The Prescription Medicines Code of Practice Authority (PMCPA) has published revised guidance on social media.

Social media has remained a significant focus for the PMCPA in recent years, with numerous companies found in breach of the ABPI Code (the Code) due to activity on social media by the companies themselves, their employees, or associated third parties. Compliance in this space is particularly challenging given the global reach of social media and its inherently public nature, especially when the promotion of prescription-only medicines (POMs) to the public is prohibited in the UK.

The PMCPA’s earlier social media guidance, first published in 2023, was therefore highly anticipated. While the newly updated guidance retains many of the key principles, it adopts a completely revised format. It is now presented as a series of website pages incorporating Q&As and links to relevant PMCPA cases. According to the PMCPA, this new structure is intended to support more regular updates in response to the rapidly evolving social media landscape.

The guidance is divided into the following sections:

• Social media principles
• Responsibility
• Types of activity
• Types of content
• Working with others

The guidance consistently emphasises the need for companies to understand the specific social media platforms they use, recognising that these channels are inherently proactive and can easily give rise to promotional activity. The guidance also highlights the importance of robust governance: ensuring that activity is properly monitored and maintained, fulfilling pharmacovigilance obligations, overseeing comments to identify and address any non-compliant or inappropriate content, and managing risks when staff responsible for corporate accounts leave the organisation.

This blog focuses on the sections of the guidance where there have been significant updates from the previous guidance:

Clinical trial recruitment

This is a new section, reflecting the recently published memorandum of understanding (MOU) between the ABPI, the PMCPA and the Health Research Authority (HRA), which came into effect on 1 February 2026. The MOU provides that where the PMCPA receives a complaint relating to clinical trial recruitment materials that have been approved by the HRA, those materials will be regulated and adjudicated upon by the HRA rather than the PMCPA.

The guidance notes that questions about clinical trial recruitment materials, including those on social media, should be directed to the HRA given its specific regulatory remit in this area. It also clarifies that companies do not need to certify participant-facing clinical trial recruitment advertisements on social media and they are not within the scope of Clause 8.3 of the Code.

Responding to misinformation

The PMCPA acknowledges that this is a difficult area to give specific guidance on, as much will depend on the nature of the misinformation and any potential harm to patients. Companies should establish their own policies and are reminded to always put patient safety first.

Companies are reminded that if they become aware of misinformation about their medicines posted by their own employees or by third parties, action should be taken as soon as possible to have the posts corrected or removed, as the company may be held responsible under the Code. Requesting the correction of a factual inaccuracy alone is not enough to compromise an arm’s‑length relationship, provided the company attempts to correct all inaccuracies about its medicines in the material in question.

Companies are encouraged to consider whether it would be preferable to approach the account holder privately with a correction first and only escalate publicly if no correction is made. The guidance also notes that companies should consider whether it is more appropriate to refer to regulatory documents in general terms (e.g. PIL or SmPC) rather than citing specific sections, as referring only to a section may introduce an element of judgement.

The guidance also acknowledges the complexity of jurisdictional issues arising where posts are globally accessible; companies should take care to ensure that the intended audience is made clear when providing corrected information.

Signposting

The PMCPA highlights that the distinction between disseminating information directly and signposting to information is “critical to engaging with stakeholders on social media compliantly”. Signposting, whereby companies direct an audience to information without communicating that information directly, must be used when the information being signposted is intended only for a specific audience, such as healthcare professionals.

A compliant signpost must:

• enable the viewer to determine whether the information is relevant to them and decide whether to access it;
• be appropriate for the public;
• not promote a POM to the public;
• not promote an unlicensed medicine.

The guidance provides helpful examples of acceptable approaches. Depending on the content of the material that is being signposted to, the individual may need to confirm their status prior to accessing further or be validated by the pharmaceutical company. For example, it might be acceptable for a healthcare professional to self attest to access the page to register for an event that is suitable for healthcare professionals only.  However, more formal validation by the pharmaceutical company might be required prior to the individual attending the event.

News for an investor audience / the media

In this area, the PMCPA again emphasises the importance of differentiating between direct dissemination and signposting. Signposting must be used when the underlying information is intended only for investors or the media.

Recommended safeguards include:

• ensuring the information is genuinely newsworthy and tailored to the intended audience;
• making the intended audience prominent at the outset in both the post and the linked content, although self-attestation is not required;
• ensuring all information is factual, balanced, and does not encourage the public to seek a specific POM;
• avoiding naming medicines (brand or non‑proprietary) in the body of a social media post, as this is likely to be considered promotional;
• posting such information only on accounts likely to be followed by the intended audience (e.g. the accounts of senior executives);
• avoiding excessive posting about the same news, as this might constitute promotion.

The guidance includes helpful examples of compliant communications of financial results, new product authorisations, new major published data, and a new company acquisition.

Pharmacovigilance responsibilities

The revised guidance reiterates that, in line with MHRA expectations, companies must have mechanisms to identify adverse events and events of special interest reported or mentioned on social media platforms owned by the company or under their control.

Companies may add general information to their social media platforms signposting users on how to report adverse events, for example signposting to the company website. They may also provide this information in response to reports where it is not possible to ascertain validity or where further information is required.

While monitoring is more challenging on channels not owned or controlled by the company, the guidance states that if non‑company channels are being screened for any reason, adverse event information should still be collected where possible, although follow‑up or further signposting may not always be feasible.

The guidance also reminds companies that it is permissible to disable posts, comments and direct messages on company‑owned or sponsored accounts to avoid the need to signpost or monitor.

Scope of the ABPI Code

The key principle remains unchanged: for social media activity to fall within the scope of the ABPI Code, there must be a UK nexus. The revised guidance includes further detail on when and how a UK nexus may be established and provides diagrams illustrating scenarios where a nexus clearly does, does not, or may possibly exist.

Factors indicating a UK nexus include activity posted by:

• a UK company;
• a third party contracted by a UK company;
• a member of staff who lives in the UK or has a contract with a UK company.

Social media influencers

The revised guidance contains additional detail on the due diligence companies must conduct when working with influencers and the requirement to monitor influencer activity. Companies are expected to review influencers’ past posts and assess risks such as promotional language, misleading content or lack of transparency.

Companies may remain responsible for an influencer’s activity even after the contract ends if the content relates to the contractual subject matter. Contracts should therefore clearly address the handling of posts and materials after the end of the arrangement, including deletion requirements.

Companies should monitor influencers’ accounts, at least during the contractual period, to ensure content remains appropriate, including monitoring user comments for pharmacovigilance purposes.

Transparency is essential. The relationship between the company and the influencer must be made clear at the outset. Use of “#ad” is not sufficient; the declaration must be unambiguous so that readers immediately understand the extent of company involvement.

Declaration of involvement for sponsored meetings and events

This new section highlights the requirements relating to declaration of sponsorship of meetings and events, including how this applies to social media.

Any social media material related to events or meetings sponsored by a pharmaceutical company must clearly declare the sponsorship. This includes meetings funded by grants, such as CME‑accredited programmes.

Where there are multiple sponsors, these may be listed on a separate, clearly linked page provided it remains clear from the face of the post that pharmaceutical companies are among the sponsors.

The requirement applies beyond the duration of the event: posts published after the event or retained on webpages must continue to include the declaration.

Conclusion

The additional detail and practical examples in the new guidance provide welcome clarity. However, given the open and transient nature of social media, pharmaceutical companies must continue to think carefully before engaging in or facilitating discussions about medicinal products on these platforms.

Companies are advised to:

• assess the potential reach of any activity, including who may receive the information and what controls exist to prevent sharing or re‑sharing with unintended audiences such as the general public;
• ensure that third parties, including consultants, are aware of Code requirements. Written agreements should address ownership, control and withdrawal of materials during and after the contractual period. Companies are strongly advised to preview social media content from contracted parties;
• develop UK‑specific policies and procedures regarding social media use, including expectations of employees when using company accounts or interacting with third‑party and personal accounts. Policies should address monitoring, responding to and correcting information and fulfilling pharmacovigilance obligations;
• only use a particular platform if confident that the company can meet all Code requirements and comply with platform terms and conditions. Companies must be fully aware of platform functionality and limitations and have systems in place to identify changes.