Analysis · Organisation · September 2026
Not which tool to buy: AI agents across the pharma value chain
In April, BCG argued that China's biopharma industry has won the decade of efficiency and must now climb to value. On 18 September, ten Chinese government departments published the pharmaceutical industry's 15th Five-Year Plan, which calls for pharma-specific models and AI agents. Read side by side, they cover the value chain from the laboratory to the regulator. That changes the question a pharma executive should be asking.
JUMO Partners · 23 September 2026 · Sources at the end. English renderings of the Chinese plan are our own.
Two documents, opposite ends of the chain
BCG’s report makes the commercial case. Over ten years, it says, China’s biopharma innovation went through a “deep and systemic ‘efficiency revolution’”, built on scale, speed and cost. The next step is harder: turning that efficiency into “globally recognized innovation value — with the accompanying price tag”. AI appears as the lever on speed and cost. BCG’s framing is precise: the aim is to move the advantage “from lower point costs to a lower end-to-end cost of success”, by migrating trial and error upstream so that course corrections come earlier and cost less.
The policy direction comes from the Five-Year Plan (工信部联规〔2026〕210号). In its chapter on digital-intelligence transformation (数智转型), one of eight priority areas, it asks companies, hospitals and research institutes to build high-quality pharma datasets and a trusted health-data space, and to “accelerate the development of pharma-specific vertical models and agents” (加快研发医药垂类大模型与智能体). It names where they should be applied — drug discovery, clinical research, process optimisation, quality management, distribution and use, and smart regulation — and sets out five families of priority AI applications across that chain.
The plan does not promise funding. It sets out where the state intends to push, which in China’s pharmaceutical industry is usually where the regulatory and industrial effort goes next.
Two halves of one chain
The two documents weight different parts of the value chain.
BCG’s weight is upstream. Its AI section covers target identification, preclinical risk filtering and clinical development. It is candid about maturity: AI deployment at scale “remains in the early stages”, and the proven applications are still concentrated in small-molecule discovery. But it also says AI is expanding “from a point tool into a multimodal capability stack deployed across the R&D value chain.”
The plan’s weight is downstream and lateral. It adds full-process data capture and traceability in manufacturing, real-time control on critical quality attributes, computerised-system validation, prescription review, real-world evidence, and data infrastructure underneath all of it.
Put together, they run from the laboratory to the regulator. That is the core of our argument: an agent strategy in pharma is an organisation-wide change, not a tool purchase.
Function by function
What the two documents ask of each function, and where an agent can take a share of the work
| Function | What BCG and the plan say | Where an agent comes in |
|---|---|---|
| Discovery & preclinical | BCG: AI is moving upstream into target prioritisation and druggability prediction, and into ADMET and toxicology prediction, “migrating trial and error upstream”. Plan: AI for target screening, molecular design, virtual screening and analysis of candidate properties. | Literature and patent review; target triage; early filtering of weak candidates; a searchable record of what has already been screened, and why it was dropped. |
| Clinical development | BCG: “beginning to enter a scalable phase” — trial design, patient stratification and enrolment, clinical-data analysis; outcome prediction and stop-loss next. Plan: real-world data platforms, AI-assisted protocol review. | Feasibility and site identification; data cleaning and query handling; safety-signal monitoring; real-world evidence collection. |
| Regulatory affairs | BCG: the credibility climb — multi-regional trials, co-development, dual filings. Plan: AI models and agents for review, approval and inspection, used by the regulator itself. | Pathway mapping across NMPA, EMA and FDA requirements; dossier assembly and consistency checks; regulatory-intelligence monitoring. Always with an expert signing off. |
| Manufacturing & CMC | Plan: automatic data capture and traceability across the whole production process; real-time early warning and closed-loop control on critical quality attributes; shared services for computerised-system validation (CSV). | Deviation prediction; electronic batch-record drafting and review; validation support; scheduling. |
| Quality & pharmacovigilance | Plan: quality management is one of the six areas where AI should be applied; quality-management, quality-review and deviation-analysis systems are among the industrial software it wants developed. | Quality-gate checks written from existing SOPs; deviation and CAPA triage; case intake; audit readiness and document-version consistency. |
| Distribution & use | Plan: AI-assisted prescription review and medication guidance, and data across the product’s whole life so that quality and safety are “controlled throughout”. | Traceability and compliance checks; supply-risk and shortage monitoring. |
| Talent & organisation | BCG: scarcity now lies in “compound” talent — people who combine scientific, clinical and organisational judgement. Plan: compound-talent training. 2025 implementation plan: the top executive answers for the transformation. | Not an agent. This is where someone decides who is accountable for the work the agents above do. |
The regulator is building agents too
The line in the plan with the most practical consequences is easy to miss. One of the plan’s five families of priority AI applications is the regulation of production and distribution: review, approval and inspection “large models and agents” for drugs, cosmetics and medical devices. They would handle product classification, task allocation, dossier review, knowledge retrieval, issue identification and report generation.
For a company filing in China, this means that before the end of the decade, the first reader of a dossier may be a machine working to explicit rules. Inconsistencies between documents, versions that contradict each other, and data that cannot be traced back to its source are the things such a system is built to find. Good document discipline used to be a mark of quality. It is becoming a cost of entry.
Why quality is the place to start
Pharma has an advantage that most industries lack: in quality, the criteria are already written down, versioned and audited. An SOP is already a specification an agent can be tested against. A deviation-triage agent or a document-consistency check can be judged by the same standard a human reviewer is judged by, and the plan explicitly asks for validation services to support this.
That also explains why governance matters more than productivity for a healthcare buyer. In a regulated industry, work done by a machine cannot sit outside someone’s responsibility. Every agent output that reaches a batch record, a dossier or a safety report needs a named person who answers for it.
The question is organisational
China’s regulators had already said as much. The 2025–2030 implementation plan for the digital-intelligence transformation of the pharmaceutical industry, issued in April 2025 by seven departments, asked companies to make the top executive personally responsible for the transformation (“一把手”负责制), to set up a dedicated team, and to adapt their organisation structure and management systems to it.
So the useful question is not which tool to buy. It is who is accountable for the work an agent does, and what a job becomes when one person directs several agents. In our work we treat each seat as human, hybrid, agent-held or suspended. We write the protocol for returning it to human operation before the agent is deployed, not after something goes wrong.
What it means in each direction
For a European company operating in China, the plan describes the environment your Chinese peers, partners and regulator are being pushed towards. An organisation that runs on unconnected documents and personal know-how will find that the counterpart across the table, and eventually the reviewer, works differently.
For a Chinese company heading to Europe, BCG’s evidence points the same way. China’s share of originators in global BD deals rose from 17% in 2020 to 31% in 2025. Co-development accounted for nearly 40% of licensing deals between 2023 and 2025. Dual filings among leading companies have reached around 30%. BCG notes that multinational buyers are moving “from buying an opportunity point to plugging into a platform-based organizational capability.” A partner that can show how its agent-assisted work is controlled, traced and signed off offers a stronger platform to plug into.
Neither document tells a company how to organise itself. That part is still a management decision.
Where this applies
This is the organisation practice.
Operating model, accountability and the deployment of management standards across the Europe–China corridor, now including the seats that agents hold.
Sources
- Boston Consulting Group (Chun Wu, Qicong Hu, Jing Du, Lulu Chao, Cliff Hu), Beyond Efficiency: China’s Next Leap in Biopharma Innovation, April 2026. bcg.com. Accessed 23 September 2026.
- Ministry of Industry and Information Technology, National Development and Reform Commission and eight other departments, 《医药工业发展“十五五”规划》 (15th Five-Year Plan for the Development of the Pharmaceutical Industry), notice 工信部联规〔2026〕210号, published 18 September 2026. miit.gov.cn. Accessed 23 September 2026.
- Ministry of Industry and Information Technology and six other departments, 《医药工业数智化转型实施方案(2025—2030年)》 (Implementation Plan for the Digital-Intelligence Transformation of the Pharmaceutical Industry, 2025–2030), 工信部联消费〔2025〕79号. nmpa.gov.cn. Accessed 23 September 2026.
Quotations from the Chinese documents are our translations. Figures are as published by their authors; JUMO Partners has not re-estimated them.