MFN and Nordic pharma

Local pricing decisions with global consequences

Most Favored Nation (MFN) policies are reshaping how pharmaceutical companies think about pricing, access, evidence, and launch strategy. The concept is simple: the United States should not pay more for a medicinal product than comparable countries. The implication is not that simple.

Even without formal implementation, MFN risk is already influencing global decision-making. Pricing corridors are being protected, launch plans are reassessed, and evidence strategies are scrutinized. This is not because rules have changed, but because the perceived downside of getting it wrong has increased.

What is MFN and why it matters now

MFN is built on international reference pricing. If a medicine is available at a lower price in one country, that price can influence reimbursement decisions in other countries. While many countries already reference each other, the U.S. has historically stood outside this system.

Why the urgency now? US policymakers have signaled renewed interest in MFN mechanisms, and even without formal implementation, pharmaceutical companies are already adjusting their strategies. The perceived risk of downstream price impact is enough to reshape how you evaluate RWE investments, reimbursement approaches, and launch timing.

Why the Nordics are under scrutiny


Commercial leaders face a difficult position: they’re asked to prepare launches without knowing if or when they will happen. MFN uncertainty makes it difficult to justify a full commercial build-up, so many opt for lighter, reversible models.

The Nordics attract attention for their transparent pricing systems, predictable access pathways, and inclusion in international reference baskets. Denmark holds a unique position. It sits alongside the G7 nations and Switzerland in the reference basket most commonly discussed in US policy proposals. That makes Denmark “tier 1” in global pricing conversations, a status that carries weight well beyond the country’s small patient population.

In practice, pricing decisions in the Nordics are often viewed through the same lens. A pricing or access decision in one country can raise questions across the region, whether or not formal reference links exist. As a result, Nordic affiliates face heightened scrutiny and a higher bar for justification, alignment, and timing.

Local pricing decisions with global consequences


Market access leaders recognize that a single local price can cascade globally. Many have become increasingly cautious, sometimes delaying HTA submissions until they can thoroughly validate their MFN assumptions.

Global pricing committees are paying closer attention to Nordic submissions, and what was once a straightforward market access process may now involve additional layers of review. One of the challenges is alignment. When Pricing, Access, Commercial, and Medical teams operate with different assumptions about MFN risk, it’s likely to result in internal friction:

  • Pricing may flag a submission as high-risk while Access sees it as routine
  • Commercial teams push for faster launch while global holds back
  • Medical invests in evidence generation without visibility into how pricing concerns might delay its use

These disconnects create unnecessary loops of escalation, rework, and second-guessing that drain resources and frustrate teams on all sides.

What might appear to be indecision on the surface is actually risk avoidance. When the downstream consequences are unclear, waiting becomes the safest option. The result is delayed submissions, postponed launches, and missed windows, not because teams can’t agree, but because no one wants to be the function that triggered a global pricing problem.

What capabilities do pharma companies need to manage MFN risk?

MFN’s impact on evidence and launch strategies


Medical affairs leaders find that MFN is starting to influence which studies they’re willing to run locally. If a study doesn’t clearly support access or differentiation, it becomes hard to justify the investment given the downstream pricing risk.

MFN concerns are changing how pharmaceutical companies view Real-World Evidence in the Nordics. Broad, country‑specific studies are giving way to more targeted evidence with a clear strategic purpose: supporting value narratives, stakeholder perception, and access in defined settings.

One visible shift is the move from country-level to regional evidence projects. Rather than running separate studies in Denmark, Norway, and Sweden, we see companies increasingly design Nordic-wide protocols. At the same time, launch strategies are becoming lighter and more reversible, forcing earlier and tougher prioritization: deciding which products justify full commitment and which do not.

The hidden cost is momentum. Markets move quickly, and delayed or diluted launches are hard to recover from.

Balancing local access ambition and global constraints


Country managers want to bring innovation to patients, but they’re increasingly concerned about becoming a low-price reference country. That puts them in a difficult position between local access ambition and global constraints.

Affiliates need ammunition: why Denmark, why now, and why the risk is manageable. Without a clear, fact-based narrative, the path of least resistance for global teams is to delay or deprioritize. Denmark can be perceived as high MFN risk, but how much of that perception is proven and how much is assumed? The distinction matters when you’re trying to make the case for local investment.

At the same time, leaner affiliate organizations may not have the internal capacity to build these arguments alone. Strategic capability that used to sit in-house now often requires external support to maintain.

Data-driven clarity to support your decisions

MFN policy is still evolving. No one can offer certainty, and we won’t pretend otherwise. What matters is having decision support that holds up under uncertainty.

We help you make the right decision by separating real MFN risk from assumed risk and aligning commercial, medical, and market access functions around shared scenarios. That includes modeling the trade-offs between price, volume, and access to support clearer go, pause, or redesign decisions. We also help you shape evidence and launch strategies that hold up to scrutiny both locally and at HQ, backed by Nordic-specific data that strengthens your case.

As part of Lif, the Danish Association of the Pharmaceutical Industry, we’re uniquely positioned to follow how policy discussions evolve and what they mean for your Nordic strategy.

Get in touch to discuss what MFN means for your portfolio, your launches and your organization.

For more information, please contact

Rasmus Tolstrup Larsen, employee at Signum, Director, Commercial Excellence & Business Execution

Rasmus Tolstrup Larsen

Nordic Director of Consulting


rtl@signumlifescience.com

+45 42 42 30 07