Disclosure UK: How It Works, Deadlines, Consent and Objections

Disclosure UK is the ABPI’s public database of payments and benefits in kind from pharmaceutical companies to UK healthcare professionals (HCPs), other relevant decision makers and healthcare organisations (HCOs). It is how UK companies meet the annual disclosure requirements of the ABPI Code of Practice. This guide explains what is disclosed, the deadlines, and how consent and objections work.

What the ABPI Code requires

Clause 28 of the 2024 ABPI Code requires companies to document and publicly disclose, every year, certain transfers of value to HCPs, other relevant decision makers and HCOs. The supplementary information states that Disclosure UK is the central platform for UK disclosure and that companies must use it.

The categories in Clause 28.2 include collaborative and joint working, donations and grants, fees and expenses for contracted services, support for attendance at events, and sponsorship or contributions to event costs. Payments to HCOs are disclosed per activity. Where recipients cannot be identified for legal reasons, amounts are disclosed in aggregate, and each company publishes a methodology note.

Separate clauses cover patient organisations (Clause 29), disclosed on the company website with a link submitted through the Disclosure UK gateway, and contracted services provided by members of the public, including patients and journalists (Clause 30), where the total number of people and total amount are disclosed without names.

Deadlines

Clause 31 requires disclosure annually, for each calendar year, in the first six months after the year ends. Disclosures stay public for at least three years, and records are kept for at least five.

The ABPI’s published timeline for 2026 data is:

Step	Date
Data submission deadline	14:00 BST, Wednesday 31 March 2027
Gateway links deadline	23 June 2027
Publication	30 June 2027

Checking data before publication

According to the ABPI, HCPs and HCOs can check the data companies have provided before it is published, through a private disclosure portal. HCPs can raise a query on specific rows, including to object to publication. Once an HCP’s query is saved, the related data is suppressed until the query is resolved; queries raised by HCOs do not suppress data.

Consent or legitimate interests

To publish an HCP’s name, companies need a lawful basis under data protection law. The ABPI’s December 2025 factsheet says a majority of companies rely on consent, and if an HCP refuses, the company publishes the value in aggregate. Under legitimate interests, the company does not ask for permission but must allow individuals to object. The ABPI champions the use of legitimate interests. Information about HCOs is not considered personal data, and the ABPI expects all values to HCOs to be published individually. Our article on GDPR and transparency reporting goes into more detail.

Getting it right

• Capture transfers of value at source, including through agencies and affiliates.
• Keep one record of each HCP’s consent or objection status.
• Reconcile before the March submission deadline, not in June.
• Assign an owner for queries raised during the review period.
• Submit patient organisation and public disclosure links through the gateway on time.

See also: EFPIA disclosure requirements and our disclosure deadlines by country. This article summarises the ABPI Code and ABPI guidance; it is not legal advice.