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February 2026 | Pharmaceutical Regulation in an International Context: Implications for the Portuguese National Health Service
News | 19 February 2026 February 2026 | Pharmaceutical Regulation in an International Context: Implications for the Portuguese National Health Service

The Health Expenditure Observatory aims to promote regular analysis of the dynamics of health expenditure in Portugal. This publication analyzes the implications that pharmaceutical regulations in an international context may have for the Portuguese National Health Service (SNS).  

Based on the German experience following the 2011 AMNOG reform, which introduced mandatory drug price negotiations, the study shows that, in a European context where many countries use the external reference price (ERP) system, the prices charged in one country can be used as a reference in others. These interdependencies mean that national decisions send price signals across borders. 

For the Portuguese SNS, these dynamics mean that decisions on listed drug prices, transparency, and evaluation schedules affect not only public spending but also the timing of patient access to new drugs and the bargaining power of the public system vis-à-vis the pharmaceutical industry. 

In this context, the note highlights the importance of Portugal strategically using net price-based instruments, such as confidential managed access agreements and outcome-based mechanisms, to prevent the listed price from becoming a rigid anchor with adverse effects at the international level. At the same time, it highlights the need to strengthen early assessment, the predictability of processes, and the ability to quickly distinguish between innovations that justify rapid access and those where more demanding negotiations are compatible with a modest additional benefit. 

🌐 View the full report in Portuguese here

Author of the study: Giovanni Righetti​
Coordinators: Pedro Pita Barros and Carolina Borges da Cunha Santos.

This report is part of the Social Equity Initiative , a partnership between Fundación "la Caixa" , BancoBPI, and Nova School of Business and Economics.

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