History

The UK’s disclosure framework has evolved over several decades in response to changes in legislation, professional guidance, public expectations, and international transparency initiatives. What began as voluntary reporting under the ABPI Code of Practice has developed into one of the most comprehensive industry led‑led transparency mechanisms in Europe.

Foundations of industry self‑regulation

1958 First ABPI Code of Practice for the Pharmaceutical Industry
1968 UK Medicines Act

Introduction of patient organisation transparency

2006 ABPI Code of Practice requires pharmaceutical companies to disclose their involvement with patient organisations including publishing a list of all patient organisations to which they provide financial support
2007 EFPIA Patient Organisation Code agreed to come into operation on 01 July 2008
2008 ABPI Code of Practice requires pharmaceutical companies to expand patient organisation disclosures to include significant indirect/non-financial support and short descriptions
2010 US Healthcare Reform
2011 EFPIA updates Patient Organisation Code
2011 ABPI Code of Practice requires pharmaceutical companies to disclose monetary value of support to patient organisations with a value of £250 per project or more (threshold removed in 2012)

Early healthcare professional and organisation disclosures & global influence

2012 ABPI Code of Practice requires pharmaceutical companies to disclose payments to healthcare professionals in aggregate for the first time, and disclosure of grants and donations made to healthcare organisations on a per activity basis
2013 Ethical Standards in Health & Life Sciences Group (ESHLSG) consulted on plans for a central UK disclosure database receiving support from almost 80% of respondents.
2013 US Sunshine Act established
2013 EFPIA Disclosure Code agreed. Full disclosure required across all EFPIA member countries (commencing with 2015 data published in 2016)
2014 First US Sunshine Act report released

Laying the foundations for modern transparency

2014 Revised ABPI Code of Practice expands disclosures about healthcare professionals and organisations to include joint working activities (HCO-only), contracted services, and aggregate disclosure about research and development activities; introduces the requirement for a methodological note; encourages companies to seek consent to name individual healthcare professionals; includes first mention of a potential UK central platform.
2015 Revised ABPI Code of Practice requires pharmaceutical companies to use a central platform and the standardised template for UK disclosure (commencing with 2015 data published in 2016)
2016 Revised ABPI Code of Practice (no changes to disclosure requirements)
2016 First EFPIA disclosure report
2016 Disclosure UK database launched on 30 June with 2015 data

Embedding transparency across the health system

2017 NHS England directly references use of Disclosure UK in their Guidance for managing conflicts of interest in the NHS developed with representation from the ABPI
2017 ABPI/NHS England published a joint letter on shared commitment to 100% named HCP disclosure.
2017 General Medical Council guidance includes a HCP case study on declaring conflicts of interest, which incorporates being named on Disclosure UK
2017 The Academy of Medical Royal Colleges (AoMRC) publishes statement recommending HCPs agree to be named on Disclosure UK (Academy reinstated their position in 2018)
2019 EFPIA publish consolidated Code, bringing European disclosure requirements into a single EFPIA Code
2021 Revised ABPI Code of Practice requires pharmaceutical companies to disclose aggregate payments to members of the UK public for certain services for the first time
2021 ABPI launches Patient Organisation ‘gateway’ via Disclosure UK, gathering links to disclosures on company websites
2021 ABPI publicly champions use of Legitimate Interests as GDPR lawful basis for named HCP disclosure supported by 18x of the UK’s medical, government and regulatory bodies
2023 EFPIA launches European disclosure gateway
2023 ABPI launches Members of the Public gateway via Disclosure UK
2023 UK government launch public consultation on mandatory disclosure recognizing Disclosure UK as a robust transparency mechanism
2024 Revised ABPI Code mandates use of Disclosure UK gateways for patient organisation and public disclosure data
2024 NHS England update their guidance for managing conflicts of interest, maintaining support for Disclosure UK
2024 The Academy of Medical Royal Colleges (AoMRC) reaffirms it’s commitment to transparency in HCP relationships with industry
2025 Tenth year of data published on Disclosure UK (2015 – 2024): record transparency levels achieved.