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

Module 1

Training & readiness

Workshops for access leads, EU HTA toolkit, governance readiness assessment.

Module 2

PICO scoping & access strategy

Anticipate PICOs country by country, map the treatment landscape and payer logic, build the evidence-based value story.

Module 3

Gap analysis & evidence plan

Identify evidence gaps against each PICO, indirect comparisons needed, generation plan.

Module 4

Pricing & JCA strategy

Comparator price benchmarking, price corridor per country, validated with payer-side experts.

Module 5

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