What does the law actually say?
It says you may not publish an advertisement that is likely to lead to the use of a prescription-only medicine. That is regulation 284 of the Human Medicines Regulations 2012, in Part 14, which covers advertising. The only exceptions are ministerially approved vaccination campaigns and campaigns about the spread of pathogens. Weight-loss medicines have neither. Mounjaro (tirzepatide), Wegovy (semaglutide) and Saxenda (liraglutide) are all prescription-only, and so is the oral form of semaglutide licensed for weight management.
Three features of Part 14 matter for a pharmacy. First, "advertisement" is defined widely. Regulation 7 covers anything designed to promote the prescription, supply, sale or use of a medicine, in any medium. The Blue Guide summarises it as "any thing or any activity which is intended to encourage prescription or supply by healthcare professionals and use of medicines by the general public". Reference material, factual informative statements, trade catalogues and price lists are excluded, but only if they make no product claim. So is correspondence answering a specific unsolicited question.
Second, regulation 280 sets general principles for any advert that is permitted. It must be consistent with the summary of product characteristics, encourage rational use by presenting the product objectively, and not mislead. Third, regulation 303 makes breach a criminal offence. On summary conviction the penalty is a fine up to the statutory maximum. On indictment it is a fine, imprisonment for up to two years, or both. Part 14 also treats causing another person to publish an advert as publishing it yourself, which is why paying an agency or an influencer does not move the liability.
The test is "likely to lead to the use of" a POM. It does not require a brand name. That single phrase is what makes the indirect references discussed below unlawful, and it is why the MHRA and the ASA read the whole customer journey, not just the headline.
Can you advertise the service instead?
Yes, and this is the whole basis of lawful weight-loss marketing. Appendix 6 of the MHRA's Blue Guide deals with medicinal treatment services, including online clinics and pharmacies. Its position is that such services "may promote the service they provide" but "should not draw attention to specific prescription only medicines". The MHRA repeats the same line on every 2026 enforcement page: "Treatment-service providers may promote the service or consultation offered."
Appendix 6 then gets specific about websites. Any mention of a prescription-only medicine on the home page "is likely to be considered as advertising". The home page may give indicative prices for treating a particular medical condition, but not for a named medicine. Other pages may carry a factual list of prices for available treatments and pack sizes, provided it makes no product claims. Descriptions should say "XXX is used to treat", never "XXX, the best, fastest or strongest treatment for". Icons or other features encouraging the purchase of POMs should not be used. And it should be clear that the customer "is being offered a medical consultation and that this may or may not lead to the provision of a prescription".
Appendix 6 also expects a service to give a balanced overview of the range of therapeutic options for the condition. A weight-loss page that only ever leads to one injectable is not balanced, whatever the wording. The MHRA's Voy decision, published on 9 January 2026, shows how the journey is judged. A sponsored social media advert for orlistat, an over-the-counter medicine, said "Start from £94 a month for the same medication" and carried the company's chief medical officer's image and signature. Its links led to pages promoting two prescription-only weight-loss medicines. The MHRA found the price claim misleading, the professional endorsement improper and the links a promotion of POMs to the public. The company withdrew the advert.
What counts as an indirect reference?
Anything the public will read as the injection. The Advertising Standards Authority, the MHRA and the GPhC issued a joint enforcement notice on 11 April 2025, after named-medicine adverts spread across Facebook, Instagram, TikTok, sponsored search and influencer content. It was sent to all 13,214 registered pharmacies. On 23 September 2025 the three bodies updated it, because advertisers had swapped brand names for descriptions. The updated notice names the substitutes.
| Element | Position under the enforcement notice and Blue Guide |
|---|---|
| Naming Mounjaro, Wegovy, Ozempic, Saxenda or an active ingredient | Prohibited in any public-facing advert. |
| "Weight-loss injection", "weight-loss pen", "obesity treatment jab", "GLP-1" | Prohibited as indirect references likely to lead to use of a POM. |
| Images of injection pens, branded or unbranded, or vials of liquid | Prohibited. |
| Prices, discount codes or special offers attached to a medicine | Prohibited; the GPhC says offers are likely to promote the specific POM. |
| A general weight-loss advert that links straight to a page promoting a POM | Prohibited; the landing page is read as part of the advert. |
| Advertising a weight-loss consultation or service, and the conditions treated | Permitted. |
| Indicative price for treating a condition on the home page | Permitted under Appendix 6, without a medicine name. |
| Factual price list for treatments on an inner page, no product claims | Permitted under Appendix 6. |
The ASA's own explanation of its July 2025 rulings lists the exact phrases it acted on: "Weight Loss Injections", "Weight Loss Pen", "Obesity Treatment Jab" and "GLP-1". It acted on unbranded pens, branded pens and vials too. If your creative contains any of them, it is inside the ruled-against set, not a grey area.
What have the ASA and MHRA actually ruled?
Enough to remove any doubt about how the rule is applied. On 9 July 2025 the ASA published nine rulings against advertisers of prescription-only weight-loss medicines, six of them GPhC-registered pharmacies. The rulings came from a monitoring sweep rather than complaints. Between February and June 2025 the ASA's AI-based system captured more than 20,000 adverts from 35 high-priority pharmacies, about 10,000 of them for weight-loss treatments. More than 99 per cent complied with the named-medicine prohibition; 80 referenced a named drug directly. The rulings went beyond names, treating "GLP-1" and pen imagery as breaches in their own right. The GPhC said it would review the six rulings for further enforcement action, and confirmed it refers pharmacies to the ASA and MHRA when inspections find advertising concerns.
The MHRA's enforcement runs monthly. Its September 2025 statement said it had taken action against more than 25 businesses in 2025 for promoting prescription-only weight-loss medicines to the public. Its published investigations for 2026 name the companies below. Every entry records the same failing: direct or indirect promotion of weight-loss POMs, including references to GLP-1s or weight-loss injections. Every entry records the same outcome: the company amended its advertising after MHRA action on complaints.
| Month of action | Published | Companies named by the MHRA |
|---|---|---|
| January 2026 | 12 February 2026 | Dr Frank's Weight Loss Clinic, London Slimming Clinic, Slimming Direct, Trim, Pharmacy Planet. |
| February 2026 | 10 March 2026 | HealthExpress, WeightLossUK (a price comparison site). |
| March 2026 | 10 April 2026 | Bolt Pharmacy and Fella Health, Oushk Pharmacy. |
| April 2026 | 8 May 2026 | Dr Frank's Weight Loss Clinic, Click2Pharmacy, Weightless. |
| May 2026 | 8 June 2026 | CutKilo, EveryDayMeds, Curely. |
| June 2026 | 7 July 2026 | Davies Pharmacy Havant and Southdowns Pharmacy Group, Tesco Pharmacy, The Harper Clinic. |
That is 18 companies in six months, and the list includes a national multiple, a price comparison site and a clinic named twice. The Tesco entry, published on 7 July 2026, drew a GPhC response reported the next day: "We will not hesitate to act where those that we register fail to meet our standards". Nobody on the list was prosecuted. All of them were named, which for a business trading on trust is the sanction that costs.
Who enforces, and what can they do?
Three regulators, and since April 2025 they pool what they find. The MHRA's Advertising Standards Unit enforces Part 14. GOV.UK's guidance on advertising medicines says it usually pursues informal resolution first: amending or withdrawing the advert, publishing a correction, or requiring future material to be vetted before use. It publishes the outcome with the company's name. Prosecution under regulation 303 remains available, and the guidance is explicit that breaches are criminal offences carrying fines and up to two years' imprisonment.
The ASA enforces the CAP Code, whose rule 12.12 states that no prescription-only medicine may be advertised to the public. It can rule against an advertiser, require the advert to be withdrawn, and refer persistent offenders to its compliance team or to the MHRA. Its monitoring is proactive: the enforcement notice says AI-based active ad monitoring is scanning for breaches, so an advert can be caught with nobody complaining.
The GPhC's lever is the register. Its notice of 11 April 2025 says it may take enforcement action against the pharmacy, the owner and the superintendent pharmacist. It may also investigate the fitness to practise of every pharmacy professional involved. Advertising is now a documented inspection theme. The GPhC's April 2026 review of weight-management services found that 17 per cent of the 1,307 concerns it received between January 2024 and December 2025 were about advertising. That is how the GPhC's weight-loss enforcement now works, as our article on GPhC policing of online weight-loss supply sets out in full.
An advertising breach no longer ends with the ASA. It arrives at your pharmacy regulator with your name on it.
What about influencers, affiliates and social posts?
The same law applies, and the pharmacy is on the hook. Regulation 284 binds any person who publishes an advertisement, and the April 2025 enforcement notice states that it covers paid adverts, organic social media content, sponsored search results and influencer marketing. An influencer posting about their Mounjaro results with your discount code is publishing an advert for a POM. You caused it to be published. The GPhC's April 2026 review recorded reports of pharmacies paying influencers, particularly on TikTok, to promote weight-management medicines using discount codes. Those reports sit inside the 17 per cent of concerns about advertising.
Two further traps arrived in 2026. On 18 June 2026 the ASA, MHRA and GPhC issued a joint statement after seeing businesses promote pipeline products. The examples included waiting lists for newer oral and injectable weight-loss products, and newly licensed oral GLP-1s. An unlicensed medicine cannot be advertised at all, under regulation 279. A waiting list for one is a promotion of it. And the oral semaglutide that went on sale on 6 July 2026 is a POM like the injections. The MHRA's Julian Beach put the principle plainly: "A consultation with a healthcare professional is the most appropriate way to determine suitable treatment options for an individual patient".
Patient testimonials raise their own questions under the CAP Code and consumer law, which we cover in our article on patient reviews. The short version for weight loss: a review that names the medicine is an advert for the medicine, and hosting it on your site makes you the publisher.
What can you still say?
Quite a lot, provided the subject is the service and the reader is offered a consultation rather than a product. The following wording is consistent with Appendix 6 and the enforcement notice.
- "Private weight management service, led by a pharmacist prescriber" names the service and who runs it.
- "We treat obesity and weight-related conditions" states the conditions treated, which the notice expressly permits.
- "Book a consultation. Treatment is only prescribed if it is clinically appropriate for you" makes clear a prescription may not follow.
- "Programmes from £X a month" on a home page is an indicative price for a condition, not a medicine price, if no medicine is named.
- A factual price list of treatments on an inner page, with no product claims and no buy buttons.
- Clinical support, monitoring and follow-up described as part of the service, which also reflects what the GPhC expects a service to deliver.
Audit every public-facing surface against the updated enforcement notice, not against what competitors are doing. That means the home page, treatment pages, paid search, social accounts, affiliate and influencer briefs, email and printed leaflets. Remove medicine names, GLP-1 and injection wording, pen imagery and medicine prices. Check where each advert lands. Then put marketing sign-off in the superintendent's hands, because the GPhC will hold that person responsible alongside the owner. The MHRA's 2026 list shows the ASA's scanner finds breaches without a complaint, and it names the company either way.
Getting the advert right does not get the service right. What must happen after the click, from independent BMI verification to follow-up, is covered in our guide to the verification duties.
Key takeaways
- Regulation 284 of the Human Medicines Regulations 2012 bans any advertisement likely to lead to the use of a prescription-only medicine. Regulation 303 makes breach an offence with up to two years' imprisonment.
- You may advertise a weight-loss service or consultation, but the Blue Guide's Appendix 6 says services must not draw attention to specific POMs, and a home page must not mention one.
- The joint enforcement notice of 11 April 2025, updated on 23 September 2025, prohibits indirect references including "weight-loss injection", "GLP-1", pen imagery, medicine prices and landing pages that promote a POM.
- In July 2025 the ASA ruled against nine advertisers, six of them pharmacies, after scanning more than 20,000 adverts from 35 pharmacies. Only 80 named a medicine, but indirect references were ruled breaches too.
- The MHRA acted against more than 25 businesses in 2025 and named 18 companies in the first six months of 2026, including Tesco Pharmacy.
- Influencer posts, discount codes and organic social content are adverts for the medicine, and the pharmacy that arranges them is the publisher.
- Advertising was 17 per cent of the 1,307 weight-management concerns the GPhC received in 2024 and 2025. The GPhC can act against the pharmacy, the owner, the superintendent and individual registrants.
Sources and further reading
- Human Medicines Regulations 2012
- The Blue Guide, advertising and promoting medicines (MHRA)
- Advertise your medicines (GOV.UK)
- Enforcement notice: advertising of prescription-only weight-loss treatments (ASA, CAP, MHRA and GPhC)
- GPhC joins forces with other regulators over advertising of weight management medicines (GPhC, 11 April 2025)
- MHRA and partners unite to reaffirm prescription weight-loss medicine advertising rules (GOV.UK, 26 September 2025)
- Advertising investigations by MHRA (GOV.UK collection)
FAQs
Paid search is the same rule, harder policed.
Google's own pharmacy policies sit on top of the MHRA and ASA rules, and an ad that names a medicine can cost you the account as well as a ruling. Our guide covers what pharmacies can and cannot run.
Read the guide