Germany 2027: a 15.5% manufacturer rebate that applies to imports, and pharmacy-level biosimilar substitution

What changed

The rebate. Manufacturers of medicines dispensed to Germany’s statutory health funds pay a statutory rebate on each pack, currently 7%. The contribution-stabilisation law, passed by the Bundestag on 10 July 2026 and in force since 30 July, adds a further 8.5 points from 1 January 2027, so 15.5% in all, as a permanent measure. Three groups are exempt: biosimilars and their reference products; products whose price is set by a negotiated reimbursement amount under the AMNOG benefit-assessment system; and products backed by substantial clinical trials conducted in Germany. The price freeze (Preismoratorium), which holds manufacturers’ prices at their 2009 level with inflation adjustment, is extended to the end of 2030. The vaccine rebate rises to 9% with a price freeze for 2027–30, the price-volume factor rises, and a pilot allows rebate contracts on patented drugs in five substance groups until 2030. An expert panel has since proposed a “location clause” that would reduce the rebate for products made or researched in Germany; amendments were under discussion in October 2026.

Biosimilar substitution. The Federal Joint Committee decided on 4 December 2025, with effect from 1 April 2026, that pharmacies must substitute a prescribed biologic with a biosimilar sharing the same reference product, indication, route, strength, pack size, pharmaceutical form and device, unless the prescriber has excluded substitution or the pharmacy sees patient-specific grounds against it. Exchange groups are listed in a new annex to the medicines directive. The rule makes exclusive biosimilar rebate contracts between health funds and manufacturers workable, which the biosimilar industry association has criticised as a route to single-supplier dependence. Rules for parenteral preparations are to follow.

The pharmacy import clause. Unchanged. German pharmacies must fill a share of prescriptions with imports where the import is cheaper by the graded thresholds in the framework contract (at least 15% up to €100, at least €15 between €100 and €300, at least 5% above €300), with a savings target of 2% of import-relevant turnover. The 2026 pharmacy reform left it alone; the Commission has been asked to review it.

What it means if you are…

A parallel importer. The rebate is charged on the pack dispensed, whichever company placed it on the German market, so an imported pack carries the 15.5% rebate from 2027 just as the original does. On a business built on a 15% price gap, an 8.5-point rebate increase is a direct margin cut, partly offset by the price freeze, which keeps the originator’s German price from rising and so keeps the arbitrage stable. Imported biologics are exempt from the extra rebate with the rest of the biosimilar group, but the substitution rule means an imported biologic pack must match device, pack size and form to be dispensed against a prescription that a pharmacy would otherwise fill with a biosimilar.

A generics or biosimilar planner. Biosimilars gain twice: exempt from the extra rebate, and now the default dispensing choice at the pharmacy counter for matched presentations. Matching the reference product’s device and pack sizes becomes a commercial requirement, not an option. Generics are not exempt from the rebate but are largely outside AMNOG, and the price freeze applies to them.

A buyer. Germany’s funds have been handed a 15.5% rebate and a biosimilar default at the same time, so expect a sharp fall in net spend on biologics from 2026 and on everything else from 2027, and expect tender-style exclusive contracts for biosimilars.

What to watch

The location clause, which would turn the rebate into an industrial-policy instrument; the final text on AMNOG guard rails; the parenteral-preparation rules for biosimilars; and the Commission’s view of the pharmacy import quota.