Pricing Implications for Medicines Following Bulgaria’s Euro Adoption
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11 Nov Pricing Implications for Medicines Following Bulgaria’s Euro Adoption

Posted at 13:00h in Pricing & Reimbursement by

Bulgaria is set to adopt the euro on 1 January 2026, marking a major shift in its monetary regime and one that carries important implications for pharmaceutical pricing and market dynamics.

Although the domestic legislative transition appears relatively straightforward — with automatic conversion rules for local pricing — the more significant ripple effects for MAHs lie in secondary and reference-market systems, especially for markets that reference Bulgaria’s pricing.

Cross-border reference pricing implications – the Greek market in focus
One of the most salient concerns for MAHs in this transition is the effect on the Greek market where the maximum ex-factory price for a medicinal product is set by external reference pricing (ERP) tied to other euro-area member states: the average of the 2 lowest different ex-factory prices in Member States of the Eurozone.

This means that as soon as Bulgaria moves into the euro-area, the published ex-factory prices in euros may enter the basket of “euro-zone reference countries” for Greece. That could result in downward pressure on the Greek price, if Bulgarian ex-factory pricing is among the lowest in the euro zone or becomes so.

Therefore:

  • Once Bulgaria is integrated into the euro-area, its price outcome becomes highly relevant for the Greek ERP benchmark.
  • MAHs should consider the possible scenarios.
  • Timing is critical. While we are not aware of a formal Greek announcement explicitly describing how Bulgarian prices will be treated, past transitions (for example when Croatia joined the euro in 2023) provide a precedent. Considering the annual Greek repricing cycles, one might reasonably expect Bulgaria’s pricing to enter the Greek basket no later than October 2026, depending on the actual timing of Bulgarian price publication and the Greek reference-pricing cycle.

 

Implications for Bulgaria’s own reference system
Bulgaria already uses an external price-referent mechanism for Rx medicines: ex-factory manufacturer prices must not exceed the lowest publicly registered price among a specified basket of ten EU Member States: Belgium, Greece, Spain, Italy, Latvia, Lithuania, Romania, Slovakia, Slovenia and France. ERPs that rely on the lowest one price—such as the Bulgarian system—can lead manufacturers to adopt strategies like delaying product launches or withdrawing older, more affordable medicines from lower-priced countries to avoid a “spillover” effect on prices in higher-priced markets. These negative effects become more pronounced when lower-priced markets are used as references by larger ones—such as the Greek pharmaceutical market referencing the Bulgarian.

Strategic risks and recommendations for MAHs
The overall price erosion effect is hard to predict, especially considering the Greek system, which takes the average of the lowest prices and would probably mitigate the impact. However, MAHs should not wait for too long to assess that risk: to conduct an impact assessment product-by-product for the Bulgarian and Greek portfolios and, if necessary, to review their pricing strategy.