Pharmaceutical pricing in Türkiye runs under Decree No. 73 (2007) on the Pricing of Medicinal Products for Human Use. The system's backbone is simple but its consequences run deep: the price is carried into Türkiye in euro terms based on the lowest price among reference countries, and that euro amount is converted into Turkish lira at the pricing euro rate determined by Presidential Decree. The variable that really governs drug prices is therefore not the list price but the FX rate. Developments at the end of 2025 and through 2026 show the mechanism evolving from an annual reset into a stepped, more frequent update regime. This article explains how the mechanism works, the milestones of its FX history, and how companies should rebuild pricing strategy around the FX calendar.
How Decree No. 73 works: the reference-price logic
Under the Decree, prices are set by taking the lowest retail price at which the product is sold in reference countries. The reference-country set has been shaped by amendments and consists of a cluster of lower-priced European markets. In practice, the Turkish price takes the lowest of those prices in euro; VAT and pharmacy-wholesaler margins are computed to reach the TRY retail price. The system serves two purposes: securing internationally comparable prices for the payer and offering companies a predictable rule set.
Price determination and update applications run through the TİTCK. Filings occur for new authorisations, new strengths/forms and reimbursement-list entries; under FX updates, list-wide recalculation and company-specific processes operate. The Decree's rules include provisions linking prices across different dosages of the same active substance and reference-linked discounts for generics — which is why pricing is not a single-product exercise but portfolio management.
A short history of the pricing euro rate
The rate has been held low since 2007, below inflation-comparable increases, pushing Turkish prices below reference-country levels and periodically creating parallel-export pressure. The milestones: in early 2022 the rate moved from 7.86 TL by 36.8% to 10.76 TL; a second in-year update took it to ~16.68 TL, then ~19.66 TL; in 2024 a 23.5% increase brought it to 21.67 TL. At every step, prices of listed products were recalculated at the new rate, while Annex-4/C euro-based prices moved on a separate track.
December 2025: +16.9% and the new periodic logic
By a Presidential Decree published in the Official Gazette on 19 December 2025, the pricing euro rate was increased by 16.9% to the new periodic value of approximately TRY 25.33 for 2026. A technical detail of the Decree mattered: under its relevant article, no additional euro update would be made until a new determination in February 2026 — signalling a shift to "periodic determination + interim assessment" logic.
The stepped transition in 2026: 25.33 → 26.87 → 29.11
2026 was the year the stepped regime materialised. In March 2026 the rate was first raised from TRY 25.33 to 26.87, and then, effective 1 April 2026, stepped up to TRY 29.11. This means updates spread across the year instead of a single large revision: price lists may be recalculated three or four times a year, and stock, returns and invoice processes must be re-verified at every step.
For companies this raises three planning questions: (1) Which stock and invoice dates will the new price list bind to? (2) How will price differences (closing differences) be managed along the wholesaler-pharmacy chain? (3) What net price do public-sales discounts and payment terms produce at the new rate? Without these answers, mistaking an FX increase for a "price increase" leads to serious financial-planning errors.
Discounts and net price: why an FX step does not grow the list alone
List growth and realised net price are not the same thing. In public sales, the chain of standard rebates, negotiated additional discounts and reimbursement-linked price cuts absorbs part of the FX increase. Meanwhile an FX step directly changes the parallel-export calculation: when the Turkish retail price, converted to euro, falls below reference-country levels, parallel export becomes attractive. The critical threshold for a company is the point where the Turkish price approaches the lowest reference price; as it nears, supply allocation and stock planning must be run scenario-based.
Parallel export and supply-chain dynamics
Parallel export is the re-export to Europe of products licensed and marketed in Türkiye to exploit the price gap. As the rate lags, the gap widens and supply interruptions can occur in the Turkish market, directly affecting patient access. This mechanism lay behind the supply problems of 2022-2024. The stepped updates aim to ease this pressure, but company-level outcomes differ at each step. For every critical product in your portfolio, a "parallel-export risk score" (Turkish price versus reference minimum, margin, supply elasticity) should be computed and refreshed with each FX step.
Reflections on SUT prices and the reimbursement side
An increase in the price list is not automatically a "gain" on the reimbursement side. In health services costed through SUT prices and in pharmacoeconomic models, the FX parameter must be re-run after every major update. Good practice in budget-impact analyses is to build two scenarios: current rate and FX-update calendar (including forward steps). Also, the date stamp on cost tables in the reimbursement file signals its currency at the Institution; a file entering the room with six-month-old FX assumptions weakens at the first question.
Price-filing processes and TİTCK practice
Price movements beyond FX updates are also tied to the FX calendar: in new-product price filings, strength changes on existing products and annex-list entries, the foreign price documents TİTCK expects are assessed at the current rate. The chronology of foreign price certificates submitted must be consistent with the product's price history; inconsistency is among the most common reasons filings drop into correction rounds. Companies filing between FX steps should track announcements closely to clarify which rate applies to which filing.
Strategy: binding the pricing function to the FX calendar
- FX scenario table: at the start of the year, build a table of announced and expected FX steps; compute portfolio net-price and margin effects per scenario.
- Price-list operations protocol: bind the steps — from new-rate announcement to list update, wholesaler notification and pharmacy communication — into an hour-by-hour protocol.
- Parallel-export monitoring: track Turkish versus European prices quarterly for critical products; update supply plans when the risk threshold is crossed.
- Model refresh: re-run cost assumptions in active reimbursement files after every FX step; state the FX reference date in the file annex.
- Payer communication: where an FX step changes your product's access position (e.g. price-list mismatch), plan proactive notification to the Institution.
The price chain step by step: how the calculation turns
Let us make the mechanism concrete. Assume a product's lowest reference-country retail price is EUR 100. Price determination takes this amount; the ex-factory price excluding VAT is computed and Türkiye's statutory contributions and rebates defined on top. With the pricing euro rate at TRY 29.11, EUR 100 produces a materially different list price than at TRY 25.33 — same euro amount, different rate, different TRY price. In public sales the standard rebate applies; wholesaler and pharmacist margins produce the retail price. The critical point for companies is recomputing the whole chain at every step — not just the list price but the realised net price; since negotiated rebates typically apply proportionally, the net effect of an FX step can differ from the list effect.
How the 2022-2026 FX steps show up in market data
The steps' market impact is visible in İEİS data: after the double increase of 2022, value growth hit historic peaks; the 2024 (23.5%) and end-2025 (16.9%) steps produced similar value growth. Yet box growth stayed far more limited in the same period — proof that FX-driven growth is price growth. In planning language: an FX-step year is a "growing market" year; but the growth is shared — firms with negotiating power (irreplaceable products) convert the FX wind into net margin, while in competitive segments the increase is partly clawed back through rebate pressure.
Reference-price risk and ceiling-floor dynamics
For companies under international reference pricing, the Turkish price is never a local matter: some countries include Türkiye in their reference sets. Raising the Turkish list price can therefore echo as a low-price reference elsewhere. Known management routes: making price moves through net price (rebates) where possible, synchronising list changes with global pricing strategy, and monitoring parallel-export risk thresholds. Managing this balance requires a standing protocol between the local access team and global pricing — it cannot be run on ad-hoc decisions.
Frequently asked questions
- Does an FX increase flow to the list automatically? It flows through the recalculation of the price list under the FX update; but public-sales rebates and negotiated terms determine the net price.
- Are Annex-4/C products priced at the same rate? No; that list works with euro-based amounts and is revised partly independently of FX steps.
- At which rate is a new product priced? The pricing euro rate in force at the evaluation date of the filing; filing timing is therefore strategic.
- Does an FX increase reduce parallel-export risk? To the extent it moves the Turkish price closer to reference countries; it may still not cross the threshold depending on margin and supply cost.
- Which rate should reimbursement models use? The rate in force; additionally, an FX-step scenario should be presented as sensitivity analysis.
Reference countries and external price control
Decree No. 73's reference logic means price is not merely a domestic negotiation outcome: foreign prices form the upper bound of the Turkish price. In practice the company attaches the product's reference-country price certificates to the filing; the payer takes the lowest of these. Three practical consequences follow. First, reflection of foreign price cuts: if the price falls in a reference country, an update risk arises in Türkiye; global price management must know the Turkish calendar. Second, difficulty of raising prices: increase attempts are checked against the reference minimum; products pinned to the ceiling cannot rise. Third, document management: the chronology and consistency of foreign price certificates is where filings most often stall; a certificate inconsistent with price history means a correction round. Pricing teams should bind these three consequences into procedure and institutionalise information flow with the global team.
Wholesalers, pharmacies and channel economics: who keeps what?
The distribution of the drug price across the channel is defined by regulation: VAT, wholesaling and pharmacy margins are built onto the ex-factory price to form the retail price, with the standard rebate applied in public sales. Because FX steps scale this distribution proportionally, channel players' expectations also enter the pricing agenda. The critical monitoring point for companies is availability at the end of the chain: around price increases, wholesaler stock behaviour (stockpiling before, acceleration after) affects supply planning, while price confusion in the transition period can create false perception among patients and physicians. A well-run price operation runs channel notification and stock reconciliation in step with the list update.
An early-warning system: building the company's FX radar
Fx steps need not always surprise; the company radar feeds on four indicators. (1) The official calendar: typical decision periods (pre-year-end, quarter transitions) and forward-looking signals in decree texts — the December 2025 decree's "new determination in February 2026" phrase is exactly such a signal. (2) Market expectation: periods where the FX and inflation path makes an update inevitable; as the lag accumulates, step probability rises. (3) Sector signals: TİTCK announcements, institutional briefings and association communications. (4) Scenario readiness: portfolio effects of 5%, 10% and 15% steps computed in advance. With this radar in place, an FX announcement becomes a scheduled operation rather than a crisis; marketing and finance enter price scenarios prepared.
Types of price-change filings: a guide
The core transaction types in pricing practice and their subtleties: New-product price determination: the first price after licensing; current, consistent foreign price certificates are critical, and timing against the FX calendar determines which rate applies. Strength/form changes: prices of new doses or forms are subject to price-relationship rules within the same series; imbalance sends the filing back. Fx-driven price updates: lists are recalculated after an FX announcement; whether a separate company filing is needed varies by announcement scope. Reflection of foreign price cuts: if a reference-country price falls, the Turkish price must be updated; delay creates compliance risk. Cancellation/withdrawal: on market withdrawal, the fate of the price record and the annex-list status must be clarified. A single owner and document template should be defined internally for each transaction type; pricing is a specialisation demanding documentation discipline.
Financial planning across FX periods: scenario budgeting
Scenario budgeting for finance between FX steps runs on three layers. Layer 1 — the realised rate: the income-cost table and product-level gross margin at the current rate. Layer 2 — announced steps: recalculation at, say, the rate effective after 1 April; the net-price effect of the list update (after the rebate chain) is estimated. Layer 3 — expected steps: probability-weighted additional scenarios based on FX lag accumulation; cash flow and supply budget rebuilt per scenario. This three-layer exercise should be presented in management reporting as the "FX sensitivity" page. Stock policy should additionally be tied to the FX calendar: movement in wholesaler stocks ahead of an increase requires preparation on both supply and accounting (stock valuation). A company managing the FX period manages not the price list but the entire value chain.
Sources and key takeaways
Core sources: Decree No. 73 and its amendments; the Presidential Decrees on the euro rate (December 2025; March/April 2026) and TİTCK announcements; association pricing reviews. Recommended monitoring: the Official Gazette (decrees), the TİTCK pricing page, and market FX indicators (for lag analysis). Our key takeaways: (1) pricing is now calendar-managed — build the FX scenario table at year start; (2) an FX step grows the list while the rebate chain determines net margin; (3) track parallel-export risk scores quarterly on critical products; (4) refresh and date-stamp FX assumptions in reimbursement files after every step; (5) a price operation is more than a list update — channel notification and stock reconciliation run on the same calendar.
Practical summary: the pricing team's period-opening checklist
At the start of every FX period the pricing team should work a seven-item checklist. (1) Rate table: the rate in force, announced forward steps and probability-weighted expected steps in one table. (2) Portfolio effect: per product, list price, net price after public-sales rebate and margin — with step effects. (3) Filing inventory: pending price determinations/updates and which rate will govern them. (4) Document currency: is the chronology of reference-country price certificates consistent with product history? (5) Parallel-export radar: the Turkish-price-versus-reference-minimum spread on critical products, with threshold alerts. (6) Channel readiness: wholesaler-pharmacy notification plan, stock reconciliation procedure, transition-communication texts. (7) File sync: FX reference dates and currency of sensitivity scenarios in active reimbursement files. With all seven complete, the team runs a rehearsed operation when the announcement comes — not a crisis. A surprise-free pricing function is the sharpest competitive weapon of FX periods.
Conclusion
The move to stepped FX updates has turned pharmaceutical pricing into a calendar-managed discipline. An FX step grows the list; but access and net margin are governed by the rebate chain, the parallel-export balance and reimbursement synchronisation. To model your pricing scenarios on the FX calendar, protocolise your list operations and strengthen your reimbursement position, contact the Omega Arastirma team.