Consultation link: Consultation on internationally-qualified pharmacists’ education and training | General Pharmaceutical Council (Closing date 21 July)

The GPhC is currently consulting on proposed changes to the route for internationally qualified pharmacists wanting to register in Great Britain.

The proposals include:

• reducing the current route from two years to one year;
• allowing prior learning and experience to shorten training;
• building independent prescribing into the new route;
• creating new learning outcomes for internationally qualified pharmacists.

Why pharmacists should respond

Even if you support the proposal, it is important to respond. This affects:

• future pharmacist supply;
• pharmacist pay and competition;
• independent prescribing capacity;
• domestic pharmacy education;
• patient safety;
• public confidence in the register;
• the value of UK-based pharmacy training.

The consultation is open to individual pharmacists. A high response rate from practising pharmacists is more likely to make the practical consequences visible.

Below is a draft Q&A template. Please adapt it to reflect your own views rather than submitting it unchanged.

Q1. Should training be reduced from two years to one year?

Suggested answer: No

I do not support reducing the route from two years to one year without stronger independent evidence.

The proposed reduction may improve speed of registration and workforce supply. However, it also risks lowering the effective cost and training burden required to enter the same professional register.

The GPhC appears to rely on individual qualification checks, comparison of national standards, GB-based conversion training, supervised practice and the registration assessment. It does not appear to provide for full audit or accreditation of the original non-EEA university, including admissions standards, assessment quality, clinical exposure, placement quality, faculty standards, regulatory oversight or provider costs.

That matters because non-EEA pharmacy education systems may vary substantially. Some may have lower entry requirements, lower tuition costs, lower provider costs, less clinical exposure or different assessment standards than GB pharmacy education. If those upstream differences are not fully audited, a one-year route may create an unequal pathway into the same protected profession.

There is also an economic risk. A shorter route may increase pharmacist supply. If funded service demand does not increase proportionately, the likely effects are greater competition, weaker wage growth, and reduced return on investment for pharmacists who trained domestically. It may also undermine the perceived value of GB pharmacy degrees and domestic pharmacy schools.

There is also a potential institutional conflict of interest. Increasing pharmacist intake increases future registration-fee income for the regulator. This does not imply improper motive, but it does mean the proposal should be supported by independent evidence and transparent economic analysis.

For these reasons, I would only support a shortened route where equivalence is demonstrated, not assumed. The GPhC should publish evidence on how foreign education systems are assessed, whether provider-level audits are performed, and how differences in admissions, training intensity, clinical exposure, educational cost and regulatory oversight are accounted for.

Without this, I do not believe a blanket reduction from two years to one year is justified.

Q2. What alternative route should be used?

I would prefer a conditional route rather than a blanket one-year route.

The default route should remain two years unless the applicant can demonstrate strong equivalence in prior education, clinical exposure, assessment standards and professional experience. A shortened route should only be available where the GPhC has verified that the applicant’s original training system is substantially comparable to GB standards.

A stronger alternative would include:

• initial GPhC eligibility checks, including qualification validity, registration status, good standing and fitness-to-practise checks;
• jurisdiction-level and provider-level assessment of the original education system, including admissions standards, assessment quality, clinical exposure, placement quality, faculty standards, regulatory oversight and provider costs;
• national criteria for recognising prior learning, so previous education or experience is assessed consistently across all GB providers;
• minimum supervised GB practice exposure, including UK law, ethics, NHS systems, safeguarding, clinical governance, responsible pharmacist duties, patient-facing care and professional accountability;
• independent prescribing only after sufficient GB clinical supervision and prescribing-specific assessment;
• the Common Registration Assessment for all candidates;
• published outcomes by provider and route, including pass rates, attrition, supervisor feedback and fitness-to-practise issues;
• independent economic and regulatory impact assessment, including effects on domestic pharmacy schools, pharmacist pay, competition, workforce supply, registration-fee income and the value of GB pharmacy degrees.

This would allow genuinely equivalent candidates to progress faster while reducing the risk of inconsistent standards, unfair competition, public-protection gaps, and economic disadvantage to domestically trained pharmacists.

Q3. Should providers be allowed to recognise prior learning and experience to shorten training?

Suggested answer: No / Disagree unless nationally controlled

I do not support provider-level discretion to shorten training unless it is controlled by a clear national GPhC framework.

Recognition of prior learning is reasonable in principle. It may prevent unnecessary duplication for candidates with recent, relevant and genuinely comparable education or experience. However, if individual providers decide this locally, there is a risk of inconsistent standards between universities.

The threshold for “recent, relevant and similar to Great Britain” must be nationally defined. Otherwise, two candidates with similar backgrounds could receive different training requirements depending on which provider assesses them.

There is also a public protection risk. Prior experience may be recent and relevant, but still not equivalent to GB practice in areas such as UK law, NHS systems, safeguarding, clinical governance, responsible pharmacist duties, patient-facing care and prescribing accountability.

I would only support recognition of prior learning where the GPhC sets mandatory national criteria, requires evidence of equivalence, audits provider decisions, and publishes outcome data. Without this, shortening training through provider discretion risks inconsistent access to the register and reduced confidence in the fairness of the route.

Q4. Do you agree with the proposed criteria for recognising prior learning and experience?

Suggested answer: Disagree

I disagree with the proposed criteria in their current form.

Recognising prior learning and experience is reasonable in principle, but the criteria appear too broad and may create inconsistent standards. In particular, allowing reductions based on full-time work in community or hospital pharmacy support roles may not reliably demonstrate equivalence to pharmacist-level education, clinical judgement, legal accountability, prescribing readiness, or autonomous professional decision-making in Great Britain.

The proposal also places significant responsibility on programme providers to verify evidence and determine relevance. This risks variable interpretation between providers unless the GPhC sets strict national criteria, audits decisions, and publishes outcome data.

I am also concerned that qualification equivalence appears to rely on national standards and learning outcomes verified by the GPhC, rather than full provider-level audit of the original overseas university or training provider. This may not adequately account for differences in admissions standards, assessment quality, clinical exposure, placement quality, faculty standards and educational infrastructure.

Prior learning should only reduce training where equivalence is clearly demonstrated against pharmacist-level GB standards. It should not be used to shorten the route on the basis of support-role experience alone unless there is robust evidence that the experience included relevant patient-facing clinical responsibility, supervised assessment, and comparable professional outcomes.

I would support recognition of prior learning only if it is governed by a mandatory national GPhC framework, with minimum GB practice exposure that cannot be waived, independent moderation of provider decisions, and transparent reporting of pass rates, attrition, fitness-to-practise issues and early-career outcomes.

Q5. Should independent prescribing be built into the new route?

Suggested answer: No, not automatically

I do not support automatically building independent prescribing into the new route in its current form.

Independent prescribing requires more than general pharmacist competence. It requires safe clinical assessment, diagnostic reasoning, risk management, understanding of UK prescribing governance, NHS pathways, referral thresholds, monitoring responsibilities, and accountability within GB practice.

For UK-trained pharmacists, prescribing is being integrated after several years of education and staged exposure to the GB healthcare system. For internationally qualified pharmacists, prior education and clinical exposure may vary substantially. If the GPhC has not fully audited the original overseas provider, it is difficult to assume that a compressed one-year programme can reliably provide equivalent prescribing readiness for all candidates.

There is also a fairness issue. Many existing GB-trained pharmacists registered before prescribing was integrated must complete a separate IP qualification at additional time and cost. Automatically giving the same annotation through a shortened international route may create unequal treatment between cohorts.

I would support inclusion of independent prescribing only where the candidate has completed a minimum non-waivable period of supervised GB clinical practice, prescribing-specific supervision, assessment against national criteria, and independent moderation. Prescribing status should be awarded only where competence is clearly demonstrated in the GB context, not automatically attached to completion of a shortened conversion route.

Q6. Are the proposed learning outcomes sufficient?

Suggested answer: Strongly disagree

I strongly disagree that the learning outcomes are sufficient in their current form.

The proposed outcomes may describe general pharmacist competence, but they do not appear to address the main risk in this route: whether internationally qualified pharmacists have had equivalent upstream education, clinical exposure, assessment standards and professional formation before entering a shortened GB programme.

Learning outcomes alone do not prove equivalence. A candidate may be assessed against outcomes at the end of the programme, but this does not necessarily replace several years of GB-based education, practice exposure, legal context, NHS experience, safeguarding, governance and professional accountability.

Additional learning outcomes should include explicit competence in:

• GB pharmacy law, NHS systems, clinical governance and safeguarding;
• responsible pharmacist accountability and autonomous decision-making in GB practice;
• UK prescribing governance, referral thresholds, monitoring duties and escalation pathways;
• patient-facing clinical assessment in the GB context, including risk recognition and documentation;
• understanding differences between the candidate’s original training system and GB pharmacy practice;
• evidence-based use of prior learning, including awareness of the limits of overseas or support-role experience;
• professional and economic understanding of the GB pharmacy system, including service funding, workforce pressures and the pharmacist’s role within multidisciplinary care.

I am also concerned that the outcomes do not compensate for the lack of provider-level audit of the original overseas university. If admissions standards, assessment quality, clinical exposure and training infrastructure vary substantially between countries, then learning outcomes delivered within a compressed programme may not be sufficient to ensure equivalent readiness.

Therefore, the outcomes should be strengthened and linked to minimum supervised GB practice exposure, independent prescribing readiness, and nationally audited assessment standards.