The European launch is dead - How Pharma/Biotech must rethink EU commercialisation in 2026
- Andrew Cummins

- Jan 11
- 4 min read
For more than two decades, European pharmaceutical launch strategy has been built on a reassuring simplification: Europe is complex, but it is ultimately manageable as a single market. Execute a coordinated EU5 launch, align pricing corridors, navigate HTA sequentially, and scale from there. That assumption is now obsolete.
By 2026, Europe will no longer fail companies because it is slow or bureaucratic. It will fail them because it is structurally fragmented in ways that invalidate the traditional “EU launch” concept altogether. Companies that continue to treat Europe as a single commercial event will systematically underperform, destroy optionality, and misallocate capital.
The end of the “Single EU Launch” assumption
The idea of a unified European launch has always been more aspiration than reality. However, historical convergence across clinical standards, HTA logic, and price referencing created the illusion that simultaneity was both achievable and desirable. But what has happened to dismantle that illusion:
Institutional divergence, not convergence
The introduction of the EU HTA regulation was intended to harmonise clinical assessment. In practice, it has decoupled clinical review from commercial decision-making, pushing pricing, access, and evidence interpretation even more firmly back to the national level.
Fiscal pressure has become political
National drug budgets are no longer technical constructs; they are politically visible pressure points. Governments are responding with bespoke access controls, informal thresholds, and silent delays that vary dramatically by country.
Early access has matured and hardened
What were once compassionate or exceptional mechanisms are now structured, gated, and scrutinised. Early access is no longer a workaround; it is an alternative commercial pathway with its own logic and risks.
The result is not temporary volatility. It is a permanent structural shift.
What has actually fragmented in Europe?
1. HTA timelines and decision logic
Even with shared clinical assessments, national HTA bodies are diverging in:
Evidence acceptance thresholds
Comparator expectations
Tolerance for uncertainty
Use of conditionality and reassessment
A positive clinical opinion no longer translates into predictable downstream access.
2. Early access eligibility - Early access is no longer uniformly permissive:
Some markets are narrowing eligibility to ultra-rare or life-threatening indications only.
Others are expanding early access but tightening price scrutiny and volume controls.
Several now require real-world data commitments that resemble post-launch obligations.
This creates opportunity, but only if planned deliberately.
3. Net price formation - List price convergence has given way to net price opacity:
Confidential rebates dominate.
Managed entry agreements vary widely in structure.
External reference pricing now penalises poor sequencing more than ever.
A single “EU price” concept is commercially dangerous.
4. Evidence expectations post-approval - Evidence generation is no longer linear:
Randomised trial data opens the door.
Real-world evidence determines durability.
Failure to plan RWE early increasingly results in stalled or reversed access.
Europe now rewards evidence strategists, not just trial designers.
Why the traditional EU5-first model now destroys value
The EU5-first approach, launching simultaneously in Germany, France, Italy, Spain, and the UK, was historically justified by scale, reference pricing influence, and signalling value.
In 2026, it creates systemic risks:
Premature price anchoring - Early exposure in reference markets locks in prices before value is fully demonstrated.
Evidence mismatch - Launching broadly without market-specific evidence increasingly triggers negative reassessments.
Cash burn without revenue certainty - Commercial infrastructure is deployed long before sustainable access is achieved.
For capital-constrained biotech, this is existential. For larger pharma, it is margin erosion by design.
The new winning model: Europe as a monetisation portfolio
Winning in Europe now requires abandoning the idea of a single launch moment. The successful companies treat Europe as a portfolio of monetisation opportunities, each with distinct timing, risk, and return profiles.
Sequenced, not simultaneous, launches
Leading strategies now:
Select initial markets based on speed to revenue, not size.
Delay exposure in price-sensitive reference markets.
Use smaller or early-access-friendly countries to build evidence and confidence.
Sequencing is no longer a concession, it is a competitive advantage.
Early access as a primary revenue bridge
Early access is moving from contingency to strategy:
Used deliberately to fund evidence generation.
Structured to demonstrate real-world value.
Integrated into long-term access planning, not separated from it.
However, this requires governance, pricing discipline, and operational maturity.
Evidence-Led expansion
Instead of “launch then defend,” companies now:
Launch narrowly.
Generate targeted RWE.
Expand access iteratively, supported by local data.
This flips the traditional risk profile on its head.
What boards and investors must ask in 2026
European underperformance is increasingly a governance failure, not a market one. Boards should now be asking:
Where do we generate European revenue before full reimbursement?
Which market defines our reference price risk?
What evidence will HTA bodies demand after approval?
How do we fund Europe without betting the company on it?
Who owns European strategy execution, not just planning?
If these questions are not being asked explicitly, value is already leaking. The winners in 2026 will not be those with the biggest sales forces or the fastest filings. They will be those who:
Treat Europe as a series of deliberate commercial decisions.
Integrate early access, pricing, and evidence from day one.
Accept that optimal launch timing differs by country—and act accordingly.
Europe has not become smaller. It has become sharper. Companies that adapt will build durable, capital-efficient European franchises. Those that do not will continue to describe Europe as “challenging,” without ever quite understanding why.
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