Is the pharmacist prescribing clinic loophole the same across the UK?

No. Wales and Scotland have addressed this gap because they recognised it was happening. In England, at the time of writing, the loophole is still there. This is one of several areas where prescribing and regulation differ across the four UK nations, so where you practise matters.

If the clinic isn't regulated, does that mean the pharmacist isn't either?

No — and this is the crucial point. Even if the business is not a CQC-registered clinic or a GPhC-registered pharmacy, you as a pharmacist are still regulated by the GPhC. The GPhC can investigate and raise fitness to practise, and many pharmacists have got into trouble for not following good practice. The gap is in the business, not in you.

Should you rely on the loophole when setting up a private clinic?

No. Even where a business escapes formal registration, you carry the clinical and professional responsibility, and the direction of travel is towards closing these gaps, as Wales and Scotland already have. The sensible approach is to set the clinic up properly — governance, scope, documentation and the right registrations — rather than relying on a gap that may not survive, and that never removes your personal GPhC accountability.

Prescribing · Compliance

The Regulatory Loophole for Pharmacists: Who Regulates a Private Prescribing Clinic?

Q: Who regulates a pharmacist-led private prescribing clinic?

It depends on the setup, and that is exactly where the loophole sits. The CQC regulates clinics and professions such as doctors and nurses; the GPhC regulates pharmacies and pharmacists. A solo independent prescriber pharmacist running a private prescribing service — with no doctors or nurses involved, and not operating as a registered pharmacy — can fall into the gap, so the business itself may end up without the regulatory oversight people assume is there. Always verify the current position for your specific service with the CQC and GPhC, because the rules and exemptions are nuanced and change.

Q: What standards must a pharmacist prescriber follow?

You must follow good practice and the GPhC's Standards for Pharmacy Professionals, and when prescribing you should work to the RPS Prescribing Competency Framework. Following these is what protects your registration, whatever the regulatory status of the premises or business you work in.

Faheem Ahmed·11 August 2026·7 min read

The clinic can slip into the gap between the two regulators — but the pharmacist never does.

Here’s a question I got that’s sharper than it sounds: an independent prescriber pharmacist can open a private prescribing clinic almost anywhere — so who actually regulates it? The honest answer exposes a genuine loophole, and understanding it protects you either way.

The short version

The setup: an independent prescriber can open a private prescribing clinic almost anywhere.
The gap: a solo pharmacist clinic can fall between the CQC (the clinic) and the GPhC (the pharmacy) — so the business may have no clear oversight.
Not UK-wide: Wales and Scotland have addressed it; in England the loophole is still there.
The catch: the gap is in the business, not in you — the GPhC still regulates you.
The rule: follow good practice, the Standards for Pharmacy Professionals and the RPS competency framework, whatever the premises.

This is the written companion to my short video answering exactly this question. Watch it here, then read on for the detail.

The question: who regulates the clinic?

An independent prescriber can, technically, open up a clinic almost anywhere and prescribe on private prescriptions. And because they’re prescribing privately — not as an NHS pharmacy — the obvious question is: who is regulating that? Think about how regulation is usually carved up. The CQC regulates clinics and a range of professions and settings — doctors, nurses and the like. The GPhC regulates pharmacies and pharmacists. So what happens when a pharmacist decides to run a prescribing service on their own — no doctors, no nurses involved, and it isn’t a registered pharmacy? Who regulates that business?

A solo pharmacist prescribing clinic can fall between the two regulators.

The CQC framework is built around certain settings and professions; the GPhC is built around pharmacies and pharmacists. A one-person private prescribing clinic can slip through the middle.

The loophole — and where it’s already been closed

As it stands, this is a real loophole, and it’s one that has already been addressed in Wales and in Scotland, precisely because the regulators there recognised it was happening. In England, at the time of writing, the loophole is still there. I say this not as a how-to for dodging oversight, but because I’m genuinely speaking to people for whom this is a live question — it does happen, and you need to understand it clearly.

But make no mistake: you’re still regulated

Here’s the part that matters most, and the part people get dangerously wrong. Even if the business has no clear regulatory oversight, you as a pharmacist are still regulated by the GPhC. That doesn’t switch off because you opened a private clinic. There are many instances where pharmacists have got into trouble — because they didn’t follow good practice, or did something they shouldn’t — and the GPhC can still investigate and raise fitness to practise. (I’ve written openly about what the fitness-to-practise process is actually like.)

So the gap is in the business, not in you. Whatever the premises, you are expected to work to good practice and the GPhC’s Standards for Pharmacy Professionals, and when you prescribe you should be working to the RPS Prescribing Competency Framework. That is what protects your registration — not the regulatory status of the building.

	The business / clinic	You, the pharmacist
Who regulates it	Possibly no clear regulator (the loophole)	Always the GPhC
England vs devolved	Loophole open in England; addressed in Wales & Scotland	GPhC applies wherever you practise
What governs you	CQC / GPhC registration where it applies	Good practice, Standards for Pharmacy Professionals, RPS framework
The risk	May escape formal registration — for now	Fitness to practise if you fall short

So what should you actually do?

Don’t build a clinic on a loophole. Even where a business currently escapes formal registration, two things are true: you still carry the clinical and professional responsibility, and the direction of travel is towards closing these gaps — as Wales and Scotland already have. The sensible move is to set the clinic up properly from the start: clear scope, governance, documentation, indemnity and the right registrations for the activities you actually provide. That’s also the version that survives when the rules change. (If you’re weighing prescribing up more broadly, see is community pharmacy independent prescribing worth it? and how to set up an online prescribing service safely.)

How I can help

This is exactly what our GPhC & CQC compliance work is for — helping clinicians set up a private clinic properly, understand which registrations apply, and keep their registration safe. If you’re setting up or already running a prescribing service and want it done right, get in touch.

Work with me

Important: this article is educational commentary and reflects my reading of the position at the time of writing — it is not legal or regulatory advice, and nothing here encourages avoiding regulation. Whether a specific service requires CQC registration (and how GPhC standards apply) is nuanced, varies across the UK nations, and changes over time. Verify the current requirements for your particular service directly with the CQC and the GPhC, and take professional advice before you set up.

Frequently asked questions

Who regulates a pharmacist-led private prescribing clinic?

It depends on the setup, and that’s where the loophole sits. The CQC regulates clinics and professions such as doctors and nurses; the GPhC regulates pharmacies and pharmacists. A solo independent prescriber pharmacist running a private service — no doctors or nurses, not a registered pharmacy — can fall into the gap, so the business itself may lack the oversight people assume is there. Verify the current position for your specific service with the CQC and GPhC.

Is the loophole the same across the UK?

No. Wales and Scotland have addressed it because they recognised it was happening. In England, at the time of writing, the loophole is still there. Prescribing and regulation differ across the four nations, so where you practise matters.

If the clinic isn’t regulated, is the pharmacist unregulated too?

No — and this is the crucial point. Even if the business isn’t a CQC-registered clinic or a GPhC-registered pharmacy, you as a pharmacist are still regulated by the GPhC, which can investigate and raise fitness to practise. The gap is in the business, not in you.

What standards must a pharmacist prescriber follow?

Good practice and the GPhC’s Standards for Pharmacy Professionals, and when prescribing, the RPS Prescribing Competency Framework. Following these is what protects your registration, whatever the regulatory status of the premises.

Should you rely on the loophole to set up a clinic?

No. You still carry the clinical and professional responsibility, and the direction of travel is towards closing these gaps, as Wales and Scotland already have. Set the clinic up properly — governance, scope, documentation and the right registrations — rather than relying on a gap that may not last, and that never removes your personal GPhC accountability.

Faheem Ahmed

Educator, author and consultant across healthcare and education — and the voice behind The Pharmacy Guy. He supports clinicians, teams and prospective owners through teaching, training and consultancy, including setting up private clinics and prescribing services properly.

Watch on YouTube →

Comments

Running or setting up a private prescribing clinic — or want me to break down which registrations actually apply? Leave a comment below; I read them all.