In July 2026, the Singapore Association of Pharmaceutical Industries (SAPI) revised its Code of Conduct (“SAPI Code”) to provide greater clarity on disguised promotions in clinical research and transparency.

The SAPI Code provides guidance for its member companies in the marketing and promotion of pharmaceutical products and serves as the basis for self-discipline in the pharmaceutical industry.

Article 9.2 of the SAPI Code previously stated that all human subject research must have a legitimate scientific purpose; and human subject research, including clinical trials and observational studies, must not be “disguised as promotion”.

The phrase “disguised as promotion” has been revised to “disguised promotion” to align with the language of Section 9.2 in the International Federation of Pharmaceutical Manufacturers Associations (IFPMA) Code of Practice 2019 (“IFPMA Code”). The IFPMA Code sets out a compliance framework for clinical research, fees for services and support for continuing medical education. Many local and regional associations, such as SAPI, rely on the IFPMA Code as guidance for their own codes of conduct.

The revision of the phrase also strengthens the interpretation of Article 9.2. It is now clearer that Article 9.2 aims to prevent human subject research from being disguised promotions.

The SAPI Code is an industry code and does not strictly have force of law (i.e., non-compliance with the SAPI Code is not in itself a breach of local regulations). The SAPI Code is only drafted for member companies’ compliance. Nonetheless, the SAPI Code presents a set of industry-accepted best practices in relation to the marketing and promotion of therapeutic products, including pharmaceutical companies’ interactions with healthcare professionals.

This is the second revision that SAPI has made to the SAPI Code this year. This shows that SAPI is actively looking into streamlining and improving the SAPI Code. SAPI members and industry players alike should closely monitor the evolving requirements to ensure that their conduct is in line with industry best practices.

Our previous client alert on the updates to the SAPI Code in March 2026 can be accessed here.

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