After 18 June 2025, it will be an offense for a pharmacist or pharmacy technician to operate a clinic without registration
Pharmacists and pharmacy technicians in Scotland who wish to provide an independent clinic are now required to register with Health Improvement Scotland (HIS).
This follows a recent legislative change by the Scottish government, granting HIS authority to regulate independent clinics where services are provided by pharmacists and pharmacy technicians.
Implemented under sections 10G and 105(7) of the National Health Service (Scotland) Act 1978, the amendment also expands the definition of Independent Medical Agency (IMA) to cover services provided by dental practitioners, registered nurses, registered midwives, dental care professionals, pharmacists, and pharmacy technicians, including wholly online services based in Scotland.
Effective 19 June 2024, the legislative update also allows HIS to cancel the registration of independent healthcare services that fail to pay their continuation fees.
The change aims to “increase public safety and avoid situations where pharmacists and pharmacy technicians provide services from unregulated clinics … and where wholly online providers are able to provide services to patients in Scotland without being regulated.”
The government acknowledges that changes to IMAs are “particularly urgent” as online healthcare services that do not currently fall within regulation by HIS pose a “public health risk.”
However, the amendment provides a grace period of one year until 18 June 2025. During this time, clinics operated by unregistered pharmacists or pharmacy technicians will not face penalties, allowing them to apply for HIS registration.
Notably, the legislation excludes services provided in registered pharmacies and those under NHS contract.
The amendment follows a public consultation held from 1 February 2023 to 26 April 2023, during which the majority of respondents supported the proposed regulatory changes.
