GPhC Fitness to Practise: Complete Guide for Pharmacists and Pharmacy Technicians
How the General Pharmaceutical Council handles concerns about pharmacists, pharmacy technicians and registered pharmacies: the legal grounds, the acceptance criteria introduced in 2026, every stage from triage to a Fitness to Practise Committee hearing, the latest numbers, sanctions and appeal rights, a Supreme Court ruling every registrant should know, performance findings and free support.
Reviewed October 2026 against the Pharmacy Order 2010, GPhC acceptance criteria, decision-making guidance and annual reports, the PSA's 2025-26 performance review and UK Supreme Court case law
Short answer: GPhC fitness to practise is the process the General Pharmaceutical Council uses to decide whether a pharmacist or pharmacy technician can practise safely without restriction. Concerns have risen sharply, to 9,928 in 2025-26, but about 95% of those reaching triage were closed at initial assessment. Since January 2026, published acceptance criteria set out which concerns are likely to be investigated, such as dishonesty, harassment and repeated errors, and which are not, such as isolated minor errors or customer service disputes. Serious cases go to the Investigating Committee and, if needed, to a Fitness to Practise Committee hearing, which can issue a warning, impose conditions, suspend or remove. In 2025-26, 22 people were removed from the register.
Key takeaways
- About half of concerns come from members of the public. The GPhC is not a complaints body and cannot order apologies or compensation.
- Isolated, minor errors that have been dealt with locally are unlikely to be investigated. Dishonesty, harassment, concealing mistakes and failing to declare convictions are likely to be.
- The Investigating Committee meets in private and you do not attend: your written representations are your chance to be heard.
- Removal is never available on health grounds alone, and you have 28 days to appeal a Fitness to Practise Committee decision.
- The PSA found the GPhC met 17 of 18 standards in 2025-26, but not the standard on timely resolution of cases.
This guide covers the GPhC only. For how all UK regulators compare, see our complete guide to fitness to practise in the UK.
Who and what the GPhC regulates
Register at 31 March 2025, from the GPhC annual report 2024-25.
Unlike most healthcare regulators, the GPhC regulates premises as well as people. Concerns about a registered pharmacy, such as staffing, storage of medicines or online sales, are handled through inspection and enforcement, while concerns about an individual go through fitness to practise. Superintendent pharmacists and pharmacy owners can be affected by both.
The GPhC regulates pharmacy in Great Britain: England, Scotland and Wales. Pharmacists in Northern Ireland are regulated separately by the Pharmaceutical Society of Northern Ireland, covered in our PSNI fitness to practise guide.
The legal grounds
Article 51(1) of the Pharmacy Order 2010 lists the grounds on which your fitness to practise can be impaired. They are wider than at most regulators.
What the GPhC will and will not investigate
In January 2026 the GPhC published acceptance criteria for the first time. It says plainly: "We are not a general pharmacy complaints body." It does not resolve disputes and cannot require an apology or order compensation.
- Dishonesty
- Sexual or racial bullying and harassment
- Inappropriate relationships with patients
- Not being open about mistakes, or concealing them
- Not declaring a criminal conviction or caution to the GPhC
- Reckless handling of high-risk medicines
- Supplying medicines without considering the patient's best interests
- Working beyond your knowledge, experience or skills
- Repeated errors, or not learning from mistakes despite feedback and support
- Continued poor performance after local management
- Criminal matters with a prison or suspended sentence, or involving sex, violence, dishonesty or your practice
- Health concerns where you lack insight or worked while clearly unfit
- Isolated or minor errors with no ongoing risk to patients
- Issues already handled appropriately locally
- Poor customer service or rudeness without aggression or threats
- Minor driving offences, youth matters, conditional cautions, and protected cautions or convictions
- Well-managed health conditions, or substance misuse where you are abstinent and engaged in treatment
- Mental health issues where you have insight and support
Summarised from GPhC Acceptance Criteria, version 1, January 2026.
Two things stand out. First, concealment is treated as more serious than the original mistake: "not being open about mistakes" is on the list of concerns likely to be investigated, as explained in our guide to the duty of candour. Second, failing to declare a conviction or caution is itself a likely investigation, as covered in our guide to failure to disclose.
Concerns about a registered pharmacy
For premises, the criteria follow the five standards for registered pharmacies. The most serious, likely to lead to an intelligence-led inspection, include selling pharmacy medicines or handing out prescriptions without the responsible pharmacist present, potentially unlawful supply, supplying out-of-date medicines, unsecured controlled drugs, poor cold-chain storage and patient recalls not actioned. Isolated dispensing errors not involving high-risk medicines, customer service complaints, temporary stock shortages and untidy premises with no evidence of risk are unlikely to need an inspection.
The numbers
| Measure | Figure | Period and context |
|---|---|---|
| Concerns received | 9,928 | 2025-26, up from 7,378, a rise of about a third |
| From members of the public | 5,004 | 2025-26, about half of all concerns |
| From other healthcare professionals | 1,274 | 2025-26, 13% |
| Self-declarations | 137 | 2025-26 |
| Closed at initial assessment | About 95% | 2025-26, of 7,653 concerns reaching triage |
| Reached a Fitness to Practise Committee | 81 | 2025-26: 22 removals, 36 suspensions |
| Investigating Committee decisions | 53 | 2024-25: 44 warnings, 8 advice, 1 no further action |
Sources: GPhC annual report 2025-26, published 17 September 2026, and GPhC annual report 2024-25.
The GPhC's chief enforcement officer has described "a sharp increase in lengthy AI-generated complaints", one reason for the rising volume. In 2024-25, the GPhC also reported a notable rise in public concerns about the prescribing and oversight of weight-management medicines.
How long it takes
Cases have historically been slow. In 2024-25 the median time to close an investigation was 12 to 14 months from receipt, a case at Investigating Committee stage took a median of just under two years, and a case closed by the Fitness to Practise Committee just under three years. The GPhC now says concerns are assessed within five weeks and most investigations finish within 40 weeks. Cases open for more than two years fell from 179 to 142 over the PSA's 2025-26 review period.
How a GPhC case moves
- 1
Triage and initial assessment
The concern is checked against the acceptance criteria. Most are closed here, sometimes with a reminder about the standards, or passed to local resolution.
- 2
Investigation
The GPhC gathers evidence and may ask for your account and insight. Many investigated cases close with guidance or no further action. Our guide to the investigation stage explains what to expect.
- 3
Investigating Committee
The committee "meets in private" and you do not attend or give oral evidence. The GPhC writes to you first and invites a written representation on the allegation and the Registrar's recommendations. You are told the outcome within 10 days of the decision.
- 4
Fitness to Practise Committee
A hearing, usually in public, decides the facts, impairment and sanction. Health cases, and cases that may lead to an interim order, are held in private unless the public interest outweighs your interests. See our guide to fitness to practise hearings.
What the Investigating Committee can decide
Using its guidance Good decision making: investigating committee meetings and outcomes (updated October 2025), the committee can:
Because the Investigating Committee meets in private, your written representations carry the whole weight of your case at this stage. The acceptance criteria show what decision makers weigh: how serious the issue is, whether it forms part of a pattern, whether it involved recklessness, and whether there is an ongoing risk. A strong representation speaks directly to each:
Our guide to writing your response sets out how to structure them, and our guide to warnings and undertakings explains when to accept them.
Interim orders
If it is "necessary for the protection of members of the public or is otherwise in the public interest", or in your own interests, the Fitness to Practise Committee can suspend you or impose conditions while the case continues (article 56). An interim order can last up to 18 months, must be reviewed within six months and then at least every six months, and you can ask for an earlier review after three months. Only the High Court, or the Court of Session in Scotland, can extend it, by up to 12 months at a time. See our guide to interim and substantive suspension.
Sanctions, publication and appeals
The Fitness to Practise Committee uses Good decision making: fitness to practise hearings and outcomes guidance (2024). Under article 54(2) of the Pharmacy Order, if it finds impairment it can:
Warning
Details are recorded in the register.
Conditions
For up to three years, using the GPhC conditions bank.
Suspension
For up to 12 months, often with a review hearing.
Removal
From the register, in the most serious cases.
Removal cannot be ordered where impairment is "solely by reason of adverse physical or mental health" (article 54(7)). The determination is added to your register entry, and public determinations are published on the GPhC hearings page.
You have 28 days to appeal a Fitness to Practise Committee decision, and the outcome takes effect only after that period or after any appeal is decided. The committee can impose interim measures that apply immediately during the 28 days and remain while an appeal is pending. The Professional Standards Authority can also refer a decision it considers unduly lenient to the High Court, or the Court of Session in Scotland. If you are removed, you cannot apply to be restored for five years, as explained in our guide to how long remediation takes.
Khan v General Pharmaceutical Council [2016] UKSC 64
What happened. A pharmacist was convicted of a series of domestic violence offences against his wife between 2010 and 2012. The conduct did not involve his professional practice and no patient was at risk. The Fitness to Practise Committee found him impaired and, deciding that a maximum 12-month suspension was not enough, removed him. He then spent almost three and a half years under interim suspension while the case went through the courts.
The outcome. The Supreme Court held, on 14 December 2016, that a review committee cannot extend a suspension simply to reflect the gravity of the original misconduct: a review looks at whether fitness to practise remains impaired, judged by what the registrant has achieved since. It also said courts can more readily depart from a committee's view of public confidence where misconduct is unrelated to professional performance. Finding removal "disproportionate", it substituted a four-month suspension with a review, taking account of the long interim suspension and his insight, admissions, remorse and steps taken.
The lesson: reviews are about rehabilitation, so what you do during a suspension matters. Insight, early admissions and evidence of change are recognised mitigation, even in serious non-clinical cases.
Online pharmacy and weight-loss medicines
Concerns about online prescribing, especially weight-management medicines, are rising. The GPhC's guidance for pharmacies providing services at a distance, including on the internet, updated in February 2025, sets the safeguards decision makers will measure you against.
Do not rely on the questionnaire
"The prescriber does not base prescribing decisions on the information provided in a questionnaire alone." Information should be checked independently, for example through records or the person's GP.
Verify weight-loss measurements
For weight management, "the prescriber independently verifies the person's weight, height and/or body mass index", and a phone call alone "would not be appropriate".
Two-way communication
There must be "a means to allow timely two-way communication between the prescriber and the person."
Identity checks
Staff must be able to check that the person "is who they claim to be", proportionate to the medicine.
Preferred medicine is not a choice
People may state a preferred medicine, but the pharmacy must make clear that "the decisions about treatment are for both the prescriber and the person."
No regular GP
Where there is no regular prescriber, weigh the risks and benefits, record the reasons, and refer the person elsewhere if prescribing is not safe.
Pharmacist prescribers should also follow the GPhC's in-practice guidance for pharmacist prescribers, updated in April 2025. Supplying "without considering the patient's best interests" is one of the concerns the acceptance criteria say are likely to be investigated.
Common concerns and how to avoid them
Dispensing and medicines errors
One error dealt with properly is unlikely to be investigated. Repeated errors, errors with high-risk medicines, or not learning from them are. Report, record and reflect on every error.
Weight-management and online prescribing
The GPhC reported a notable rise in concerns about prescribing and oversight of weight-management medicines. Supplying without considering the patient's best interests is on the list of likely investigations.
Honesty and records
Dishonesty and concealing mistakes are treated as among the most serious concerns. See our guides to dishonesty allegations and records and probity.
Declarations
Failing to declare a conviction or caution is itself a likely investigation, often more damaging than the original matter.
Boundaries and harassment
Sexual or racial harassment and inappropriate relationships with patients are likely to be investigated. See our guide to professional boundaries.
Working beyond your competence
Taking on services or prescribing outside your training is a listed concern for individuals, and staff working outside their competence is a high-risk concern for premises.
The standards your case is measured against
GPhC cases are judged against the nine Standards for pharmacy professionals. Pharmacy professionals must:
- provide person-centred care
- work in partnership with others
- communicate effectively
- maintain, develop and use professional knowledge and skills
- use professional judgement
- behave in a professional manner
- respect and maintain the person's confidentiality and privacy
- speak up when they have concerns or when things go wrong
- demonstrate leadership
The GPhC also publishes supporting guidance on topics such as consent, confidentiality, raising concerns, maintaining clear sexual boundaries, conflicts of interest and demonstrating professionalism online. Our guides to conflicts of interest and probity cover the most common areas.
Related coursePharmacy Professionalism: the nine standards in practice→Revalidation, renewal and inspections
Some removals are administrative rather than fitness to practise decisions. Every year you must renew your registration, make a set of declarations and complete revalidation: four CPD records, one peer discussion record and one reflective account against the standards, with at least one record reflecting on any annotation or specialist role. The GPhC says: "If you don't renew, you'll be removed from the register and won't be able to practice." Your declarations must be accurate: an inaccurate declaration can itself become a fitness to practise concern, as explained in our guide to failure to disclose.
Registered pharmacies are inspected against the standards for registered pharmacies, and the GPhC publishes inspection reports for inspections carried out since April 2019 on its inspections website, searchable by pharmacy. If you are a superintendent pharmacist or pharmacy owner, the premises findings and any concerns about governance or staffing can sit alongside personal fitness to practise questions.
Performance and what is changing
PSA review 2025-26
The Professional Standards Authority's review, published on 30 September 2026, found the GPhC met 17 of 18 standards. It did not meet standard 15 on timely resolution of cases. The PSA found no evidence of inappropriate closures at triage and praised the quality of investigations and decisions, and the GPhC's guidance on Islamophobia and antisemitism.
Capacity and new services
The GPhC plans to increase hearings capacity by 50%, resolve most very old investigations, and test an independent pharmacy concerns resolution service for complaints that do not need regulatory action.
Support during a GPhC case
Independent Support Service
Run by Victim Support for anyone involved in a GPhC case, including pharmacists, pharmacy technicians and owners. It is free, impartial and private, and will not share what you say with the GPhC unless someone is at immediate risk. Call 0300 373 2801, Monday to Friday 8am to 6pm, with a 24/7 team outside those hours.
Your defence body or union
Contact your indemnity provider, defence association or union as soon as you hear from the GPhC and before you reply. The support service does not give legal advice; your named GPhC contact can answer questions about your case.
If your health is part of the case, see our guide to health and fitness to practise. If you are struggling, you can contact Samaritans at any time on 116 123.
If you have just heard from the GPhC
- Check the concern against the acceptance criteria. It tells you how seriously it is likely to be treated.
- Get advice from your defence body or union before you reply.
- Be open. Concealing a mistake is treated as more serious than the mistake.
- Secure your records and never alter them after a concern is raised.
- Start reflecting and learning now, with evidence. Our guides to insight and reflective accounts explain how.
- Use support, including the Independent Support Service.
Evidence that carries weight is covered in our guide to evidence of remediation, and more real decisions in our fitness to practise case studies.
Frequently asked questions
How many pharmacists are struck off by the GPhC?
In 2025-26, 22 pharmacy professionals were removed from the register and 36 suspended, out of 81 cases reaching a Fitness to Practise Committee.
Will the GPhC investigate a single dispensing error?
Usually not. Isolated or minor errors with no ongoing risk, dealt with appropriately locally, are unlikely to be taken forward. Repeated errors, errors with high-risk medicines, or not learning from mistakes are more likely to be.
What does the GPhC investigate?
Under its 2026 acceptance criteria, concerns such as dishonesty, harassment, inappropriate relationships, concealing mistakes, failing to declare convictions, reckless handling of high-risk medicines and repeated poor performance are more likely to be investigated.
Do I attend the GPhC Investigating Committee?
No. It meets in private. You are invited to send a written representation beforehand and are told the outcome within 10 days of the decision.
How long does a GPhC investigation take?
In 2024-25 the median was 12 to 14 months to close an investigation. The GPhC now says concerns are assessed within five weeks and most investigations finish within 40 weeks.
What sanctions can the GPhC impose?
A Fitness to Practise Committee can issue a warning, impose conditions for up to three years, suspend for up to 12 months, or remove a pharmacy professional from the register.
Can a pharmacist be removed because of ill health?
No. Removal cannot be ordered where impairment is solely because of adverse physical or mental health, though conditions or suspension can.
How long do I have to appeal a GPhC decision?
28 days. The outcome takes effect after that period or after any appeal is decided, unless an interim measure applies.
How long can a GPhC interim order last?
Up to 18 months, reviewed within six months and then at least every six months. Only the court can extend it, by up to 12 months at a time.
Can the GPhC make a pharmacy apologise or pay compensation?
No. The GPhC says it is not a general complaints body and cannot require an apology or order compensation. Complaints about service go to the pharmacy first.
Does the GPhC regulate pharmacists in Northern Ireland?
No. The GPhC covers England, Scotland and Wales. Pharmacists in Northern Ireland are regulated by the Pharmaceutical Society of Northern Ireland.
What are the GPhC rules for online weight-loss prescribing?
Under guidance updated in February 2025, prescribers must not rely on a questionnaire alone, must independently verify weight, height or BMI (a phone call alone is not enough), check identity and allow two-way communication with the person.
What do I need for GPhC revalidation?
Each year: four CPD records, one peer discussion record and one reflective account, with at least one record reflecting on any annotation or specialist role. If you do not renew, you are removed from the register.
Can I see a pharmacy's GPhC inspection report?
Yes. The GPhC publishes reports for inspections carried out since April 2019 on its inspections website, searchable by pharmacy.
Does the GPhC Investigating Committee publish warnings?
A warning is usually published. Undertakings can only be agreed if you accept that your fitness to practise is impaired.
Is there support for pharmacists under investigation?
Yes. The Independent Support Service, run by Victim Support, offers free and private emotional support on 0300 373 2801.
Primary sources
19 official documents, laws and judgments
- GPhC: Acceptance Criteria (January 2026)
- GPhC: Annual report and annual fitness to practise report 2024-25
- GPhC: PSA performance review 2025-26 (September 2026)
- GPhC: What the Investigating Committee does
- GPhC: What the Fitness to Practise Committee does
- GPhC: Standards for pharmacy professionals
- GPhC: Guidance for pharmacy professionals
- GPhC: Guidance for registered pharmacies providing pharmacy services at a distance (February 2025)
- GPhC: In practice, guidance for pharmacist prescribers (April 2025)
- GPhC: Revalidation and renewal
- GPhC: Pharmacy inspection reports
- GPhC Independent Support Service (Victim Support)
- Pharmacy Order 2010, article 51
- Pharmacy Order 2010, article 54
- Pharmacy Order 2010, article 56 (interim orders)
- Pharmacy Order 2010, article 57 (restoration)
- Pharmacy Order 2010, article 58 (appeals)
- Khan v General Pharmaceutical Council [2016] UKSC 64
- PSA: Regulators we oversee
