⚖️ List Price ≠ Net Price: What is the “real” price of an innovative medicine in Germany?

 

The visibility of pharmaceutical prices is becoming increasingly relevant in the context of International Reference Pricing (IRP) and Most Favoured Nation (MFN) approaches.

 

But are we talking about the list price or net price❓

👉 When discussing pharmaceutical prices in Germany, the list price is often the starting point. However, particularly for innovative medicines, it tells only part of the story.

 

What information is publicly available to derive the actual net price❓

👉 Following an early benefit assessment under AMNOG, the reimbursement price will generally differ from the freely set launch price. In addition, mandatory manufacturer rebates (currently 7%, as of January 1st 2027 15.5%) need to be VAT adjusted and other contractual discounts can further reduce the actual amount realized by the pharmaceutical company.

 

The picture becomes even more interesting with the introduction of the confidential reimbursement price under the Medical Research Act.

Under certain conditions, manufacturers can opt for a confidential reimbursement price. The agreed reimbursement price is then not publicly disclosed, while the original launch price remains visible as the list price. The confidentiality comes at a cost of additional 9% on the negotiated price. The current framework is initially limited until June 30th 2028.

 

How the net price is actually derived, is shown in our simplified illustration. 👉 🖼️

 

For pharmaceutical companies, understanding the difference between what is publicly visible and what is actually paid is becoming increasingly important.