Interactions with Healthcare Professionals, Transfer of Values and Conditions of Payment

Interactions between life sciences companies and healthcare professionals (“HCPs”) in Türkiye continue to be governed by a well-established regulatory framework. In the pharmaceutical sector, promotional activities remain subject to the Regulation on the Promotion of Medicinal Products for Human Use, which strictly limits promotion to healthcare professionals and prohibits direct or indirect advertising to the public. Engagements such as consultancy and service arrangements with HCPs are permitted, provided they are supported by written agreements, comply with ethical principles and the full-time work framework, and are transparently reported where value transfers exceed applicable thresholds.

Although draft amendments to the pharmaceutical promotion regime were circulated for consultation in 2024, no new regulation entered into force in 2025. As a result, the regulatory environment has remained formally unchanged. Nevertheless, this period of legislative stability should not be interpreted as reduced regulatory attention. On the contrary, supervisory practice increasingly emphasises strict adherence to existing rules, particularly in relation to the justification, documentation, and proportionality of HCP engagements.

In the medical devices sector, promotional activities continue to be regulated under the Regulation on Sale, Advertising, and Promotion of Medical Devices. While this framework traditionally offers more flexibility, particularly in comparison to pharmaceutical promotion, enforcement practice increasingly reflects converging expectations.

Across both sectors, the evolution of engagement models has introduced new compliance challenges. Digital meetings, hybrid scientific events, remote advisory boards, and distributor-mediated interactions are increasingly central to HCP engagement strategies. These formats, while operationally efficient, raise questions regarding attribution, transparency, and the delineation between scientific exchange and promotion.