceedings
In-person access to the case file Access to the case file pursuant to Section 38 of Act No. 500/2004 Coll., the Administrative Procedure Code, remains available at the Institute’s premises. When: Working days, 8:00–16:00 Where: SÚKL headquarters – Building B (Benešovská 2538/40, 101 00 Prague 10) Contact for appointment booking: cau_sekretariat@sukl.gov.cz
Monitoring the Official Notice Board Due to the technical outage, participants in administrative proceedings are advised to pay increased attention to monitoring the Institute’sOfficial Notice Board. Documents published by way of public notice in proceedings under Part Six of Act No. 48/1997 Coll., on Public Health Insurance, may be posted there and may include deadlines for procedural actions.
Procedural Deadlines and Applications If a technical obstacle on the part of the Institute objectively prevents a party from performing a procedural act within the prescribed time limit, the following instruments under the Administrative Procedure Code may be used: Extension of a deadline / suspension of proceedings: This may be requested if there is a risk of missing a deadline due to the unavailability of remote access. The request must be submitted sufficiently in advance. Waiver of missed deadline: If a deadline has already expired, the party may request a waiver pursuant to Section 41(2) of the Administrative Procedure Code. Each such request will be assessed individually, taking into account the current technical situation.
Note: Information on the restoration of the Verso system will be published on this page without delay. We apologise for the inconvenience caused and thank you for your understanding.
FAQ
1) Is it currently possible to access a case file?
Yes, in person at the Institute’s premises, Monday–Friday, 8:00–16:00. The Verso service may be temporarily unavailable.
2) What is DSŘ and can it be used instead of case file access?
DSŘ is an automated method for downloading selected documents (system-to-system communication). It is not an alternative to access to the case file under Section 38 of the Administrative Procedure Code and cannot replace it. DSŘ availability may be limited.
3) I am unable to meet a deadline due to the outage — what should I do?
Submit a timely request for an extension of the deadline or suspension of proceedings; after the deadline has expired, you may request a waiver pursuant to Section 41(2) of the Administrative Procedure Code.
4) How should I proceed if I need a specific document?
Book an in-person file inspection; for general orientation in the proceedings, continuously monitor the Official Notice Board.
The text of this article was taken in full from the SÚKL website.
SÚKL warns of possible limitations affecting remote access to case files via the Verso application and automated access to documents of administrative proceedings in CAU (DSŘ).
The Institute
initiated an ex officio abbreviated reimbursement review on the grounds
of the entry of the first similar medicinal product into the
reimbursement system, without undue delay after verifying that the product
concerned had been placed on the Czech market.
However, one of
the affected marketing authorisation holders appealed against the initiation of
the proceedings, arguing that the entering product was not the first similar
medicinal product and referring to earlier proceedings in which the newly
entering product had not been assessed as similar.
The Ministry of
Health (MoH) rejected this objection, stating that although in the referenced
proceedings the assessed product and the reference (originator) product
contained the same active substance, they differed in dosage, standardisation
units and pharmaceutical forms. At the same time, the products were assessed
against additional criteria—such as therapeutic indications or pharmacological
properties—and, on that basis as well, were not considered similar.
In the present
case, however, the MoH considers the medicinal product concerned to be a generic
within the meaning of the Act on Medicinal Products. The products involved in
the proceedings contain the same active substance and a comparable
pharmaceutical form as the reference product, and the appellant repeatedly
failed to demonstrate otherwise.
In the case under
review, the conditions for initiating a review on the grounds of the entry of
the first similar medicinal product were therefore met.
The MoH further notes that although, under the legislation applicable at the time, SÚKL could have initiated the proceedings earlier, the appellate authority considers the approach whereby SÚKL waited for the first actual supply of the medicinal product concerned to be appropriate and well justified. This prevented a reduction in reimbursement for similar products based on a first similar medicinal product that was not yet commercially available.
Pursuant to the amendment to the Public Health Insurance Act, in abbreviated reviews initiated after 1 January 2026, there is now an obligation to verify market availability at a minimum level of 5%, or 2% for ZÚLP.
Are you interested in reading regular commentaries on decisions by
Pharmeca a.s.? Feel free to contact us.
At Pharmeca, we help you navigate the complex landscape of
pharmaceutical and medical device information. We also offer flexible services
that can be tailored to your needs at any time.
Our market position and experience allow us to support you whenever you
need expert guidance.
A continuously
updated overview of decisions issued by SÚKL and the Ministry of Health in the
field of pricing and reimbursement is available on the Pharmeca a.s. website.
The State Institute for Drug Control (SÚKL) has published an updated, already 3rd version of Guideline CAU-08 – Requirements for the structure of expert documentation supplementing an application and for the structure of statements of other participants when submitting evidence in proceedings on the determination or change of the amount and conditions of reimbursement of medicinal products / partially reimbursed medicinal products, effective as of 2 January 2026.
The main change is the introduction of a new Annex No. 5 – Structured Submission A for marketing authorisation holders – immunisation.
SÚKL has published an updated version of guideline CAU-08 - Requirements on the structure of technical documentation to be submitted along with applications and on the structure of opinions of...
The determination of prices and reimbursement of medicinal
products is based on external price referencing, within which foreign
prices denominated in foreign currencies are converted into Czech crowns.
Currently, foreign prices are converted using the quarterly
average exchange rate published by the Czech National Bank for the calendar
quarter preceding the calendar quarter in which the administrative proceedings
were initiated (the “relevant exchange rate”).
According to the amendment to the implementing decree, where
no more than three manufacturer prices of a given medicinal product are
available and the relevant exchange rate differs by more than 10 % from
the average exchange rates over the six quarters preceding the relevant
exchange rate, the conversion for the affected medicinal product is carried
out using the average exchange rate over those six quarters.
Where more than three manufacturer pricesof a given
medicinal product are availableand the relevant exchange rate differs by more
than 10 %from the average exchange rates over the six quarters preceding
the relevant exchange rate, such a price is excluded from the calculation.
To make it easier to assess whether these conditions are
met, we have updated a visual support tool on our website.
With a single
click, you can now find not only the relevant average exchange rate for the
preceding quarter but also its deviation compared to the previous six quarters.
The amendment to the Public Health Insurance Act and its implementing decrees has introduced changes, effective from the beginning of the year, also in the way exchange rates are applied for price...
