Can the PMCPA give companies any guidance about using artificial intelligence (AI) to assist in the review of promotional materials and activities covered by the ABPI Code?

The requirements of the Code, for example, that information must be accurate, balanced, not misleading etc. remain unchanged. The use of AI to support Code compliance does not absolve a company of any of its responsibilities under the Code.  The Code and applicable UK laws are in place to ensure patient safety.

Companies should have policies or similar to clearly communicate corporate standards, expectations and behaviour, and should provide appropriate training. There are other laws and regulations beyond the ABPI Code that are relevant to the use of AI, thus companies should also conduct a tailored risk assessment and implement appropriate business governance.

If the PMCPA receive a complaint in which the use of AI is relevant, the Panel may take account of the company’s processes and governance around the use of AI in its consideration of the case.

Companies must also bear in mind the requirements of Clause 8. For example, Clause 8.1 includes that promotional material must not be issued unless its final form, to which no subsequent amendments will be made, has been certified by a nominated signatory (see Clause 8.1 and its supplementary information for full details). Requirements such as this cannot be fulfilled solely by the use of AI.

Companies may find the IFPMA’s AI toolkit and associated materials useful in their internal assessment.  IFPMA Artificial Intelligence Principles | IFPMA

The PMCPA will continue to monitor the use of AI in relation to materials and activities covered by the ABPI Code and will develop further guidance as required.

(Last revised: June 2025)