Can pharmacists prescribe under a PGD or do they need to be an independent prescriber?

What is a patient group direction?

A written instruction that lets a named health professional supply or administer a specified medicine to any patient who fits its criteria, without a prescription for that patient. Regulation 213 of the Human Medicines Regulations 2012 defines it. A PGD is a written direction relating to the supply and administration of a description or class of medicine. It must be signed by a doctor or dentist and by a pharmacist. It relates to supply to persons generally, subject to any exclusions it specifies. The patient is not named. The criteria are.

Every PGD must contain the 17 particulars in Schedule 16 Part 1 to the Regulations. They start with the period the direction has effect and the clinical situations it covers. They include the eligibility criteria, the excluded classes of patient, the dose, strength, route and frequency, and the warnings and follow-up. They end with the referral arrangements and the records to be kept. If a particular is missing, the direction is not a PGD and the supply is unlawful. Schedule 16 Part 4 lists who may work under one: pharmacists, nurses, midwives, paramedics, optometrists, physiotherapists and other registered professions. Registered pharmacy technicians joined the list on 26 June 2024 under SI 2024/729.

The PGD must also be authorised by the right body. Regulation 229 covers NHS bodies and local authorities. Regulation 233 covers a person conducting a retail pharmacy business, which is the one a community pharmacy uses. It allows supply under a PGD made through an arrangement with a listed body. The NHS list covers an NHS trust, an integrated care board, NHS England, a local authority and UKHSA, plus police forces and prisons. For private work, the body is an independent hospital, clinic or medical agency. NICE guideline MPG2, published in 2013 and updated in 2017, sets the professional frame. A PGD should be reserved for limited situations in which it offers an advantage for patient care without compromising safety. It should carry an expiry date of no more than three years.

What can an independent prescriber do that a PGD cannot?

Decide. A pharmacist independent prescriber, annotated as such on the GPhC register, may prescribe any medicine for any condition within their competence, on their own assessment of the individual patient. That includes changing a dose, choosing between products, prescribing off-label where justified, prescribing an unlicensed medicine, and prescribing controlled drugs. The Misuse of Drugs (Amendment No.2) (England, Wales and Scotland) Regulations 2012 opened controlled drugs to them. A pharmacist independent prescriber may prescribe any controlled drug in Schedules 2 to 5, except cocaine, diamorphine or dipipanone for treating addiction.

A PGD can do none of that. It supplies the product it names at the dose it states to patients who meet its criteria. It cannot supply an unlicensed medicine. It cannot adjust the dose of a medicine the patient already has. Controlled drugs are largely out. Regulation 8(8) of the Misuse of Drugs Regulations 2001 permits only narrow exceptions. They include diamorphine or morphine for the immediate, necessary treatment of sick or injured people, and Schedule 5 drugs or ketamine. Everything else in Schedules 2 and 3, including ADHD stimulants, needs a prescriber.

The prescriber carries duties a PGD user does not. The GPhC's In practice guidance for pharmacist prescribers, updated in April 2025, says pharmacist prescribers must prescribe only within the limits of their knowledge, skills and area of competence. They must make an adequate and safe clinical assessment. They must not make prescribing decisions for high-risk medicines on the basis of online questionnaires alone, with no access to the person's medical history. The guidance also says prescribers should keep the initial prescribing separate from the supply of the medicines prescribed, to protect the person and minimise risk. The GMC's prescribing guidance, updated on 13 December 2024, sets equivalent expectations for doctors. Our note on remote prescribing rules for high-risk medicines covers the safeguards in detail.

Which pharmacy services suit a PGD?

Anything with a standard product, fixed criteria and a one-off decision. That describes most NHS advanced services and the best-established private ones. Pharmacy First supplies its seven clinical pathways under a set of national PGDs and one clinical protocol. The NHS pharmacy contraception service runs on PGDs for the combined pill, the progestogen-only pill and, since 29 October 2025, oral emergency contraception. Flu, COVID-19, RSV and pertussis vaccination run under PGDs or national protocols. On the private side, travel vaccines, antimalarials, emergency contraception, period delay and a growing list of acute treatments are sold as PGD packages. The provider's registered clinic or medical agency authorises them.

The PGD route has two practical virtues. It is quick to start, because the direction, the training and the governance come as a package. And it does not depend on one person, so the service survives staff changes. Our guide to setting up a travel clinic shows the model at its simplest.

When does a service need an independent prescriber?

When the decision cannot be written down in advance. MPG2 is explicit. Do not use PGDs for managing long-term conditions, such as hypertension or diabetes, or when uncertainty remains about the differential diagnosis. Do not use one where there is an opportunity in the care pathway for the medicine to be safely prescribed on an individual basis. PGDs are also unsuitable where medicines need frequent or complex monitoring. Weight-management injections fail all three tests: semaglutide and tirzepatide are titrated over months, monitored throughout and used for a long-term condition. That is why the GPhC's weight-management FAQs speak only of prescribers. Its April 2025 guidance lists weight-management medicines among those needing extra safeguards when prescribed remotely, alongside medicines liable to misuse, long-term condition medicines needing monitoring and black triangle medicines. See the checks pharmacies must make before supplying weight-loss medicines.

The same logic settles the other private services. HRT needs a regimen chosen for the individual and reviewed at three months and then annually, so a menopause service is prescriber-led. ADHD medicines are Schedule 2 controlled drugs, so no PGD can touch them; a prescriber working within competence and a shared-care arrangement can. Testosterone is a Schedule 4 controlled drug and its use in women is off-label. Aesthetic products need a physical examination, and the GPhC says it is not appropriate to carry out a remote consultation for non-surgical cosmetic products. Our guide to how online clinics work with dispensing pharmacies explains the partner-clinic model many pharmacies use where they have no prescriber of their own.

Who writes, signs and authorises a PGD?

Three different groups, and confusing them is the commonest mistake. Drafting is done by a multidisciplinary group. MPG2 expects it to include a doctor, a pharmacist and a representative of the professional group that will use the direction, and to work from the current evidence and the product's licence. Signing is a legal requirement in regulation 213: a doctor or dentist and a pharmacist must sign every PGD. Authorising is the third step, and it belongs to the organisation the Regulations name.

For NHS bodies, Schedule 16 Part 2 says who signs on the organisation's behalf. It is the trust for an NHS trust, the chief executive or director of public health for a local authority, and the chief executive for UKHSA. For an integrated care board or NHS England, it is the body itself. For a community pharmacy's own private service, regulation 233(1)(a)(x) requires an arrangement with an authority or person carrying on an independent hospital, clinic or medical agency. Regulation 233(5)(e) then requires the PGD to be signed by or on behalf of the registered provider and, if there is one, by the relevant manager. That registered provider is what a commercial PGD supplier is. A PGD package is that arrangement, the authorised direction and usually the training; it is not a licence to write your own.

Two more requirements sit with the pharmacy. The person administering under the PGD must be one of the Schedule 16 Part 4 professions and must be designated in writing for that purpose. And the pharmacy must keep the records the direction specifies, which is the seventeenth particular. An inspector will ask for the signed PGD, the training evidence and the list of designated users.

Can technicians and locums work under a PGD?

Yes to both, with conditions. Registered pharmacy technicians were added to Schedule 16 Part 4 on 26 June 2024 by SI 2024/729. Its explanatory note says the change enables them to supply and administer medicines under a PGD in the course of their professional practice. The NHS contraception service took up the change on 29 October 2025. A technician can therefore be trained and designated to use any PGD whose authorising body allows it, and the direction itself may limit which professions it covers. A technician cannot become an independent prescriber, so any service on the prescriber side of the table stays with a pharmacist.

Locums are covered by the same rule as everyone else: the PGD is used by named individuals, so the locum must be trained and designated before the first supply. That is a governance task for the pharmacy, not the locum. Keep a standing file for regular locums with their training certificates and signed authorisation sheets, and diarise the PGD's expiry date; a lapsed direction makes every supply unlawful. A locum who is an independent prescriber brings their own annotation. The pharmacy still needs a written arrangement setting out what they may prescribe, how it is recorded and how prescribing is kept separate from supply.

How do you become an independent prescriber, and is the market moving that way?

Through a GPhC-accredited course, and yes. The GPhC says an accredited independent prescribing course typically takes six months part time. It requires a minimum of 26 days of teaching and at least 12 days, or 90 hours, of learning in practice under a designated prescribing practitioner. Entrants need relevant experience in a UK pharmacy setting. On completion the GPhC annotates the register. Our guide to becoming a pharmacist independent prescriber covers funding and course choice.

The bigger shift is at registration. The GPhC states that pharmacists who follow education and training meeting its 2021 initial education and training standards will become independent prescribers when they register. Graduates who entered foundation training in August 2025 are due to register in 2026 as prescribers, according to NHS England's workforce, training and education directorate. From that point the supply of prescribers stops being the constraint; competence and governance become the constraint instead.

The NHS has been testing the service model. NHS England's Independent Prescribing Pathfinder Programme ran more than 33,000 patient consultations across 164 pharmacy sites. More than 59% resulted in a prescribing intervention, according to its transition statement of 30 October 2025. The programme formally concluded on 31 December 2025, with integrated care boards able to keep sites running to the end of March 2026 with £1,500 of support per site. NHS England said it would publish the national evaluation and a governance framework for prescribing in community pharmacy. As of this article's date, no national NHS prescribing service exists; PGDs remain the NHS route.

How do you choose for a new service?

Start from the decision the service requires, not from the staff you have. If a clinician could write the eligibility criteria, the exclusions and the dose on one page in advance, a PGD will work and will be cheaper and more resilient. If the answer depends on the patient's history, response and preferences, or changes over time, you need a prescriber. A controlled drug or an unlicensed product settles the question on its own.

The two routes are not rivals. Pharmacies that prescribe still run vaccinations and contraception under PGDs, because the direction is faster and does not tie the service to one person. Pick the service, then the route.

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