Non-NHS provision of medicines: what are the issues?

Access to medicines privately has increased in recent years, largely driven by online pharmacies. As part of a wider switch to digital provision, this has brought a significant increase in convenience, but at what cost? As weight-loss medications drive a surge in private — often online — access to medicines, the Department of Health and Social Care (DHSC) launched a call for evidence on 12 August 2025 to understand the landscape around private prescribing and medicines supply.

Backing the call in the document’s foreword, the UK’s four chief pharmaceutical officers say they “want to ensure that improving convenience and choice” in how medicines can be accessed “does not inadvertently reduce safety or quality of care”.

The government says that in a world where increasing access to private prescription medicines has provided convenience, flexibility and choice for patients, it is also vital to ensure the checks and balances are in place to support patient safety.

Several concerns have been expressed in recent years over the availability of privately obtained medicines in recent years, again, often online, and the General Pharmaceutical Council has made various attempts to introduce stronger checks and balances.

As pharmacists consider how they could contribute to the call for evidence, The Pharmaceutical Journal looks at the current private medicines supply landscape.

Who is accessing medicines privately?

The call for evidence will consider prescriptions written by prescribers registered in the European Economic Area and Switzerland that are dispensed in the UK, private prescriptions written by UK prescribers, and medicines accessed through patient group directions (PGDs) outside of the NHS.

This could cover anything from a private flu jab or travel vaccine delivered in a community pharmacy, to privately prescribed medications, including weight-loss drugs, ADHD medication, HRT and medical cannabis.

James Kingsland, a GP and chair of the Digital Clinical Excellence (DiCE) network, which supports digital healthcare providers within primary care, says there has been an “exponential rise” in people accessing private healthcare, particularly for weight management — with, he says, an estimated 1.7 million people choosing to pay for weight-loss medication privately in May 2025.

“That sort of order on a monthly basis, [is] going to online providers just for weight management — never mind all the other services you get online. It’s a significant future for healthcare in this country, and it’s driven by patient choice — not by marketing or selling. It’s based on a need that sometimes many of the services are not provided by the NHS,” he explains. 

National Institute for Health and Care Excellence (NICE) guidance is based both on efficacy and the cost to the NHS of a drug, and while non-NHS prescribers are expected to follow good practice, they are not bound by local formularies in the same way NHS prescribers are.

This can mean medicines are prescribed differently under private practitioners in a way they would not be under the NHS. For example, a review of evidence published in The Pharmaceutical Journal in February 2025 revealed that private menopause care often leads to testosterone being initiated earlier than recommended, possibly driven by patients who are paying for treatment and have higher expectations than those treated within the NHS. The review authors also pointed out that once a prescription has been advised or even started in the private sector, it was difficult for GPs to disagree with the advice of a specialist and refuse to prescribe.

The call for evidence will consider the impact of private medicines supply on health inequalities, as the private market could mean those with the means to pay privately have different access to medicine than NHS patients.

Private supply of medication can also impact the availability of drugs for NHS patients, such as in 2023, when off-label prescriptions for semaglutide for weight loss drove a shortage of the GLP1-RA for people with type 2 diabetes mellitus.

On rare occasions, the government has intervened in private medicines supply. In March 2024, the NHS stopped routine prescriptions of puberty blockers to patients aged under 18 years, in response to a NICE evidence review. The findings were echoed in the Cass review of gender identity services, published in April 2024. Then, in June 2024, an emergency three-month order banned private or overseas prescriptions of the medicines. The ban was renewed twice more and then made indefinite on 1 January 2025. The impact of this ban is one of the questions the DHSC wants to answer in its call for evidence.

How is private access to medicines currently regulated?

As it stands, the private supply of medicine weaves its way through a variety of regulatory bodies — from drug licensing by the Medicines and Healthcare products Regulatory Agency (MHRA); marketing and communications by the Advertising Standards Authority (ASA) and the Association of the British Pharmaceutical Industry (ABPI); to prescribing and supply by the General Pharmaceutical Council (GPhC), Care Quality Commission (CQC) and other professional regulators.

Any supply of medicine from a provider not regulated by the GPhC or CQC is illegal, whether it is provided online or in-person, or supplied privately or by the NHS. On 25 August 2025, the pharmacy regulator urged the public to check an online pharmacy’s registration number to avoid falling prey to fake pharmacies supplying potentially harmful substances. 

Kingsland also suggests that an additional quality standard akin to the British Standards Institution’s kitemark could give people “confidence and trust” in private prescribers.

Prescribing professionals and a legally defined list of professionals who can work under PGDs are regulated by their own professional regulators. In March 2024, pharmacy technicians — who are regulated by the GPhC — joined the list of professions able to be named on a PGD.

PGDs cannot legally be used for unlicensed medications, but they can be used for an off-label or off-license use of the medicine if they state why this use is recommended with reference to the supporting evidence or guidance. They must be authored by a pharmacist and a doctor/dentist with relevant clinical skills, who are subject to their own professional regulator. And they must follow the law set out in the Human Medicines Regulations 2012.

“UK-registered healthcare professionals delivering private services are subject to the same professional regulations and standards as their NHS counterparts,” explains Malcolm Harrison, chief executive of the Company Chemists’ Association.

“They should abide by the standards and guidance given by the professional regulator and any policies their employer has in place, as well as taking into account national clinical guidance.”

However, Harrison adds: “A small minority of pharmacies work with prescribers, often from overseas, who at times may not fully adhere to UK regulations and standards.”

“This puts patients at risk of harm,” he adds. “We hope that this consultation will help to address the matter of private prescribing that does not confirm with UK standards and regulations, whilst maintaining patients’ access to high-quality private services.”

PGD and prescribing practices and support for clinicians can vary from provider to provider. For instance, an investigation by The Pharmaceutical Journal, results of which were published in April 2025, revealed that distance-selling pharmacies continue to fail GPhC inspections at a higher rate than their bricks-and-mortar counterparts. In August 2025, the regulator raised concerns relating to the supply of medicines from non-UK providers, while fake, unregulated and illegal online sellers inappropriately supplying medication frequently hit the headlines.

Challenges around private medicines supply

Even pharmacies that are operating legitimately face challenges when it comes to private medicines supply. In 2024 the GPhC introduced tougher guidance that requires prescribers to “independently verify” certain information, such as height and weight, when supplying weight-loss medication, rather than simply relying on asynchronous questionnaires.

But this isn’t always straightforward. GPs have pushed back on providing this information to private prescribers, citing workload concerns. And, although changes to the GP contract will make it compulsory from 1 October 2025 for GPs to give providers of private healthcare read-only access to patient care records, private providers must obtain explicit permission from the patient to do so.

Some critics think regulation needs to go further. Arran McFaull, head of medical information and compliance at Pharmadoctor, which provides clinical services packages to pharmacies, suggests the DHSC review should consider whether online provision of certain services is appropriate.

“If there’s no face-to-face consultation with a healthcare professional, who’s to say that what the patient’s inputting on the system is correct? … That leads to huge risks of someone potentially lying to get medication, medication misuse, no training to the patient about how to use the medication, things like that. So I think this is an opportunity for us to review that and hopefully make a change there for the positive,” he says.

The issue of accessing a patient’s records — and of verifying that they are telling the truth about their condition, other medications and contraindications — is not new, and is not limited to weight-loss medications. In 2019, the Royal Pharmaceutical Society (RPS) called for an investigation after several online pharmacies supplied opiates to an investigative reporter without contacting their GP — against GPhC guidance.

The lack of integrated IT systems between private and NHS settings is also an issue. While medicines prescribed in NHS primary care and dispensed in the community use the electronic prescription service (EPS), private prescriptions do not — they must be checked and verified by the dispenser. The DHSC calls for evidence asks dispensers whether they find it difficult to verify the authenticity of paper prescriptions from UK private prescribers and EEA prescribers.

More information needed 

One thing that is clear about the world of private prescribing is that its impact on patients and medicines supply is often, to the outside world, unclear. Organisations like DiCE and Pharmadoctor say they collect a wealth of information on what medicine is being provided to patients, and how — and would be willing to share evidence with government to make medicines access safer for all. 

Meanwhile, both the GPhC and the RPS have told The Pharmaceutical Journal that they are currently considering their responses to the consultation. However, pharmacists working in all settings have experience, data and opinions that could contribute to the government’s wide-ranging call for evidence, which closes on 4 November 2025.