Updated social media guidance: What pharmaceutical companies need to know

The Prescription Medicines Code of Practice Authority (PMCPA) has published revised and expanded guidance on the use of social media by pharmaceutical companies. The guidance reflects the PMCPA’s current interpretation of the ABPI Code of Practice, informed by UK medicines law, European Federation of Pharmaceutical Industries and Associations (EFPIA) and the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) requirements, and an increasing body of PMCPA case precedent. It is intended to help companies navigate the particular compliance risks posed by social media’s public, interactive and global nature.

While the guidance does not replace the ABPI Code, it provides important practical direction on how the Code applies in a social media context — an area that has generated a significant number of complaints and rulings in recent years.

In addition to the ABPI Code, companies are reminded that obligations also arise under advertising law and codes of practice, data protection legislation and the terms of use for social media platforms.

Scope and status of the guidance

The PMCPA emphasises that it cannot pre-approve social media activity. Any complaint will be assessed on its facts. The guidance therefore serves as a risk management tool rather than a safe harbour. 
It applies to all social media activity undertaken by or on behalf of pharmaceutical companies, including activity by employees, contractors, agencies and third parties where the company has responsibility under the ABPI Code. Importantly, the guidance stresses that sections should not be read in isolation, as core principles (such as responsibility and transparency) cut across all types of activity.

Fundamental principles

At the heart of the guidance is a reminder that social media is inherently proactive and promotional in character. Even content that appears factual or corporate can become promotional once placed in a public, interactive environment. As a result, companies must exercise particular caution to avoid:

• promotion of prescription only medicines (POMs) to the public
• pre licence or off label promotion
• misleading or unbalanced information
• failure to meet pharmacovigilance obligations

Responsibility under the ABPI Code cannot be delegated away. Companies remain accountable for content on corporate channels, content posted by third parties they engage with, and in some circumstances the social media activity of their employees, even on personal accounts.

Governance, oversight and monitoring

A theme running through the guidance is the importance of robust governance. Companies are expected to have appropriate systems in place to monitor social media activity on an ongoing basis, respond to comments, and manage user generated content. This includes identifying and handling adverse event reports and product complaints in line with pharmacovigilance requirements.

The guidance also highlights practical risks such as staff managing corporate accounts leaving the organisation, inactive accounts remaining live, and historic posts becoming non compliant due to changes in regulatory status or guidance. Social media activity is therefore treated as something that must be actively supervised.

Content specific guidance

The guidance contains detailed sections on common categories of social media content, many of which link directly to previous PMCPA cases to illustrate risk areas.

Links, hashtags, tagging and resharing

Companies are reminded that linking to third party content does not remove responsibility. Links must be appropriate, transparent about their destination, and must not lead the public to promotional POM content. Similar caution applies to hashtags, tagging other accounts, and resharing content, all of which can inadvertently contextualise otherwise compliant material in a promotional way.

Corporate news, disease awareness and patient support

Corporate announcements, pipeline milestones and disease awareness campaigns may be permissible, but only where they are genuinely non promotional and balanced. The guidance reiterates that disease awareness activity must not stray into indirect promotion, particularly where a company markets a medicine that is uniquely associated with the condition discussed.

Patient support initiatives shared on social media must be carefully structured to avoid encouraging treatment requests or implying product preference, especially where the audience may include members of the public.

Working with influencers and third parties

Recognising the growing role of influencers, the guidance confirms that companies can work with social media influencers, but remain responsible for their content under the ABPI Code. Clear contractual controls, training, and oversight are essential, and transparency around the nature of the relationship is critical.

Promotion to health professionals and clinical trial recruitment
The guidance distinguishes carefully between activity aimed at health professionals and other relevant decision makers and content accessible to the general public. Even where a platform allows targeting, companies must consider the practical risk of content being shared beyond its intended audience.

A notable recent development is the inclusion of a dedicated section on clinical trial recruitment. This reflects the new memorandum of understanding between the PMCPA, ABPI and the Health Research Authority (HRA), effective from 1 February 2026. Under the MOU, where clinical trial recruitment materials have been approved by the HRA, complaints about those materials fall within the HRA’s remit rather than the PMCPA’s.

The guidance directs companies to engage with the HRA on questions relating to clinical trial recruitment materials on social media, recognising its specialist role in this area.

Practical takeaways

Taken as a whole, the PMCPA’s social media guidance reinforces that pharmaceutical companies can, and do, engage on social media — but only with a clear understanding of the medium’s risks and the Code’s strict limitations. Key takeaways include:

• social media activity must be planned, monitored and maintained, not treated as low risk corporate communications
• responsibility under the ABPI Code is broad and fact specific
• apparently minor features (hashtags, tags, comments or links) can materially change compliance risk
• governance, training and documentation remain critical, particularly when working with third parties

As social media platforms and norms continue to evolve, the PMCPA’s modular, regularly updated guidance — with links to relevant cases — is intended to support ongoing compliance in a fast moving landscape. 

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