Types of activity

Direct dissemination of information can be done through creating and posting new content, or by interacting/engaging or sharing existing content. Use of social media must not constitute promotion of a prescription only medicine to the public or promotion of a medicine prior to the grant of its marketing authorisation.

  • Creating content: links, hashtags and tagging

    Links

    Any material associated with a post, for example, a link within a LinkedIn post, would normally be regarded as being part of that post.

    Pharmaceutical companies should be confident about the choice of linked information/websites and that these do not promote prescription only medicines to the public or contain otherwise inappropriate content. Due diligence needs to be conducted and documented in assessing the appropriateness of content being linked to. In the event of a complaint, multiple factors would be taken into account, including chronology.

    Links in company posts should:

    •    not be inappropriately named
    •    indicate when a user is being directed to a website which is not that of the company

    Linked material should:

    •    make clear from the outset the pharmaceutical company’s involvement in the material where applicable
    •    be clear regarding the intended audience (if not intended for the general public) 
    •    include instructions to direct those who are not the intended audience elsewhere when required by the Code

     

    Relevant cases to read (non-exhaustive list):

     

    Tags

    Many social media platforms enable users to tag posts to facilitate browsing and searching. Social media tags most commonly appear as hashtags (#) or user tags (@).

    Hashtags (#)

    A hashtag is a word or key phrase preceded by a hash symbol #. Hashtags are used within social media posts to help those who may be interested in the topic to find it. Clicking on a hashtag would take readers to the hashtag’s feed where they could see content posted which related to the hashtag topic and view all posts which mentioned that hashtag.

    Caution must be taken by pharmaceutical companies. Pharmaceutical companies should give consideration to the fact that hashtags are often not owned or controlled by the company and an individual hashtag could therefore be used for multiple different purposes at the same time.

    Companies should consider the wording of the hashtag in combination with other wording in the post and whether it could indirectly refer to a specific medicine.

    An indication or therapy area e.g. #obesity might constitute promotion of a product if it was used in combination with other language which could identify a specific product. Particular care should be taken where the company’s product, even though not named, is the only medicine available for the disease or symptoms in question.

    Companies should also consider the hashtag feed to which readers will be taken if clicking on the hashtag.

    In the event of a complaint, multiple factors would be taken into account, including chronology. Companies would be expected to conduct reasonable due diligence (i.e. check content visible with some scrolling) when evaluating the current state of the hashtag feed before choosing to use it, and to document this check. Companies should not use hashtags with a history of misuse or a history of containing inappropriate content.

     

    Relevant cases to read (non-exhaustive list):

     

    User tags (@)

    Most social media platforms enable other accounts to be mentioned in posts which usually sends them a notification about the post.

    Pharmaceutical companies can mention different stakeholders in their posts, including health professionals, healthcare organisations and patient organisations. Their permission might not be required to mention them, but care must be taken to ensure that stakeholders are mentioned respectfully and appropriately. It may be advisable for a company to ask before tagging another account if it is not already covered in a written agreement between the parties, particularly if, for example, the ‘tag’ suggests any form of endorsement of the content of the post or refers to an activity that the parties are or were involved in.

    Pharmaceutical companies should be cautious about the effect of tagging others and thus directing readers to the associated social media account.

    Account holders have control over whether or not to tag others in their posts. In that regard, pharmaceutical companies that include tags as part of their posts and therefore direct readers to other accounts, need to be satisfied that the content on those accounts are appropriate as far as the ABPI Code is concerned. If that were not the case, then pharmaceutical companies would be able to direct readers to independent profiles and their contents as a means of circumventing the ABPI Code.

    In the event of a complaint, multiple factors would be taken into account, including chronology. Companies would be expected to conduct reasonable due diligence (i.e. check content visible with some scrolling) when evaluating the current state of the account before choosing to tag it, and to document this check. Companies should not tag accounts with a history of misuse or a history of containing inappropriate content.

     

    Relevant cases to read (non-exhaustive list):

     

    If a pharmaceutical company (or its personnel) conducted activity that linked to another account, feed or page, this would likely be in breach of Clause 26.1 of the ABPI Code if there was evidence to show that, at the time of linkage, there was promotional content for the company's medicine on that linked account/feed/page.

     

    Last revised: 2 February 2026

  • Interacting and engaging with social media content

    While the terminology may vary, most social media platforms enable users to interact/engage in some way with content on other accounts, for example by ‘liking’, commenting on or re-sharing a post. Depending on the functionality of the social media platform and the security settings of the individual account, such interaction/engagement might result in the further dissemination of the content.

    The way social media platforms treat interactions/engagements may change over time and therefore pharmaceutical companies should regularly check the current terms and conditions for the relevant social media platform to ensure its activities comply with the platform’s rules as well as all applicable codes, laws and regulations.

    Activity conducted on social media that might alert an individual’s connections to the activity will likely be considered proactive dissemination of material. Proactive dissemination of material that directly or indirectly refers to a specific medicine is likely to be considered promotion of that medicine.

    Care must be taken when interacting/engaging with content in this way to ensure that the post and any linked content is in line with the ABPI Code and certified where required.

    Pharmaceutical company policies should cover how and when staff may interact/engage with content on social media, including in relation to interaction/engagement with company posts.

     

    Relevant cases to read (non-exhaustive list):

     

    Last revised: 2 February 2026

  • Targeting social media activity and closed communities

    Some social media platforms can be used as a closed channel for a specific audience where verification/disclosure of the audience status or credentials is possible and can be required before providing access. For example, currently some social media platforms allow closed user groups where the user invites individuals to join a group which they can restrict to a specific audience, e.g. health professionals. There might be a limit to the number of individuals who can be invited, depending on the platform used.

    Some platforms may have functionality to target materials to individuals based on criteria such as location, job title, education and specialism. Pharmaceutical companies should take care to ensure that any targeting criteria are robust and specific. The requirements of Clause 15.5 may also be relevant.

    The target audience of the closed channel/group or activity should be clearly identified. A pharmaceutical company may choose to have one corporate account or separate accounts dedicated to specific activities or stakeholder groups. Pharmaceutical companies should consider how each activity is restricted and tailored to the needs of the intended audience. It is also important that companies have regular oversight of all their accounts, including when staff managing the accounts leave the company.

     

    Relevant cases to read (non-exhaustive list):

     

    Last revised: 2 February 2026

  • Monitoring comments and meeting pharmacovigilance responsibilities

    Pharmaceutical companies should establish procedures to review and monitor their activities, content, and materials on social media to ensure compliance with relevant codes and applicable laws including monitoring of adverse events.

    Annex 2 of the EFPIA Code ‘Principles for the use of digital channels’ states that for digital channels owned by the pharmaceutical company, processes should be established to monitor, moderate and/or delete any inappropriate comments in a timely manner to the extent permitted by the data protection regulations and applicable laws and codes. Pharmaceutical companies might need to have similar processes when using digital channels owned by other companies or organisations.

    Pharmaceutical companies are encouraged to have social media community guidelines in place. These guidelines should set the expectations and boundaries to clarify what behaviour is expected online. They are important to help the company protect its community as well as itself.

    Pharmacovigilance

    Pharmaceutical companies should implement policies and/or procedures on social media platforms to ensure they meet their pharmacovigilance responsibilities, including the obligation to record and report any adverse events that are discussed about their medicines on company-owned/sponsored social media or other social media received via ‘active listening’, market research or similar activities. Such policies and procedures should include information about how adverse events can be reported and how follow-up requirements would be met.

    The ABPI Code has only limited requirements in this regard. Pharmaceutical companies must ensure that all personnel (and others retained by way of contract) are fully conversant with pharmacovigilance requirements relevant to their work and this must be documented (Clause 9.2). Furthermore, a statement about reporting adverse events must be included in:

    •    promotion to health professionals/other relevant decision makers (Clause 12.6)
    •    certain information for patients (Clause 26.4)
    •    campaigns for the public approved by health ministers (Clause 26.1 supplementary information).

    The current position in the UK is that if a pharmaceutical company (or an individual or third party on its behalf) becomes aware of an adverse event associated with one of its products then certain information must be collected and reported to the MHRA.

    The MHRA advice is that pharmaceutical companies must have mechanisms in place to identify adverse events and events of special interest from social media platforms either owned or under their control. Pharmaceutical companies may add general information to their social media platforms to signpost users on how they can officially report adverse events e.g. company website address, including in response to reports where it is not possible to ascertain whether an event is valid or where further information is required to assess the report. If non-company sponsored/owned social media are being screened by the company for any reason, adverse events and events of special interest should be collected as necessary; however, it is acknowledged by the MHRA that follow-up and/or signposting may not always be possible in these circumstances. Further information can be obtained from the MHRA.

    Alternatively posts and comments underneath posts and direct messages to company owned or sponsored social media accounts can be disabled on certain social media platforms to avoid the need to signpost and monitor.

     

    Last revised: 2 February 2026

  • Responding to misinformation or inaccuracies

    This is an area where companies need to use their judgement, bearing in mind the four key ABPI principles of Patients, Integrity, Transparency and Respect. It is difficult for the PMCPA to give specific guidance as much will depend on the misinformation and the potential harm to patients. Companies should always put patient safety first.

    Company personnel (including third parties)

    Companies are responsible under the Code for the acts and omissions of their personnel which come within the scope of the Code, even if they act contrary to the instructions which they have been given. Company personnel includes members of staff, those retained by way of contract and third parties. If companies are aware of misinformation about their medicines published on social media by their personnel, including their third parties, they should contact the account holders as soon as possible to get the posts corrected or removed, as the companies themselves may be held responsible under the Code.

    Companies are sometimes hesitant to contact patient organisations for fear that this may compromise any existing arm’s-length arrangement. However, requesting correction of a factual inaccuracy alone is not enough to compromise an arm’s-length relationship, so long as the company is attempting to correct all factual inaccuracies about its medicine in the material at issue.

    Individuals and organisations with no relationship to the pharmaceutical company

    Responding to misinformation or inaccuracies about prescription only medicines published on social media by individuals and organisations with no relationship to the pharmaceutical company is a difficult area and is a question of policy for a company. Given the volume of misinformation that may be available, companies should have a documented strategy based on a risk assessment. If a company decides to attempt to correct misinformation in particular material, it should attempt to correct all factual inaccuracies about its medicine in that material.

    How to correct misinformation

    Rather than responding publicly to an incorrect social media post, it may be more appropriate for the company to privately contact the account holder and inform them of the inaccuracy as soon as possible. If the company does not get a response within a reasonable timeframe, it could publicly respond to the post in an attempt to limit any harm that may be caused to patients/public by the misinformation. A pharmaceutical company could cross-refer to a particular section of a regulatory document (e.g. SPC or package leaflet) if it is trying to counter specific misinformation, e.g. cross-refer to Section 5 of the package leaflet if trying to counter misinformation about how to store the medicine. However, in other circumstances, a more general cross-reference to the regulatory documents might be more appropriate to prevent introducing an element of judgement in what is quoted.

    A pharmaceutical company could refer readers of the particular misinformation to its own reference information (as defined in the supplementary information to Clause 26.2 of the ABPI Code) about the medicine by means of a link to an appropriate landing page. Clearly, all the reference information needs to comply with the ABPI Code and must be non-promotional.

    Given the global nature of social media, companies should make an assessment as to the most appropriate country regulatory document to cross-refer to when correcting a particular piece of misinformation and this should also be made clear to the reader. UK companies will, at times, need to liaise with their overseas affiliates in this regard.

    Proactive correction of general misinformation to address patient safety concerns

    Companies should discuss such patient safety concerns with the MHRA.

    While social media is one way to reach an audience, there may be other ways of reaching the relevant population. Companies should carefully consider their approach to reaching the target audience and the rationale for the proposed communication. Companies should align with government messaging where available. Companies need to be careful that the communication itself does not constitute promotion of a prescription only medicine to the public.

    Companies can report any concerning social media activity to the relevant social media platform. Depending on its nature, companies could also report the concerning activity to the Advertising Standards Authority (ASA) or OFCOM.

     

    Last revised: 2 February 2026

  • Creating a personal profile

    Social media platforms, particularly LinkedIn, are widely used to share professional profiles publicly to show an individual’s previous work experience and current role. These professional profiles can be used by employers to find candidates and by job seekers to apply for jobs.

    A CV is a personal matter but when it is in the public domain, such as within a LinkedIn profile, there is an additional responsibility to ensure that the language used, and the impression given, are appropriate. Employees should be extremely cautious about any reference to a medicine and about how the pharmaceutical industry might be perceived by the public and health professionals.

    Job titles and descriptions in employee profiles should avoid mentioning prescription only medicines as this may constitute promotion. It is particularly likely to constitute promotion if the medicine is named alongside the product indication, therapy area, or key product benefits. This is especially important on platforms where updates to the profile might be sent to others as notifications. A poorly worded job title that was proactively distributed to many people is likely to be considered to be promotion of a prescription only medicine to the public.

    It might, however, be permissible to include, in an appropriate and proportionate way, brief details with regard to product names, therapy areas worked in and/or publications authored within the more detailed sections of the profile that require further navigation (active search and additional clicks and/or scrolling) to reach. For example, the ‘Experience’ section or ‘About’ section of a LinkedIn profile is primarily directed at those with an interest in the individual’s work experience, such as prospective employers or professionals seeking to connect or collaborate.

     

    Relevant cases to read (non-exhaustive list):

     

    Last revised: 2 February 2026

PMCPA social media guidance