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In brief

The 2021 APBI Code was approved by ABPI members at a special General Meeting on Tuesday 12 January 2021 and it will come into operation on 1 July 2021. The changes to the 2021 ABPI Code were primarily made to reflect the structure of the 2019 EFPIA Code of Practice, which is a consolidation of the three EFPIA Codes. The PMCPA, the arms’ length body that enforces the ABPI Code, has a range of materials to help companies prepare. The new Code can be found on the PMCPA website. The PMCPA’s support materials include a version of the 2021 ABPI Code with tracked changes, a guide to the 2021 ABPI Code, a presentation including a summary of the changes, and templates.

The 2021 ABPI Code incorporates the new four primary ABPI Principles: Patients, Integrity, Transparency and Respect. These set out the behaviours that embody the spirit of the Code, and the ABPI’s expectation is that companies will start now incorporating these into their business culture, across their organisation. The Principles, amended and developed further by the ABPI, are now based on the EFPIA principles which were introduced in the 2019 EFPIA Code and also take account of the IFPMA Ethos.

Following similar structure to the 2019 EFPIA Code, the updated and reformatted Code has six distinct colour-coded sections for different audiences and interactions. The first section is the overarching requirements, these have broad applicability, and it is important these are applied into all levels of the companies. The harmonisation with the EFPIA Codes means that requirements for certain activities, which were previously only applicable to interactions with certain groups, now have a broader application. For instance, patient organisations and their representatives are now incorporated in many areas of the Code that previously only included health professionals, other relevant decision makers, healthcare organisations etc. Similarly, health professionals, other relevant decision makers and healthcare organisations have been incorporated into areas of the ABPI Code which previously only referred to patient organisations. Members of the public are now also included in the requirements for contracted services.

Other changes include the introduction of the concept of collaborative working, which offers greater flexibility for broader working with NHS organisations as well as incorporating the existing concept of joint working. Under the 2021 ABPI Code companies will also have to disclose more information about payments to the public, including patients and journalists starting with the disclosure of 2022 data in 2023.

Following Brexit, ABPI remains an EFPIA member and the ABPI Code and other ABPI guidance will continue to be closely harmonised with the EFPIA Code and other relevant EFPIA guidance.


Julia joined Baker McKenzie's London office as a trainee in 2005, qualifying in 2007, with a secondment to the Singapore office, and has shaped her practice to focus exclusively on regulatory matters affecting the Healthcare & Life Sciences industry.


Elina is an associate in Baker McKenzie London office.