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Photo of Shai Mulinari. Private photo.

Shai Mulinari

Associate Professor | Senior Lecturer

Photo of Shai Mulinari. Private photo.

Pharmaceutical industry self-regulation and non-transparency : country and company level analysis of payments to healthcare professionals in seven European countries


  • Shai Mulinari
  • Luc Martinon
  • Pierre-Alain Jachiet
  • Piotr Ozieranski

Summary, in English

The European pharmaceutical industry uses the alleged efficacy of self-regulation to question the need for transparency laws similar to the US Physician Payment Sunshine Act. We conducted a comparative analysis of 20 large companies’ payment disclosures in seven European countries in 2017–2019. The data was extracted as part of, a novel transparency project that scrapes and integrates publicly available databases and disclosures. Our analysis of EUR 735 million showed marked differences in country payment patterns. For example, payment totals per registered doctor were substantially larger in Spain and lowest in Sweden. There were significant country and company differences in individualized data completeness. Only 19% of totals were reported with recipient names in Germany, compared to Ireland (59%), the United Kingdom (60%), Italy (67%), Switzerland (73%), Sweden (79%) and Spain (100%), with little or no improvement over time. Payment data in Spain was particularly difficult to extract. Thus, in no country did self-regulation generate comprehensive individualized data allowing for building an accurate picture of financial relationships between the industry and healthcare professionals. We conclude that the cultures and policies of countries and companies create structural problems of data inaccessibility and incompleteness within the self-regulatory framework. Therefore, this study supports calls for a Europe-wide “Sunshine Act” to achieve real transparency of drug company payments.


  • Sociology

Publishing year







Health Policy





Document type

Journal article




  • Sociology (excluding Social Work, Social Psychology and Social Anthropology)
  • Health Care Service and Management, Health Policy and Services and Health Economy




  • What can be learnt from the new pharmaceutical industry payment disclosures? A network and policy analysis of ties between companies and health professionals and organisations
  • Following the money: cross-national study of pharmaceutical industry payments to medical associations and patient organisations


  • ISSN: 1872-6054