Germany has started a government-led process to develop broader exemptions from the additional 8.5% manufacturer rebate introduced by the Statutory Health Insurance Contribution Rate Stabilisation Act (GKV-Beitragssatzstabilisierungsgesetz, GKV-BStabG). The work is at an initial policy-design stage, with no further exemption criteria yet agreed.
The Federal Ministry of Health (Bundesministerium für Gesundheit, BMG) and Federal Ministry for Economic Affairs and Energy (Bundesministerium für Wirtschaft und Energie, BMWE) announced on 28 August that an expert panel had begun work on the ‘location clause’. Recommendations are due by 30 September, with implementation intended from 1 January 2027.
The panel brings together experts in economics, law and clinical research with representatives of industry, statutory health insurance, trade unions, coalition parties and the Länder. Its remit follows a Bundestag resolution adopted alongside the July GKV-BStabG.
The resolution asks the government to examine further exemptions that could support pharmaceutical production and investment in Germany, including value creation, collectively bargained employment and resilient supply. Any approach must comply with EU and trade law and preserve statutory health insurance contribution-rate stability. The government must also consider ways to offset additional payer costs and support outside health insurance, including EU and federal economic-development instruments.
The exercise goes beyond the narrow exemption enacted in July. New active substances first marketed from 2027 can avoid the additional rebate where at least 5% of participants in relevant company clinical trials were enrolled at German sites.
Payer organisations have already challenged the broader approach. The AOK Federal Association (AOK-Bundesverband) argues that industrial-location policy should not be financed through statutory insurance contributions and warns that wider exemptions could reduce the savings expected from the July law.
The panel therefore opens a possible route for domestic investment to affect the effective rebate on patented medicines. The criteria, financial scale and legal design remain to be determined.
Source: Federal Ministry for Economic Affairs and Energy, BMWE (Federal Ministry for Economy)
Link: Pharmastandort Deutschland: Neues Fachgremium nimmt Arbeit auf (Germany as a pharmaceutical location: new expert panel begins work)
Date: 28 August 2026
Source: German Bundestag (Bundestag Dserver)
Link: Entschließungsantrag der Fraktionen der CDU/CSU und SPD zu der dritten Beratung des Gesetzentwurfs der Bundesregierung – Entwurf eines Gesetzes zur Stabilisierung der Beitragssätze in der gesetzlichen Krankenversicherung (Resolution motion by the CDU/CSU and SPD parliamentary groups on the third reading of the government bill – Draft Act to Stabilise Contribution Rates in Statutory Health Insurance)
Date: 10 July 2026
Source: AOK Federal Association (AOK)
Link: Reimann: Geplante Standortklausel für Pharmafirmen wird ihre Ziele verfehlen (Reimann: planned location clause for pharmaceutical companies will fail to achieve its objectives)
Date: 27 August 2026
