Transparency data

12 December 2025 minutes

Published 20 February 2026

Meeting details

This meeting was held on 12 December 2025 from 10am to 11:50am in the conference rooms at the Department of Health and Social Care (DHSC) office at 39 Victoria Street and on Microsoft Teams.

The chair was Nico Reynders.

Minutes were taken by Michael Vidal.

Attendees

From the Department of Health and Social Care (DHSC):

• Noah Kidron-Style
• Bilal Evans
• Abigail Bishop-Laggett
• Tom Slingsby
• Simon Roer
• Lisa Holloway
• Hannah Keys
• David Barley
• Ishi Shrivastava
• Annie Ghouri
• Andrew Wheeler
• Nicholas Moriarty
• Michael Vidal

From NHS England:

• Jack Turner
• Claire Foreman

From the Association of the British Pharmaceutical Industry (ABPI):

• Kim Assender
• David Watson
• Roz Bekker
• Joe Edwards
• Victoria Jordan
• Pinchas Kahtan
• Guy Phillips
• Nico Reynders
• Janet Valentine
• Peter Wickersham

From the devolved governments:

• James Gordon (Northern Ireland)
• Alison Strath (Scotland)
• Andrew Evans (Wales)

From the Office for Life Sciences (OLS):

• Rory MacFarlane

From the National Institute for Health and Care Excellence (NICE):

• Arron Dunphy
• Alexander Ng
• Jacoline Bouvy
• Ian Saunders
• Andrew Wheeler

From Medicines UK:

• Mark Samuels (observer)

From the Ethical Medicines Industry Group (EMIG):

• Leslie Galloway (observer)

From the BioIndustry Association (BIA):

• Rosie Lindup (observer)

Introductory remarks

Nico Reynders (NR), chairing, welcomed everyone to the fourth operational review of the 2024 voluntary scheme for branded medicines pricing, access and growth (VPAG).

Noah Kidron-Style (NKS) expressed thanks to colleagues across industry and within government for their sustained collaboration during what had been a challenging period. It was noted that, despite the pressures faced, all parties continued to demonstrate a strong spirit of trust and partnership.

NKS noted that government is happy to have an agreement which brings certainty around the future of VPAG and the commercial environment, but noted that work needs to be done to implement it. The group agreed on the need for collaboration around a collective target in 2026.

NR recognised the importance of agreeing a sustainable model beyond the VPAG scheme, to make sure that all parties’ objectives are met. NR noted the importance of uptake to achieving the milestones outlined in the deal and improving outcomes for patients.

VPAG objective 1: NHS financial sustainability

2026 headline payment percentage

Updating the group, Abigail Bishop-Laggett (ABL) confirmed that the 2026 payment percentage had been published earlier that day, setting the rate at 14.5%. This represented a decrease from 2025 and was considered a positive outcome. It was noted that the primary driver of the reduction was the impact of patent expiries, which had resulted in a significant shift from newer to older medicine categories. This shift, while substantial, was alongside broader positive trends in medicines growth.

ABL further explained that although the 15% payment percentage ceiling had been announced, it had not been triggered for 2026.

She outlined the ongoing work to prepare text amendments to the current scheme, reflecting what had been agreed in the new UK/USA pharmaceutical trade deal. Draft amendments would be sent to the ABPI, including commitments relating to the baseline adjustment mechanism for ensuring that the 25% price increase is not recouped within the scheme mechanism. All parties agreed on the need to consistently communicate that the impact of the 25% increase applies only to prices of new launches. This is essential to avoid any misrepresentation of the deal.

ABL noted that detailed design work on these mechanisms would continue into next year, ensuring everything is finalised ahead of the 2027 rate-setting process. Further explanation was provided on early thinking regarding how the 15% ceiling may operate, including that its application would likely be after under and over payment calculations.

Action: draft amendments will be sent to ABPI, with detailed design work continuing into next year ahead of the 2027 rate setting process.

Scheme metrics

David Barley (DB) noted that his update would cover both the findings from the 12 November 2025 pre‑meeting and new insights from the latest metrics pack.

DB summarised that the pre‑meeting highlighted several developments, including:

• rising mean and median durations of NICE technology appraisals since the year 2024 to 2025
• positive company feedback on DHSC’s revised price increase financial return (exceptional price increase) requirements
• ongoing uncertainty about USA’s most favoured nation (MFN) policy, though its effects are not yet clearly visible in current data

Reviewing the metrics pack, DB noted:

• a higher than usual volume of appraisal terminations in the first 6 months of the year; very strong growth in new active substance (NAS) sales
• a sharp reduction in overall new‑medicine year‑to‑date sales growth
• an even split of pricing applications awaiting DHSC versus company action
• continued growth in PharmaScan records
• a modest but incomplete recovery in clinical trial recruitment

NR welcomed the metrics but urged that process indicators (for example terminations, technology appraisal durations) be complemented with outcome‑focused measures, showing how many licensed medicines actually reach patients. NICE colleagues explained that termination data implicitly captures non‑submission cases. Kim Assender (KA) referred to the NICE/ABPI terminations work that was conducted to understand the reasons behind the terminations to raise awareness of discussions that are happening in different forums.

Arron Dunphy of NICE added that termination peaks are historically normal and not cause for immediate policy action. The group agreed to review trends again at year end and acknowledged that MFN‑related effects would need monitoring throughout 2026.

Action: convene ABPI/DHSC/NICE ‘deep dive’ on Medicines Impacts and Investment Survey (MIIS) results to identify where and why UK launch delays occur; include severity and/or duration and MFN issues.

Older medicines stocktake

Tom Slingsby (TS) recapped some of the key findings and discussion points from the 24 November older medicines stocktake, and sought agreement on the proposed areas for further monitoring or analysis ahead of the spring 2027 mid-scheme review.

When looking at older medicines’ income and distribution, DHSC’s initial analysis showed a fall in forecast income from older medicines, some evidence of price erosion among the highest cost older medicines, and average prices increasing and volumes falling among lower value products. These findings suggest that older medicines experience the mechanism in different ways. TS noted that the findings are only preliminary and that more detailed analytical work is needed before drawing firm conclusions.

The group agreed 3 priority areas for this workstream:

• segmenting older medicines to better understand the impact of the mechanism and/or identify patterns
• continuing to monitor income to understand whether early findings are structural or temporary
• examining whether and/or how the mechanism is impacting competitive dynamics in markets which might in turn impact supply resilience

KA and David Watson (DW) agreed it is too early to draw conclusions on this workstream, and noted that price erosion, even with lower payment rate, may still indicate the mechanism is delivering NHS value. The group agreed that 2026 data will be crucial to show whether these early signs persist or change.

TS noted that the de-branding workstream had been analytically challenging due to the many factors shaping company behaviour. Early findings show de‑branding of older medicines fell in 2025 while de‑branding of newer medicines rose, with causes still unclear. DHSC had seen no direct evidence of supply issues as a result of the older products mechanism, though industry noted companies may avoid exceptional pricing increase applications due to administrative burden and instead withdraw small products.

KA also raised concerns that the mechanism may discourage repurposing and other forms of innovation in older active substances such as those that support environmental sustainability. Additionally, some products remain branded for regulatory reasons and may be disproportionately affected, warranting closer analysis.

KA and TS agreed that innovation can come in different forms, such as reformulations, lower-emissions administration or repurposing. The group agreed to continue monitoring de‑branding and supply, assess how the mechanism may discourage innovation in older actives, examine branded‑by‑requirement products, and explore adding supply‑risk signals to DHSC’s discontinuations and shortages (DaSH) portal. DHSC noted this will require additional cross‑team analysis.

TS set out that the reference pricing rules worked well. Most older medicines had their reference price set at their reference anchor date, and most reference prices were calculated with no further adjustments, meaning a close comparator was identified. Average selling price data was used in the majority of cases where the scheme rules allow.

TS thanked companies for engaging extensively to verify reference pricing data.

KA reciprocally thanked DHSC for adjusting approaches during the intense 2024 to 2025 implementation period, noting that this was a major exercise involving thousands of products.

ABPI MIIS survey results

Pinchas Kahtan (PK) presented findings from ABPI’s September to October 2025 MIIS. PK noted the data was collected during a period of significant uncertainty ongoing VPAG negotiations, unclear UK/USA MFN implications and wider commercial pressures. Attendees were asked to interpret results within this context, as the survey will act as a baseline for assessing the impact of the new agreement.

The survey reached all VPAG and statutory scheme members, with responses from 42 companies across a broad mix of sizes and therapeutic areas. The profile aligns with earlier 2025 surveys, supporting comparability.

PK noted that the survey showed a continued decline in the UK’s global launch priority. Companies cited regulatory and commercial uncertainty, slow uptake, and VPAG/MFN related unpredictability. Global headquarters increasingly viewed the UK as a higher risk launch market.

Respondents reported 46 products negatively affected since January 2024, including delayed, private only, or withdrawn UK launches, spanning multiple therapy areas, notably oncology. Attendees highlighted opportunities to link this with NICE initiation and/or termination data.

Cross referencing the 46 products with the Committee for Medicinal Products for Human Use (CHMP) and company pipelines suggests around 20% of expected launches were adversely affected. ABPI acknowledged methodological limits but sees value in year-on-year tracking. NKS cautioned about self-selection bias but agreed long term data would be useful.

NICE reported stable early engagement activity up to 24 months pre-launch. Industry explained that withdrawal decisions typically occur later, meaning NICE’s early-stage stability does not contradict the survey. Both sides agreed to explore where drop offs occur in the pathway.

Key themes included VPAG uncertainty, MFN spillover concerns, ongoing uptake challenges and reduced confidence in the UK’s predictability. Future surveys will aim to classify root causes more precisely. Suggestions were made to map delays to specific decision points.

Twenty-four products showed supply viability concerns, with 70% to 80% citing VPAG as a contributing factor. DHSC highlighted the need to distinguish between competitive shifts and true resilience risks, noting that loss of plurality, rather than firm level performance was the key issue.

In conclusion, PK noted that ABPI plans to publish a public report in early 2026 and re-run the survey in late 2026 to assess impacts of the new VPAG deal and MFN developments. There are also plans to hold a joint technical session with DHSC and NICE.

VPAG objective 2: promoting better patient outcomes

Update on access, adoption and outcomes commitments

Jack Turner (JT) outlined progress on VPAG chapter 3 commitments, covering horizon scanning, commercial processes, uptake, and data transparency. Despite disruptions from VPAG negotiations and UK/USA discussions, JT was grateful that all organisations had continued to make steady and collaborative progress in delivering chapter 3 commitments.

Most chapter 3 commitments are already delivered, with the remainder on track. Joint bi-monthly workshops will continue, with the UK/USA deal not affecting these commitments.

Horizon scanning capability has strengthened, with NHS England and NICE aligning operationally and PharmaScan upgrades underway, including new data fields for service readiness risks. JT encouraged consistent industry input.

On commercial processes, NHS England plans ‘deep dive’ work from January to June 2026, followed by a second commercial framework (CF) consultation later in 2026. JT noted that the consultation delay also pushes back formal adoption of confidential primary care rebates, though pilots may proceed case by case.

For uptake, national and regional clinical leaders are promoting NICE guidance, linking this work to broader reforms such as the single national formulary.

JT noted that data transparency projects were progressing, including the adoption of a national patient support programme database, a minimum data set for local formularies, and a rebuilt innovation scorecard using OpenSAFELY, now targeting April 2027.

The Medicines and Medical Devices Access Initiative continues to operate and may focus more on 4 nation co-ordination on access and adoption, as well as further approaches for outcomes-based payments.

On outcomes‑based payment, accounting issues have slowed progress, and a real‑world pilot in 2026 is now needed. ABPI and NHS England will encourage companies to propose suitable candidates.

Peter Wickersham asked about timelines for therapeutic ‘deep dives’. JT explained that the NHS is shifting away from ad‑hoc deep dives toward a pipeline‑wide horizon‑scanning approach focused on medicines expected 2 to 3 years ahead. A new criteria‑based prioritisation framework will highlight high‑priority pathways with multiple upcoming products. The aim is to improve service readiness, reduce funding variation, assess capital needs, and incorporate new key performance indicators into the CF.

As there were no objections to the change request, JT outlined upcoming actions, including drafting a letter to ABPI confirming agreed changes and delaying consultation on the CF to align with wider government work. The delay also pushes back the planned confidential primary care rebate model, though pilots remain possible case by case.

The letter will also clarify the NICE threshold transition period and outline processes for medicines that pass committee stages during the policy shift.

JT closed by noting strong progress across access, adoption, and outcomes, with major data initiatives set to improve NHS insight. The year 2026 offers key opportunities to align chapter 3 with wider system reforms, including the 10 Year Health Plan for England, the life sciences sector plan and the single national formulary.

VPAG objective 3: supporting UK economic growth

Investment programme update and look ahead to spring 2026

Rory MacFarlane (RM) gave an update on the VPAG investment programme, noting strong progress since the last operational review group meeting in September 2025. The programme is now in full delivery, with over 20 active projects supported by 9 delivery partners, and he thanked ABPI for their continued support.

A joint communications plan with the ABPI is being developed to highlight the programme’s impact and provide clearer information to scheme members on how they can engage with the various projects. Communications will be tailored for both UK stakeholders and a global audience, with the intention of increasing clarity and visibility.

Plans also include sharing materials with other trade associations, ensuring all scheme members understand how investments are being used.

RM updated on the ongoing work streams noting that in October 2025, 14 primary care commercial research delivery centre (CRDC) sites were launched with £10 million in funding to accelerate commercial clinical trials, support decentralised models and widen participation among under‑represented groups. Scotland is expanding clinical trial capability into community settings, and a UK‑wide CRDC network, co-ordinating 21 CRDCs and 14 primary care sites was established to strengthen research capacity and industry engagement. A January 2026 event will further connect industry with CRDC leads.

Eight Grand Challenge manufacturing projects were announced during London Life Sciences Week, focusing on circularity, green chemistry and resource efficiency to advance UK medicines manufacturing.

The programme also continues to support health technology assessment (HTA) and access work, including UK PharmaScan. Northern Ireland has published a medicines access review and set up a new leadership group. Wales is developing a prescribing variation dashboard, while Scotland is preparing to pilot a new patient reported outcome measures platform.

Alison Strath (AS) added further detail on the HTA work programme from a Scotland perspective, explaining that it focuses on 3 main outcomes:

• streamlining methods, aligned with wider PharmaScan work, to ensure Scotland’s HTA processes remain cutting‑edge
• digital pathways and implementation, improving how medicines advice and guideline updates are connected and accessed digitally by clinicians, including close work with the Scottish Intercollegiate Guidelines Network
• data‑driven approaches to support outcome‑based pricing, underpinned by stronger digital solutions

AS also noted 3 structural developments:

• a horizon scanning advisory board to support service readiness
• a new sub‑regional planning process (east and west) to help NHS Scotland prepare for innovation
• ongoing work on regional formularies, which will inform whether Scotland moves toward 1 national formulary or retains 3 regional ones

Joe Edwards welcomed progress on the investment programme, noting strong alignment with timelines and emphasising that 2026 will be a pivotal year for demonstrating real-world outcomes. He stressed 3 communication priorities:

• transparency on how industry funding is used
• early demonstration of value (‘green shoots’)
• clear guidance for companies on how to engage with programme initiatives

He suggested involving all trade associations to jointly shape communications before the end of the year or early next year.

Action: RM agreed to take forward the action to engage trade associations and acknowledged the need for a clearer, unified message. He noted the upcoming CRDC network event in January 2026 as an opportunity to show how CRDCs sit within the broader clinical trials infrastructure.

Any other business

There was no other business. In closing, NR noted that 2025 had been a particularly demanding and heavy year, marked by significant discussion, differing views, and moments of disagreement. NR felt that these were all healthy indicators of a functioning democratic process, and that such open dialogue strengthens collective decision‑making.

Looking ahead, NR expressed a sincere hope that 2026 will bring greater stability and calm.