What do the new Superintendent standards mean for owners and SPs?

What are the new superintendent standards?

They are five draft standards that describe, for the first time, how a superintendent pharmacist is expected to run a pharmacy business. The GPhC published them for consultation on 17 December 2025, in the same document as draft rules and standards for responsible pharmacists. The consultation closed on 25 March 2026 with 411 written responses.

The standards fill a gap that has been open since 2018. The current standards for registered pharmacies do not mention the superintendent at all. They say "responsibility for meeting the standards lies with the pharmacy owner", and that where the owner is a body corporate "the directors must assure themselves" the standards are met. The superintendent's duties sat in the Medicines Act and in practice, not in a GPhC document.

None of this is in force yet. At its meeting on 16 July 2026 the GPhC Council was asked to note the consultation findings, not to approve the standards. The package is expected back before Council on 15 October 2026. The GPhC has said the supporting rules and standards will be in place by 10 December 2026, when the second phase of the supervision changes commences. The companion article on the new responsible pharmacist standards covers the other half of the package.

What does the law already require of a superintendent?

More than most owners realise, and it has been the case since 1 December 2022. Section 71 of the Medicines Act 1968 sets the conditions for a body corporate to carry on a retail pharmacy business. The Pharmacy (Responsible Pharmacists, Superintendent Pharmacists etc.) Order 2022, SI 2022/849, rewrote them. The table summarises the current section 71 and the new section 72AA.

Two consequences follow. First, "senior manager" is a legal test, not a job title. A pharmacist who is named on the GPhC form but excluded from decisions about staffing, services or premises does not meet it. Second, the duty runs "at all times". The GPhC's own guidance for new superintendents says the SP "remains responsible for the pharmacy at all times, including outside business hours". The draft standards build on that base rather than replace it.

What do the five draft standards require?

They turn section 72AA into a working job description. Each standard has a short explanation and a list of things the superintendent "must" do. The table summarises the drafts from the GPhC's December 2025 consultation document.

Standard 4 carries the most weight for a modern business. It reaches "unregulated services linked to the pharmacy" and "services provided by a third party". It also names the authorisation SOP that phase two of the supervision reform depends on. The draft says that SOP "needs to specifically set out the requirement that authorisations must be accurately recorded in writing on the day they are given". If your pharmacy prescribes, runs a clinic or works with an online platform, see what the superintendent already answers for in online services.

What must owners give their superintendent?

Authority, time and resources, in that order. The draft standards are written as duties on the superintendent, but almost every one depends on something only the owner controls. A superintendent cannot "get the right skill mix" without a staffing budget, or "make sure succession and contingency planning is in place" without a say in recruitment. The GPhC's draft is explicit that an SP must "have the skills, experience, commitment, time and resources in place" to carry out their responsibilities.

Standard 1 adds a line owners should read twice. The superintendent must "appropriately manage personal and organisational goals, incentives or targets" so that professional judgement is not compromised. That puts sales targets, conversion rates and service volumes inside the superintendent's remit. A bonus scheme that pushes staff to supply is now a governance question for the SP, not only a commercial one for the board.

The 2018 premises standards already require directors of a body corporate to "assure themselves" the standards are met. The draft SP standards give directors a named person whose job is to give that assurance, and give that person grounds to ask for what they need. An owner who appoints a superintendent and then overrides them is creating evidence against both. Our guide to choosing and appointing a superintendent pharmacist covers how to write authority into the contract.

Can one superintendent cover several companies?

Yes, and the draft standards accept it with conditions. Before December 2022 a pharmacist could not be superintendent of more than one body corporate. The 2022 Order removed that bar. The GPhC's draft says a superintendent "can be responsible for retail pharmacy businesses owned and operated by more than one legal entity". That "is likely to involve being responsible for multiple registered pharmacy premises with different owners".

The draft then lists what makes that hard. Different and possibly complex ownership structures. Different governance frameworks. Different services, different commercial interests, and in some cases different nations with different NHS arrangements. The superintendent must meet all five standards in each business. There is no discount for scale.

The multiples saw the opposite problem. The Company Chemists' Association told the consultation the drafts were "not aligned" with how multi-site pharmacy businesses operate. That tension is one reason Council did not approve the package in July. Owners with a group structure should read the drafts alongside our guide on how a pharmacy business should be structured. The superintendent's reach now follows the legal entities, not the brand.

How does accountability shift between owner, SP and RP?

The draft package draws the line by layer. The superintendent has "organisational oversight of the management and operation of the pharmacy business", including the records that go with it. The responsible pharmacist keeps the records for the "safe and effective day-to-day running of the pharmacy". Where a business has no superintendent, the owner takes the superintendent's share. The table sets out the split as drafted.

The interim rule is the one owners asked about most. If a superintendent leaves, or cannot perform the role during an extended absence, "immediate arrangements must be put in place to replace the Superintendent". That may mean an interim appointment. The GPhC must be told in writing within 28 days both when the old superintendent stops and who the new one is, permanent or interim. The consultation asked whether "immediate" was reasonable, and the timing of interim appointments is one of the four areas the GPhC says needs more work.

Delegation is the other shift. Standard 3 requires details of delegation to be recorded, "including who is accountable and responsible", and kept up to date. That is new. Today a superintendent can delegate area management or clinical governance informally. Under the draft, an inspector can ask to see the record.

What did the consultation find, and what happens on 15 October?

It found broad support for the standards and sharp disagreement on the edges. The Pharmacist reported the July Council paper on 23 July 2026. "While there was consensus agreement for the majority of proposals, some were less clearly supported," it said. Some received "fairly strongly opposing views". The 411 responses included 374 from individuals and 30 from organisations.

On superintendents specifically, 57 per cent of respondents supported additional minimum requirements for the role. The GPhC had not proposed any beyond the legal criteria; it asked the question and left it open. The responses split on what those requirements should be. The NPA argued that "time served is not a guarantee of suitability" and asked for competency-based tests built on leadership skills. The Royal College of Pharmacy, still the RPS when it responded in March, said any extra requirements "should not be restrictive". Others, including the Pharmacist Cooperative, pressed for a fixed number of years on the register.

The GPhC listed four areas needing further work before Council can approve. Two concern superintendents directly: minimum requirements for the appointment, and the timing expected for appointing a new or interim SP. The others are clarity on roles across the positions and the wording of the two-hour responsible pharmacist absence rule. The package is expected back before Council at its meeting on 15 October 2026, which the GPhC lists on its meetings page. A further meeting is scheduled for 10 December 2026, the day pharmacists gain the power to authorise technicians.

What should owners and SPs do now?

Fix the things the law already requires and prepare for the things the draft adds. The senior manager test, the section 72AA duty and the 28-day notification are current law. The five standards are the direction of travel, and the areas under review are about minimum requirements and timing, not about the substance of the duties. The checklist below is for a body corporate with one or more branches.

For superintendents covering online services, read the draft with the GPhC's standards for online pharmacies. Standard 4 asks for systems to confirm patient identity and to spot inappropriate requests. Those are the two points inspectors have pressed hardest on since the February 2025 distance-selling guidance.

Key takeaways

FAQs