Social media principles

Social media is a term used to describe interactive technologies, including websites and applications (apps), that focus on user-generated content, content sharing, interaction and communication among virtual communities and networks.

The social media landscape is constantly changing and evolving and there are differing interpretations of which digital platforms should be referred to as ‘social media’, but examples include:

•    Social networks where the focus is on the user – for example, Facebook and LinkedIn
•    Microblogs where users exchange small elements of content – for example X (formerly known as Twitter) and Tumblr
•    Media sharing networks where the focus is on the content – for example, Instagram, YouTube and TikTok
•    Community based networks where the focus is on in-depth discussion and communities often form around select topics – for example, Reddit

Other digital platforms are increasingly incorporating social media-type features – for example, including an option for one-to-many broadcasts within a messaging app, such as WhatsApp.

The definition of social media is continually evolving. It is, therefore, important to understand the general wider principles that apply in relation to social media and the ABPI Code.

 

Last revised: 2 February 2026

Under UK law, organisations and individuals are prohibited from advertising prescription only medicines to the public and from promoting a medicine prior to the grant of the marketing authorisation which permits its sale or supply.

In general, social media platforms are digital channels that are used to reach or interact with as many individuals as possible and are considered to be aimed at the public. Due to their open and transitory nature, pharmaceutical companies should consider carefully before engaging in and facilitating discussions about medicinal products or treatment options on these platforms.

It is often not possible to control factors that are inherent in the user interface of a social media platform, such as font size/type. It is for pharmaceutical companies to understand the different features, functions, terms and conditions for the social media platforms it uses and engages with. Companies should only use a particular platform if they are confident they can meet all the requirements of the Code and the terms and conditions of that platform.

A social media platform is only a channel for communicating and consuming information – laws and regulations applicable to other platforms and media also apply to digital media, including social media. The content, target audience and use of the platform are relevant factors to determine applicable rules, not the media channel as such.

Pharmaceutical companies should always bear in mind the impact the information might have and the overall impression created by their communications, activities and materials.

 

Key principles from the ABPI Code

The ABPI Code distinguishes between proactive and reactive pharmaceutical company activities in relation to information for the public. Examples are set out in the supplementary information to Clause 26.2.

The definition of promotion is broad. Proactive dissemination of information by a pharmaceutical company about its medicine is likely to be considered promotion of that medicine unless the company can clearly demonstrate otherwise (there are certain exemptions set out in the Code). Providing the same information reactively or as reference information which requires one to search for it is less likely to be considered promotion.

It is important to note that social media activity that could potentially alert one’s connections/followers to an activity or material is likely to be considered proactive dissemination.

• Clause 1.17 defines ‘promotion’ as “any activity undertaken by a pharmaceutical company or with its authority which promotes the administration, consumption, prescription, purchase, recommendation, sale, supply or use of its medicines.” The PMCPA informal advice is that, in general, the product name (brand or non-proprietary), particularly if alongside its indication, is likely to be seen as promotion. It is also an accepted principle under the ABPI Code that, depending on the context and current landscape, a medicine could be promoted without its name being mentioned.
  
  
• Clauses 3.1 and 11.1 prohibit the promotion of a medicine prior to the grant of its marketing authorisation. There are certain exemptions set out in the supplementary information.
  
  
• Clauses 3.2 and 26.1 prohibit advertising prescription only medicines to the public. This prohibition does not apply to vaccination and other campaigns carried out by pharmaceutical companies and approved by the health ministers, which is an exceptional situation.
  
  
• Clause 11.2 requires that promotion must be in accordance with the marketing authorisation and must not be inconsistent with the summary of product characteristics.

 

Last revised: 2 February 2026

In addition to the requirements of the ABPI Code, pharmaceutical companies should also be aware of:

•    The current terms and conditions for the social media platforms it uses and engages with
•    The requirements of the Data Protection Act 2018 and the UK General Data Protection Regulation (GDPR)
•    The Advertising Standards Authority UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code), which sets out the rules for non-broadcast advertisements, sales promotion and direct marketing communications

Particular attention is drawn to the overarching requirement for UK activity to comply with Part 14 (Advertising) of the Human Medicines Regulations 2012. The MHRA acts on behalf of health ministers to oversee this area of law to protect public health and is obliged to consider any complaints made to it about the advertising of medicines. The MHRA can refer complaints to the PMCPA as appropriate. Complaints are investigated by the MHRA on their own merits looking at the facts of the case and whether the content of concern is considered an advertisement for a medicinal product under the Regulations. For the Regulations’ definition of ‘advertisement’ and ‘medicinal product’ see the Human Medicines Regulations 2012. It is an offence for any individual or organisation to be in breach of the Regulations.

 

Last revised: 2 February 2026

• What is the objective of the activity?
  • Why would the activity not be considered as promotion to the public?
• What is the nature of the activity?
  For example, creating an original post, interacting with a company post, interacting with a post made by an independent party.
  • What information is linked to and therefore forms part of the content?
• What social media platform(s) will be used?
  • Are the terms and conditions of the platform and its functionality fully understood by the company?
  • Does the proposed activity breach the terms and conditions of the platform?
  • Is there any functionality that will limit the ability to meet all the requirements of the Code?
• Who is the intended audience?
  For example, the public, health professionals, media, investors
  • Is the content suitable for that audience?
  • Is the content appropriately signposted for that audience where required?
  • Can access be limited to the intended audience where required?  
  • Is interaction with the social media activity limited or controlled, and if not how does this affect the risk of the activity?
  • Is the audience expected to respond or participate in discussion?
• Is the content related to medicines?
  • Is the content promotional or non-promotional?
  • Does the medicine have a marketing authorisation/is the content in accordance with the terms of its marketing authorisation?
• Is the role of the pharmaceutical company clear from the outset?
  
  
• How will the activity be reviewed and approved?
  • Is it in line with company guidance? Is the company guidance clear and consistent with all applicable codes, laws and regulations?
• How will the activity be monitored and maintained?
  • What are the arrangements for pharmacovigilance obligations?
  • How will comments be monitored for non-compliant or inappropriate content?
  • Will the post need to be deleted or recertified in the future?

 

Last revised: 2 February 2026