Pharmacists and pharmacy technicians
GPhC fitness to practise: defence for pharmacists and pharmacy technicians
The General Pharmaceutical Council filters concerns through published threshold criteria and two committees. The Pharmacy Order 2010 also gives you choices that many pharmacy professionals do not know they have. This page sets out each stage from the GPhC's rules and guidance. It also covers what to do on day one and how we act for you on fixed fees.
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Day one
When the GPhC letter arrives
Do
- Note every date in the letter and diarise the deadline for your response.
- Tell your indemnity provider, union or defence association straight away.
- Keep the dispensing records, standard operating procedures, audit results and correspondence as they are, and take copies.
- Write a private note of what you remember while it is fresh.
- Speak to us before you respond to the investigation, agree a voluntary arrangement or request a referral.
Do not
- Reply to the GPhC straight away to explain yourself.
- Contact the patient or the person who raised the concern.
- Alter records, labels or logs after the event.
- Discuss the case with colleagues who may become witnesses.
- Post about it online, even in a closed group.
The stages
How a GPhC case runs, in the GPhC's own terms
The investigation
The GPhC explains its powers in its guidance for pharmacy professionals facing a concern. It may send you a copy of the concern and ask for your response. It may also visit your pharmacy, take witness statements and, in a health case, seek information from your doctor. The guidance promises an update every two months. You can continue to practise during the investigation unless the GPhC tells you otherwise.
The threshold criteria
At the end of the investigation the registrar tests the case against the threshold criteria. These come from the GPhC's investigations guidance, updated in October 2025. The registrar should not refer a case to the Investigating Committee unless two conditions hold. First, the evidence must suggest one of four things about your conduct or performance. It may present an actual or potential risk to patient or public safety, or it may undermine confidence in the pharmacy professions. Alternatively, it may involve a serious or persistent failure to meet the standards. Or it may mean your honesty or integrity can no longer be relied on. Second, the referral must be in the public interest. The registrar may close the case, issue informal guidance or refer it to the Investigating Committee. Other options are a referral direct to the Fitness to Practise Committee or an application for an interim order. Our article on pharmacists and the GPhC sets the criteria out in full.
The Investigating Committee
The Investigating Committee decides whether the case ought to go to the Fitness to Practise Committee. Where it decides a hearing is unnecessary, article 53 of the Pharmacy Order 2010 lets it give you advice or a warning. The register records any warning. The same article lets you request a referral to the Fitness to Practise Committee instead. Use that right only after advice, because a hearing carries the full range of outcomes.
Interim orders
Only the Fitness to Practise Committee can impose an interim order. Under article 56 it may suspend your entry or make it conditional for up to 18 months. It must be satisfied that the order is necessary to protect the public or otherwise in the public interest. An order in your interests is also possible. It must review the order within six months and then within each further six months. You can ask for an earlier review once three months have passed. The GPhC can ask the court to extend it by up to 12 months at a time. Our guide to interim orders explains how to prepare.
The Fitness to Practise Committee
The committee sits as three: a chair, a registered pharmacy professional and a lay member. It decides the facts on the balance of probabilities, then impairment, then the outcome. The committee holds health hearings in private. The GPhC's hearings and outcomes guidance of March 2024 lists the outcomes after a finding of impairment. They are no action, undertakings, a warning, conditions for up to three years and suspension for up to 12 months. The final outcome is removal from the register, which is not available in a case about health alone. The committee may impose interim measures under article 60 to cover the appeal period, and those take effect at once.
Appeal
Article 58 gives you 28 days to appeal to the High Court. The period begins with the date the GPhC sent the written notice of the reasons for the decision. Under its rules, the court may allow a longer period. The Professional Standards Authority may refer a decision it considers too lenient. It has a further 40 days to do so. Appeals run through a regulated law firm we work with, and we stay involved.
How we help
What you can expect from Eloquia
Saqib Khan leads your case from the first letter. A specialist barrister works alongside him from the outset, rather than appearing only once the GPhC lists a hearing. We put the most effort in early, because the stage you can still influence is the one that repays preparation. We pair a clear account of the events, set against the records, with evidence of what you have done since. That gives the decision maker a reason to close the case or to choose the least restrictive outcome.
Before each stage starts, we confirm in writing what it covers and what it costs. You then decide whether to go ahead. You deal with the same people throughout. Where a hearing follows, we prepare the evidence, the witness statements and any expert report. We also prepare you to give evidence, and we present your case.
You may also face a police investigation, an inquest or a disciplinary process at work. If so, we run every track as one strategy, so that nothing said in one forum harms you in another.
Fees
The same fixed fee approach as for doctors
We quote a fixed fee for each stage before it starts, in the same way as we do for doctors. Every fee we quote is plus VAT. You pay stage by stage, so you never pay in advance for a hearing that may not happen. We do not act on conditional fee agreements. Our fee menu for GMC cases shows how we price the stages of a doctor's case. We price the stages of your case on the same basis. Has your indemnity provider, union or defence organisation declined to help? Read our page on cover refused or limited.
Each fee is plus VAT and includes a specialist barrister. We involve the barrister from the outset to give you additional support and advice. Fees do not include additional expenses such as expert fees, which we quote separately.
Read at source
The rules and guidance this page draws on
Sources
- Pharmacy Order 2010, article 53 (Investigating Committee)
- GPhC: Good decision making, investigations and threshold criteria guidance, updated October 2025
- Pharmacy Order 2010, article 54 (Fitness to Practise Committee)
- GPhC: Good decision making, fitness to practise hearings and outcomes guidance, March 2024
- Pharmacy Order 2010, article 56 (interim orders)
- GPhC: Guidance for pharmacy professionals facing a concern
- Pharmacy Order 2010, article 58 (appeals)
- GPhC: What the Fitness to Practise Committee does
Questions and answers
Questions pharmacy professionals ask
What are the GPhC threshold criteria?
They are the tests the registrar applies at the end of an investigation before referring a case to the Investigating Committee. The evidence must suggest one of four things about your conduct or performance. It may present an actual or potential risk to patient or public safety, or it may undermine confidence in the pharmacy professions. Alternatively, it may involve a serious or persistent failure to meet the standards. Or it may mean your honesty or integrity can no longer be relied on. The referral must also be in the public interest. Our article on pharmacists and the GPhC explains them.
Can I ask for a hearing instead of accepting a warning?
Yes. Article 53 of the Pharmacy Order 2010 lets you request a referral to the Fitness to Practise Committee. That right applies where the Investigating Committee would otherwise give a warning or advice. A hearing carries the full range of outcomes, so take advice before you use the right.
How long can a GPhC interim order last?
Up to 18 months under article 56. Only the Fitness to Practise Committee can impose one. It must review the order within six months and then within each further six months. You can ask for an earlier review once three months have passed. The GPhC can apply to the court to extend the order by up to 12 months at a time.
What outcomes can the GPhC Fitness to Practise Committee impose?
After a finding of impairment it can take no action, agree undertakings or give a warning. It can also impose conditions for up to three years or suspend you for up to 12 months. The most serious outcome is removal from the register, which is not available in a case about your health alone. The committee may also impose interim measures that take effect at once to cover the appeal period.
How long do I have to appeal a GPhC decision?
Article 58 gives you 28 days to appeal. The period begins with the date the GPhC sent the written notice of the reasons for the decision. Under its rules, the High Court can allow longer. The Professional Standards Authority has a further 40 days to refer a decision it considers too lenient.
Does Eloquia act for pharmacists on fixed fees?
Yes. We quote a fixed fee for each stage before it starts, and every fee is plus VAT. Each fee includes a specialist barrister from the outset. We quote expert fees separately. Our fees and funding page explains how staged payment works.
More answers sit on our questions and answers page, and our glossary explains the terms regulators use.
Read more
Guides on this subject
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Pharmacists and the GPhC: threshold criteria, committees and your options
How GPhC fitness to practise filters concerns through threshold criteria, and the choices the Pharmacy Order gives you.
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