24.10.2025

SL Insight Newsletter #6

BAG sets limits for 40% deductible

Marcel Boller

On September 1, 2025, the FOPH published the new circular on differentiated deductibles (Art. 38a KLV) (link). The key date is August 1, 2025: only the factory prices (FAP) as of August 1 are included in the calculation of the thresholds.

What does that mean specifically?
  • Price reductions resulting from the triennial review as of December 1, 2025, are not taken into account.
  • This may mean that, despite the price reduction, packages will continue to be subject to the 40% deductible until the end of the year.
  • New limit value list now online: Implementation of the 40% allocation will take place on December 1, 2025 (link)
What does market access mean?

Companies should check whether their own products appear on the list of limit values and whether price or packaging adjustments can still be implemented before December 1.