What we do not know

This decides whether the whole Dutch route buys price freedom or only legality. The ECJ in C-148/15 and a July 2025 BGH decision say foreign mail-order pharmacies are not bound; a 2024 Munich appellate ruling reportedly upholds price binding against foreign senders, and the 2020 VOASG reinstated uniform pricing through social-insurance law. These cannot both be fully right for the same category of sale.

How to close it. One hour with a German pharmaceutical lawyer who has argued AMPreisV. Bring both lines of authority and ask specifically about private (non-GKV) prescriptions dispensed from another member state.

Bears on: Germany, Netherlands · the dutch route

Since Lilly suspended UK wholesaler sales, this is the sanctioned route to Mounjaro. Without a manufacturer arrangement, UK gross margin is negative at 7.5mg, 12.5mg and 15mg, the doses patients titrate to.

How to close it. Email LillyDirect UK directly. It is one email and it is the cheapest kill-or-continue test in any UK plan.

Bears on: United Kingdom · supply chain, unit economics

Every payback calculation in this atlas rests on an assumed figure. No UK or German CAC, CPA or category CPM is published anywhere. The difference between £150 and £250 flips the worst-case patient from marginally profitable to a loss.

How to close it. Not desk-researchable. Either run a small paid test with compliant creative, or get a number from an operator or an agency that buys in the category.

This is now the highest-leverage unresolved structural question after German price binding. Hi-Doctor serves Hungarian patients using prescriptions registered in the Spanish REMPE system. Estonian digiretsept prescriptions are dispensable in ten other member states. Both lean on Directive 2011/24/EU cross-border recognition, which was designed for patient mobility rather than for a domestic telehealth channel operated from abroad. If the mechanism holds, it partially routes around national prescriber licensing across most of the EU. If it does not, several visible operators are exposed.

How to close it. An EU health-law specialist on the scope of Directive 2011/24/EU and its national implementations, plus a direct question to one destination-state regulator, most usefully the Hungarian OGYEI or the Estonian Ravimiamet.

Bears on: Hungary, Estonia, Spain · infrastructure

Only one point is public, 15mg supplied at £247.50 rather than the £330 list. The margin table extrapolates a uniform 25% rebate across doses. If the rebate is narrower at lower doses, several become genuinely loss-making.

How to close it. Ask a dispensing partner what they actually pay, or raise it in the LillyDirect conversation.

Bears on: United Kingdom · unit economics

It is the largest single line in a brand-first P&L and nothing is published. Confirmed absent, not merely unfound.

How to close it. Quotes from Kamille Apotheek, Helix Pharmacy, Phlo Connect and CloudRx. Four emails, and the spread between them is itself the answer.

Bears on: Netherlands, United Kingdom · infrastructure

Five research passes found the European Commission decision of 15 July 2026 with a primary Novo source. One pass reading the EMA EPAR pages concluded the opposite. The EC decision is the better-evidenced position, but before relying on availability in any specific market the register should be checked.

How to close it. Check the EMA EPAR for Wegovy directly, and the national medicines agency register for the target market.

Every logistics plan in this space is built on the ABDA figure of seven. Checking it against national primary sources produced two errors in opposite directions: Lithuania has permitted it since July 2022 and is missing from the list, and Malta is on the list although its own regulator says the law does not provide for internet pharmacies at all. The count survives at seven; the membership does not. If two of seven were wrong, the remaining five deserve the same treatment.

How to close it. Check the national medicines agency register of authorised distance sellers in each of the 27 states directly. Tedious, cheap, and nobody appears to have done it recently. Germany, Denmark, Estonia, Finland, the Netherlands and Sweden are the five still resting on the secondary list.

Bears on: Lithuania, Malta · the dutch route, supply chain

Slovenia has unusually high per-capita self-pay GLP-1 intensity, six of the top ten self-pay best-sellers, but pharmacy provision is a municipal public service with concessions granted to individual pharmacists. Whether any corporate participation is possible decides whether Slovenia is a market to serve or a market to skip.

How to close it. A Slovenian healthcare lawyer on the ZLD-1 concession conditions, plus one municipality.

Bears on: Slovenia · ownership rules

All three are inferred as closed from their absence from the ABDA list of seven permitting states, not from a primary national source. Three of the larger Western European markets should not rest on an inference.

How to close it. Direct confirmation from ANSM, FAGG and the HPRA respectively.

Bears on: France, Belgium, Ireland · the dutch route

The Bolt structure suggests brands build their own captive prescriber entity rather than renting one. If nobody rents, the CQC application is on the critical path rather than optional.

How to close it. Approach HealthHero and two or three others directly. None publishes pricing.

Bears on: United Kingdom · infrastructure

If it holds, standard couriers become viable for injectable last-mile delivery, cutting packaging cost and wastage materially.

How to close it. Read the Novo Nordisk SmPC and patient information leaflet. Single-sourced from a secondary site at present.

This is what actually determines whether a low-cost back office can serve a German or UK front end. Salary data is available; language capacity is not, and it is the binding variable.

How to close it. Recruiters, not desk research. Two conversations per market.

Bears on: Poland, Czechia, Hungary, Bulgaria, Romania · operating bases

Easy to assume GPhC plus CQC covers the UK. It does not, and the rules for online-only services are genuinely unsettled, HIS's own guidance is written for face-to-face services and tells providers to email and ask.

How to close it. Written confirmation from HIS, HIW and RQIA before selling into those nations.

Bears on: United Kingdom

Greece rolled out reimbursement through late 2025, which compresses the cash-pay opportunity. Without the BMI and comorbidity thresholds, the residual private segment cannot be sized, so Greece cannot be ranked properly.

How to close it. The formal decision published in December 2025, or EOF directly.

Bears on: Greece

Malta is repeatedly listed among the small group of EU states permitting Rx mail order, and it has an unusually liberal ownership rule. If both were true it would be a genuinely interesting base.

How to close it. Read the Malta Medicines Authority page that serves as the national register under article 85c(4) of Directive 2001/83/EC.

Closed. Closed August 2026, and the answer is no. The Malta Medicines Authority states that the legislation caters for physical community pharmacies and does not provide for the establishment of internet pharmacies, and that none exist. The national register is empty. Cap. 458 never transposed article 85c. What Malta permits is inbound receipt by residents of medicines bought from internet pharmacies established elsewhere, which is a different thing and is the likely origin of the error. The ownership rule is genuinely liberal, so Malta remains interesting, but not as a mail-order base.

Bears on: Malta · the dutch route

Lithuania appeared to be the one Baltic market where the owner need not be a pharmacist, and the only one where a pan-EU operator openly advertises home delivery. The 2023 amendment was widely reported as an ownership restriction.

How to close it. A Lithuanian lawyer reading the current Farmacijos istatymas.

Closed. Closed August 2026. There is no pharmacist-ownership requirement. The 1 July 2023 reform that closed 34 pharmacies imposed a requirement that a qualified pharmacist be physically present during opening hours, which is a staffing rule, not an ownership rule. Separately, Rx mail order has been lawful since 12 July 2022 under order V-1491. Lithuania moves into the open-ownership group.

Bears on: Lithuania · ownership rules, the dutch route

The citation appears across secondary summaries and placed Croatia in the closed group, which changes whether it is worth looking at as an ownership target at all.

How to close it. Read the consolidated act.

Closed. Closed August 2026. It does not. Article 38 concerns the financing of the Pharmacists Chamber. The current text contains no ownership percentage threshold anywhere. The real constraint on entry is county-level concession and network planning, not who owns the company.

Bears on: Croatia · ownership rules

An earlier version of this atlas recorded Slovakia as pharmacist-only, which would have excluded it from any ownership plan.

How to close it. Read zakon 362/2011 Z.z. directly rather than a secondary summary.

Closed. Closed August 2026, as a correction to our own earlier error. Paragraph 3 ods. 5 of zakon 362/2011 Z.z. permits a legal entity to hold the pharmacy permit provided it appoints an odborny zastupca. Dr.Max Holding SK and BENU both operate on that basis.

Bears on: Slovakia · ownership rules