Reimbursement approval gets a medicine onto the Greek positive list. It does not get it into a public hospital. That last step runs through a separate machine entirely — centralised tendering by EKAPY, the National Central Health Procurement Authority, under Greek and EU public procurement law. Companies that treat the tender as an administrative afterthought routinely find themselves excluded on formal grounds, holding a valid marketing authorisation and no hospital orders.
Who buys, and under which rules
EKAPY acts as a central purchasing body, planning and running tenders for medicines, medical devices and consumables on behalf of Greece’s public hospitals. It was re-established in its current form as a private-law entity by Law 4865/2021, with a remit covering not only tendering but also receipt, storage and distribution of health products, monitoring of hospital consumption, and the operation of electronic registries and the national health procurement platform.
The procedural rulebook sits elsewhere. Public procurement in Greece is governed by Law 4412/2016, which transposed Directives 2014/24/EU and 2014/25/EU into a single act and has since been amended repeatedly, most recently by Law 5218/2025. Contracts are run through ESIDIS, the national electronic public procurement system; under Law 5218/2025 any contract above €30,000 must be conducted on the platform even where it falls below the EU publication thresholds. Above those thresholds, the notice also goes to the Official Journal of the European Union.
What a bid actually has to contain
The substance of a hospital tender bid is regulatory, not commercial. Typical failure points are unglamorous:
- A marketing authorisation that does not exactly match the pack, strength or presentation specified in the tender lot
- Missing or expired supporting certificates — GMP, GDP, ISO, batch release documentation, free-sale certificates for imported product
- Errors in the European Single Procurement Document and the accompanying declarations of exclusion grounds
- Guarantee letters of the wrong amount, form or duration
- Supply commitments the company cannot evidence, in a system that now tracks medicine circulation electronically
These are formal grounds. An otherwise competitive offer can be rejected on any one of them without the technical or price envelope ever being opened.
The price you bid is constrained before you bid it
Hospital supply in Greece operates against a regulated ceiling. The maximum hospital price is set by reference to the ex-factory price, reduced by 8.74% — and the ex-factory price itself is derived from external reference pricing, with reference products benchmarked on the average of the two lowest prices in the EU and generics priced at a discount to their reference product. Separately, EOPYY is entitled to negotiate prices or discount rates for products reimbursed directly or supplied to public hospitals.
The practical consequence: tender strategy, pricing dossier and negotiation position have to be built together. A discount conceded in one channel narrows the room available in the others, and in a system anchored to EU-wide reference prices, a Greek concession can travel.
What changed in 2026
The buying base has widened. Under Law 5302/2026, military healthcare units and NIMTS were brought into EKAPY’s framework, and since 1 July 2026 they have been able to submit electronic pharmaceutical orders through the EKAPY platform. Alongside the traceability upgrades introduced from late 2025, the direction of travel is clear: more volume flowing through one electronic channel, with tighter visibility over what is ordered, delivered and consumed.
For suppliers, that means fewer separate hospital relationships to manage — and far less tolerance for documentation that does not hold up.
How PQRA helps
We work on the join between regulatory status and commercial access. That includes reviewing tender specifications against your marketing authorisation and pack portfolio before you commit to a lot, assembling and quality-checking the regulatory documentation pack, aligning pricing and tender positions with reimbursement and negotiation strategy, and making sure GDP and traceability obligations on the supply side can actually be met once you win.
Talk to PQRA about your Greek hospital tender and market access strategy.
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