China Releases 2026 Anti-Corruption Priorities for Pharmaceutical Sales & Medical Services

On June 8, 2026, China's National Health Commission (NHC), together with 13 other central government agencies, released an official interpretation of the "Key Points for Correcting Unhealthy Practices in the Pharmaceutical Purchase and Sales Sector and Medical Services in 2026." This guidance follows the underlying notice (Guo Wei Yi Ji Han [2026] No. 123), issued on May 22, 2026.

The policy targets a wide range of areas— including procurement, pricing, tax compliance, data governance, medical ethics, and commercial practices — to reinforce long-term institutional controls across the healthcare ecosystem.

From Campaign Enforcement to Institutional Governance

The 2026 priorities mark a transition from investigating individual corruption cases toward preventing misconduct through structural reforms, cross-agency coordination, and continuous supervision.

Fourteen government bodies are participating in the initiative, including:

• The National Health Commission (NHC)
• National Medical Products Administration (NMPA)
• National Healthcare Security Administration (NHSA)
• State Administration for Market Regulation (SAMR)
• Ministry of Public Security
• Ministry of Finance
• State Taxation Administration

This coalition reflects a government intent to supervise the pharmaceutical ecosystem from multiple angles, moving beyond the traditional oversight of healthcare regulators alone.

Broadening Commercial Compliance Expectations

The 2026 priorities demonstrate that regulators are targeting a much wider range of commercial activities.

Sales and Marketing Practices Remain Under Close Scrutiny

Authorities are intensifying efforts to eliminate improper financial incentives, specifically focusing on:

• Commercial bribery and fraudulent transactions
• Improper benefits linked to academic conferences
• Licensing abuse and false business activities
• Manipulation of procurement processes

The scrutiny of "academic activities" is particularly notable. While scientific exchange is essential, regulators are increasingly distinguishing between legitimate educational engagement and events used to disguise promotional or financial incentives. Companies should ensure all speaker programs, medical education sponsorships, and congress participation are supported by clear business justifications and robust internal controls.

Strengthening Procurement Integrity

Public procurement remains a primary focus, with tightened oversight of:

• High-value medical devices
• Medical equipment procurement
• Centralized drug procurement
• Government tendering procedures
• Purchasing decisions by hospitals

Particular attention will be paid to practices such as:

• Splitting contracts to avoid public tenders
• Customized tender specifications favoring specific suppliers
• Predetermined contract awards despite nominal competitive bidding

Intensifying Pricing and Market Discipline

The document reinforces China's commitment to maintaining discipline in pharmaceutical pricing.

Authorities intend to:

• Continue expanding centralized volume-based procurement
• Strengthen drug and medical consumable price management
• Investigate price fraud
• Address price manipulation
• Crack down on non-transparent pricing practices

The notice also refers to studying mechanisms for direct settlement between medical insurance authorities and pharmaceutical companies, potentially representing another step toward greater payment transparency.

Synchronizing Tax and Commercial Compliance

One of the more significant developments is the stronger integration of tax enforcement into pharmaceutical supervision.

The notice calls for coordinated investigations into:

• False VAT invoices
• Tax evasion
• Invoice fraud
• Institutions accepting fraudulent invoices

Authorities also intend to strengthen invoice-chain risk monitoring and enhance credit evaluation within pharmaceutical purchasing and sales.

Under these measures, tax compliance cannot be viewed in isolation; distributor relationships, promotional spending, and third-party vendor arrangements must be evaluated through both a commercial and a tax lens.

Elevating Medical Data Security

Authorities plan to strengthen supervision across the entire medical data lifecycle through:

• Enhanced approval mechanisms
• Traceability systems
• Restrictions on unauthorized data use
• Stronger protection of patient privacy

Notably, regulators specifically reference illegal commercialization of medical data through third parties operating under the guise of scientific research.

Companies involved in clinical research, real-world evidence generation, digital health solutions, or medical data partnerships should review governance frameworks to ensure that data access, use, and transfers comply with these heightened expectations.

Scaling Medical Insurance Oversight

The 2026 notice signals an expansion of the NHSA’s mandate, shifting toward a tech-forward approach that leverages big data and intelligent monitoring systems to identify compliance risks.

The notice calls for:

• Expanded use of big data supervision
• Intelligent monitoring systems
• Earlier identification of compliance risks
• Stricter investigation of improper medical insurance fund use

With authorities now able to cross-reference  institutional interactions across multiple data sources, market access strategies and reimbursement support activities require a correspondingly high standard of documentation and consistency.

Key Actions for Pharmaceutical Companies

While this notice is directed at Chinese authorities, it serves as a critical blueprint for the regulatory landscape ahead. To stay ahead of these heightened expectations, international companies must embrace an integrated, enterprise-wide strategy.

Strengthen Third-Party Oversight

Given the continued emphasis on commercial bribery, procurement integrity, tax compliance, and false transactions, companies should reassess oversight of distributors, commercial partners, consultants, conference organizers, and other third parties.

This requires verifying that third-party expenses are tied to documented, legitimate business activities, as regulators are now cross-referencing these payments with procurement and tax data.

Stress-Test Data Governance Frameworks

As China’s data regulatory framework matures, existing controls may prove insufficient. Organizations handling patient information, research data, or institutional insights must rigorously stress-test their governance frameworks. Ensure that your protocols for data access, storage, and transfer are not just compliant, but defensible under the latest cybersecurity and privacy mandates.

Prepare for Multi-Agency Regulatory Reviews

Expect future regulatory inquiries to be synchronized across multiple authorities. A routine tax audit or a pricing investigation is increasingly likely to trigger a wider, multi-agency probe covering anti-corruption, procurement, and data protection simultaneously.

Your internal investigation protocols should be designed to handle this "multi-lens" approach, ensuring that your legal, regulatory, and commercial teams can provide a consistent and coordinated response during multi-agency regulatory reviews.

From Enforcement Campaigns to Continuous Compliance

The 2026 priorities signal a fundamental shift in China’s regulatory landscape: the transition from sporadic, campaign-style enforcement to a model of continuous, systemic governance. By leveraging digital oversight, institutional accountability, and cross-departmental coordination, authorities have moved toward a permanent, data-driven approach to compliance.

For international pharmaceutical companies, this evolution changes the stakes. Compliance can no longer be a reactive or departmental task; it must be an enterprise-wide imperative that extends across affiliates, distributors, and external partners.

As regulatory expectations continue to change, Cisema helps pharmaceutical companies navigate these complex obligations through expert pharmaceutical consulting services. To discuss how the 2026 enforcement priorities may affect your business, contact Cisema today.

Further Information

• Explore Cisema’s services for pharmaceutical consulting.

References

• Notice on Issuing the Key Points for Correcting Unhealthy Practices in the Pharmaceutical Sales Sector and Medical Services in 2026
• Interpretation of the "Key Points for Correcting Unhealthy Practices in the Pharmaceutical Purchase and Sales Sector and Medical Services by 2026."