Hungarian Competition Authority launches two competition proceedings in the OTC pharmaceutical market

On 12 February 2026, the Hungarian Competition Authority (GVH) announced the launch of two separate competition supervision proceedings in the over-the-counter (OTC) pharmaceutical market (Case Nos. VJ/4/2026 and VJ/5/2026). The GVH suspects that anti-competitive conduct and potential abuse of dominance by certain market participants may be contributing to high OTC medicine prices in Hungary.

This development follows the GVH’s ongoing investigation into pharmaceutical wholesalers, announced in September 2025, which examined whether wholesalers had established pharmacy cooperation systems that may restrict competition in the pharmaceutical procurement market.

1. The two proceedings

1.1 Proceeding 1: Pharmacy shelf layout practices (VJ/4/2026)

The GVH is investigating the pharmacy shelf layout practices established by a leading pharmaceutical wholesaler and pharmacies belonging to a major pharmacy chain operator within the same corporate group, as well as incentive schemes designed to ensure compliance with these shelf layouts.

The investigation focuses on the OTC systemic painkiller market and involves three major pharmaceutical companies.

The GVH suspects that these market participants may be engaging in anti-competitive conduct by excluding OTC systemic painkillers offered by other manufacturers – potentially at more favourable prices and with the same active ingredients – from pharmacy sales. According to the GVH, pharmacy shelf layout requirements may reduce market competition, which could lead to higher prices for consumers.

1.2 Proceeding 2: Abuse of dominant position (VJ/5/2026)

In a separate proceeding, the GVH is examining whether the same wholesaler and pharmacy chain operator hold a dominant market position in certain localities where their affiliated pharmacies are the sole providers. According to the GVH, this may affect more than 100 settlements across Hungary.

The GVH’s publication suggests that the wholesaler and pharmacy chain operator largely determine many aspects of their affiliated pharmacies’ operations, including procurement, promotions and branding. As a result, other pharmaceutical wholesalers may be excluded from these local markets. The potential abuse of dominance by these market participants could likewise result in higher prices for consumers.

2. Market context

According to data from the Hungarian Central Statistical Office, OTC medicine prices in Hungary increased significantly between 2020 and 2025. For certain popular products – including cold medicines, nasal sprays and painkillers – price increases reached 40–50%.

To counteract these significant price increases, the government and industry stakeholders agreed to introduce voluntary price and margin restrictions on 34 high-turnover OTC products, effective from July 2025. The GVH welcomed this voluntary price restraint initiative.

3. Key considerations for market participants

Compliance review: Pharmaceutical wholesalers, pharmacy chains and manufacturers operating in the OTC market should review their commercial arrangements to ensure compliance with Hungarian and EU competition law. This includes:

• examining shelf layout agreements and product placement arrangements for potential exclusionary effects;
• assessing whether local market positions may constitute dominance under competition law; and
• reviewing vertical agreements with distributors and retailers for potential anti-competitive clauses.

Broader industry impact: While the proceedings target specific companies, the GVH’s focus on pharmacy shelf layouts and local market dominance signals increased scrutiny of commercial practices throughout the OTC pharmaceutical supply chain.

4. What’s next

The initiation of these competition supervision proceedings does not constitute a finding that the companies concerned have committed any infringement. The proceedings are aimed at clarifying the facts and, where applicable, proving the suspected infringements.

The statutory deadline for completing each proceeding is six months, which may be extended twice, each time by up to six months if justified.

Companies operating in the Hungarian OTC pharmaceutical market should also monitor official statements from the GVH for further developments.

For legal advice on competition compliance and commercial arrangements in the Hungarian pharmaceutical sector, please contact our Life Sciences & Healthcare and Competition teams.