Jigar Rajpura
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Portfolio · Project 05 · Cancer medicines · October 2026

Launch sequence strategy

Prices travel. Once a cancer medicine has a price in one country, other countries use it to cap, floor or negotiate their own. So the order in which a company launches decides not only when patients get the drug, but what it earns everywhere. Part 1 shows how the access rules connect, from the moment Phase 3 reads out. Part 2 is an engine: enter the drug’s epidemiology, comparator, PFS and OS, safety and price, and it recommends where to launch first and next, and why.

From Phase 3 readout to a launch sequence

Three decisions sit between a positive Phase 3 and the first patient in each country. Each one changes what the next one can achieve.

Starting pointPhase 3 reads out
Interim analysis 1

Primary endpoint met, survival immature

Often PFS or response is mature; overall survival (OS) is still early. The licence is reachable now.

Interim analysis 2

OS more mature, months later

A clearer survival estimate, which most HTA bodies weigh most heavily, at the cost of a later start.

Pipeline

More than one indication planned

Typically a smaller, high-need population and a larger, broader one, reading out at different times.

Before decidingWhat does the drug bring versus standard of care?
Added benefit

The benefit rating unlocks the price rules

  • Germany: a minor or non-quantifiable added benefit means a price no higher than the comparator’s.
  • France: ASMR I–III brings the European price guarantee; ASMR IV–V does not.
  • Brazil: proven therapeutic gain (category 1) can price up to the lowest of 14 countries; no added benefit (category 2) is capped at the comparator’s treatment cost.
The comparator

Its price is the starting point

  • Japan prices most new drugs from a comparator’s price plus premiums (innovativeness 70–120%, usefulness 5–60%), or from a cost build-up.
  • Against generics, the comparator-based caps in Germany and Brazil sit far below a brand price, so a small gain is costly.
  • Against a branded drug, parity is easier to defend, but the incumbent defends its share.
Population size

Volume changes how hard payers push

  • Germany treats an orphan drug’s added benefit as proven until sales pass €30M a year.
  • France needs a CEESP efficiency opinion once ASMR I–III is claimed and sales reach €20M a year.
  • Japan’s cost-effectiveness review for high budget impact has trimmed oncology prices by about 0.2–15%; orphans get priority review automatically.
Decision 1Which data cut do we file on?
File on IA1

Earlier licence, weaker HTA position

  • Regulators have early routes: FDA priority review and accelerated approval, EMA conditional MA (Project 01, US and EU cards).
  • Germany: OS, symptoms, quality of life and side effects carry the rating; PFS alone rarely earns added benefit.
  • England: immature data with plausible cost-effectiveness lead to the Cancer Drugs Fund, then re-appraisal.
  • Canada pairs time-limited recommendations with temporary access for NOC/c products.
Wait for IA2

Later licence, stronger benefit ratings

  • More mature OS supports a higher German benefit category and a better French ASMR, which drives price and the liste en sus.
  • Fewer managed-access conditions, but every month of waiting is a month without sales anywhere.
  • The JCA PICOs still need an answer for every comparator; more mature data make indirect comparisons more robust.
Split by market

Early where speed pays, later where survival sets price

File early with the regulator whose market prices freely and pays from approval, and bring mature survival data to the HTA bodies that rate on it. Since January 2025 the EU joint clinical assessment narrows this for EU markets: its report is completed within 30 days of authorisation, and national bodies must give it due consideration, so a later data cut usually reaches them through reassessment rather than a later launch. The engine in Part 2 makes this call market by market.

Decision 2Which indication goes first?
What payers say

The first indication sets the price

In interviews across nine OECD countries, payers named the highest price as the defining feature of first indications, which were mostly smaller populations. No example was found of a price rising after a new indication (Mills and Kanavos, 2023).

What happens at the second

Each system handles it differently

  • France, Spain, Belgium, Canada: the price is renegotiated as a weighted average.
  • England, Switzerland: different discounts per indication.
  • Italy: a mandatory discount scaled to the extra population.
  • Germany: each new indication is a new AMNOG cycle. United States: one free price.
Decision 3Where do we launch, and in what order?
Wave 1 · price setters

Markets others look at, that pay early

The US prices freely and covers from approval. Germany pays the company price from launch, with the negotiated price from month 7. Their prices then sit in other countries’ baskets.

USDEUK
Wave 2 · referencing markets

Launch once their reference prices exist

Japan checks the average of US, UK, German and French prices. France’s price guarantee looks at Germany, Spain, Italy and the UK. Canada caps at the highest of 11. Switzerland compares nine countries.

JPFRCACH
Wave 3 · low visible prices

Later, or behind a confidential deal

Markets whose published prices are low and widely referenced pull others down, so companies often launch them later or protect the list price with confidential discounts. Brazil caps at the lowest of 14 countries.

ITESBR
OutcomeFive-year sales
The trade-off. Five-year sales come from how early each market starts paying, multiplied by how high the price holds once other countries look at it. Launching a low-price market early adds volume there but can lower prices in every market that references it. Waiting protects price but loses time, and in the US a lower price abroad can now also lower the US price (most-favoured-nation pricing).

The access mesh: who looks at whose price

Each arrow points from a market to a market whose price it uses. Select a market to see what it looks at (oxblood) and who looks at it (navy). The rules come from the sourced Project 01 cards and the Reference pricing page.

Looks at (references)Looked at byUS most-favoured-nation links (2025 order and company deals)9Number in a circle: how many other markets use that market’s price; bigger circles are used more

The clocks: how soon each market pays

Speed matters as much as price. A market that pays from launch earns from day one; a market with a long funding clock adds little in the first five years however high its price. All figures come from the Project 01 cards.

Across Europe, EFPIA’s 2025 W.A.I.T. survey found an average of 597 days from EU approval to availability for medicines approved in 2021–24, and 655 days for oncology medicines.

From approvalUnited States

Medicare covers medically accepted indications from approval; the company sets the launch price.

From launchGermany

Sickness funds pay the company’s price from launch; the negotiated price applies from month 7.

About 60 daysJapan

NHI listing usually within 60 days of approval (90 at most); listings four times a year.

At licence + 90 daysUnited Kingdom

Aligned pathway: NICE guidance publishes with the licence; positive guidance funded within 90 days.

60-day benchmarkSwitzerland

Specialty List benchmark 60 days after MA, met for 43% of files in 2024; case-by-case payment before that.

About 7 monthsItaly

Non-generic negotiations averaged about 7 months; until then the drug can be sold unreimbursed (class Cnn).

180-day target, longer in practiceFrance

Real timelines run well past the legal target; early access (AP) bridges the gap for many cancer drugs.

National, then regionalSpain

About 70% of innovative medicines reached patients before the funding decision through special-situation access.

More than 1.5 yearsCanada

Average time from approval to public funding; pre-NOC filing and Ontario’s FAST pilot shorten it.

Up to 180 daysBelgium

The Minister decides on the CRM proposal within 180 days; confidential MEA conventions are routine for oncology.

150-day targetSouth Korea

The parallel pilot targets 150 days from approval to listing; early rounds ran longer. Risk-sharing agreements are usual for oncology.

The lockNetherlands

Drugs costing €20M a year, or €10M with €50,000 per patient, wait in the lock until Zorginstituut advises and a price is agreed.

Three cycles a yearAustralia

PBAC meets in March, July and November; a positive recommendation is not a listing, and price talks can still fail.

Two routesBrazil

CMED price within 90 days of registration; Conitec 180 + 90 days for the public system; ANS 120 + 60 days for cancer in private plans.

What companies have actually done

73 vs 13

Launches follow expected price and volume

In 25 markets in the 1990s, the chance of launch rose with expected price and volume. Low prices spill over through referencing and parallel trade, so firms accepted delay or no launch: 73 new drugs launched in the US, 66 in Germany and 64 in the UK, against 13 in Japan and 26 in Portugal.

Danzon, Wang and Wang, Health Economics 2005 (NBER w9874)
Belgium

Submissions held back to keep a price out of baskets

Companies systematically delayed Belgian dossiers so its price would not feed other countries’ calculations. Across seven EU countries, 11 products were not launched to avoid expected low prices.

LSE, impact of external reference pricing (2017)
10 opt-outs

Germany: leaving rather than accept a low price

Among 139 medicines assessed from 2011 to June 2016, there were 10 opt-outs and 12 supply terminations; 21 of the 22 had been rated “no added benefit”.

Staab et al., Health Economics Review 2018
Niche first

Multi-indication drugs launch the high-value use first

Payers see the first indication as the price-setting one; current systems still reward launching niche indications first. Some later indications were withheld in France, Italy and Belgium when price talks failed.

Mills and Kanavos, PharmacoEconomics Open 2023
−37.8%

US most-favoured-nation pricing reshapes Europe

In the year after the May 2025 US order, launches fell 37.8% in 11 EU states facing both MFN and the JCA, against 10.5% in the US. Insmed held back a European launch approved in November 2025 while awaiting MFN clarity.

EU Perspectives, Aug 2026 (King’s College study); BioSpace, Apr 2026
Japan 2026

Germany now counts only after AMNOG

Japan’s reference basket is the US, UK, Germany and France. Since the FY2026 reform, only Germany’s post-AMNOG negotiated price counts, so a German free launch price no longer lifts Japan’s comparison. Japanese industry asked in June 2026 to ease the foreign price adjustment because of MFN.

Windrose CG on the FY2026 reform; PharmaJapan, Jun 2026

Rules of thumb

  1. Set high, visible prices first in markets that pay early and that others reference: typically the US, Germany and the UK.
  2. Launch referencing markets after their baskets are filled with your best prices. Japan wants US, UK, French and (negotiated) German prices; France’s guarantee wants German and UK prices above Spain and Italy.
  3. Hold back or shield low visible prices. Confidential discounts keep the list price high; a later launch keeps a low price out of baskets while it matters most.
  4. Lead with the indication that earns the highest price. In most systems a later, broader indication lowers the price; it rarely raises it. Over a short horizon a much larger indication can still win on volume.
  5. Weigh IA1 against IA2 market by market. Survival-driven HTA bodies reward waiting; markets that pay from approval reward speed.
  6. Model the US as part of the mesh. With most-favoured-nation pricing, a low price abroad can now lower the US price too.

Sources

Be curious, not judgmental.

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