The medical science liaison (MSL) role used to map cleanly onto a sponsor's commercial geography: where the brand sold, the MSLs lived. That alignment is breaking. Trial geography has moved, key opinion leaders are distributed across academic medical centers in dozens of countries, and the scientific-credential bench in Europe, Brazil, Japan and the Gulf is now deep enough that medical affairs teams routinely look offshore for the next hire. The Medical Affairs Professional Society tracks the field's expansion in its annual MSL benchmarking work; the through-line is unambiguous: MSL teams are bigger, more international, and more therapeutically specialized than five years ago.
This guide is for medical affairs leaders trying to hire MSLs in countries where they have no entity. It covers where the talent is concentrating, what the scientific-credential rules look like across borders, where an Employer of Record (EOR) cleanly fits, and the country-specific compliance overlays (German AMG rules, France's loi anti-cadeaux, Italian transparency, the EFPIA HCP Code) that an EOR cannot make go away.
It is a spoke of our hub on why medical companies use EOR. Read that first if you need the broader frame.
Why MSL hiring no longer lines up with commercial HQ geography
Three structural shifts pulled MSL hiring off the commercial-HQ map.
Trial geography moved. Industry-sponsored clinical trial activity has rebalanced away from a US/China duopoly. The FDA's 2024 Drug Trials Snapshots show pivotal trials enrolling participants across an increasingly long list of jurisdictions, and CRO disclosures back this up. Parexel highlights its India operations as a strategic hub, and IQVIA's annual report describes a global delivery footprint that is no longer concentrated in any single region. MSLs are field-based scientific peers to investigators; when investigators move, MSL coverage has to follow.
KOL networks are denser outside the US. For oncology, neurology, immunology, rare disease and cell-and-gene therapy, the publishing centers of gravity sit at academic medical centers in the EU, UK, Japan, Brazil and increasingly the Gulf. A single therapeutic-area MSL bench that is 80% US-based cannot service that KOL distribution.
The talent supply is genuinely international. PharmD, PhD and MD pipelines in Spain, Portugal, Poland, Germany, Italy, Brazil, Japan and South Korea routinely produce candidates with the scientific depth and English fluency MSL roles require. Pharma annual reports increasingly disclose medical-affairs hiring outside core HQ markets; see Roche's annual report and Novartis's annual report for examples of distributed medical-affairs structures.
The result: medical affairs hiring plans now routinely include three to seven countries the company has no entity in. That is the problem an EOR exists to solve, with caveats below.
The scientific-qualification problem: PharmD, PhD, MD across countries
MSL credential expectations vary by sponsor, therapeutic area and country, and they do not transfer the way licensure does for treating clinicians.
- United States. Most large sponsors require a terminal degree (PharmD, PhD, MD, or DNP) for MSL roles. The Medical Affairs Professional Society describes this as the dominant pattern.
- United Kingdom and Ireland. PhD or MD common; PharmD is rarer in the local pipeline because UK pharmacy education is a four-year MPharm rather than a US-style PharmD, per the General Pharmaceutical Council.
- Continental Europe (Germany, France, Italy, Spain, Netherlands). PhD-led, with MD candidates common in oncology and rare disease. Local pharmacy degrees (Approbation in Germany, Diplôme d'État de Docteur en Pharmacie in France) qualify for many MSL roles even without a US PharmD equivalence.
- Japan. Domestic pharma typically hires MSLs with a Japanese pharmacist license or a PhD; the Japan Pharmaceutical Manufacturers Association frames MSL responsibilities under its industry code.
- Brazil and LATAM. MD- and pharmacist-led, with growing PhD representation. The Conselho Federal de Farmáciaregulates pharmacy practice; MSL work itself is not licensure-restricted.
The crucial point for hiring leaders: an MSL's value is scientific credibility with investigators and KOLs in their territory, not a transferable license. A German pharmacist-MSL covering DACH does not need US licensure; a Brazilian MD-MSL covering LATAM does not need EMA recognition. Hire to the territory, not to a global credential template.
Where MSL hiring is concentrating
A non-exhaustive map of where international MSL hiring volume is most visible in 2025 to 2026.
The US still represents the largest single MSL employer base. The shift is not American-MSL roles disappearing; it is that the next role for many medical affairs teams is not in the US.
Licensure and HCP-interaction rules by country
This is where MSL hiring diverges from CRA or biostatistics hiring. Most countries do not regulate "MSL" as a profession. They regulate two adjacent things:
- The MSL's own underlying credential (pharmacist, physician), if they hold one and use a regulated title locally.
- The interaction between industry-employed scientific staff and healthcare professionals (HCPs).
The second category is where employers get caught. Practice licensure is a personal matter; an MSL who is a French pharmacist needs to keep their Ordre des Pharmaciens registration in good standing whether they are MSL-ing or not. HCP-interaction rules are the employer's problem.
Headline examples:
- Germany. The Arzneimittelgesetz (AMG) §§ 8 to 13 and the Heilmittelwerbegesetz (HWG) constrain how industry communicates about medicinal products, including in 1:1 scientific exchange. The line between scientific exchange and promotion is enforced strictly; misclassifying a launch-window MSL interaction as non-promotional carries real exposure under HWG advertising rules.
- France. The loi anti-cadeaux (Articles L.1453-3 et seq. of the Public Health Code) restricts industry benefits to HCPs, with Sunshine-style transparency reporting. MSL travel, advisory-board honoraria and meals all fall inside its perimeter.
- Italy. Industry-HCP transfers of value reporting is governed by Legge 62/2022 ("Sunshine Act"), with public registry obligations.
- United Kingdom. The ABPI Code of Practice governs scientific exchange, transparency and what constitutes promotion. MSL teams operate inside it whether the sponsor is a member of ABPI or not.
- EU-wide. The EFPIA HCP/HCO Code sets the minimum baseline above which national associations layer.
- United States. PhRMA Code on Interactions with Healthcare Professionals plus the federal Open Payments / Sunshine Act reporting regime.
- Japan. JPMA Code of Practice and JPMA Transparency Guideline set MSL-relevant standards; the PMDA regulates promotional materials.
- Global. The IFPMA Code of Practice is the umbrella ethical framework most multinational sponsors map their SOPs to.
Whether MSL activity counts as "promotion" under each of these codes is the unresolved question that drives most medical-affairs compliance work. The honest answer: it depends on the interaction, the document, and the regulator. EFPIA, ABPI and JPMA all distinguish legitimate scientific exchange from promotion, but the line is fact-specific. Sponsors that ignore the line discover it during audits.
EOR, local entity, or contractor: when each works
The structural choice is identical to other regulated medical hires (covered in the hub article), but the MSL-specific weighting differs.
Employer of Record fits when:
- The hire is a single-country MSL or a small (1 to 4 person) regional team.
- The MSL holds their own underlying credential and the employer is not relying on a clinical license to authorize the work.
- The sponsor needs the hire live inside weeks, not the three-to-nine-month entity-setup window.
- The sponsor wants to test whether a country justifies a permanent footprint before committing to entity overhead.
A local entity fits when:
- The MSL team in the country will exceed roughly 10 to 20 people.
- The sponsor also needs a local marketing-authorization holder, a local pharmacovigilance qualified person, or a local distributor relationship that an EOR cannot hold.
- The country has interaction-transparency reporting that the sponsor wants to file under its own legal name rather than via a third-party employer.
Contractor / 1099 almost never fits. MSL work is closely directed by the sponsor's medical affairs leadership, follows sponsor SOPs, uses sponsor-controlled scientific materials and is often integrated into the sponsor's CRM and HCP-interaction reporting. That is the textbook profile of misclassification under the US Department of Labor economic-realities test and analogous European tests. We cover the category broadly in the healthcare contractor-misclassification problem.
A practical decision shortcut: if you are about to hire your first MSL in a country where the sponsor has no entity, EOR is almost always the right starting move. Graduate to an entity if and when the team scales.
Compliance overlay an EOR does not absolve
This is the honest-limits section. An EOR takes on the legal-employer role: contracts, payroll, statutory benefits, terminations, work permits. It does not absolve the sponsor of any of the following:
- MSL-as-promotion classification. Under German AMG and HWG, French Public Health Code, Italian Sunshine Act, ABPI Code and EFPIA Code, the question of whether a specific MSL interaction is scientific exchange or promotion is a sponsor-medical-affairs determination. The EOR is not a party to it.
- Transparency reporting obligations. Open Payments (US), French transparence santé, Italian Sunshine Act, JPMA Transparency Guideline reporting all sit with the sponsor, not the legal employer. An MSL employed via an EOR still triggers sponsor reporting obligations on transfers of value to HCPs in their territory.
- Off-label communication risk. Codes across all major jurisdictions prohibit unsolicited off-label promotion; what an MSL says in a 1:1 KOL meeting is the sponsor's risk regardless of who issues the paycheck.
- Local pharmacovigilance touchpoints. If an MSL hears of an adverse event from an HCP, the sponsor's PV system must capture it inside the regulator's reporting clock. EU GVP Module VI timelines do not pause because the employer is an EOR.
- Underlying professional registration. If the MSL is a registered pharmacist or physician using their title locally, the regulator that issued the license sets the rules. The EOR cannot vouch for or maintain that registration.
- Industry-association membership obligations. ABPI, EFPIA, JPMA and PhRMA membership commitments bind the sponsor, not the EOR.
A defensible MSL hire via EOR therefore requires: (1) a clear sponsor-side SOP for scientific exchange vs promotion in the target country, (2) a sponsor-side transparency-reporting workflow, (3) a sponsor-side PV intake path, and (4) clarity on whether the MSL's underlying credential is in scope. Without those, the cleanest EOR contract in the world will not save the sponsor from a code-of-practice complaint.
What a defensible MSL EOR engagement looks like
Five things separate medical affairs teams that hire MSLs internationally well from those that hit avoidable compliance walls.
- Country-specific scope-of-role definition. Document, per country, what the MSL will and will not do. "Scientific exchange with HCPs, no promotional materials, no comparative claims, no off-label discussion outside unsolicited request" is a starting baseline; each country code may require more.
- Owned-entity EOR coverage in the target country. Aggregator EOR models can introduce a second legal employer between the sponsor and the MSL, which complicates SOP enforcement and PV intake. Borderless AI operates on owned entities across 170+ countries; that structure simplifies the chain.
- Sponsor-controlled SOPs, training and CRM. The MSL's training records, slide decks and CRM activity must remain inside the sponsor's compliance perimeter. This is sponsor-side work the EOR cannot do.
- Transparency-reporting integration. Pull MSL-driven transfers of value into the sponsor's reporting workflow from day one. Catching them in arrears is painful.
Capital efficiency for clinical-stage sponsors. EORs that require pre-funding monthly payroll sit awkwardly against biotech runway constraints. Invoice-in-arrears models keep working capital available; see our companion piece on EOR for biotech startups.
FAQs
Can an EOR hire an MSL internationally?
Yes, in most cases. An EOR can legally employ an MSL in a country where the sponsor has no entity, handle local payroll, contracts and statutory benefits, and keep employment compliant under local labor law. The EOR does not make the sponsor's medical-affairs compliance obligations (promotion-vs-exchange classification, transparency reporting, PV intake) go away.
Do MSLs need a clinical license?
Usually no. MSL work itself is not a licensed clinical activity in most countries. Many MSLs hold a PharmD, PhD or MD, but they are doing scientific exchange, not treating patients. If the MSL is a registered pharmacist or physician using their title locally, the underlying registration must remain in good standing under the rules of the issuing regulator.
Is MSL activity considered promotion under EFPIA, ABPI, PhRMA or JPMA codes?
The codes distinguish legitimate scientific exchange from promotion, but the line is fact-specific. Unsolicited discussion of approved indications using sponsor-approved materials is scientific exchange in most regimes. Comparative claims, unsolicited off-label discussion and overtly persuasive framing tend to cross into promotion. The classification is a sponsor-side determination.
Where are medical affairs teams hiring MSLs internationally most often?
Common 2025 to 2026 destinations include Germany, the UK, Spain, Italy, the Netherlands, Poland, Switzerland, Japan, South Korea, the UAE, Saudi Arabia, Brazil and Mexico. The exact mix depends on therapeutic area and where the sponsor's KOLs and trial sites sit.
Can MSLs work fully remotely?
Field-based MSL roles include territory travel to meet KOLs, attend congresses and visit investigator sites. The "remote" framing is real in the sense that there is no office headquarters reporting line, but most MSL roles still involve substantial in-territory travel.
What does an EOR not do for MSL hiring?
An EOR does not make sponsor-side compliance go away: promotion-vs-exchange classification, transparency reporting, off-label risk, pharmacovigilance intake, professional-registration upkeep and industry-code obligations all remain with the sponsor. The EOR's role is the legal-employer relationship.
Further reading
- Why Medical Companies are Turning to Employer of Record services
- How to Hire Clinical Research Associates Globally
- How Medical Device Companies are Staffing Rollouts
- EOR for Biotech Startups on Tight Runway
- Global Hiring for Digital-Health and Telemedicine Companies
- How Tech Companies Are Turning to Employer of Record Services
Where this leaves medical affairs leaders
MSL hiring is going where the KOLs, trial sites and scientific talent already live, which is increasingly outside the sponsor's commercial-HQ country. Employer of Record is the cleanest mechanism for hiring the first one to several MSLs in a new country, provided the sponsor's own medical-affairs compliance, transparency and PV processes are in order. EOR is not a substitute for those processes; it is a way to put the right person in the right country fast, inside a compliant employment envelope, while the rest of the compliance stack does its job.
For the broader frame, see why medical companies use EOR. For specific country coverage and onboarding for medical affairs roles, Borderless AI's healthcare team is the right next conversation.
