{"id":58775,"date":"2026-05-22T09:02:53","date_gmt":"2026-05-22T07:02:53","guid":{"rendered":"https:\/\/setterwalls.se\/?post_type=articles&#038;p=58775"},"modified":"2026-05-22T09:02:54","modified_gmt":"2026-05-22T07:02:54","slug":"the-swedish-dental-and-pharmaceutical-benefits-agency-proposes-new-regulations-on-applications-for-subsidies-and-the-pricing-of-medicinal-products","status":"publish","type":"articles","link":"https:\/\/setterwalls.se\/en\/article\/the-swedish-dental-and-pharmaceutical-benefits-agency-proposes-new-regulations-on-applications-for-subsidies-and-the-pricing-of-medicinal-products\/","title":{"rendered":"The Swedish Dental and Pharmaceutical Benefits Agency proposes new regulations on applications for subsidies and the pricing of medicinal products"},"content":{"rendered":"    <section class=\"block text bg-white\">\n        <div class=\"container container-sm\">\n            <div class=\"row\">\n                <div class=\"col-12\">\n                    <div class=\"editor-content\">\n                                                <p><strong>On 20 March, the Swedish Dental and Pharmaceutical Benefits Agency (TLV) issued a consultation document containing proposals for new regulations on applications for subsidies and the pricing of medicinal products (ref. no. 01020\/2026), along with an accompanying impact assessment. The proposal means that the current regulations and general guidelines (TLVFS 2008:2) on applications and decisions regarding medicinal products will be repealed and replaced by a new regulatory framework. The new regulations also amend the Swedish Dental and Pharmaceutical Benefits Agency\u2019s regulations (TLVFS 2003:2) on non-prescription medicinal products under the Act (2002:160) on Pharmaceutical Benefits, etc. The new regulations are proposed to enter into force on 1 July 2026.<\/strong><\/p>\n<p><strong>Background<\/strong><\/p>\n<p>The current regulations were issued in 2008 and have been amended on several occasions. Nonetheless, the TLV considers that several parts of the regulations are outdated and need to be revised to reflect rapid developments in the field of medicinal products, including new treatment options and higher societal costs for medicinal products. Against this background, on 22 December 2025, the TLV referred a first proposal for new general guidelines on the subsidisation and pricing of medicinal products, along with the repeal of existing regulations and general advice (ref. no. 4517\/2025) (the \u201c<strong>First Referral<\/strong>\u201d). You can read more about this referral in our article\u00a0<a href=\"https:\/\/setterwalls.se\/artikel\/tandvards-och-lakemedelsformansverket-remitterar-omfattande-forslag-om-priser-och-subventioner\/\">here<\/a>.<\/p>\n<p>In the First Referral, the TLV proposed that the requirements for what an application for subsidies and pricing must contain should be set out in an appendix to the new general guidelines and in the handbook for companies applying for reimbursement and pricing of medicines (the \u201d<strong>Company Handbook<\/strong>\u201d), rather than in binding regulations. The overall aim of the reform is to create a more effective regulatory framework that provides greater predictability and transparency and facilitates implementation for government agencies, applicant companies and other stakeholders.<\/p>\n<p>Several consultation bodies responded to the First Referral by pointing out that requirements that are binding on individual companies should not be regulated through non-binding instruments such as general guidelines or the Company Handbook but must instead have a clear legal basis in binding regulations. To accommodate these comments, the TLV has now issued the present referral, in which the binding application requirements have been moved from the appendix to the general guidelines and the Company Handbook and into new, binding regulations.<\/p>\n<p>In light of this, the TLV proposes:<\/p>\n<ul>\n<li>new regulations on applications for subsidies and the pricing of medicinal products, and the repeal of the TLV\u2019s regulations and general guidelines (TLVFS 2008:2) on applications and decisions regarding medicinal products and contraceptives, and<\/li>\n<li>amendment of the Swedish Dental and Pharmaceutical Benefits Agency\u2019s regulations (TLVFS 2003:2) on non-prescription medicinal products under the Act (2002:160) on Pharmaceutical Benefits, etc.<\/li>\n<\/ul>\n<p><strong>Contents of the proposal<\/strong><\/p>\n<p><strong>New and revised definitions<\/strong><\/p>\n<p>The TLV proposes that the definition of what constitutes a\u00a0<em>new medicinal product<\/em>\u00a0be revised. The definition should specify what constitutes a new medicinal product, rather than what does not. It is proposed that the new provision be rewritten as bullet points, stating that \u2018new medicinal product\u2019 refers to products such as originator medicinal products, generic medicinal products and hybrids where no medicinal product with the same active substance is subsidised, parallel-imported and parallel-distributed medicinal products without a subsidised equivalent, certain new medicinal products or new dosage forms containing an established substance, and biosimilars.<\/p>\n<p>Furthermore, a completely new definition of parallel distribution of medicinal products is proposed, which is consistent with the Swedish Medical Products Agency\u2019s definition. According to the proposal, parallel distribution refers to the sale of a centrally authorised medicinal product in an EEA country other than the one in which the medicinal product was originally manufactured and released.<\/p>\n<p><strong>New and revised requirements for the content of applications for subsidies and pricing of medicinal products<\/strong><\/p>\n<p>The TLV proposes a new provision specifying the information that all applications for subsidies and pricing of medicinal products must contain. According to the proposal, an application must always include the name of the medicinal product, the medicinal product\u2019s national unique identifier (NPL-ID) and the packaged medicinal product\u2019s unique identifier (NPL pack-ID). Furthermore, applications must contain information on the product number certificate, form, strength and packaging, the applicable price for each pack stated as the pharmacy purchase price (AIP) and the pharmacy retail price (AUP). The application must also contain information on the price per unit, millilitre and milligram stated as the pharmacy purchase price. Finally, the application must specify any other information and supporting documentation that the applicant company wishes to invoke.<\/p>\n<p>Furthermore, the TLV proposes that the provisions regarding the content of applications for subsidies and the pricing of new medicinal products be amended in several respects. This includes the proposal that the application should specify whether it relates to a general or limited subsidy and which patient population(s) the application covers. As regards applications for new medicinal products, the Agency further proposes clarifications regarding the information it wishes to receive in terms of the health economics analysis. Previously, only a health economic analysis of the medicine\u2019s cost-effectiveness was required, along with information on the estimated average daily treatment cost, average treatment duration and the most relevant comparator, presented as separate items. The Agency now proposes that these requirements be consolidated into a single point and that it be made clear that the company must provide a detailed justification for its choice of comparator.<\/p>\n<p>In TLV\u2019s view, an application for new medicinal products should include information on the number of patients who have the condition over the course of a year (prevalence) and the number of new patients who develop the condition each year (incidence) based on all the medicine\u2019s approved indications and on the patient group or groups to which the company\u2019s application relates. The aim is to enable the Agency to assess whether there are grounds to require better cost-effectiveness in cases of exceptionally high sales value or to accept a higher cost than usual for medicinal products intended for rare medical conditions. Finally, it is proposed that an application should include a statement of the intention to request a tripartite consultation with the regions.<\/p>\n<p><strong>New simplified procedure for established substances<\/strong><\/p>\n<p>The TLV has previously proposed a simplified procedure for medicinal products containing established substances, i.e. substances that are already used or have been used as medicinal products, which meet a medical need within the pharmaceutical benefits scheme and which, due to the legal basis for their authorisation, in whole or in part, lack complete documentation from clinical trials and thus also evidence of the medicine\u2019s efficacy. In order for the simplified procedure to be applied, the Agency proposes that regulations be introduced specifying the information such an application must contain.<\/p>\n<p>According to the proposal, an application under the simplified procedure should specify whether it relates to a general or limited subsidy. In the case of a limited subsidy, the patient groups concerned and the specific reasons for the limitation must be specified. The application should also include the approval or marketing authorisation, the summary of product characteristics and an assessment report, or equivalent documentation from the authority issuing authorisation, demonstrating the legal basis for the authorisation.<\/p>\n<p>If the application concerns a generic, parallel-imported or parallel-distributed medicinal product, justification must be provided as to why the directly imported equivalent qualifies as a medicinal product containing an established substance. In addition, the application should demonstrate that there is no clinically relevant comparator within the benefits scheme and justify the medical need, for example by referring to licensed prescribing under a special licence and treatment recommendations. Finally, the application should include information on estimated sales volume, expected sales levels, the timing of expected full-scale sales, and a cost estimate for the medicinal product\u2019s direct costs. The specific requirements regarding the content of the application will be clarified in the TLV\u2019s general guidelines and Company Handbook.<\/p>\n<p><strong>Consequences<\/strong><\/p>\n<p>The proposal is primarily of practical relevance and will affect pharmaceutical companies applying for subsidies and pricing, as well as the regions participating in the tripartite processes. The TLV considers that the burden on applicants will be limited, as a considerable proportion of the information requested is already submitted today. Nonetheless, companies should review their internal application routines to ensure that the additional documentation requirements can be met efficiently.<\/p>\n<p>As stated above, Setterwalls has previously reported on the TLV\u2019s proposal for new guidelines on the reimbursement and pricing of medicinal products (see\u00a0<a href=\"https:\/\/setterwalls.se\/artikel\/tandvards-och-lakemedelsformansverket-remitterar-omfattande-forslag-om-priser-och-subventioner\/\">here<\/a>). In the First Referral, the TLV also proposed that the price of high-value medicinal products should be systematically and periodically reduced as their sales value increases. However, in April 2026, the TLV announced that it was adjusting the method and timeline for this proposal, partly due to the uncertainty created in the pharmaceutical industry as a result of changes in the international pharmaceutical market.<\/p>\n<p>Setterwalls will continue to monitor developments in this area and will revisit the matter periodically.<\/p>\n                    <\/div>\n                <\/div>\n            <\/div>\n        <\/div>\n    <\/section>\n","protected":false},"excerpt":{"rendered":"","protected":false},"author":16,"featured_media":36344,"template":"","meta":{"_acf_changed":true,"_seopress_robots_primary_cat":"","_seopress_titles_title":"","_seopress_titles_desc":"","_seopress_robots_index":""},"article_category":[1058],"class_list":["post-58775","articles","type-articles","status-publish","has-post-thumbnail","hentry","article_category-life-sciences-en"],"acf":[],"_links":{"self":[{"href":"https:\/\/setterwalls.se\/en\/wp-json\/wp\/v2\/articles\/58775","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/setterwalls.se\/en\/wp-json\/wp\/v2\/articles"}],"about":[{"href":"https:\/\/setterwalls.se\/en\/wp-json\/wp\/v2\/types\/articles"}],"author":[{"embeddable":true,"href":"https:\/\/setterwalls.se\/en\/wp-json\/wp\/v2\/users\/16"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/setterwalls.se\/en\/wp-json\/wp\/v2\/media\/36344"}],"wp:attachment":[{"href":"https:\/\/setterwalls.se\/en\/wp-json\/wp\/v2\/media?parent=58775"}],"wp:term":[{"taxonomy":"article_category","embeddable":true,"href":"https:\/\/setterwalls.se\/en\/wp-json\/wp\/v2\/article_category?post=58775"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}