Free template
EFPIA Disclosure Methodology Note Template
A working template for the methodology note that must accompany HCP/HCO disclosures, laid out in the mandatory Annex B structure of the EFPIA Code of Practice 2026, with prompts for what to cover under each heading.
For: Compliance, finance and transparency reporting teams preparing EFPIA-based disclosures, including Disclosure UK.
What the template covers
- 1. Definitions · 2 points
- 2. Disclosure scope · 3 points
- 3. Specific considerations · 2 points
- 4. Data protection legal basis · 3 points
- 5. Form of disclosure · 4 points
- 6. Additional information · 1 points
The headings follow Annex B of the EFPIA Code of Practice 2026. The prompts under each heading are Eunomia’s practical suggestions; national codes may add requirements. Not legal advice.
This PDF focuses on drafting the public methodological note. For the wider preparation process, use our disclosure preparation guide and editable Excel checklist, covering owners, source data and reconciliation.
Based on the EFPIA Code of Practice 2026.
Questions, answered
EFPIA Disclosure Methodology Note Template: common questions
Is the methodology note structure mandatory?
Yes, for EFPIA member companies’ HCP/HCO disclosures. The EFPIA Code of Practice 2026 requires methodology notes to follow the structure in Annex B, at the latest for the 2026 disclosure of 2025 transfers of value.
Does this template work for Disclosure UK?
The ABPI Code also requires a methodology note. This template follows the EFPIA Annex B structure; check the ABPI Code and Disclosure UK guidance for any UK-specific points.