Investors and analysts
Use a real comparator to test access timing and country-by-country uptake assumptions.
A comparator resource for how esketamine moved from EU authorization into different national access outcomes, and what that teaches for psilocybin-assisted therapy.
EMA authorization to effective basic-package reimbursement
Source: Zorginstituut Nederland
Final NICE non-recommendation, not reimbursement
Source: NICE
Recommendation, funding, listing, and practical care are different milestones
At a glance
Who this helps
Use a real comparator to test access timing and country-by-country uptake assumptions.
Identify payer issues that need work before authorization.
See why national HTA decisions can diverge after a shared EU authorization.
Country precedent
EMA authorization on 18 Dec 2019 is the shared starting point. National rows use the best available public milestone, so the date definition matters as much as the number.
ZiN / VWS / NZa
623days
Effective reimbursement from the basic package
NICE
1092days
TA854 not recommended
SMC
264days
Accepted for restricted use
Netherlands
ZiN / VWS / NZa
623 days
EMA authorization to effective basic-package reimbursement; ZiN advice was earlier, on 30 September 2020.
The Dutch case separates package advice, ministerial adoption, reimbursement start, and later care-delivery payment design.
England / Wales
NICE
1092 days
EMA authorization to final NICE guidance publication; this is a negative access signal, not a reimbursement date.
NICE is the clean negative precedent: regulatory approval did not translate into routine NHS funding.
Scotland
SMC
264 days
EMA authorization to SMC acceptance date for restricted NHS Scotland use.
Scotland shows why the UK should not be treated as one access outcome.
Ireland
NCPE / HSE
Date to verify
Funding approval month only; NCPE's earlier full HTA outcome was negative unless cost-effectiveness improved.
Ireland is a strong example of a negative HTA signal followed by confidential price negotiation and later funding.
Belgium
INAMI / RIZIV
531 days
EMA authorization to reported managed-entry convention start; post-2024 renewal should be checked before using as current status.
Belgium is useful as a managed-entry convention example, but the current convention status needs a fresh primary-source pin.
Sweden
NT-rådet
560 days
EMA authorization to NT-rådet recommendation date for restricted use.
Sweden is a treatment-sequence precedent: in normal practice, several alternatives should be exhausted before Spravato.
Finland
Hila / Kela
1322 days
EMA authorization to effective special reimbursement date.
Finland shows that reimbursement can be linked to strict eligibility and continuation criteria.
Germany
G-BA / AMNOG
Date to verify
G-BA reassessment date, not first reimbursed care; German statutory access, launch pricing, benefit assessment, and negotiated price are separate milestones.
Germany is useful for comparator-choice lessons, not for a simple first-access clock.
France
HAS
Date to verify
French HAS opinion date; mixed status because a narrow subgroup was favourable while broader reimbursement was unfavourable.
France should be shown as partial or hospital-sector restricted, not a simple yes/no outcome.
Czech Republic
SUKL / payer service code
Date to verify
Reported reimbursed in precedent literature; exact public medicine-reimbursement date still needs a primary SÚKL pin.
Keep the status separate from the date certainty: the access direction may be positive even when the best public date is not pinned.
Italy
AIFA
1163 days
EMA authorization to AIFA class C(nn) commercial classification; this is a non-reimbursed classification step, not a funding date.
Keep Italy as an unresolved access case until a later AIFA reimbursement determination is pinned.
Spain
Ministry of Health
Date to verify
Spanish 2022 public materials indicate non-financing and a later financing-change signal, but the underlying formal resolution date still needs to be pinned.
Spain should be shown as unresolved until the formal ministry resolution and effective financing date are separated.
Austria
National reimbursement record
Date to verify
No official Austrian reimbursement, non-reimbursement, or effective listing date was pinned in the current source pass.
Austria remains useful as a missing-evidence case: do not infer access from EMA authorization alone.
Denmark
Medicinrådet
2163 days
EMA authorization to current positive recommendation date after earlier negative decisions.
Denmark is a useful reversal case: earlier no decisions later turned positive after new data and price changes.
Norway
Beslutningsforum
1035 days
EMA authorization to national adoption decision not to introduce Spravato for TRD.
Norway is a negative precedent centred on evidence quality, uncertainty, and price relative to documented benefit.
Switzerland
BAG
2114 days
EMA authorization to new Swiss Spezialitätenliste inclusion date.
Swiss access is restricted and tied to specialist-setting and prior-treatment conditions.
| Country | Milestone | Date | Days from EMA | Confidence |
|---|---|---|---|---|
Netherlands EU | Effective reimbursement from the basic package | 1 Sept 2021 | 623 days | official date |
England / Wales UK | TA854 not recommended | 14 Dec 2022 | 1092 days | official date |
Scotland UK | Accepted for restricted use | 7 Sept 2020 | 264 days | official date |
Ireland EU | HSE funding after confidential price negotiations | Jan 2022 | TBC | official but date definition differs |
Belgium EU | Confidential convention start | 1 Jun 2021 | 531 days | official but date definition differs |
Sweden EU | Restricted recommendation | 30 Jun 2021 | 560 days | official date |
Finland EU | Restricted special reimbursement | 1 Aug 2023 | 1322 days | official date |
Germany EU | Positive TRD reassessment | 21 Sept 2023 | TBC | official but date definition differs |
France EU | Narrow favourable opinion; broader use negative | 24 Jun 2020 | TBC | official but date definition differs |
Czech Republic EU | Reported reimbursed; official date pending | To verify | TBC | needs primary date |
Italy EU | Public reimbursement not verified | 23 Feb 2023 | 1163 days | needs primary date |
Spain EU | Conflicting financing record | To verify | TBC | needs primary date |
Austria EU | No clean public reimbursement record verified | To verify | TBC | needs primary date |
Denmark EU | Current positive recommendation | 19 Nov 2025 | 2163 days | official date |
Norway Europe comparator | Not introduced | 18 Oct 2022 | 1035 days | official date |
Switzerland Europe comparator | Spezialitätenliste inclusion | 1 Oct 2025 | 2114 days | official date |
| Jurisdiction | Access signal | Use for psilocybin planning |
|---|---|---|
| Netherlands | Effective reimbursement from 1 September 2021 after earlier ZiN advice and ministerial adoption | Plan ZiN evidence, price, appropriate-use, and NZa payment-route arguments early |
| England / Wales | NICE did not recommend routine NHS use in TA854 | Stress-test cost-effectiveness, comparator, and uncertainty assumptions |
| Scotland | SMC accepted restricted use | Model how restrictions can shape eligible population and service design |
| Ireland | Negative HTA signal followed by HSE funding after confidential price negotiations | Do not treat a first negative appraisal as the whole access story |
| Sweden / Finland / Switzerland | Restricted positive access tied to high-severity or later-line use | Assume narrow initial eligibility, continuation criteria, and specialist settings |
| Denmark | Earlier negative decisions later turned positive after new evidence and lower price | Reassessment can matter when evidence, comparator, or price changes |
| Norway | Not introduced after national decision-making | Evidence quality, uncertainty, and price can still block access |
| Germany | AMNOG benefit-assessment dates do not equal first reimbursed patient care | Separate launch access, G-BA value signal, price negotiation, and practical specialist-site uptake |
| Czech Republic | Reported reimbursed in precedent literature, but exact public medicine-reimbursement date remains pending | Track status confidence and date confidence as separate fields |
| Europe-wide WAIT context | Average availability delays remain substantial after authorization | Do not treat authorization date as patient-access date |
| Field | Meaning | How to use it |
|---|---|---|
| EMA authorization | Common EU start date | Use as the start of every European Spravato clock |
| HTA recommendation | First formal national public advice | Useful for value-assessment timing, including negative decisions |
| Funding decision | Ministerial, HSE, or managed-entry approval | Use when effective listing is not public but funding is confirmed |
| Effective listing | Date reimbursement or convention formally starts | Best public endpoint when sourceable |
| Practical availability | First publicly evidenced treated access | Best real-world endpoint, but often unavailable |
Spravato is useful because it shows that EMA authorization starts, rather than ends, the access process. National HTA bodies still decide whether, where, and under what restrictions the product fits in routine care.
The most defensible cross-country clock starts on 18 December 2019, the EU marketing authorization date, and then uses the first public funding entitlement where that date is available. Recommendation, funding decision, effective listing, and practical care should be stored as different dates.
For psilocybin-assisted therapy, the lesson is not that the same timeline will repeat. The lesson is that comparator choice, treatment sequencing, delivery infrastructure, service payment, and uncertainty management must be prepared before authorization.
The Netherlands has a visible path from ZiN advice to ministerial adoption and effective reimbursement. Ireland shows a negative HTA signal followed by confidential price negotiation and later funding. Germany shows why AMNOG dates should not be mistaken for first reimbursed patient care.
The public page therefore labels every number with its date definition. A negative recommendation can still have a day count, and a reimbursed product can have no clean first-access day if the public record is ambiguous.
The transferable lesson is not get licensed and you will get paid. It is build the reimbursement case around a narrow, clinically credible subgroup, a controlled delivery model, relevant comparators, and a plan for durability uncertainty.
The analogy breaks because Spravato remains closer to a medicine-plus-monitoring model. Psilocybin-assisted therapy may require a larger service bundle, therapist credentialing, room capacity, and a clearer definition of what exactly is being reimbursed.