9 December 2025

The Belgian Competition Authority (BCA) announced today that it would start a thorough investigation of the commercial practices of IQVIA, a company which the BCA describes as “active in the supply (…) of technological solutions and data analysis to support pharmaceutical, biotechnology, and medical device companies in the development and commercialisation of their products” (see press release).

IQVIA stands accused of unspecified abusive behaviour in the sector of pharmaceutical data collection and processing. According to the BCA, this sector is in Belgium highly concentrated.

The investigation was prompted by a complaint and backed by an initial inquiry that allegedly pointed to “serious indications” of a possible infringement of Article 102 of the Treaty on the Functioning of the European Union and Article IV.2 of the Belgian Code of Economic Law.

It remains to be seen whether the BCA investigation will bear any resemblance to the procedure which the European Commission (Commission) conducted more than 20 years ago against IMS Health which, after its merger with Quintiles, morphed into IQVIA. The Commission’s case ended up before the Court of Justice of the European Union which established a first set of principles, later adapted and refined, regarding the application of the “essential facilities doctrine” in EU competition law.

The case concerned the refusal of IMS Health to license its “brick structure” – a method of organising regional sales data for pharmaceutical products through pharmacies – to competitors. The CJEU held that a refusal to license could give rise to an abuse of dominant position if the refusal is preventing the emergence of a new product for which there is potential demand from consumers. The CJEU added that the refusal should be unjustified and exclude any competition on a secondary market (case C-418/01, IMS Health, EU:C:2004:257, para. 38).

As the BCA points out, the pharmaceutical and broader healthcare sectors have been a priority area of competition enforcement for several years (see, Van Bael & Bellis, Belgian Antitrust Watch, 30 April 2025). For their part, pharmaceutical data draw antitrust scrutiny for various reasons and in several jurisdictions, including, most recently, in Spain where the Spanish competition authority opened an investigation against Sandoz, Alliance Healthcare, and Bluetab Solutions which allegedly exchanged sensitive commercial information of pharmacies, unbeknownst to the pharmacies at issue