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Additional minimum requirements for pharmacists to assume the role of the Responsible Pharmacist (RP) are not needed, the Royal Pharmaceutical Society (RPS) has said.
The Society made its recommendation in a response to the General Pharmaceutical Council’s (GPhC’s) consultation on draft rules and standards for Responsible Pharmacists and Superintendent Pharmacists, which has asked whether the regulator should set minimum requirements for a pharmacist to become an RP and if there should be additional minimum requirements for a superintendent pharmacist.
“The RP must be a registered pharmacist, and introducing any additional requirements would create unnecessary bureaucracy and make pharmacy practice more difficult,” the Society said.
It added that introducing additional criteria has the potential to undermine the delivery of services, as it could reduce the pool of pharmacists able to fulfil the role.
The RPS suggested that the focus should instead be on ensuring safe operation of the pharmacy premises, which includes supporting pharmacists who choose not to sign in as the RP when they believe it would be unsafe to do so.
In its response to the consultation, published in February 2026, Community Pharmacy Scotland agreed, noting that “if there is a gap between the standards met to join the register and those required to perform the role of the RP then this must be addressed as a matter of urgency via initial education and training standards” and the foundation training year.
The RPS also said that there is “a conflict with the authorisation legislation, as Regulation 220B/228 SI indicates that only the authorising pharmacist can amend or withdraw an authorisation they have issued, whereas the GPhC’s draft standards suggest that the Responsible Pharmacist may also vary an authorisation”.
In a statement published alongside its response, the Society said: “[The] RPS is supportive of the provision for RPs to do this as their overarching responsibility is for the safe running of a pharmacy. However, this requires unambiguous resolution from the regulator.”
The RPS is neutral on the question of whether superintendent pharmacists should be subject to additional requirements to fulfil the role. However, it pointed out that while “safeguarding the public and ensuring the safe delivery of services through a registered pharmacy is essential”, there are significant differences and complexities between being a superintendent pharmacist of a single pharmacy and multiple pharmacies.
“[It is] essential that a registered pharmacist uses their own professional judgement to determine whether they feel competent, alongside the responsibility of their employer,” the RPS added.
The Society added that revalidation requirements for a superintendent pharmacist could include a “form of credentialing/microcredentialing to demonstrate ongoing assurance within the role”.
Community Pharmacy Scotland’s response highlighted there was no need for additional superintendent pharmacist requirements, adding that “experience measured in years does not necessarily indicate suitability for the role, and there are no recognised qualifications or defined experience that would be fair or reasonable to insist upon as a minimum requirement”.
Claire Anderson, president of the RPS, commented: “Pharmacists play a vital leadership role in ensuring patients receive safe, effective care. Our response reflects the profession’s commitment to proportionate, workable standards that recognise competence and support professional judgement.
“We want regulations that enable Responsible and superintendent pharmacists to deliver the highest standards of care across all settings.”
