The General Pharmaceutical Council (GPhC) has reminded pharmacists, pharmacy technicians and pharmacy owners of the importance of maintaining indemnity arrangements that accurately reflect the work they carry out. As clinical services expand and supervision models evolve, the regulator is seeing more cases where indemnity cover does not match day‑to‑day practice, creating avoidable risk for both individuals and pharmacy businesses.
Under Article 32 of the Pharmacy Order 2010, all registrants and pharmacy owners must have appropriate indemnity arrangements in place. The GPhC emphasises that “appropriate” means cover that aligns with the actual activities being undertaken, not simply what is written in a job description or assumed from a traditional role. Indemnity may be provided by an employer, a professional body, a defence organisation or a combination of these, but none of these arrangements will protect registrants if the policy does not explicitly cover the services they now provide.
The regulator notes that changes in supervision requirements and the rapid expansion of clinical services are creating gaps in cover. Many registrants are now involved in prescribing, using PGDs, undertaking undifferentiated clinical assessments, providing remote consultations or taking on expanded supervisory responsibilities. If these activities are not clearly included in indemnity documentation, both registrants and pharmacy owners may be exposed to financial, operational and regulatory consequences.
To reduce this risk, the GPhC advises registrants and employers to regularly review job descriptions and compare them with actual practice, ensuring that indemnity policies explicitly cover all current activities. Any changes in roles, responsibilities or service models should be communicated to indemnity providers, and pharmacy owners should confirm the extent of employer cover, particularly for locums, and consider whether contingent indemnity is required. The regulator also highlights the importance of keeping written evidence of role changes, training and competency assessments, and ensuring that staff have the necessary skills and accredited training to work within their scope of practice and GPhC standards.
Although the GPhC’s update focuses on safe and effective practice, indemnity gaps can also have implications for regulatory processes. Where a pharmacist or pharmacy technician undertakes work outside the scope of their indemnity, or where a pharmacy owner has not ensured appropriate cover, concerns may escalate into fitness to practise or inspection‑related issues, especially if patient safety is affected. This reinforces the need for robust governance, clear documentation and proactive oversight within pharmacy settings.
Kings View Resolutions supports pharmacies in reviewing governance arrangements, identifying risks and ensuring compliance with GPhC standards. Many pharmacies seek advice when expanding clinical services, preparing for inspection, responding to improvement plans or managing regulatory concerns. Our regulatory reviews, mock inspections and internal investigations help pharmacy owners identify gaps before they become enforcement risks, strengthening compliance and supporting safe, resilient practice.
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Disclaimer: This article is for guidance purposes only. Kings View Chambers accepts no responsibility or liability whatsoever for any action taken, or not taken, in relation to this article. You should seek the appropriate legal advice having regard to your own particular circumstances.
