Most Favoured Nation (MFN) pricing policies are increasingly shaping global pharmaceutical launch, pricing, and access strategies. As MFN concepts link US prices to net prices achieved in other markets, particularly Europe, pharmaceutical companies need to assess the available strategies to mitigate the effects on their US revenues.
Below, we outline our thoughts on the key MFN mitigation strategies and what they may mean for pharma and biotech companies navigating this evolving environment.
What are MFN mitigation strategies?
1. Expanding outcomes-based and managed entry agreements
Outcomes-based contracts, managed entry agreements, and volume- or performance-linked rebates are increasingly seen as tools to maintain a higher net price, at least for a certain time, and thus reduce potential price erosion under MFN pressure.
While not a universal solution, these models may offer some flexibility where traditional price cuts would create broader international repercussions.
2. Adjusting launch sequencing and launch footprint
Launch order has become a critical strategic lever in an MFN environment. Manufacturers should consider delaying or re-sequencing launches in lower-priced or heavily referenced markets to avoid anchoring MFN benchmarks. Likewise, early launches in markets that are not referenced for MFN purposes may need to be prioritized.
This represents a shift away from broad, simultaneous European launches toward more selective sequencing.
3. Considering private-market or non-reimbursed launches
Another mitigation strategy is launching products outside public reimbursement systems in reference countries, such as:
- Private-market only launches
- Limited distribution models
The objective is to avoid setting a low public price that could later be used as an MFN reference point. While this approach can preserve price integrity, it also raises access and equity considerations. This will need to be evaluated on a case-by-case basis and whether this approach would be commercially viable depending on the product, indication and price.
4. Using portfolio architecture
One pathway which may be worthwhile exploring is portfolio-level approaches to manage MFN exposure, for example a second-brand or “clone” strategy to protect price corridors.
5. Narrower labels and alternative access pathways
To justify higher prices outside the US, companies may also pursue narrower initial labels or accept more restricted reimbursement conditions, which usually leads to higher price potential in certain referenced EU markets.
6. Policy and stakeholder engagement as a mitigation lever
Beyond commercial strategies, it is important to emphasize the importance of policy engagement.
MFN implies the risk of some companies not launching their products in Europe in case of significant price differences between the US and EU. The UK has secured certain exemptions from MFN as part of US-UK trade deals. Engaging the US, EU & national policymakers and industry associations to flag this as a priority for US-EU trade deal negotiations can support mitigating the impact of the MFN on EU.
Furthermore, as an objective of US policy is to enable US companies to be successful overseas, it is not in the best interests of all parties to have Europe disappear as a market for medicines. Likewise, the EU is unlikely to accept missing out on innovation. It is possible that a compromise on this will be found via US-EU trade negotiations. Potential levers include pledges and measures to increase spending on medicines. In this context we can for example observe that in the 2026 Social Security financing bill (PLFSS) adopted by the French Parliament, lawmakers agreed on an amendment raising the Objective national de dépenses d’assurance maladie (ONDAM) target by around 3% for 2026, above inflation and despite strained public finances. Unfortunately, once again medicines are the target of price cuts and savings. Re-calibrating this equation to enable more significant investment into medicines could represent a lever for US-EU trade negotiations and possible MFN exemptions.
What this means for pharma leaders
MFN pricing is no longer a theoretical policy debate, it is a strategic variable that touches:
- Launch planning
- Pricing and contracting
- Evidence generation
- Policy and government affairs
The most resilient strategies are likely to be cross-functional, combining pricing, market access, legal, policy, and supply chain perspectives rather than relying on a single mitigation lever. In light of continued uncertainty, scenario planning and agility are key to navigate MFN.
Stay Informed with Justin Stindt Consultants – Your Market Access Consultancy
At Justin Stindt Consultants, we are actively monitoring U.S. policy developments, including the MFN rule, to provide our pharma, biotech, and medical device clients with real-time insights and guidance.
Why Partner With our Market Access Consulting Experts?
Justin Stindt Consultants is a specialized market access consultancy offering bespoke market access consulting services. Our team of experts has extensive experience in US Market Access and EU market access, ensuring that our clients are well-prepared for seamless application submissions. Our market access consulting firm has been the preferred service provider for many pharma, biotech and medical device companies seeking consulting services.
- Proven Expertise: With years of experience in global pricing and reimbursement, our team offers unparalleled expertise and strategic insights.
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