Phase 02 · SCALE

DTx Operations Partner wherever reimbursement is statutorily defined.

Further indications, further markets with DiGA-adjacent reimbursement systems – on the same platform foundation. As in Build: DUX operates your DTx as your DTx Operations Partner, with predictable monthly cost per market instead of a flat licence.

1 role

DTx Operations Partner – in Build and in Scale. One cost structure for development and ongoing operations, no cost break when moving into additional markets.

EU+ markets

Scale scope: DE (DiGA), FR (PECAN), BE (mHealthBelgium M3), UK (NICE ESF/DTAC), US (FDA SaMD + Commercial/Medicare/VA/Employer), CH (MepV + KVG/private), others in preparation. All structured regulated markets – no pan-national pathway exists, each market stands on its own.

80+ modules

reusable per indication and per market. Every new DTx starts on the audited substrate.

0 re-audits

of platform compliance per new indication. BSI TR-03185 process-level evidence applies platform-wide. TR-03161 runs per DiGA – audits happen there per product.

Why Scale

Your DTx runs in every structured regulated market – with DUX as operator.

A DTx manufacturer listed in Germany has answered two questions in one – this is the German specificity: The BfArM decision under § 139e SGB V combines regulatory eligibility assessment and entry into statutory health insurance reimbursement in one decision for about 73 million statutorily insured individuals. Other countries are building comparable structures: France with PECAN, Belgium with mHealthBelgium M3, the UK with NICE ESF + DTAC. Add to that established non-EU regimes with their own regulatory pathways: US (FDA SaMD), Switzerland (MepV + CH-REP + Swissmedic).

In all of these markets your DTx remains yours; DUX takes over operations, regulatory work and market interface – as your DTx Operations Partner, as in Build. The cost structure stays the same: predictable monthly cost instead of a flat licence per market. No cost or process break when transitioning from Build to Scale.

What distinguishes Scale from Go Beyond. In emerging markets without statutory DTx reimbursement and often still-immature digital health regulation – LATAM, SEA, MENA, Sub-Saharan Africa – there is no structural way to feed the DTx as an ongoing subscription into the national healthcare system. There, DUX takes over national re-implementation, approval and ongoing operations as your DTx Distributor – analogous to a pharma distributor, compensated via revenue share. That’s the domain of Go Beyond. Scale is for structured regulated markets – whether with DiGA-adjacent statutory reimbursement (DE, FR, BE, UK), with their own national reimbursement pathways (CH), or with an established regulatory regime and diverse payer structures (US: Commercial, Medicare Advantage, VA, Employer).

CE marking under MDR is portable EU-wide. Switzerland runs separately under MepV (CH-REP, Swissmedic) on a CE basis. The UK accepts CE-marked medical devices until 30.06.2030. The US runs via its own FDA pathways (510(k), De Novo, PMA depending on risk class, 21 CFR 820). Reimbursement remains national and structurally heterogeneous – but the platform carries the reusable components: DiGA evidence, BSI TR-03161 security posture and the MDR file are materially reusable in PECAN and mHealthBelgium M2/M3; for FDA SaMD the MDR file forms the substantive basis from which the FDA-specific documentation is drawn.

Regulatory landscape

Europe 2026 – three tiers, ten markets.

Market access for DTx in Europe in 2026 breaks down into three tiers: Tier 1 with statutorily regulated DTx reimbursement (DE, FR, BE), Tier 2 with an independent regulatory framework and diverse reimbursement structures (US, UK, CH, AT, IT), Tier 3 fragmented or without a specific DTx pathway. This structure carries the sequencing of any market expansion.
  1. Europe tiers – market reality per country

    CE marking under MDR is the universal regulatory precondition. Reimbursement isn't. The three tiers separate what has a statutory reimbursement path (Tier 1), what offers assurance and partial reimbursement (Tier 2), and where markets run through regional or private pathways (Tier 3).

    Tier 1 · Reimbursement statutory & scaled

    Germany (DiGA) – § 33a and § 139e SGB V, DiGAV. The only statutory, nationwide, single-decision DTx reimbursement in Europe. From 01.01.2026 at least 20% of the negotiated reimbursement price is tied to AbEM outcome parameters.

    France (PECAN + LPPR numérique) – Prise en Charge Anticipée Numérique, operational since 2023. HAS/CNEDiMTS assessment, CEPS price negotiation. Early reimbursement for up to 12 months, followed by permanent listing via LPPR numérique. Smaller than DiGA, structurally very similar.

    Belgium (mHealthBelgium M3 + INAMI/RIZIV) – Three-tier pyramid (M1 CE, M2 interoperability/security, M3 socio-economic value). M3 reimbursement via indication-specific INAMI/RIZIV decisions – no unified national listing mechanism.

    Tier 2 · Structured-different · framework in place, reimbursement varies

    UK – NICE ESF (Evidence Standards Framework) plus NHS England DTAC. Assessment and assurance in place, national reimbursement fragmented – procurement via Integrated Care Systems (ICS) and individual Trusts. CE-marked medical devices are accepted via MHRA-recognised routes until 30.06.2030.

    US (FDA SaMD) – Independent regulatory pathway via 510(k) clearance, De Novo or PMA depending on risk class, flanked by Quality System Regulation (21 CFR 820). Reimbursement via Commercial Payers, Medicare / Medicare Advantage, Veterans Health Administration (VA) or directly via Employer – broad payer diversity rather than a single statutorily regulated pathway. Largest DTx market worldwide.

    Switzerland – Swiss MepV (since 26.05.2021). Swissmedic as competent authority. CH-REP (Swiss authorised representative) and registration mandatory. Reimbursement via KVG tariff positions, private/complementary insurance or cantonal/hospital procurement. Switzerland is not MDR-native; it accepts CE as the technical basis, with MepV applying on the regulatory side.

    Austria – No statutory DiGA-style pathway in force in 2026. EU MDR applies (BASG). Reimbursement via individual-case decisions by the social insurance carriers or private supplementary insurance.

    Italy – EU MDR regulation. National health service (SSN) plus 20 regions with substantial autonomy. Some regions (Lombardia, Emilia-Romagna, Veneto) have reimbursed digital therapy products regionally; no national DTx list.

    Tier 3 · Fragmented or without a DTx pathway

    Netherlands · Spain · Poland · Nordic countries – MDR regulation applies, specific digital-therapy reimbursement pathways do not exist or exist only in pilot form. Access runs via individual negotiations with health insurers, private coverage or selective health-insurer cooperation. Market entry is possible but doesn’t scale today.

What scales

Three levels of expansion – the same architecture.

  1. Level 1 · Additional indications

    A second DTx for a second indication builds on the same 80+ modules. What changes: intended purpose, clinical content, evidence strategy. What stays the same: architecture, cybersecurity, data protection review criteria, QMS.
  2. Level 2 · Additional markets

    Austria and other EU countries on the same MDR basis – CE conformity applies EU-wide. Switzerland separately under Swiss MepV (CH-REP, Swissmedic) on a CE basis. Market-specific localisation: language, terminology, medical guidelines, country-specific market access and reimbursement pathways (DE: DiGA · FR: PECAN · BE: mHealthBelgium – others in preparation). No new development – configuration.
  3. Level 3 · Operational running

    Portfolio management across all indications and markets: release coordination, compliance updates on regulatory change, post-market surveillance, incident response – one process instead of n parallel QMS.
Platform · certified onceBSI TR-03185 · ISO 13485 · ISO 27001 · MDR pipeline · BfArM Data Protection Criteria

What gets shared

The compliance infrastructure that isn’t rebuilt per product.

The core promise isn’t code reuse – many claim that. It’s reuse of the certified compliance. Every new indication, every new market benefits from work that was audited once and doesn’t need to be rebuilt per product.

Platform compliance (audited once)

BSI TR-03185 process-level evidence (DUX: first audit) · ISO 13485 QMS (certified, TÜV Hessen) · ISO 27001 ISMS (audited under TR-03185, separate cert to follow) · MDR-compliant documentation pipeline · GDPR framework · BfArM Data Protection Criteria

Technical base (reusable per indication)

Modular architecture · FHIR interfaces · health data integration · release management · monitoring & incident response

Internationalisation

Multilingual support · country-specific regulatory layer · medical terminology per market · interface layer for country-specific market-access and reimbursement pathways (DE: DiGA · FR: PECAN · BE: mHealthBelgium – others in preparation)

Portfolio operations

Central release board (process-side established) · compliance updates cross-portfolio · post-market surveillance · pharmacovigilance interface prepared · vendor audit management

Per-DiGA evidence (repeated per product)

BSI TR-03161 cybersecurity evidence · clinical evaluation per indication · market-specific CE marking (Class I: Declaration of Conformity; Class IIa: with Notified Body)

Continuous compliance

Upcoming DiGAV amendments · BfArM review-criteria updates · BSI TR revisions · MDR amendments – rolled out platform-wide, not per product

The math

One market, two markets, three indications – the cost curve.

Traditionelle EntwicklungmHealth Suite
Second indication (time to CE mark)another 9–18 monthsweeks – same platform, new configuration (clinical evaluation + Notified Body for Class IIa still needed)
Second indication (development cost)bespoke, noticeably higher than platform reusesubstantially reduced – modules are certified
Austria expansion (EU MDR)new infrastructure, new regulatory build-upCE marking applies, market-specific localisation
Switzerland expansion (MepV)new approval route, own infrastructureCE basis recognised, CH-REP + Swissmedic in addition
BSI TR-03185 per further indicationprocess audit would be per product – doesn't exist that wayapplies platform-wide – audited once
Operational running across portfolioparallel QMS per productone QMS for all indications
Regulatory changes (upcoming DiGAV amendments)caught up per productrolled out platform-wide once

Who you are

Two ways into SCALE.

Multi-market operations · DTx Operations Partner

Your DiGA is listed. Next come further countries with statutory reimbursement.

You have conquered the German market and face the question of how to open France (PECAN), Belgium (mHealthBelgium M3), UK (NICE ESF + DTAC), Austria, Italy and Switzerland without rebuilding the regulatory infrastructure per country. We localise your product: language, terminology, country-specific market-access and reimbursement pathways. CE marking under MDR applies EU-wide; Switzerland runs separately under Swiss MepV (CH-REP, Swissmedic) on a CE basis. DUX continues to operate the product per market as your DTx Operations Partner – as in Build, with predictable monthly cost per market instead of a flat licence.

Portfolio expansion · DTx Operations Partner

One indication worked. The second shouldn’t take 18 months.

Your first DTx is listed, reimbursement runs, the evidence base grows. Now the second indication should follow – ideally without going through the regulatory starting phase again. We configure a new intended purpose from the 80+ modules of your existing platform environment. BSI TR-03185 process-level evidence applies platform-wide, QMS applies. What is new: clinical evaluation, product-specific TR-03161 evidence and – for Class IIa – Notified Body review. DUX operates the second DTx as your DTx Operations Partner with predictable monthly cost per product; the portfolio structure is negotiable.

Next step

Your portfolio plan. Our cost assessment. Thirty minutes.

Tell us where you stand today – one DTx listed, two in planning, EU expansion on the boardroom agenda. We’ll run the numbers on what Build vs. Scale means and where the platform makes the difference.
Book a call with Christoph