- Pharmacist Prescribing Rights in Pakistan: What Must Happen Before Any Change?
In recent years, many pharmacists and professional bodies in Pakistan have started calling for formal prescribing rights. At the same time, Pakistan is already struggling with widespread informal prescribing, over‑the‑counter sale of prescription medicines, and weak enforcement of existing pharmacy laws. Before demanding new legal powers, the profession needs a clear, stepwise roadmap that prioritizes patient safety, regulation, and quality of care.
This article outlines a practical, regulation‑aligned approach for Pakistan if pharmacist prescribing is ever to be introduced in a responsible way.
Current Legal Landscape: Who Can Prescribe in Pakistan?
Under Pakistani law, prescribing is currently reserved for registered medical practitioners and a limited group of other authorized prescribers. The Allopathic System (Prevention of Misuse) Rules 1968 define who may prescribe allopathic medicines, and prescriptions must be signed by a registered medical practitioner with their registration number.
Alongside this, several key statutes regulate medicines and pharmacy practice:
- The Drugs Act 1976 regulates the manufacture, sale, and distribution of drugs, including prescription‑only and over‑the‑counter categories.
- The Pharmacy Act 1967 establishes the Pharmacy Councils and sets the framework for registration and practice of pharmacists.
- The DRAP Act 2012 created the Drug Regulatory Authority of Pakistan, which issues national guidelines and standards related to pharmacies, hospitals, and pharmaceutical services.
Despite this framework, studies and policy papers consistently show that:
- Prescription‑only medicines are frequently dispensed without a valid prescription.
- Unqualified personnel, including some dispensers and shopkeepers, informally “prescribe” and supply medicines.
- Regulations under the Pharmacy Act and Drugs Act are often not fully implemented at community level.
In simple terms, pharmacists today are legally recognized as medicine experts and dispensers, but not as independent prescribers.
Why a Stepwise Approach Is Essential
Any expansion of pharmacist responsibilities must not repeat the mistakes already visible in informal prescribing and lax enforcement. A stepwise approach ensures that:
- Patient safety remains the primary driver, not professional entitlement.
- The legal framework is respected and updated through evidence and stakeholder consensus.
- International good practices in clinical pharmacy, antimicrobial stewardship, and medication therapy management are adapted to Pakistan’s realities rather than copied blindly.
The following steps provide a structured roadmap that pharmacist organizations, regulators, and policymakers can use as a starting point.
Step 1 – Fully Implement the Existing Scope of Pharmacy Practice
Before talking about prescribing rights, pharmacists must demonstrate full implementation of the roles already recognized in policy and guidelines.
Key actions include:
- Hospital pharmacy standards:
- Clinical pharmacy and medication review:
- Embed routine pharmacist review of prescriptions for dose, interactions, duplications, and appropriateness, especially in high‑risk areas such as ICU, oncology, paediatrics, and geriatrics.
- Document interventions (e.g., dose adjustments, interaction warnings) to build a local evidence base on impact.
- Antimicrobial stewardship (AMS):
Evidence from Pakistan already suggests that pharmacist‑led medication management and stewardship programs can improve quality of prescribing and patient outcomes, especially in hospital settings. This evidence is a necessary foundation for any later discussion on prescribing rights.
Step 2 – Define the Future Prescribing Model (Scope and Limits)
“Prescribing rights” should never be understood as unlimited, open‑ended authority. Instead, Pakistan would need a carefully defined model that describes exactly what pharmacists can prescribe, where, and under what safeguards.
Two broad models used internationally can guide the discussion:
- Collaborative or supplementary prescribing
- A pharmacist prescribes and adjusts medicines under a pre‑agreed clinical management plan developed together with a physician.
- Suitable for chronic diseases such as hypertension, diabetes, asthma/COPD, anticoagulation, heart failure and some psychiatric conditions.
- The physician retains diagnostic responsibility; the pharmacist optimizes and continues therapy within clear parameters.
- Independent prescribing for limited conditions
- Pharmacists manage minor ailments and defined conditions using evidence‑based protocols, for example: simple skin infections, minor respiratory infections, gastrointestinal complaints, and vaccination‑related prescribing.
- Strict inclusion and exclusion criteria plus mandatory referral for red‑flag symptoms are essential.
Whatever model is chosen, Pakistan would need to:
- Restrict pharmacist prescribing to a clearly defined list of medicines and indications, aligned with national guidelines and essential medicines lists.
- Exclude high‑risk drugs (e.g., narrow‑therapeutic‑index agents, certain psychotropics) from pharmacist‑initiated prescribing, at least in early phases.
- Specify practice settings: accredited hospitals, teaching institutions, and licensed community pharmacies that meet defined standards of infrastructure, record‑keeping, and staffing.
By framing prescribing as a structured service with defined boundaries, the policy debate can move away from slogans and towards patient‑centred design.
Step 3 – Engage Key Stakeholders and Build Consensus
Experience from other health reforms shows that unilateral changes rarely succeed. For pharmacist prescribing, inclusive dialogue is essential.
Important stakeholders include:
- Medical regulators and associations (e.g., national medical regulators and specialty societies).
- Pharmacy Council of Pakistan and provincial pharmacy councils.
- Drug Regulatory Authority of Pakistan (DRAP), especially the division dealing with pharmacy services and guidelines.
- Provincial Health Care Commissions, which oversee licensing and quality of health facilities.
- Public and patient representatives who can highlight access and safety concerns.
Discussions should focus on:
- How pharmacist prescribing could safely reduce physician workload in high‑burden areas such as chronic disease management and minor ailments.
- How governance, audit, and professional accountability will work in practice.
- How to avoid conflicts of interest in situations where the prescriber also dispenses medicines, especially in a retail environment.
Consensus does not mean complete agreement on every detail, but a shared understanding that any new model will be evidence‑based, transparent, and tightly regulated.
Step 4 – Establish Education, Training, and Credentialing Standards
Granting prescribing authority without additional training would not be acceptable for patients, physicians, or regulators. Clear, national‑level education and credentialing standards would be required.
Potential elements include:
- Advanced training requirement
- A post‑graduate certificate or diploma in clinical pharmacy or pharmacist prescribing that covers clinical assessment, therapeutics, diagnostics relevant to the chosen scope, communication, and law/ethics.
- Minimum practice experience (for example, two or more years in hospital or community pharmacy) before entering the program.
- Supervised practice (preceptorship)
- Registration and annotation
This structured pathway aligns with international practice, where pharmacist prescribing is typically tied to additional qualifications and formal authorization rather than the basic pharmacy degree alone.
Step 5 – Strengthen Regulation, Licensing, and Enforcement
One of the biggest risks for Pakistan is expanding formal prescribing rights while informal, unregulated practices remain widespread. To avoid this, enforcement of existing laws must improve in parallel with any new pharmacist roles.
Key regulatory priorities:
- Enforce laws against illegal prescribing and dispensing
- Ensure that only authorized prescribers issue prescriptions for prescription‑only medicines, and that pharmacies do not dispense such medicines without valid prescriptions, except under clearly defined emergency policies.
- Health Care Commissions and drug inspectors should conduct regular inspections and apply sanctions where regulations are ignored.
- Accredit prescribing sites
- Make pharmacist prescribing possible only in licensed facilities that meet predefined DRAP and Health Care Commission standards, including private hospitals and community pharmacies.
- Require robust documentation systems so every prescription is traceable, auditable, and linked to clinical records.
- Governance and accountability
Stronger enforcement will protect patients and also help legitimize any future expansion in pharmacist responsibilities.
Step 6 – Design and Evaluate Pilot Programs
Before making national legal changes, Pakistan can learn from carefully designed pilot projects. These pilots should test specific pharmacist prescribing models in real settings under close supervision.
Possible pilot areas:
- Pharmacist‑managed hypertension and diabetes clinics in tertiary hospitals, where pharmacists titrate medicines using agreed protocols.
- Pharmacist‑run minor ailment services in accredited community pharmacies, with strict protocols and referral criteria.
- Pharmacist‑led antimicrobial stewardship interventions for selected infections, where pharmacists can initiate, modify, or stop antibiotics under protocol.
Each pilot should define clear evaluation indicators:
- Clinical outcomes (e.g., blood pressure or HbA1c control, symptom resolution).
- Medicine‑related outcomes (medication errors, adherence, appropriateness of therapy).
- System outcomes (waiting times, physician workload, hospital readmissions).
- AMR‑related outcomes where antibiotics are involved (appropriateness of antibiotic choice, duration, and resistance trends).
If the pilots show safety, acceptability, and added value, the data can then inform targeted amendments to relevant laws and rules such as the Allopathic System (Prevention of Misuse) Rules and associated regulations.
Step 7 – Legislative and Policy Amendments
Only after successful pilots and strong stakeholder support should formal changes to prescribing laws be considered. Potential legal and policy steps include:
- Amending the definition of authorized prescribers in the Allopathic System (Prevention of Misuse) Rules 1968 to include “registered pharmacist prescribers” within a defined scope.
- Updating DRAP guidelines on pharmacies and hospital pharmacies to incorporate pharmacist prescribing standards, documentation requirements, and quality indicators.
- Updating national and provincial health policies to formally recognize pharmacist prescribers as part of the multidisciplinary care team, particularly for chronic disease management and antimicrobial stewardship.
Such changes should always preserve the principle that diagnosis and complex therapeutic decisions remain under physician leadership, with pharmacists providing extended but clearly defined prescribing support.
Step 8 – Communication With the Public and the Profession
Public trust will determine whether pharmacist prescribing succeeds. Transparent communication is therefore essential.
Important messages to communicate include:
- Pharmacist prescribing is not an attempt to replace doctors, but a way to improve access and quality for selected, well‑defined services.
- Pharmacists who prescribe will be specially trained, registered, and audited, and will work within clear guidelines and referral pathways.
- Stronger regulation will simultaneously tackle unsafe, informal prescribing and unauthorized sales of prescription‑only medicines.
Within the profession, pharmacy bodies should focus on building clinical skills, encouraging evidence‑based practice, and promoting ethical standards that put patient welfare above commercial interests.
Conclusion: A Responsible Roadmap, Not a Shortcut
Pakistan faces a dual challenge: on one side, overburdened health services and unmet needs; on the other, widespread informal prescribing and weak regulatory enforcement. In this context, pharmacist prescribing should not be approached as a shortcut or a political slogan.
Instead, it requires a careful roadmap: fully implementing current pharmacy roles, defining a limited and collaborative prescribing model, building robust training and accreditation, strengthening regulation and enforcement, running well‑designed pilots, and then considering targeted legal reform based on evidence.
Handled in this way, pharmacist prescribing could become a tool to enhance patient safety, expand access, and support rational medicine use—rather than adding another layer of unregulated practice to an already fragile system.
References
- World Health Organization Regional Office for the Eastern Mediterranean. Independent prescription of medicines and diagnostic test advice by final-year medical students in Pakistan. East Mediterr Health J. 2017;23(12).
- Government of Pakistan. The Drugs Act, 1976. Islamabad: Ministry of Law and Justice; 1976.
- Government of Pakistan. Drug Regulatory Authority of Pakistan Act, 2012 (as amended till Feb 2022). Islamabad: DRAP; 2022.
- Drug Regulatory Authority of Pakistan. Draft Guidelines on Standards for Establishment of Pharmacies in Pakistan. Islamabad: DRAP; 2024.
- Drug Regulatory Authority of Pakistan. Guidelines on Minimum Standards for Establishment of Hospital Pharmacies in Pakistan. Islamabad: DRAP; 2024.
- Pharmacy Act (Pakistan) – compiled text and rules related to registration and practice of pharmacists.
- Khyber Pakhtunkhwa Health Care Commission. Registration and Licensing Regulations, 2022. Peshawar: KP HCC; 2022.
- Government of Khyber Pakhtunkhwa. Health Care Commission Act 2015. Peshawar: Government of KP; 2015.
- Medication therapy management in Pakistan. BMJ Open (or similar journal – as per article metadata in PubMed Central). 2025; online first.
- Developing a pharmacist-centered novel antimicrobial stewardship program in Pakistan. East Mediterr Health J. 2025; online first.
- Antimicrobial stewardship in Pakistan: a pharmacist’s perspective. IDStewardship; 12 Dec 2025.
- Socioecological factors linked with pharmaceutical behavior (self-medication and prescribing context). BMJ Global Health. 2023;6(Suppl 3):e010853.
- Perceptions of healthcare professionals and patients on the role of pharmacists in Pakistan. Front Pharmacol. 2022;13:965806.
- FIP (International Pharmaceutical Federation). National Level Intelligence Report: Pakistan 2020. The Hague: FIP; 2020.