Mandatory methodological note structure – NEW PMCPA guidance

Important information about changes to requirements for the methodological note document applicable to 2025 HCP/HCO disclosure submission to Disclosure UK before end of March 2026.

What has changed?

In 2025, the EFPIA Code (annex B, binding) was updated to include a new mandatory structure for methodological notes applicable to 2025 disclosures published in 2026 in all EFPIA member countries. This change aims to increase the minimum level of information provided, improve alignment between companies and countries, and provide greater transparency around data complexities.

The new requirement currently only applies to HCP/HCO disclosures, and not patient organisation (PO), or members of the public (MoP) disclosures. Although, companies are welcome to develop their PO/MoP methodological notes in-line, if they wish. 

Where can I find support?

To support this change, the PMCPA have updated their existing methodological note guidance for companies disclosing in the UK, and published a new, optional, methodological note template which companies can choose to use, or not.

Optional vs mandatory?  

The PMCPA template is optional, but the structure is mandatory, i.e. companies can use their own document if they wish but they must use the same headings and subheadings as the PMCPA template which is based on the new EFPIA requirement.

What do I need to do?

Companies are required to use the new structure, verbatim, in all future methodological note documents, starting with 2025 transfers of value disclosed in 2026, and beyond. For the complete details, companies are strongly encouraged to read the updated PMCPA guidance in full.

•    Guidance: PMCPA method note guidance for HCP/HCO disclosure
•         Optional template   : PMCPA publications > click filter for Optional Templates

Please contact info@pmcpa.org.uk if you have any feedback on the new resources, or disclosure@abpi.org.uk for queries about your operational disclosure commitments.