Why You Can’t Just Open a Pharmacy (Even If You Have the Money)
Hey everybody, it’s Faheem — The Pharmacy Guy. One of the most common questions I get is some version of: “I’ve got the money, so why can’t I just open a pharmacy?” The honest answer surprises people. In England you cannot simply open a community pharmacy, however deep your pockets — because it’s a controlled market, and the door is opened by proving need, not by writing a cheque. Here’s exactly how it works, in six stages.
The short version
- It’s a controlled market. NHS funding is finite, so entry is deliberately restricted — that’s what gives a contract its value.
- You need the pharmaceutical list. No place on the list, no NHS contract, no pharmacy.
- The rulebook is the 2013 Regs. The NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013.
- The PNA decides it. Your application must meet a need set out in the local Pharmaceutical Needs Assessment.
- It takes months, not days. Roughly 30–45 days for the application, up to six months or more with objections and appeals.
This is the written companion to my full video on the same question — the one where the word nobody warns you about turns out to be PNA. Watch it first if you like, then read on for the detail.
Stage 1: Pharmacy is a controlled market — on purpose
Start here, because everything else follows from it. You can’t just open a pharmacy off the bat because getting hold of an NHS contract is a controlled environment. That control is exactly why the contract has a value: not everyone can hold one, it’s scarce, and you have to be invited in or meet a strict set of criteria. There’s only a certain amount available.
Why is it capped? Because NHS funding is limited. Pharmacy is funded from a single government pot — on the order of £3.6 billion — and the system is designed so that a pharmacy operating at a certain level can achieve a certain level of profit. If the market were thrown wide open and everyone piled in, that profit per pharmacy would fall for everybody. So entry is controlled to keep roughly 8,000 to 9,000 pharmacies in a workable balance. The control is the value. You can’t buy a contract just because you feel like it — you have to earn entry.
This is the single idea most first-timers miss. A pharmacy isn’t a shop you can open anywhere you can afford the rent — it’s a regulated NHS service with a deliberately limited number of slots.
Stage 2: The gatekeeper is the pharmaceutical list
In legal terms, the way into the market is to get onto the pharmaceutical list — the register of premises permitted to provide NHS pharmaceutical services in an area. That’s the key thing. No place on the list, no NHS dispensing. There are two routes onto it:
- Open a brand-new pharmacy by making a successful market-entry application — the hard route, and the one this article is really about.
- Buy or take over an existing pharmacy that’s already on the list — you step into a slot that already exists.
Either way, the list is the gate. And to get a new entry onto it, you have to meet the needs set out in a particular document. Which brings us to the rulebook.
Stage 3: The rulebook — the NHS 2013 Regs
The legal framework that governs all of this is what people call the 2013 Regs — formally the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013. This is the bible, the gospel of opening a pharmacy. It’s not a single rule; it’s a whole system — a set of processes, inclusion and exclusion criteria, laid out step by step — and that system is what defines market entry.
Two bodies sit either side of it:
- The Health and Wellbeing Boards write the criteria — the assessment of what the local area actually needs.
- The Integrated Care Boards (ICBs) assess applications against it: you put an application in, and they decide whether it meets the documented need.
Stage 4: The document that decides it — the PNA
Here’s the word nobody tells you about: the Pharmaceutical Needs Assessment, or PNA. This is the document — produced by the Health and Wellbeing Board and assessed by the ICB — that your application stands or falls on. It’s published roughly every three years (with the odd interim change), and it sets out the current and future pharmaceutical needs of the population in that area.
This is the most practical thing in the whole article, so do it now: search your area plus “Health and Wellbeing Board Pharmaceutical Needs Assessment” — say “Manchester Health and Wellbeing Board Pharmaceutical Needs Assessment” — and read it. It will tell you the current and future need for pharmacy where you are.
I get a lot of enquiries that go: “Faheem, I’ve looked at my local pharmacy, the waiting times are huge, they’re clearly struggling — we should open one here.” And the answer is often: that won’t work. Busy isn’t the test. Need, as defined in the PNA, is the test. If the PNA doesn’t identify a gap, a “they look busy” application goes nowhere.
Stage 5: The four application routes
Once you understand the PNA, you can see where an application can actually come from. Broadly there are four routes — plus a couple that have largely closed.
| Route | What it is |
|---|---|
| Routine | The PNA itself identifies a need for a pharmacy, and you apply against it. Doable — but you have to be genuinely active and read the PNA closely. |
| Unforeseen | Something has changed since the PNA was published — a couple of pharmacies have closed, a new housing estate or GP practice has opened — a need that wasn’t captured at the time. |
| Expected / excepted | Changes to pharmacies that already exist: change of ownership, consolidation, or relocating a pharmacy. You’re not adding to the pot, so these are normally expected. |
| Routes now largely closed | The old 100-hour exemption (granted if you opened 100 hours a week) and distance-selling pharmacies (granted regardless of local need). These are now thin on the ground and unlikely to be available. |
When I opened my first pharmacy, the 100-hour and distance-selling routes were real options — you could be granted entry without strictly meeting a PNA need. Those doors have mostly shut, which is why the PNA matters more than ever today.
Stage 6: The process — and why it takes months
Say you’ve justified your application and met the need. What happens next?
- The application stage typically takes around 30 to 45 days, though it can run longer.
- Then come objections — other parties can object, which adds time.
- All in, the process can take up to six months or more to finalise. It can also be refused, at which point you may go to NHS Resolution, which handles disputes and appeals.
This is the real reason you can’t wake up one day and open a pharmacy by the weekend. It’s a controlled market, gated by a list, governed by the 2013 Regs, decided by a needs document, and processed over months with the chance of objection and refusal. None of that is a reason not to do it — it’s a reason to go in with your eyes open and your paperwork right.
Where to go next
If you want to take this further yourself, two things are worth knowing. Primary Care Support England (PCSE) holds the application forms, and the NHS pharmacy manual is the practical companion to the 2013 Regs for understanding and handling applications. Read your PNA, then those.
And if you’d rather not navigate it alone — I write market-entry applications start to finish, and I help prospective owners work out whether there’s a real, evidenced need before they spend a penny. If that’s you, get in touch.
Frequently asked questions
Why can’t you just open a pharmacy if you have the money?
Because community pharmacy in England is a controlled market. To dispense NHS prescriptions you must hold an NHS contract, and to get one you must be admitted to the pharmaceutical list. NHS funding is finite — a global sum of roughly £3.6 billion shared between around 8,000 to 9,000 pharmacies — so entry is deliberately restricted to protect the value of existing contracts. You can’t simply buy your way in; you have to meet a legal test of need.
What is the pharmaceutical list and how do you get on it?
The pharmaceutical list is the register of premises permitted to provide NHS pharmaceutical services in an area. You get onto it in one of two ways: by opening a brand-new pharmacy through a successful market-entry application, or by buying or taking over an existing pharmacy already on the list. A new application is assessed against the area’s Pharmaceutical Needs Assessment.
What are the NHS 2013 Regulations?
The 2013 Regs — formally the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 — are the rulebook for market entry. They set out the system of inclusion and exclusion criteria and the step-by-step process you must satisfy to be admitted to the pharmaceutical list. They are, in effect, the gospel of opening a pharmacy in England.
What is a Pharmaceutical Needs Assessment (PNA)?
The PNA is a document published by each Health and Wellbeing Board, normally refreshed about every three years. It sets out the current and future pharmaceutical needs of the local population. A market-entry application generally succeeds only if it meets a need identified in the relevant PNA — so the first thing any prospective owner should do is read their local board’s PNA. Applications are assessed by the Integrated Care Board (ICB).
How long does it take to open a new pharmacy?
The application stage typically takes around 30 to 45 days, but the whole process — including the objection period and any appeal — can run to around six months or more. Objections are handled by NHS Resolution, and an application can be refused, so realistic planning means months, not weeks.
Comments
Thinking about opening a pharmacy, or want me to break down a market-entry application or a particular PNA in a follow-up? Leave a comment below — I read them all.