International comparison of pharmaceutical industry payment disclosures in the UK and Japan: implications for self-regulation, public regulation, and transparency

Piotr Ozieranski, Hiroaki Saito, Emily Rickard, Shai Mulinari, Akihiko Ozaki

Research output: Contribution to journalArticlepeer-review

6 Citations (SciVal)


Background: Self-regulation of payment disclosure by pharmaceutical industry trade groups is a major global approach to increasing transparency of financial relationships between drug companies and healthcare professionals and organisations. Nevertheless, little is known about the relative strengths and weaknesses of self-regulation across countries, especially beyond Europe. To address this gap in research and stimulate international policy learning, we compare the UK and Japan, the likely strongest cases of self-regulation of payment disclosure in Europe and Asia, across three dimensions of transparency: disclosure rules, practices, and data.

Results: The UK and Japanese self-regulation of payment disclosure had shared as well unique strengths and weaknesses. The UK and Japanese pharmaceutical industry trade groups declared transparency as the primary goal of payment disclosure, without, however, explaining the link between the two. The rules of payment disclosure in each country provided more insight into some payments but not others. Both trade groups did not reveal the recipients of certain payments by default, and the UK trade group also made the disclosure of some payments conditional on recipient consent. Drug company disclosure practices were more transparent in the UK, allowing for greater availability and accessibility of payment data and insight into underreporting or misreporting of payments by companies. Nevertheless, the share of payments made to named recipients was three times higher in Japan than in the UK, indicating higher transparency of disclosure data.

Conclusions: The UK and Japan performed differently across the three dimensions of transparency, suggesting that any comprehensive analysis of self-regulation of payment disclosure must triangulate analysis of disclosure rules, practices, and data. We found limited evidence to support key claims regarding the strengths of self-regulation, while often finding it inferior to public regulation of payment disclosure. We suggest how the self-regulation of payment disclosure in each country can be enhanced and, in the long run, replaced by public regulation to strengthen the industry’s accountability to the public.
Original languageEnglish
Article number14
Number of pages42
JournalGlobalization and Health
Issue number1
Early online date3 Mar 2023
Publication statusPublished - 31 Dec 2023

Data Availability Statement

The documentary materials supporting the analysis of disclosure rules in the article are cited throughout the Findings. The analysis of disclosure practices and data was based on the Japanese Money Database as well as the Disclosure UK database and the repository of drug company methodological notes managed by the Association of the British Pharmaceutical Industry:


  • Comparative case study
  • Financial conflicts of interest
  • Payment disclosure
  • Pharmaceutical industry
  • Research and development
  • Self-regulation
  • Transparency

ASJC Scopus subject areas

  • Public Health, Environmental and Occupational Health
  • Health Policy


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