UK pharma enters Q2 2026 with a significantly improved national picture for UK market access. There has been progress driven by three interconnected developments: reforms to VPAG; the UK-US pharmaceutical arrangement, and an increase in NICE cost-effectiveness thresholds from April 2026.
On the ground, we have seen NICE technology appraisals moving forward that once had stalled. More investment in the UK market from global; bigger budgets and launch plans accelerating. Momentum is taking hold and we are barely a month in!
NICE analysis suggests a further three to five new medicines per year will receive a positive technology appraisal following the changes. This is three to five additional new medicines available for UK patients in areas of high unmet need and in step-change therapies.
Reframing market access beyond HTA
However, there is also a widening gap between a positive NICE technology appraisal (TA) and real-world patient access in the UK due to NHS system constraints.
We now have this last mile; the gap between a positive NICE TA and real-world patient access to overcome. This last mile is subnational access and in 2026 subnational access is in the spotlight.
Market access can be viewed through different lenses depending on if you are in health economics, pricing and reimbursement or subnational access. Regardless of your lens, in market access you are in the business of ensuring that innovative medicines reach patients and that market access barriers to prescribing are removed. Market access professionals are seeking broad and equitable patient access to innovative medicines.
Since 2020, the European Federation of Pharmaceutical Industries and Associations (EFPIA) has annually reported on ten interrelated factors that delay access to innovative medicines, in the UK and across Europe. These are grouped together in five root causes: the time before marketing approval; the pricing and reimbursement process; the value assessment process; health system constraints and resources; the subnational approval process.
Subnational access is 40% of the access strategy
Often market access success is measured by a positive HTA; in the UK, a positive NICE TA. Over time, pharma companies have become attuned to going further with market access, into the complexity of healthcare systems to ensure patients can actually gain access to innovative medicines at the point of prescribing. This is subnational access and it deals with two of the EFPIA root causes: health system constraints and resources; and the subnational approval process.
Illustrated by EFPIA’s data, if two out of five root causes to access delays are not planned for, 40% of the market access strategy is missing. That is a lot of unmanaged risk on the table.
The national market access drivers mean additional innovative medicines will be launched in the UK. It is critical this translates to patient access and patient outcomes. For this, we need the last mile of market access, subnational access, to be planned and optimised.
Subnational access is the last mile, but start T-24
Well executed subnational access commences T-24 from launch. Head office strategic teams need to understand the complexities of the whole system care pathway that their new innovative medicine is launching into. They need to map, analyse and identify pathway pressure points that will slow patient access. Will the new medicine introduce new pathway complexities? Is a new test or diagnostic required? Is there different monitoring? Does this require input from other health system specialities and other services? This planning highlights if pathway redesign and transformation is required. If this is indicated then a new exemplar pathway should be developed by the head office market access team. A blueprint designed to support systems at launch.
At T-18 to T-12, advance budget notification should be brought to the system, alongside a deep understanding of all system stakeholders who will be involved in formulary decision-making, pathway optimisation and service delivery at launch.
For launch, the value proposition and service impact for local system customers needs perfecting. Local stakeholders are seeking solutions to local issues. They are commissioning outcomes for the populations they serve and finding real-word solutions to close the gap on health inequalities. They are tackling workforce, equipment and diagnostics shortages, capacity issues and long queues.
This is what subnational access deals with, and what de-risking the market access strategy requires. We need the right conditions nationally. We also need investment and delivery locally. When these are combined, the root causes and barriers to medicines adoption will be removed. Patient outcomes then will be achieved.
