Why JCA matters now
EMA approval is the entry ticket, not the access
Under Regulation (EU) 2021/2282, clinical value is now assessed once at EU level through the Joint Clinical Assessment (JCA) — but pricing and reimbursement decisions are still made country by country. JCA became mandatory for oncology new active substances and ATMPs from January 2025, with selected high-risk medical devices following, orphan medicines in scope from 2028, and all new medicines from 2030.
The useful window to prepare is early — 18 to 24 months before EMA submission, while the evidence plan can still shape the comparators. Companies targeting 2028–29 submissions are scoping their evidence now.
A positive JCA outcome doesn’t deliver a price on its own — but it removes the excuse for a weak clinical case, and fixes, at EU level and very early, the comparators every national procedure will have to live with.
Why it's hard to manage in-house
The problem we solve
- Limited influence on scope — sponsors propose no PICO (Population, Intervention, Comparator, Outcome); strict conflict-of-interest rules limit expert input
- One early-advice opportunity — with no second attempt and limited capacity
- A dossier built on a ~100-day clock — once the PICO scope is confirmed
- Evidence readiness before scope confirmation — analyses largely have to be prepared before the final PICOs are known
- Cross-functional orchestration — EU and national workstreams run in parallel, across teams, languages and methodologies
Our offering
Five modules, taken together or one at a time
Training & readiness
Workshops for access leads, EU HTA toolkit, governance readiness assessment.
PICO scoping & access strategy
Anticipate PICOs country by country, map the treatment landscape and payer logic, build the evidence-based value story.
Gap analysis & evidence plan
Identify evidence gaps against each PICO, indirect comparisons needed, generation plan.
Pricing & JCA strategy
Comparator price benchmarking, price corridor per country, validated with payer-side experts.
JCA dossier
Full dossier against final PICOs — systematic literature review, statistics, submission support.
Most clients enter at module 2. Modules can be commissioned individually or as a coordinated end-to-end programme, with one point of contact from kick-off to the end of the EU procedure.
Beyond the JCA
We don’t stop at the JCA — and that’s the point
A JCA is clinical only. The commercial outcome is decided in the national procedures that follow, and the two have to be built together — national dossiers start on the back of the EU report, not after it.
PLG integrates, under one governance:
- Regulatory strategy & MAA — EMA strategy, interactions and dossier support
- EU HTA / JCA — PICO strategy, gap analysis, statistics, dossier
- National pricing & reimbursement — in-house in France, Italy and Spain; Germany and the UK through long-standing named partners
For a sponsor without a European affiliate, this is the difference between coordinating four separate workstreams and buying one launch.
In practice
A live European market entry
Anonymised case: a top-tier China-headquartered pharmaceutical company, first launch in Europe
Situation
Two oncology assets, first launch in Europe (EU4 + UK); no European affiliate to integrate the work; evidence generated largely outside Europe.
Action
One programme, one governance, three workstreams — marketing authorisation, JCA and national pricing & reimbursement run in parallel, not in sequence.
Outcome
14 regulated deliverables coordinated across 6 markets, under a single accountable partner.
Why now
China biopharma out-licensing reached $137.7bn in 2025, across 186 cross-border deals — up from $13.9bn in 2021. Every one of those assets that reaches Europe goes through the JCA. Most sponsors have never run one.
Source: PharmCube via PharmaSource (Feb 2026); Regulation (EU) 2021/2282