Early Access in Europe: Generating Revenue Before Marketing Authorisation

One of the most under-used levers in European market entry is early access: several major markets allow a therapy to reach patients — and in some cases generate chargeable revenue — before full marketing authorisation. For rare and ultra-rare diseases with high unmet need, this can mean first European revenue years earlier than a conventional launch timeline implies.

The four core schemes

CountryMechanismNote
FranceAccès Précoce (AP1 / AP2)Chargeable; among the most structured early-access systems in Europe
ItalyLaw 648/96Reimbursed use of medicines outside their authorised indication where no alternative exists
Germany§2 SGB VAccess route within the statutory health insurance framework
SwitzerlandArt. 71a-d KVVCase-by-case reimbursement of non-listed medicines

Why early access is strategic, not just tactical

Beyond the revenue itself, early-access programmes generate real-world evidence that strengthens the later HTA and pricing dossiers. A patient treated under France’s Accès Précoce today is also a data point that supports the AMNOG or HAS submission tomorrow. Sequenced correctly, early access and formal launch reinforce each other.

The risks of getting it wrong

Early-access pricing can anchor later negotiations and, through international reference pricing, leak across borders. This is why early access must be designed alongside the pricing corridor and IRP firewall — not bolted on opportunistically. FDA spillover effects into markets such as the UAE, KSA, Greece and Spain also need deliberate handling.

Planning your European entry? Mirava Bio orchestrates and executes the full pathway as your outsourced European team — one contract, you retain control. Let’s talk about your case →

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