Eunomia perspective · 2026-09-30 · ABPI Code & PMCPA, Regulatory Updates & Compliance News
Lessons from Recent PMCPA Cases: What 2026 Rulings Mean for Your Processes
Published by Eunomia Pharma Services · Updated
What do recent PMCPA cases tell pharma compliance teams?
In 12 cases completed between February and August 2026, the recurring themes were social media (including employees’ own LinkedIn posts), press releases and media coverage, certification lapses, prescribing information and whether company involvement was made clear. Four of the 12 included a breach of Clause 2.
Practical steps
- Bring personal social media and job adverts into your review scope.
- Treat press releases that can reach the UK as in scope for UK review.
- Give every live material an owner and a recertification date.
- Check prescribing information against the current SmPC at each certification.
- Use real cases in training and monitoring.
The practical steps above are Eunomia’s operational guidance. See the source notes below for the scope of the external references.
The PMCPA publishes every completed case under the ABPI Code of Practice. Reading them is one of the most practical ways to see how the Code is applied, and where companies go wrong. We reviewed 12 cases completed between February and August 2026, ten under the 2024 Code and two under the 2021 Code, and summarise the themes below. Each case is linked to its PMCPA report.
This is a sample, not a statistical analysis of all PMCPA cases. The counts below refer only to these 12 cases.
The cases at a glance
| Case | Company | Topic | Clauses in breach |
|---|---|---|---|
| CASE/0686/08/25 | AstraZeneca | A senior leader’s LinkedIn post linking to a news article that named a medicine | 5.1, 26.1 (no breach of Clause 2) |
| CASE/1000/06/26 | Ferring | An employee’s LinkedIn job advert describing a medicine before it had a UK licence (abridged procedure; breaches accepted) | 3.1, 5.2 |
| CASE/0900/03/26 and CASE/0915/03/26 | GSK | Facebook adverts for a health professional webinar alleged to reach the public | No breach |
| CASE/0685/08/25 | Eli Lilly | A news article about Phase 3 results that originated from a company press release (upheld on appeal) | 2, 3.1, 5.1 |
| CASE/0688/08/25 | Sanofi | A global press release comparing hospitalisation data | 2, 5.1, 6.1, 6.2, 6.6, 26.1, 26.2 |
| CASE/0719/09/25 | AGB Pharma | Prescribing information that omitted warnings in the SmPC | 2, 5.1, 6.1, 12.1 |
| CASE/0999/06/26 | Sanofi | A disease-education video used after its certification lapsed, after company personnel left and the material was not reassigned (voluntary admission) | 8.5 |
| CASE/0748/09/25 | Ipsen | Company content in a doctors’ network email newsletter | 3.6, 15.6 |
| CASE/0784/10/25 | Novo Nordisk | Sponsorship not clearly declared on conference materials | 5.6 |
| CASE/0812/11/25 | AstraZeneca | A company-funded therapy review service | No breach |
| CASE/0409/12/24 | Alnylam | Congress booth, tutorials and an evening meeting (2021 Code; Clause 2 ruling overturned on appeal) | 5.1, 11.2 |
| CASE/0303/09/24 | Theramex | Leadership and compliance culture, prescribing information and non-interventional study certification (2021 Code) | 2, 4.7, 5.1, 8.3, 12.1 |
Theme 1: social media and employees’ own accounts
Three of the 12 cases were about social media, and two of those found a breach. Both breaches involved posts on individual employees’ LinkedIn accounts: a senior leader sharing a news article that named a medicine, and a job advert describing an unlicensed medicine. A fourth case partly concerned social media advertisements.
What to do: make the social media policy cover personal accounts used in a professional context, train people with real examples, and include job adverts and recruitment posts in the scope of review. The PMCPA’s own social media guidance is a useful starting point; see our article on it.
Theme 2: press releases and media coverage
Two cases concerned press releases, one through the news coverage it generated, and both included a breach of Clause 2 (upholding confidence in the industry). One involved a medicine before it was licensed in the UK; the other involved comparative data in a global release. Two cases in the sample involved promotion before a licence (Clause 3.1).
What to do: treat press releases, interviews and global communications that can reach the UK as in scope for UK review, and check what the resulting coverage is likely to say to the public.
Theme 3: certification and material lifecycle
Two cases found certification breaches. In one, a video stayed in use after its certification lapsed, after company personnel left and the material was not reassigned. Clause 8.5 requires material still in use to be recertified at intervals of no more than two years.
What to do: keep an owner for every live item, set recertification reminders, and make leaver processes include a handover of materials. See our guide to ABPI signatories and certification.
Theme 4: prescribing information and transparency of company involvement
Two cases found breaches of Clause 12.1 on prescribing information. Three cases looked at whether the company’s role was made clear, through sponsorship declarations or disguised promotion, and two of those found a breach.
What to do: check prescribing information against the current SmPC at every certification, and make sponsorship and company involvement visible on every asset, including websites and social adverts.
Theme 5: culture and leadership
One case, brought by employees, concerned leadership, compliance culture and several process failures. The sanctions included a public reprimand and an audit of the company’s procedures by the PMCPA. It is a reminder that the Code looks at how a company operates, not only at individual materials.
How to use these lessons
- Test your own processes against each theme, starting with social media and certification.
- Use real cases in training; they make the Code concrete.
- Add the themes to your monitoring plan so issues are found before a complaint.
We will update this review as new cases are completed. You can browse all 21 cases we have summarised in our PMCPA case library.
This article summarises published PMCPA case reports. It is not legal advice; read the full report for each case.
Sources and scope
- PMCPA: completed cases
The published case reports summarised in this article; each case is linked in the table.
- PMCPA: 2024 ABPI Code of Practice
The clauses referred to in the case rulings.
External sources accessed 30 September 2026. Check the applicable country rules and current source text for a specific engagement.