PMCPA 2026 Consultation: What Pharmaceutical Companies Need to Know Before 21 September

The Prescription Medicines Code of Practice Authority (PMCPA) is consulting on targeted changes to its Constitution and Procedure that will affect how complaints about promotional activities are handled, how long companies remain exposed, and how visible breaches become.

With the response deadline of 21 September 2026, this is a key moment for companies that promote licensed medicines to get involved.

What’s Changing at a Glance

Key proposals include:

• Expanded Abridged Complaints Procedure (ACP) — More routine complaints could be handled via a faster, streamlined process.
• Limitation periods — Generally two years for complaints and six months for personal social media activity by company staff.
• Clearer rules on joining and leaving self-regulation — Narrower retrospective liability for new members, with no ‘escape’ from pending complaints when exiting.
• Stronger audit and scrutiny powers — More targeted, mandatory audits of specific promotional areas.
• Potentially greater publicity for serious breaches — Including Clause 2 cases, corrective statements and public reprimands.

These changes could directly affect your complaints workload, documentation requirements and reputational risk.

Why This Matters for Your Business

• Faster, potentially more frequent complaints via the expanded ACP mean you need rapid triage processes and evidence packs that are ready to go.
• Time limits reward good record-keeping. Clear ‘last used’ dates for materials and robust social media policies will be increasingly important.
• Audit readiness moves from ‘nice to have’ to ‘must have’, particularly for digital campaigns, speaker programmes and patient materials.
• Reputational stakes may increase if serious breaches are publicised more prominently.

What You Can Do Now

1. Read the consultation documents published by the PMCPA.
2. Map the proposed changes against your promotional channels and identify any gaps in records, policies and audit readiness.
3. Submit your response by 21 September 2026. The PMCPA is explicitly seeking input from companies that promote medicines.
4. Start internal preparations now — including archiving, social media policies, complaints handling and audit readiness — so you are better prepared when the final rules are published.

How We Can Help

We can:

• Support you in identifying the changes most relevant to your portfolio and promotional channels.
• Help you draft a concise, evidence-based consultation response.
• Run a rapid gap analysis and prioritise practical compliance improvements.

If you promote licensed medicines in the UK, your voice matters in helping to shape a fair and workable system.

If you would like support in understanding what the proposed changes could mean for your business, preparing your consultation response, or strengthening your promotional compliance processes, get in touch with our team at consultancy@regenold.co.uk.

The deadline for responses is 21 September 2026.

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