UCMPMD Amendment 2026: Relaxation on Extension of Travel and Hospitality to HCPs and Other Key Changes

The Department of Pharmaceuticals has issued Circular No. 1 of 2026 (“UCMPMD 2026”), amending the Uniform Code for Marketing Practices in Medical Devices, 2024 (“UCMPMD 2024”).

1. Foreign Training Regime Liberalised

The most significant change introduced via UCMPMD 2026 relates to foreign training. Under UCMPMD 2024, the position was restrictive and approval driven. Conduct of training in foreign locations was prohibited, save for narrowly defined “exceptional circumstances” (i.e., where requisite trainers or equipment were unavailable in India). Even in such cases, companies were required to submit detailed information, including justification, participant details, duration, venue, trainer credentials and estimated expenditure to the Department of Pharmaceuticals (“DoP”) at least three months in advance, and could proceed only upon specific approval. In practice, approvals were difficult to obtain. UCMPMD 2026 fundamentally alters this framework:

i. The express prohibition on foreign training has been removed and replaced with a softer standard (“should generally be avoided”).

ii. The prior approval regime has been eliminated entirely- the circular expressly clarifies that no approval from DoP or any authority is required.

iii. The earlier three-month pre-approval requirement for overseas clinical trainings has been substituted with a one-month prior disclosure to the relevant industry association, which will place the information in the public domain.

iv. Compliance responsibility is squarely shifted to the company, with enforcement routed through the existing complaint and penalty framework (Sections 12 and 13).

The regime moves from a pre-approval model to a disclosure-based, self-regulatory framework.

2. Travel and Hospitality

Under UCMPMD 2024, clauses 8.2 (travel) and 8.3 (hospitality) prohibited extension of travel and hospitality benefits to HCPs, subject to a limited exception where the HCP was a speaker or training participant and the underlying training had received DoP approval under clause 6.2. The 2026 amendment removes this entirely:

i. References to DoP approval have been deleted from both clauses. 

ii. The exception is now self-contained; that is, travel and hospitality may be extended only where the HCP is:

a) a speaker at a CME/CPD programme; or

b) a participant in a training programme.

3. Alignment with NMC Regulations

UCMPMD 2026 expressly provides that, where any aspect is not covered under the Code, the National Medical Commission (Registered Medical Practitioner Professional Conduct) Regulations, 2023 will prevail on the said aspect.  2 earlier reference to the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002 (“IMC Regulations”) to the NMC Registered Medical Practitioner (Professional Conduct) Regulations, 2023 (“NMC Regulations”). The NMC Regulations, notified in 2023 under the National Medical Commission Act, 2020, represent a materially stricter framework, starting from specifying who can conduct CPD events to obtaining approval to conduct the CPD events, including credits to RMPs for attending CPD events, as opposed to the IMC Regulations that did not define what is entailed by CME/CPD events.

4. What this means for Medtech businesses?

Medtech companies can now plan overseas training without regulatory lead time or approval risk. However, this also means that every overseas training programme a company runs will be publicly disclosed through the Industry Association, visible to competitors, journalists, NGOs, and regulators simultaneously.

There is also an absence of clarity on the scope of what must be disclosed. UCMPMD 2026 requires companies to share details of training, justification, participant details and estimated expenditure with their Industry Association, using the word “etc.” which leaves the precise scope open. In particular, it is not clear whether the names of individual participating HCPs must be disclosed, which raises legitimate concerns around confidentiality and the risk of disclosing customer engagements and activities to competitors through a public filing. In our view, companies may reasonably take the position that disclosure of aggregate participant numbers, rather than named individuals, should satisfy the intent of the provision.

It is relevant to note that conducting domestic CME/CPD events never required DoP approval, and the removal of the approval cross-reference from clauses 8.2 and 8.3 is a consequential edit flowing from the policy change in clause 6.2(i) that applies to advanced clinical training in foreign locations. The more significant point to be noted is in the context of clauses 8.2 and 8.3, which permit extension of travel and hospitality to HCPs who are participants in a training programme, without distinguishing between domestic and foreign contexts.

Companies would be prudent in drawing a clear distinction between CME/CPD events and “Training programmes”, as these are separate and distinct categories of HCP engagement under the applicable laws. CME and CPD are both referenced terms under the NMC Regulations and attract, among other requirements, a cap on the speaker-to-participant ratio of 1:10 under the UCMPMD framework. “Training programme”, by contrast, is not a defined term under the NMC Regulations and accordingly does not attract the same regulatory governance as is attracted for CPD events under the NMC Regulations. This distinction is particularly significant for the medical devices industry, where a substantial portion of HCP engagement is directed at product familiarisation, device handling and skill-based training, which are activities that are more accurately closer to being described as a “training programme” than a CME or CPD programme. Critically, it is also the precise category that enables the travel and hospitality exception under clauses 8.2 and 8.3, which DoP might have intended to relax in order to meet the product and skill-based training needs of the industry. However, the requirement to share the details of such “Trainings” similar to CME /CPDs on company website continues under UCMPMD 2026, keeping it open to scrutiny.

A separate question arises in relation to product demonstrations. UCMPMD 2026 permits foreign demonstrations by experts where the relevant equipment or experts are unavailable in India, without requiring prior approval. However, there is no express clarity on whether travel and hospitality may be extended to HCPs attending a product demonstration in a domestic context, since a product demonstration does not squarely fall within the description of a CME, CPD, or training programme. In order to take benefit of the relaxation on travel and hospitality for training purposes, companies will have to choose between categorising demonstration programmes as training and disclosing details of such demonstration programmes on their website, or operating under the old position where demonstration programmes were considered to be outside the ambit of UCMPMD and therefore no demonstration programmes were required to be disclosed on the website.