Eunomia perspective · 2026-07-30 · Compliance Programmes, Audits & Training
How Small and Mid-Sized Pharma Companies Can Build an Effective Compliance Risk Assessment Framework
Published by Eunomia Pharma Services · Updated
How do you build a practical pharma compliance risk assessment?
Begin with the company’s actual activities, markets and third parties. Describe what could go wrong, assess the exposure and existing controls, then prioritise gaps with named owners and completion dates. Review the assessment when activities or risks change. A useful risk register explains decisions and drives action; a score alone does not show that a risk is controlled.
A practical starting structure for your risk register
- Activity and exposure: record the process, country, stakeholders and a specific risk scenario.
- Existing controls and evidence: identify the control owner and evidence that the control operates in practice.
- Priority and response: explain the likelihood and impact assessment, remaining exposure and proposed action.
- Follow-up: assign an accountable owner, target date and a check to establish whether the action worked.
The practical steps above are Eunomia’s operational guidance. See the source notes below for the scope of the external references.
How do inherent risk, residual risk and a control gap differ?
Use these terms consistently before assigning scores. Otherwise, two teams can give the same activity different ratings simply because one assumes controls work and the other ignores them. The distinctions below are a suggested working method, not a prescribed scoring system.
| Assessment | Question to answer | Evidence to record |
|---|---|---|
| Inherent risk | What could happen before considering controls? | Activity, affected stakeholders, likelihood and potential impact. |
| Control effectiveness | Does the control operate as intended? | A recent sample, named owner and evidence of exceptions. |
| Residual risk | What exposure remains after the controls? | A reasoned rating and any uncertainty about the evidence. |
| Control gap | What needs to change? | Action, accountable owner, deadline and effectiveness check. |
How would this work for an HCP engagement?
Consider an illustrative engagement approved after the work has begun. The issue is not simply an incomplete form: the company may have committed to a service before checking its purpose, fee and approvals. Trace the request, agreement and payment through the process. Establish whether the problem was unclear ownership, a bypassed system step or a genuine emergency route. Agree a response that addresses the cause and test a later sample. A new procedure alone does not establish that the gap has closed.
Sources and scope
- Ministry of Justice: Bribery Act 2010 guidance
UK guidance on proportionate bribery-prevention procedures; it is not a universal healthcare compliance checklist.
External sources accessed 28 September 2026. Check the applicable country rules and current source text for a specific engagement.
