A detailed guide for pharmacists and pharmacy technicians to General Pharmaceutical Council fitness to practise: the threshold criteria, the Investigating Committee, Fitness to Practise Committee hearings, outcomes from informal guidance to removal, and what the GPhC's own guidance says about insight, remediation, apology and testimonials.
Choose one to see what it means and where to focus.
Select your situation to see where to start.
The GPhC investigates information that might call into question whether a pharmacy professional's fitness to practise is impaired, and takes action to restrict their practice when that is necessary to protect patients and the public.
The GPhC's guidance says a pharmacy professional is fit to practise when they have the skills, knowledge, character, behaviour and health needed to work safely and effectively and maintain the reputation of the profession. Under Article 51 of the Pharmacy Order 2010, fitness to practise can be impaired for reasons including misconduct, deficient professional performance, not having the necessary knowledge of English, ill health and a conviction for a criminal offence.
It is also clear about what it does not do. The GPhC's investigation guidance (updated October 2025) says its role does not involve resolving disputes between professionals, employers and individuals, that it cannot help anyone get an apology or compensation, and that it will not investigate concerns that focus purely on customer service or employment issues.
The GPhC is the regulator for pharmacists, pharmacy technicians and registered pharmacy premises in Great Britain. This page is about individual pharmacy professionals' fitness to practise. Inspection of pharmacy premises is a related but separate function, covered below.
Registered professionals subject to the Standards for Pharmacy Professionals and FTP.
Registered professionals, subject to the same standards and FTP process.
Premises inspected against the Standards for Registered Pharmacies. A different regulatory route from individual FTP.
The GPhC can also act where someone who is not registered is practising as a pharmacy professional or using a protected title such as "pharmacist" or "pharmacy technician".
Creates the GPhC, the register and its committees. Article 51 sets the grounds of impairment.
Govern procedure, from the threshold criteria to hearings, reviews and language assessments.
Nine standards every pharmacist and pharmacy technician must meet.
Separate documents for investigations (October 2025), Investigating Committee meetings, and hearings and outcomes (March 2024).
Scrutinises all FtP Committee decisions and can appeal them.
Every GPhC concern is measured against nine standards. Identifying which are engaged is one of the most useful first steps in understanding and addressing a concern.
| Standard | Possible concern | Guide |
|---|---|---|
| 1. Provide person-centred care | Unsafe or inappropriate care; not meeting individual needs | Professionalism |
| 2. Work in partnership with others | Poor teamworking, unsafe handover or delegation | Professionalism |
| 3. Communicate effectively | Failing to counsel patients or communicate appropriately | Professionalism |
| 4. Maintain, develop and use professional knowledge and skills | Deficient professional performance, gaps in competence | Competence |
| 5. Use professional judgement | Poor clinical decision-making, unsafe supply | Competence |
| 6. Behave in a professional manner | Misconduct, dishonesty, boundaries, discrimination | Probity |
| 7. Respect and maintain the person's confidentiality and privacy | Patient information breaches | Confidentiality |
| 8. Speak up when things go wrong | Failing to be candid or to raise concerns | Misconduct |
| 9. Demonstrate leadership | Failures as a responsible or superintendent pharmacist | Performance |
Mapping explains the standards involved. It does not establish misconduct or impairment.
Most pharmacy FTP concerns fall into familiar groups. A single error, openly reported and learned from, is usually not an FTP matter; the threshold criteria look for risk, seriousness, persistence or loss of trust.
Wrong medicine, strength, formulation, patient or instructions; checking failures; near misses not reported. The threshold criteria ask whether actions were reckless or intentional, whether the issue recurs and whether the professional acted openly. Medication remediation
Independent prescribers can face concerns about prescribing outside competence, inadequate assessment, or remote prescribing without adequate information. Medication remediation
Record-keeping, storage, destruction and supply failures; diversion or personal misuse. Misuse may also lead to a health assessment.
Consultation notes, prescribing rationale, dispensing records and audit trails. Falsifying patient records is one of the GPhC's examples of dishonesty so serious that removal may be the only proportionate outcome. Documentation remediation
Inappropriate access or disclosure, including through digital systems, remote consultations and social media. Confidentiality remediation
NHS or employer fraud, false claims, misleading records, plagiarism, concealment and false declarations. Probity remediation
From harassment to serious offences, and inappropriate relationships with vulnerable patients or colleagues. The GPhC's guidance treats these as among the most serious concerns. Misconduct remediation
Including online comments about groups with protected characteristics. The GPhC's guidance says committees should usually consider outcomes at the upper end of the scale.
The GPhC's guidance says committees should take very seriously a failure to raise concerns where patient safety is at risk, and deliberate steps to avoid candour.
Convictions are a ground of impairment. Cautions or convictions involving alcohol or drugs often lead the GPhC to consider a health assessment.
A health condition only matters where it affects the ability to practise safely. Removal cannot be ordered where impairment is solely due to ill health.
The registrar or a committee can direct a language assessment where there is a concern about English needed for safe practice in Great Britain.
The responsible pharmacist is accountable for the safe and effective running of the pharmacy while signed in, including supervision, delegation, procedures and the record. Failures can raise individual FTP concerns, separate from any premises issue. Leadership is standard 9.
Performance remediationRemote consultations and online prescribing create specific risks: patient identity, clinical information, medical history, safeguarding, documentation, monitoring and escalation. GPhC inspection findings repeatedly focus on risk management, clinical documentation, prescribing governance and safe supply.
Documentation remediationNot following SOPs, failing to learn from previous incidents, or working around checks can turn a one-off error into a pattern. Evidence of changed practice often includes updated SOP training and incident review.
Competence remediation| Individual fitness to practise | Pharmacy inspection | |
|---|---|---|
| Concerns | An individual pharmacist or pharmacy technician | A registered pharmacy |
| Standard | Standards for Pharmacy Professionals | Standards for Registered Pharmacies |
| Outcome | Outcomes on the individual's registration | Inspection findings, improvement action plans |
| Link | Closed FTP cases, including informal guidance, may be used when inspecting relevant pharmacies, in line with the GPhC's publication and disclosure policy. | |
The GPhC's hearings guidance says a case can end at four points. Each has its own decision-maker and its own guidance.
The GPhC looks at all the information, considers whether it can act, and decides whether to investigate. It checks whether the concern relates to a registrant, to someone practising unregistered, or to one of the legislative categories. It will investigate when this is needed for patient safety, in the registrant's own interests, or otherwise in the public interest. Concerns better handled by another body are passed on, though the GPhC sometimes investigates alongside another agency.
A case officer or inspector gathers information: pharmacy and prescribing records, dispensing evidence, witness and employer information, training records and your response. The GPhC may seek a health assessment, direct an English language assessment, and refer safeguarding concerns to the Disclosure and Barring Service or Disclosure Scotland. In exceptional circumstances, the registrar can accept an application for voluntary removal.
Where urgent action is needed, the GPhC can apply for an interim order, suspending or placing conditions on practice. It can only be imposed by a Fitness to Practise Committee, can last up to 18 months, and can be extended only by the High Court or Court of Session. The test is protecting the public, the public interest, or the professional's own interests. An interim order is not a finding.
In certain circumstances, the registrar can refer a case straight to a Fitness to Practise hearing, for example where the public interest is best served by urgent consideration.
Being investigated is not the same as being found impaired.
At the end of an investigation, the registrar applies published threshold criteria. A case should not be referred to the Investigating Committee unless the evidence as a whole suggests that at least one of these applies, and referral is in the public interest.
The registrar takes into account the professional's behaviour, whether actions were reckless or intentional, whether the issue recurs, and whether they acted openly and honestly. It may also consider whether the professional has learned from the incident and taken remedial action, such as training or changing their practice.
An educational model of the GPhC's published decision table. Tick what the evidence suggests.
Tick to see the possible outcome.
| Outcome | Effect on registration | When it may apply |
|---|---|---|
| No further action | Not recorded on the online register; may be taken into account if future concerns arise | Lack of evidence, threshold not met |
| Closure with informal guidance | Not recorded on the register; may be used if future concerns arise | Threshold not met, actions not reckless or intended to harm, remedial action possible, no future risk |
| Referral to the Investigating Committee | The referral itself is not recorded; a later IC or FtPC outcome may be | More serious cases, for example serious breaches of standards, discriminatory behaviour or sexual misconduct |
The Investigating Committee considers referred cases at a meeting, using its own published guidance. It decides whether a case should be concluded, with outcomes such as advice or a warning, or referred to the Fitness to Practise Committee for a hearing. Its role is distinct from the hearing stage: it does not make findings of impairment after hearing evidence.
Hearings are held by a panel of three: a chair, a professional member and a lay member, supported by a legal adviser and sometimes a medical adviser. The committee is independent of the GPhC. Most hearings are held in public; health and interim order hearings are held in private unless the public interest outweighs privacy. If you attend without a representative, the chair should explain the process and ask about any needs or vulnerabilities.
The committee follows a three-stage process. The GPhC's guidance stresses that the stages must be kept separate.
The GPhC must prove them on the balance of probabilities. Facts you admit must be found proved.
Not whether it was at the time. Even a finding of misconduct may lead to a finding of no current impairment.
Starting from the least severe outcome, and explaining why the next one up is not needed.
The committee considers whether the conduct or behaviour presents an actual or potential risk to patients or the public, has brought or might bring pharmacy into disrepute, has breached a fundamental principle of the profession, or shows that the professional's integrity can no longer be relied upon.
It also considers whether the conduct can be addressed, has been addressed, and is likely to be repeated, and whether a finding of impairment is needed to declare and uphold proper standards or maintain public confidence. The committee must make its own decision on impairment even if the professional admits it.
The GPhC's hearings guidance states plainly that insight and remediation are key factors for committees to consider. It defines the expectation that a professional can accept and understand that they should have behaved differently (insight), and will take steps to prevent a recurrence (remediation).
Committees consider whether the professional has genuinely demonstrated insight, not only consistently throughout the hearing but also through their actions after the incident, and whether they show understanding after the committee's findings. When deciding what action to take, they consider the nature of the concern, whether the actions can be remedied, and whether the professional can demonstrate insight.
Credible insight usually covers what happened, your responsibility, the impact on patients and trust, the standards engaged, what should change, and evidence that your behaviour has changed.
The GPhC's guidance says some conduct may be so serious that it is not remediable: even with evidence of insight and remediation, it is not appropriate to rely on that evidence when considering an outcome. Its examples are concerns involving discriminatory behaviour or sexual misconduct, where regulatory action is necessary to protect the public and maintain confidence in pharmacy. This is case-specific, not a blanket rule, but it matters for anyone facing such allegations.
Factual disagreement is not automatically a lack of insight. Distinguish what you dispute from what you have learned, and never make admissions simply to appear insightful. Take advice before responding in an active case.
| Concept | Meaning |
|---|---|
| Apology | An expression of regret |
| Remorse | An emotional response to wrongdoing |
| Reflection | Structured consideration of events |
| Insight | Understanding of the professional significance |
| Remediation | Action taken to address the concern |
| Changed practice | Demonstrable, sustained change |
The GPhC's guidance is unusually detailed here. Committees should see candid explanations, expressions of empathy and apologies as positive steps, and should not treat them as an admission of impairment without other evidence.
It asks committees to be aware that cultural differences, communicating in a second language, ill health, disability or neurodiversity can affect how insight, remorse and apology are expressed, including written apologies, intonation, eye contact and non-verbal cues.
Deliberately avoiding candour with a patient, or preventing someone else from being candid, should be taken very seriously, with outcomes at the upper end of the scale.
Concern → Learning need → Intervention → Application → Evidence → Sustained change
Interventions can include targeted education, supervised practice, competency assessment, clinical mentoring, relevant CPD, reflection, audit, workplace review, retraining, SOP learning and professional development.
| Evidence | Potential value |
|---|---|
| Relevant course | Knowledge and learning |
| Assessed course | Demonstrated understanding |
| Reflection | Understanding and learning |
| CPD record | Continuing development |
| Clinical or dispensing audit | Application in practice |
| Supervisor report | Observed change |
| Competency assessment | Demonstrated capability |
| Workplace evidence | Sustained practice |
| Action plan | Future safeguards |
| Repeat audit | Sustainability over time |
Testimonials can matter when they speak to remediation, reflection, insight or remorse. General character references are unlikely to be directly relevant to current impairment. Committees consider whether authors knew about the events, and may give more weight to verified evidence. The guidance also recognises that some professionals, including those recently qualified overseas, may find testimonials hard to obtain, and says committees should not make assumptions about their absence.
CPD is ongoing professional development. Remediation is a targeted response to an identified concern. A CPD certificate may be evidence of learning, but it is not automatically evidence that a concern has been remediated. Testimonials and evidence of current practice belong at the impairment stage, not only at the outcome stage.
The GPhC says dishonesty damages public confidence, but cases can be complicated and there is no presumption of removal in all dishonesty cases. Some acts are so serious that removal may be the only proportionate outcome: intentionally defrauding the NHS or an employer, falsifying patient records, or dishonesty in clinical drug trials.
Probity remediationSome acts will be incompatible with continued registration, and removal is likely unless there are clear mitigating factors. It is particularly serious where there is a serious sexual offence, abuse of trust, involvement of a child or vulnerable adult, or registration as a sex offender.
Misconduct remediationCommittees should usually consider outcomes at the upper end of the scale, especially where behaviour was intentional, repeated or harmful, including offensive comments on social media about people with protected characteristics.
Professionalism remediationTaken very seriously where patient safety is at risk, with outcomes at the upper end of the scale and removal in the most serious cases.
Misconduct remediationKnowledge gaps, repeated errors and poor judgement. Conditions are designed for cases where the professional may respond positively to retraining and supervision.
Competence remediationPremeditation, attempts to cover up, sustained or repeated conduct, taking advantage of a vulnerable person, abuse of trust, financial gain, and a relevant fitness to practise history.
FTP outcomesIf a committee finds fitness to practise impaired, it can take no action, agree undertakings, issue a warning, impose conditions, suspend, or remove the professional from the register. The GPhC says these outcomes protect the public and the wider public interest and must not be chosen solely to punish.
No action can apply even with impairment where there is no risk. Advice can only be given where no impairment is found but a formal response is needed.
Publicly acknowledges that conduct fell below acceptable standards where there is no continuing risk. Can be given with or without a finding of impairment.
Promises about future practice, such as supervision or retraining. Only appropriate where the committee is satisfied the professional will comply, for example because of genuine insight. Non-health undertakings are recorded on the register.
From a standard bank of conditions, where there are significant shortcomings but the professional may respond positively to retraining and supervision. Monitored; reviewed before they end.
Where lesser outcomes are not enough. Usually reviewed before it ends; can be extended, and after two years can become indefinite.
Where behaviour is fundamentally incompatible with registration. Not available where impairment is solely due to ill health. A wait of five years applies before applying for restoration.
Where the committee directs removal, suspension or conditions, it can impose interim measures that take effect immediately and cover the 28-day appeal period, and continue if you appeal. At a review hearing, you are expected to provide evidence that any past impairment has been addressed.
Timescales depend on the case, the evidence needed and whether it reaches a hearing. Many cases end at initial assessment or after investigation. Check the GPhC's current published performance data for timescales.
| GPhC | Employer |
|---|---|
| Professional regulator | Employer or pharmacy owner |
| Registration | Employment |
| Public protection | Workplace and employment matters |
| Standards for Pharmacy Professionals | Employer policies and SOPs |
| Can restrict registration | Can affect employment |
Both can run at the same time. The GPhC encourages effective local investigation so that its own investigations are better targeted, but will not investigate purely employment issues.
Different purposes, decision-makers and standards of proof. A committee must also tell the registrar if it thinks the GPhC should consider its own prosecution powers.
The FtP Committee also has powers over pharmacy companies under section 80 of the Medicines Act 1968, separate from individual FTP.
Choose learning that matches the concern. Completing a course does not by itself establish insight, remediation, competence or fitness to practise, and cannot guarantee a GPhC outcome.
Structured CPD · 1.5 CPD ptsStructured CPD · 1.5 CPD ptsStructured CPD · 1.5 CPD ptsStructured CPD · 2 CPD ptsStructured CPD · 2 CPD ptsStructured CPD · 2 CPD ptsStructured CPD · 2 CPD ptsStructured CPD · 1.5 CPD ptsStructured CPD · 3 CPD ptsDepending on the concern, Documentation Professionalism, Confidentiality, Clinical Competence or Duty of Candour may also be relevant. See all GPhC remediation courses.
Twice.
Ask for more time early if needed.
Records, SOPs, logs.
It can create a new, serious concern.
Which of the nine.
While memory is fresh.
What you know versus what you think.
From the root cause.
Indemnity provider, PDA or a solicitor.
Targeted, not generic.
Audit, supervision, feedback.
Your conduct during the process matters.
This educational material is not legal or regulatory representation. Consider advice from an appropriately qualified solicitor, your indemnity provider, the Pharmacists' Defence Association or another regulatory specialist before responding to allegations or making admissions.
A simplified educational model.
The GPhC's process for investigating whether a pharmacist's or pharmacy technician's fitness to practise is impaired, and restricting practice where necessary to protect the public.
Pharmacists, pharmacy technicians and registered pharmacy premises in England, Scotland and Wales. Northern Ireland is regulated by the PSNI.
Information suggesting misconduct, deficient professional performance, insufficient English, ill health or a criminal conviction, among the grounds in Article 51 of the Pharmacy Order 2010.
No. The GPhC does not investigate purely customer service or employment issues, cannot obtain apologies or compensation, and passes some concerns to other bodies.
The GPhC reviews the information, considers whether it can act and decides whether to investigate, assigning a case officer or inspector if so.
Published criteria the registrar applies after an investigation: risk to safety, undermining confidence, serious or persistent failure to meet standards, honesty or integrity no longer reliable, or health risk, plus whether referral is in the public interest.
The committee that considers referred cases at a meeting and decides whether they should be concluded or referred to the Fitness to Practise Committee.
An independent committee whose three-person panels hold hearings and decide facts, current impairment and any action.
That the professional's fitness to practise is currently impaired, considering risk, disrepute, breach of fundamental principles and whether integrity can be relied upon, and whether the conduct has been addressed.
Sometimes, but a single error handled openly and learned from usually will not meet the threshold. Recklessness, recurrence or concealment make it more serious.
It can. The GPhC says there is no presumption of removal in all dishonesty cases, but NHS or employer fraud, falsifying patient records or dishonesty in clinical trials may make removal the only proportionate outcome.
Accepting and understanding that you should have behaved differently, shown consistently and through your actions after the incident.
Taking steps to prevent a recurrence. The GPhC calls insight and remediation key factors for committees.
A relevant course can form part of remediation, especially if assessed and applied in practice. It cannot guarantee an outcome.
No. It shows learning. Evidence of changed practice, such as audit and supervision reports, shows remediation.
Potentially. Disagreeing with facts is not automatically a lack of insight. Take advice and never make admissions just to appear insightful.
The GPhC says candid explanations and apologies should be seen as positive steps and will not usually amount to an admission of impairment.
Restrictions for up to three years, drawn from a standard bank, used where the professional may respond positively to retraining and supervision.
A public acknowledgement, recorded on the register, that conduct fell below acceptable standards where there is no continuing risk.
You cannot practise for up to 12 months. It is usually reviewed, can be extended, and after two years can become indefinite.
You can no longer work as a pharmacy professional in Great Britain, and must wait five years before applying for restoration.
Yes. A conviction is a ground of impairment, and convictions involving alcohol or drugs often lead to a health assessment.
Only where health affects safe practice. Removal cannot be ordered where impairment is solely due to ill health.
Both processes can run together. They have different purposes and one does not decide the other.
No. FTP concerns individual professionals; inspection concerns registered pharmacies against separate standards.
It varies with the case and stage. Many cases end early. Check the GPhC's current performance data.
Yes, particularly before responding to allegations or making admissions. Your indemnity provider, the PDA or a regulatory solicitor can help.
No. IRR Practice is an independent education provider. It is not the GPhC and does not make regulatory decisions.
This guide is based on the GPhC's published guidance. IRR Practice is independent; naming the GPhC does not imply endorsement.
Content governance. Last reviewed September 2026. Next scheduled review March 2027, or sooner if GPhC rules or guidance change. IRR Practice is an independent healthcare education provider. It is not the General Pharmaceutical Council and does not make regulatory decisions.
Revalidation, dispensing errors, investigations and remediation for pharmacy professionals.
Writes for IRR Practice on professional standards, fitness to practise, insight, reflection and remediation for UK healthcare professionals.
Last reviewed: September 2026