§ 02 · Comparison

Compare regulatory pathways side-by-side

Benchmark MAHMAH, GMPGMP, HTAHTA and pathway requirements across up to three markets.

Country A

Country B

Country C

Highlight differences

Criterion	🇨🇭Switzerland 3 of 4 pathway fees confirmed	🇺🇸United States Fees verified 12 September 2026	🇪🇺European Union Fees verified 12 September 2026
Authority & dossier
Fee confirmation	3 of 4 pathway fees confirmed	Fees verified 12 September 2026	Fees verified 12 September 2026
Regulatory authority	Swissmedic	FDA	EMA
English submissions	Yes	Yes	Yes
CTD accepted	Yes	Yes	Yes
eCTD accepted	Yes	Yes	Yes
Reliance pathway	Available	None	Available
Reference agencies	FDA, EMA, MHRA, Health Canada +2	Not stated	Not stated
Lead pathway (timeline & fees), Standard Authorisation Procedure · New Drug Application, 505(b)(1) · Centralised Procedure
Pathway name	Standard Authorisation Procedure	New Drug Application, 505(b)(1)	Centralised Procedure
Approval timeline	330-365 days	304-365 days	210-277 days
Headline fee and pathway	CHF 80,000, Standard Authorisation Procedure	USD 4,682,003, New Drug Application, 505(b)(1)conditional on other	EUR 865,200, Centralised Procedureconditional on other
Recurring charges	Aufsichtsabgabe supervisory levy, 6.5 per mille of the factory gate price of products sold	USD 442,213 a year, per product	EUR 232,400 a year, per marketing authorisation, other applications
Local representative	Required	Not required	Required
Local manufacturing	Not required	Not required	Not required
GMP inspection	Required	Required	Required
MAH & local presence
Local entity required	Yes	No	Yes
Local responsible person	Yes	Yes	Yes
RP role	Fachtechnisch verantwortliche Person (FvP / responsable technique): Swiss-based qualified person responsible for compliance with the HMG, batch release, and pharmacovigilance contact.	US Agent: a person residing or maintaining a place of business in the US, designated to act on behalf of the foreign establishment for FDA communications, including notification of inspections.	Qualified Person Responsible for Pharmacovigilance (QPPV), must reside and operate in the EU/EEA, is responsible for the establishment and maintenance of the pharmacovigilance system. A Qualified Person (QP) in the EU/EEA performs batch certification under Article 51 of Directive 2001/83/EC. Local Contact Person for pharmacovigilance required in each Member State where the product is marketed (since 2012 GVP).
Accelerated pathways
Designations available	4 designations	6 designations	6 designations
Examples	Fast-Track Authorisation Procedure, Orphan Drug Designation, Temporary Authorisation (Art. 9a HMG) +1	Priority Review, Breakthrough Therapy Designation, Accelerated Approval, Subpart H/E +3	Accelerated Assessment, Conditional Marketing Authorisation, Authorisation under Exceptional Circumstances +3
Post-approval lifecycle
Variations framework	Variations classified as Type IA, IA(IN), IB, II following the EU classification, adapted for Swiss specifics. Renewals and grouped variations supported.	FDA classifies post-approval changes as: Annual Reportable, Changes Being Effected (CBE-0 immediate, CBE-30 with 30-day pre-implementation notice), and Prior Approval Supplements (PAS), the most significant changes requiring FDA approval before implementation. Major manufacturing or labelling changes typically require a PAS.	Commission Regulation (EC) 1234/2008 establishes four categories: Type IA (minor, Do and Tell, 12-month notification), Type IAIN (minor, immediate notification), Type IB (minor, Tell, Wait, and Do, 30-day default), Type II (major, prior approval, 60 to 90 days), and Extensions (Annex I changes, full review). Worksharing procedures consolidate variations across multiple authorisations.
Renewal cycle	First renewal at 5 years; subsequent renewals every 5 years (some products eligible for unlimited validity after first renewal under Art. 16 HMG, since the 2019 OAMéd revision).	FDA does not require periodic renewal of NDAs or BLAs, approvals remain in effect indefinitely subject to compliance, payment of annual program fees, and post-marketing requirements. Annual reports are required.	Initial 5-year renewal, application 9 months before expiry. After the first renewal, MA is granted for unlimited duration unless the CHMP/NCA, on justified grounds relating to pharmacovigilance, decides on one additional 5-year renewal.
Pharmacovigilance	PSUR (PBRER) submission aligned with EU schedules; MAH must designate a Swiss QPPV-equivalent. Adverse drug reaction reporting via the ElViS electronic system.	Mandatory expedited reporting of serious unexpected ADRs within 15 calendar days; periodic safety reports (PADERs/PAERs) for the first 3 years post-approval, then annually. PSURs in ICH E2C(R2) format accepted in lieu of PADERs by agreement. FAERS database receives spontaneous reports. Post-Marketing Requirements (PMRs) and Commitments (PMCs) tracked publicly.	Comprehensive PV framework under Directive 2010/84/EU and Regulation (EU) 1235/2010, codified in Good Pharmacovigilance Practices (GVP). Pharmacovigilance System Master File (PSMF) required. Periodic Safety Update Reports (PSURs) on EU-harmonised birth-date list. Risk Management Plans for all new MAs and significant variations. Suspected serious ADR reporting to EudraVigilance within 15 days. Black triangle (▼) for additional monitoring of selected products.
Unlicensed access
Named Patient Supply	Available	Available	Available
Compassionate Use	Available	Available	Available
Emergency Import	Available	Available	Available
Parallel Import	Permitted	Not permitted	Permitted
Clinical trials
CTA approval	Required	Required	Required
Ethics approval	Yes	Yes	Yes
CTA timeline	30-60 days	30-30 days	60-106 days
GCP standard	ICH-GCP E6(R3)	ICH E6(R3) (adopted via FDA guidance January 2025); 21 CFR 312, 314, 50, 56	ICH E6(R3), Commission Regulation (EU) 2024/2748 transposing R3, applicable from 23 July 2025
Pricing & reimbursement
Price regulation	Regulated	Free pricing	Regulated
Reference pricing	Yes	No	Yes
HTA required	Yes	No	Yes
HTA body	Federal Office of Public Health (FOPH/BAG), Speciality List unit	ICER (Institute for Clinical and Economic Review), independent, non-binding	EU HTA Coordination Group (EUnetHTA legacy); national HTA bodies (NICE, HAS, G-BA/IQWiG, AIFA, AEMPS, etc.)

Verdict colours indicate lower, moderate, or higher regulatory burden, they're not value judgements on a market.

Authority & dossier

Fee confirmation

Switzerland3 of 4 pathway fees confirmed
United StatesFees verified 12 September 2026
European UnionFees verified 12 September 2026

Regulatory authority

SwitzerlandSwissmedic
United StatesFDA
European UnionEMA

English submissions

SwitzerlandYes
United StatesYes
European UnionYes

CTD accepted

SwitzerlandYes
United StatesYes
European UnionYes

eCTD accepted

SwitzerlandYes
United StatesYes
European UnionYes

Reliance pathway

SwitzerlandAvailable
United StatesNone
European UnionAvailable

Reference agencies

SwitzerlandFDA, EMA, MHRA, Health Canada +2
United StatesNot stated
European UnionNot stated

Lead pathway (timeline & fees), Standard Authorisation Procedure · New Drug Application, 505(b)(1) · Centralised Procedure

Pathway name

SwitzerlandStandard Authorisation Procedure
United StatesNew Drug Application, 505(b)(1)
European UnionCentralised Procedure

Approval timeline

Switzerland330-365 days
United States304-365 days
European Union210-277 days

Headline fee and pathway

SwitzerlandCHF 80,000, Standard Authorisation Procedure
United StatesUSD 4,682,003, New Drug Application, 505(b)(1)conditional on other
European UnionEUR 865,200, Centralised Procedureconditional on other

Recurring charges

SwitzerlandAufsichtsabgabe supervisory levy, 6.5 per mille of the factory gate price of products sold
United StatesUSD 442,213 a year, per product
European UnionEUR 232,400 a year, per marketing authorisation, other applications

Local representative

SwitzerlandRequired
United StatesNot required
European UnionRequired

Local manufacturing

SwitzerlandNot required
United StatesNot required
European UnionNot required

GMP inspection

SwitzerlandRequired
United StatesRequired
European UnionRequired

MAH & local presence

Local entity required

SwitzerlandYes
United StatesNo
European UnionYes

Local responsible person

SwitzerlandYes
United StatesYes
European UnionYes

RP role

SwitzerlandFachtechnisch verantwortliche Person (FvP / responsable technique): Swiss-based qualified person responsible for compliance with the HMG, batch release, and pharmacovigilance contact.
United StatesUS Agent: a person residing or maintaining a place of business in the US, designated to act on behalf of the foreign establishment for FDA communications, including notification of inspections.
European UnionQualified Person Responsible for Pharmacovigilance (QPPV), must reside and operate in the EU/EEA, is responsible for the establishment and maintenance of the pharmacovigilance system. A Qualified Person (QP) in the EU/EEA performs batch certification under Article 51 of Directive 2001/83/EC. Local Contact Person for pharmacovigilance required in each Member State where the product is marketed (since 2012 GVP).

Accelerated pathways

Designations available

Switzerland4 designations
United States6 designations
European Union6 designations

Examples

SwitzerlandFast-Track Authorisation Procedure, Orphan Drug Designation, Temporary Authorisation (Art. 9a HMG) +1
United StatesPriority Review, Breakthrough Therapy Designation, Accelerated Approval, Subpart H/E +3
European UnionAccelerated Assessment, Conditional Marketing Authorisation, Authorisation under Exceptional Circumstances +3

Post-approval lifecycle

Variations framework

SwitzerlandVariations classified as Type IA, IA(IN), IB, II following the EU classification, adapted for Swiss specifics. Renewals and grouped variations supported.
United StatesFDA classifies post-approval changes as: Annual Reportable, Changes Being Effected (CBE-0 immediate, CBE-30 with 30-day pre-implementation notice), and Prior Approval Supplements (PAS), the most significant changes requiring FDA approval before implementation. Major manufacturing or labelling changes typically require a PAS.
European UnionCommission Regulation (EC) 1234/2008 establishes four categories: Type IA (minor, Do and Tell, 12-month notification), Type IAIN (minor, immediate notification), Type IB (minor, Tell, Wait, and Do, 30-day default), Type II (major, prior approval, 60 to 90 days), and Extensions (Annex I changes, full review). Worksharing procedures consolidate variations across multiple authorisations.

Renewal cycle

SwitzerlandFirst renewal at 5 years; subsequent renewals every 5 years (some products eligible for unlimited validity after first renewal under Art. 16 HMG, since the 2019 OAMéd revision).
United StatesFDA does not require periodic renewal of NDAs or BLAs, approvals remain in effect indefinitely subject to compliance, payment of annual program fees, and post-marketing requirements. Annual reports are required.
European UnionInitial 5-year renewal, application 9 months before expiry. After the first renewal, MA is granted for unlimited duration unless the CHMP/NCA, on justified grounds relating to pharmacovigilance, decides on one additional 5-year renewal.

Pharmacovigilance

SwitzerlandPSUR (PBRER) submission aligned with EU schedules; MAH must designate a Swiss QPPV-equivalent. Adverse drug reaction reporting via the ElViS electronic system.
United StatesMandatory expedited reporting of serious unexpected ADRs within 15 calendar days; periodic safety reports (PADERs/PAERs) for the first 3 years post-approval, then annually. PSURs in ICH E2C(R2) format accepted in lieu of PADERs by agreement. FAERS database receives spontaneous reports. Post-Marketing Requirements (PMRs) and Commitments (PMCs) tracked publicly.
European UnionComprehensive PV framework under Directive 2010/84/EU and Regulation (EU) 1235/2010, codified in Good Pharmacovigilance Practices (GVP). Pharmacovigilance System Master File (PSMF) required. Periodic Safety Update Reports (PSURs) on EU-harmonised birth-date list. Risk Management Plans for all new MAs and significant variations. Suspected serious ADR reporting to EudraVigilance within 15 days. Black triangle (▼) for additional monitoring of selected products.

Unlicensed access

Named Patient Supply

SwitzerlandAvailable
United StatesAvailable
European UnionAvailable

Compassionate Use

SwitzerlandAvailable
United StatesAvailable
European UnionAvailable

Emergency Import

SwitzerlandAvailable
United StatesAvailable
European UnionAvailable

Parallel Import

SwitzerlandPermitted
United StatesNot permitted
European UnionPermitted

Clinical trials

CTA approval

SwitzerlandRequired
United StatesRequired
European UnionRequired

Ethics approval

SwitzerlandYes
United StatesYes
European UnionYes

CTA timeline

Switzerland30-60 days
United States30-30 days
European Union60-106 days

GCP standard

SwitzerlandICH-GCP E6(R3)
United StatesICH E6(R3) (adopted via FDA guidance January 2025); 21 CFR 312, 314, 50, 56
European UnionICH E6(R3), Commission Regulation (EU) 2024/2748 transposing R3, applicable from 23 July 2025

Pricing & reimbursement

Price regulation

SwitzerlandRegulated
United StatesFree pricing
European UnionRegulated

Reference pricing

SwitzerlandYes
United StatesNo
European UnionYes

HTA required

SwitzerlandYes
United StatesNo
European UnionYes

HTA body

SwitzerlandFederal Office of Public Health (FOPH/BAG), Speciality List unit
United StatesICER (Institute for Clinical and Economic Review), independent, non-binding
European UnionEU HTA Coordination Group (EUnetHTA legacy); national HTA bodies (NICE, HAS, G-BA/IQWiG, AIFA, AEMPS, etc.)