The General Pharmaceutical Council regulates pharmacists, pharmacy technicians and registered pharmacies. That last point shapes how concerns about individuals arise. A concern about you can come from a patient, an employer or a colleague. It can also come from one of the GPhC's own inspectors during a visit to the pharmacy where you work. Whichever way the concern reaches the GPhC, the Pharmacy Order 2010 and guidance the GPhC publishes then set its route. This guide explains how GPhC fitness to practise cases run, from investigation to appeal.
The investigation
The GPhC's guidance for pharmacy professionals facing a concern explains what it may do. It may send you a copy of the concern and ask for your response, visit your pharmacy and take witness statements. It may also ask you to undergo an assessment of your English. In a health case it may ask for information from your doctor or for a medical examination. The GPhC gives two different statements of its target time. The guidance page says it aims to complete investigations in less than a year. Its FAQs, by contrast, say it usually finishes within six months. Both promise an update every two months. While the investigation runs, you can continue to practise unless the GPhC tells you otherwise.
The threshold criteria
At the end of an investigation the GPhC tests the case against published threshold criteria. They appear in its investigations and threshold criteria guidance, last updated in October 2025. The registrar should not refer a case to the Investigating Committee unless the evidence as a whole suggests that the conduct or performance:
- presents an actual or potential risk to patient or public safety
- undermines, or is likely to undermine, confidence in the pharmacy professions
- involves a serious or persistent failure to meet the standards for pharmacy professionals, or
- means your honesty or integrity can no longer be relied on.
A separate limb covers adverse physical or mental health that presents a risk to safe practice. In every case the referral must also be in the public interest. In applying the criteria the registrar considers, among other things, whether your actions were reckless or intentional. The registrar also considers whether the concern reflects a recurring issue and whether you acted with openness and honesty.
Your response to the investigation is your chance to address those factors directly. Show that the error was isolated, explain what you did when you discovered it, and set out what has changed since. If the registrar does not refer the case, it closes, sometimes with informal advice. For some health and performance concerns the GPhC may instead propose a voluntary agreement. Under it, you work with the GPhC to manage the issue.
The Investigating Committee and a choice you hold
If the registrar refers the case, the Investigating Committee decides whether it ought to go to the Fitness to Practise Committee. The committee may decide that a hearing is unnecessary. In that case, article 53 of the Pharmacy Order 2010 lets it give you a warning, recorded in the register, or advice. The same article lets the person concerned request a referral to the Fitness to Practise Committee. If you dispute the facts and a recorded warning would harm your career, that right is worth knowing about. Even so, use it only after careful advice, because a hearing carries the full range of sanctions.
The Fitness to Practise Committee
The Fitness to Practise Committee sits as a panel of three: a chair, a registered pharmacy professional and a lay member. It decides in three stages whether the facts are proved, whether your fitness to practise is impaired and what action to take. The standard of proof is the balance of probabilities. Health hearings must take place in private. Most other hearings are public, with a power to sit in private where your interests outweigh the public interest.
If it finds impairment, article 54 allows it to give a warning or impose conditions for up to three years. It may also suspend your registration for up to 12 months, or remove you from the register. The GPhC's own page adds that outcomes can include undertakings. Where there is a serious risk, the GPhC can apply to the committee for an interim order. That order can suspend you or impose conditions while the GPhC investigates.
After the decision
You have 28 days to appeal to the High Court. The outcome does not take effect until that period ends or the court decides any appeal. A High Court appeal runs through a regulated law firm Eloquia works with, because conducting litigation is a reserved legal activity. To cover the appeal period, the committee can impose interim measures, and those take effect at once. The Professional Standards Authority can also refer a decision it considers unduly lenient to the court. It must do so within 40 days, in addition to your own appeal period.
Eloquia acts for pharmacy professionals before the GPhC on our GPhC page, part of our track for other healthcare professionals. We quote a fixed fee for each stage before it starts, stated plus VAT. That fee includes a specialist barrister whom we involve from the outset. We quote expert fees separately, and our fees and funding page explains how staged payment works.
Practical points
The GPhC's examples of what it investigates include dispensing errors, criminal conduct, dishonesty or fraud, working under the influence of drink or drugs, and poor professional performance. In an error case, the strongest response pairs a candid account with documentary evidence of the changes made. Examples include revised standard operating procedures, audit results and training records. In a dishonesty case, the threshold criterion on integrity is engaged from the outset, and the response needs care from the first line.
Sources
- GPhC: Guidance for pharmacy professionals facing a concern
- GPhC: Fitness to practise FAQs
- GPhC: Good decision making, investigations and threshold criteria guidance (updated October 2025)
- GPhC: What the Fitness to Practise Committee does
- Pharmacy Order 2010, article 53 (Investigating Committee)
- Pharmacy Order 2010, article 54 (Fitness to Practise Committee)
