Pharmaberater under § 75 AMG: what German law actually requires of pharma field sales

Everybody in German pharma says Pharmareferent. The law says Pharmaberater, and it treats Pharmareferent as one of several ways to qualify for the job. That difference sounds like pedantry until you are the person trying to move into field sales and someone tells you that you need a course you may not need at all.

This is the most widely held named role in German pharma, and the least understood one. I write this from 16 years recruiting in the industry, where the § 75 question came up in almost every conversation about a move into the Außendienst.

What the provision actually says

§ 75(1) AMG puts the obligation on the company. A pharmaceutical entrepreneur may only commission people who hold the expertise described in § 75(2) to visit members of the healing professions on a full-time basis in order to inform them professionally about medicinal products. Those people are the Pharmaberater.

Read that sentence slowly, because three things sit in it. The duty binds the employer rather than you. It covers visiting healthcare professionals as your main occupation. And the purpose is professional information about medicines, which is why the role carries statutory duties rather than only a sales target.

The three qualification routes

§ 75(2) lists them. First, pharmacists, and people who hold a certificate of completed university study in pharmacy, chemistry, biology, human medicine or veterinary medicine. Second, pharmacy assistants and people with completed training as a technical assistant in pharmacy, chemistry, biology, human medicine or veterinary medicine. Third, Pharmareferenten, meaning the examined qualification itself.

§ 75(3) adds a route that international candidates keep missing: the competent authority can recognise a foreign qualification as equivalent. If you trained as a pharmacist in Poland, a biologist in Spain or a veterinarian in Romania, that is the door, and the decision sits with the authority rather than with the recruiter reading your CV.

What follows from the list is the part that changes plans. A biology graduate does not need the Pharmareferent course. A PTA does not need it either. The examined Pharmareferent qualification exists for people who come from outside those fields, which in practice often means a commercial background, and for them it is the shortest legal route into the job. Chasing the certificate when your degree already qualifies you is time and money spent on nothing.

The duties in § 76, which candidates rarely read

Where you inform a healthcare professional about a specific medicine, you have to present the Fachinformation under § 11a. When a doctor or pharmacist tells you about side effects, contraindications or other risks connected to a medicine, you have to record that and pass it to the company you work for, in writing or electronically. And where you hand out samples on the company's behalf, records have to show who received what, in what quantity and when, and those records go to the authority on request.

The second duty is the one that matters in an interview. You are a reporting channel into pharmacovigilance, which is why the field force feeds the same system the Stufenplanbeauftragter is accountable for. A candidate who can describe how a report travelled from a practice visit into a case in the safety database sounds like someone who has done the job. Most candidates talk only about targets.

Where the confusion comes from

Job ads use Pharmareferent, Pharmaberater, Außendienstmitarbeiter, Sales Representative, Medical Sales and Key Account Manager for work that all sits inside the same provision. The legal test does not care about the title on the contract. It cares whether your main job is visiting healthcare professionals to inform them about medicines.

Two consequences. If your degree qualifies you, apply for the roles even when the ad asks for a Pharmareferent certificate, and say in the first paragraph of your application which route in § 75(2) you meet. And if you sit in an adjacent commercial role and want to move into the field, the examined qualification is a real, well-defined path rather than a vague upskilling project. I have described how these commercial moves are read in the guides on pharma field roles and career changes into pharma sales.

What the market looks like

Field forces have been reshaped for years by tighter access to physicians, hospital purchasing groups and digital channels, so the numbers move and I am not going to quote a headcount trend I cannot verify. What I can describe is what hiring managers ask for. Specialty care asks for scientific depth, which is where degree holders win. Primary care asks for territory management and consistency. Hospital-facing roles ask for tender and formulary literacy. Rare disease asks for the ability to hold a conversation with a specialist who knows more than you about the disease and less than you about the product.

What a CV has to evidence for this role

Name your § 75(2) route in the first third of the CV, literally. Then show the substance: therapy areas, customer types, territory size, whether you carried a target and how it was built, launch experience, whether you worked with a Medical Science Liaison and how you split the scientific conversation. If you have handled adverse event reports from the field, write it down, because it separates you from candidates who describe the job as pure sales. German applicant tracking systems match on the literal words Pharmaberater and Pharmareferent, so both belong in the document; the mechanics are in my guide on the ATS in pharma.

A note on salary

I will not quote a band. Field pay splits into base and variable, and the split moves with therapy area, seniority, territory and how the bonus is constructed. Two people with the same title can be far apart because one carries a launch in specialty care and the other a mature primary care portfolio. Ask about the base to bonus ratio, the target mechanics, the territory, and the car policy before you compare offers, because those four decide the number more than the headline base does.

Frequently asked questions

Do you need the Pharmareferent qualification to work in pharma field sales in Germany?

Only if you do not already meet one of the other routes in § 75(2) AMG. A university degree in pharmacy, chemistry, biology, human or veterinary medicine qualifies, as does a completed training as a pharmacy assistant or as a technical assistant in those fields. The examined Pharmareferent qualification is the route for people who come from outside those disciplines.

What is the difference between Pharmaberater and Pharmareferent?

Pharmaberater is the term the AMG uses for the role: the person a company sends to inform healthcare professionals about medicines. Pharmareferent is one of the qualifications that allows you to hold that role, and it is also the word the market uses for the job itself. The legal duties attach to the role, whichever qualification got you there.

Can a foreign degree be recognised?

Yes. § 75(3) AMG allows the competent authority to treat an equivalent qualification obtained abroad as sufficient. The assessment sits with the authority, so clarify it before an employer has to decide whether to take the risk on your file.

What duties does the law attach to the role?

Under § 76 AMG you present the Fachinformation under § 11a when informing about a specific medicine, you record reports about side effects, contraindications or other risks that reach you and pass them to your employer in writing or electronically, and where you distribute samples on the company's behalf, records of recipients, type, extent and time have to be kept and shown to the authority on request.

Sources

§ 75 AMG, expertise of the Pharmaberater (gesetze-im-internet.de, German)
§ 76 AMG, duties of the Pharmaberater (gesetze-im-internet.de, German)
§ 11a AMG, Fachinformation (gesetze-im-internet.de, German)

© 28 July 2026 Andreas Schulz. All rights reserved. This article is career guidance, not legal advice; the statutory text prevails.