So far, the implementation of the Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPs) and the dynamics of innovation systems have been discussed fairly separately from each other. Research on TRIPs implementation has tended to focus on the (non-) adoption of certain TRIPs flexibilities while the literature on National Systems of Innovation (NSI) widely neglects the impact of global norms on innovation systems. This paper aims to reconcile these two approaches. My analysis of the post-TRIPs pharmaceutical innovation systems (PIS) in India and Brazil reveals major differences in the regulatory outcomes that go far beyond the mere (non-)adoption of certain flexibilities. Driven by unequal state roles, India and Brazil have evolved into having two different types of innovation systems in the post-TRIPs era. The paper asks how innovation systems are developing under the conditions of globalization and, through this, it contributes to the discussion on innovation systems in emerging economies.