Code Clarity

It's faster, and done right, good for everyone at the table. So why does the PMCPA's Abridged Procedure remain the road less travelled? Rina & Jean investigate the case for using it more: the benefits for companies facing complaints, for complainants seeking resolution, and for the PMCPA itself. If it works this well, what's holding the PMCPA back?

The PMCPA has released its 2025 Annual Report - but does the data point to a genuinely transformational year, or business as usual? In this episode, Rina & Jean dig into the numbers to ask the question everyone in pharma is thinking: are companies actually getting more compliant, or are complaints simply getting worse?

Whether you are a new or seasoned signatory, the question of signatory standards is worth considering. Two experienced signatories (Rina & Jean) chat about 3 of the most important standards (the full 10 will be discussed in detail at our subscribers webinar on 17 Sept 26 - get in touch at hello@codeclarity.co.uk if you are not a subscriber).

Why does this matter to you? Because for the first time 'it happened ages ago' is now a legitimate defence (within limits). PMCPA Q&A on policy here.

No boring Code training: Rina & Jean summarise their webinar (free for subscribers) on Social Media Case ruling trends. To subscribe contact hello@codeclarity.co.uk

One third-party event, three pharma company sponsors & three complaints. All about the same thing - sponsorship declarations. If you organise third party events sponsored by pharma, Rina & Jean summarise what you can do to make compliance easier. (Cases/0556/04/25;/0557/04/25 & /0558/04/25)

A recent ruling found a MSL presenting at a promotional meeting no breach but why? Was it a technicality or a new PMCPA position?

Rina & Jean discuss the criteria in determing if a meeting is compliant. Venue is only one!

Rina & Jean discuss a recently published PMCPA ruling vs GSK about their corporate ad - placed before a finance podcast for the public. Was this actually promotion to the public or genuinely good corporate affairs work?

Theramex is the third UK pharma company to leave PMCPA jurisdiction in three years (Sandoz 2023, Evolus 2024, Theramex 2026). Does that reflect increasing rules, companies avoiding audit, or self-regulation management of issues? Rina & Jean discuss how we got here and what it means for the future of self-regulation.

Competence is not just about job titles. Rina & Jean discuss why real skills and practical experience remain essential to understanding the INTENT behind the Code to applying JUDGEMENT in complex approval scenarios. The Code Clarity Final Signatory & AQP Collections are available now.

In this episode, Rina and Jean discuss what happens when senior global leaders speak about medicines in UK national media - and why even well-intentioned interviews can cross into promotion of prescription-only medicines to the public. (Full cases here: 0277 & 0518 )The takeaway is surprisingly simple. Only 3 minutes for our ONE top tip.

Patient stories are powerful and that's exactly why pharma want to use them. In this episode, Rina and Jean analyse three AstraZeneca videos that used patient testimony describing treatment as “the best”, and why that language ultimately led to PMCPA breaches. A must-listen for anyone approving patient-facing or patient-led materials under the ABPI Code.(Case/0360/11/24 & /0355/11/24 & /0377/11/24)

In this episode, Rina and Jean dissect the new PMCPA social media guidance and highlight three key changes that add clarity for pharma companies. Essential listening for anyone signing off or posting pharma content online.

The PMCPA has published 14 page guidance on Package Deals. We cut through the fluff and tell you what you need to know & why reviewing existing arrangements now matters for compliance and transparency.

Can a venue name alone imply excess? Rina and Jean unpack a recent case (Case/0440/01/25) where a meeting held at a “beach hotel” was perceived as lavish. They discuss how optics, assumptions, and language can affect judgment, and why facts still matter most in compliance decisions.

As MLR queues grow, complexity increases & review pain/boredom set in...there's good news for everyone! Rina & Jean are joined by Harry Bliss & Dan Bentley from Siguru to discuss how AI can help approval teams move from bottleneck to breakthrough, without compromising compliance. To find out more about AI-enabled MLR support, visit www.siguru.ai

Rina and Jean look ahead to UK pharma compliance in 2026, including likely complaint hotspots, familiar risk areas and the big question of PMCPA modernisation.

Two recent PMCPA cases (0273 & 3882) highlight a surprisingly simple point: using images that don't reflect real patients doesn't automatically mean a breach. We unpack what the rulings tell us about context, accuracy and visual representation in pharma comms - and why it matters for your next campaign. Images can be seen here.

When is a medicine… not a medicine — at least according to the PMCPA?

Speakers confirmed, slides ready… but no one shows up.

The PMCPA says (currently) most complaints still stem from social media - and they're now hinting at a cease-and-desist approach. We unpack what that could mean for pharma whilst everyone is still guessing what “promotional” really means...

It seems the PMCPA's review on defining Medical Education is freezing up ❄️. With the PMCPA's influence possibly shaping European guidance, and post-Brexit UK now charting its own stricter course, is this the moment to rethink how “medical education” and “promotion” are defined, and what it means for pharma on both sides of the Channel?

Declarations of involvement are causing drama! But they are an easy target which means a quick win for pharma too. We discuss the 5 point-plan the PMCPA don't want you to know - more of this at our conference.

Two PMCPA rulings (one old, one recent) about an "innocent" drink but involving pharma customers. A casual thank-you or a full-blown breach?Our conference on 4 Nov will discuss commercial push, medical pull and compliance risks.

SOME say UK pharma has “a slow self-regulatory process that fails to ensure compliance” (BMJ letter, Oct 23)WE say it is the PMCPA themselves bringing the industry into disrepute (evidence to be presented at conference)

Another day, another email & another PMCPA case. Can we blame Brexit for Global forgetting the UK is no longer in the EU? Can 21 emails in 3 months ever not be spam? We'll explore how medical publishers can get ahead of pharma's needs. (Case Auth/3860/12/23, 3862/12/23, 3866/12/23 & 3889/4/24)

Waiting for the PMCPA to audit your company? In this episode, we unpack why proactive compliance audits beat reactive panic, how they foster a healthy culture, and how to turn findings into solid CAPAs - not just a pile of paperwork!

It's the detail that matters. Moderna skips over the nitty-gritty and the Appeal Board isn't having any of it. Rina & Jean look at what happens when you serve generalities instead of granularity. (Case AUTH/0316/10/24 & 3835/10/23.)(3/3)

Moderna responds to a PMCPA complaint... but forgets one crucial ingredient: *all the details*. We explore why being “not-so-full and not-so-frank” came back to bite and led to an audit. (Case AUTH/0316/10/24.) (2/3)

Can a “views are my own” disclaimer really save you from the PMCPA's watchful eye? Spoiler: no. Moderna learns this the hard way. (Case Auth/ 3835/10/23) (1/3)

Rina & Jean dive into the drama of a recent confession by Pierre Fabre & the results of our audience poll... asking the big question: should voluntary admissions come with a checklist… or at least a decent apology template?

The ABPI has recently published guidance on congresses. What does the Code already say on this topic? What does the Guidance include? And what does it all mean. Code Clarity is hosting a webinar on this topic on 6th May 2025, 12.30-1.30pm. Contact us at hello@codeclarity.co.uk for more details.

Jean and Rina discuss a recent case about something said by a Celltrion sales rep - top tips relate to why it's important to prove what you say in calls is correct!

Our poll suggests 85% of you want the QR code to link to SPC OR for HCPs to refer to the SPC. So is this the beginning of the end for Prescribing Information?

A recent case about a gay dating app confirms WHEN the UK Code applies and WHY appeals are worth it.

Yay, a Complaints Masterclass to increase your confidence when it comes to self-regulation - from experts in complaints management! Register your interest: hello@codeclarity.co.uk (15th May 2025, 1.30-4.30pm, Woburn House, London, WC1H 9HQ)

An update on case rulings that may affect the way UK Pharma can do Medical Education - what's changed and what can we learn? Cases discussed are AUTH/3832/10/23 and AUTH/3825/9/23

Recent news about Astellas merging C-suite roles (medical and commercial) - what's the fuss about? And top tips if you're considering the same.

Rina & Jean discuss a recent appeal by Janssen relating to UK speakers presenting at international meetings - why was the appeal so good?!

Becs Shuttleworth joins Rina & Jean to explain the importance of bringing compliance into the light.

Yay the first abridged procedure case vs CSL Seqirus has been published! A dull case but Rina covers the 2 interesting points to take away

Oh dear - an employee of a competitor company lobs a rubbish complaint to the PMCPA and wow - they have to accept, as it's non-contactable. MADNESS.

How to influence Code changes (yes it can be done!) & tips about the practical implementation of QR Codes with Jenni Harrison and Richard Blackwell. If you need confidence, here's a link to our compliance checklist on QR codes.

Pharma supporting HCPs to attend meetings - Code vs PMCPA guidance vs our thoughts on the simple ways to achieve compliance.

Why were there so many breaches about CLAIMS in 2024? W2 discuss our 3 top tips to help you tackle this risk.

A painful PMCPA press release but our 3 minute takeaway to simplify matters.

It's no surprise who the "winner" is here, but Rina & Jean discuss the many factors involved in what makes a BIG case.

...errr...don't mention product. A recent breach for AbbVie and our advice on common sense.

Rina chats to Dr Tim Ringrose (CEO, Cognitant) about empowering patients with long-term conditions with digital tools, and how his workshop at this year's Code Clarity conference will focus on this and positive case studies.

Rina & Jean dissect the key highlights from the latest PMCPA report - what does it really tell us about their finances...