Priority area 1 - Transitional licensing compliance
The Queensland Pharmacy Business Ownership Council (Council) will prioritise communication and engagement activities to ensure that pharmacy business owners are aware of, and understand, their obligation to apply for a pharmacy business licence and when they need to apply.
Council will write to pharmacy business owners who have not applied for a licence by 31 August 2026, explaining:
- most pharmacy business owners need to apply for a licence by 2 November 2026 (one-year transitional period),
- pharmacy business owners who believe that they have until 1 November 2027 to apply for a licence (two-year transitional period) should seek specific legal advice about their eligibility,
- the detailed criteria that must be met to be eligible for a two-year transitional period, and
- that pharmacy business owners who do not apply by 2 November 2026 will need to provide evidence about their eligibility for the two-year transitional period when they make a licence application in year two.
Council will write again to pharmacy business owners who have not applied in late September/early October 2026.
Follow up direct emails and phone calls will be made in mid-October 2026 with the same key messaging as a final treatment.
Enforcement will be considered (in line with the Council’s Enforcement Policy) for seriously non-compliant pharmacy business owners. This may include:
- Owners (for example, identified through intelligence, information from other regulators or the public) who may not have engaged or notified as required under the Pharmacy Business Ownership Act 2001 i.e. they have persistently operated ‘outside the system’.
- Owners who do not apply in time, despite receiving detailed information about their obligations to apply for a licence.
In relation to licensing fees, Council will apply an escalating approach to debt recovery for unpaid fee debts, including reminders. Failure to pay can result in suspension or cancellation of a licence.
Priority area 2 – Proactive premises inspection
Council will prioritise inspections of premises that are ‘online only’ or not open to the public, new or ‘greenfield’ pharmacy premises and pharmacy businesses providing complex compounding services and will also inspect premises where appropriate in response to a complaint.
Where non-compliance is verified through the inspection process, Council will initially work with pharmacy business owner to remedy the relevant issue. Failure to remedy the issue may result in compliance actions such as refusal of an application, conditions being applied, or suspension or cancellation of the licence following a show cause process.
Priority area 3 – Audit of business arrangements
Licensing processes are designed to identify business arrangements which may:
- contravene section 22 of the Pharmacy Business Ownership Act 2024 (PBO Act) by non-owners controlling medicines and health services in a prohibited way, or
- have undisclosed material interest holders.
These risks are detected by examining documents between the parties provided at application and any open-source intelligence.
Council may audit the operations of the holder of a pharmacy business licence to the extent that they relate to the obligations of the licence holder under the PBO Act. The audits will consider whether the operational business arrangements align to the documents provided at application and any contravention of the PBO Act.
Where non-compliance is verified through the audit process, Council will initially work with the pharmacy business owner to remedy the relevant issue. Failure to remedy the issue may result in compliance actions such as refusal of an application, conditions being applied, or suspension or cancellation of the licence.
Priority area 4 – Reports about non-compliance
Council may receive reports about non-compliance with the PBO Act from:
- other regulators e.g. Office of the Health Ombudsman, Queensland Health,
- through media articles, and
- through our ‘Report a Problem’ portal on the Council website.
Council will initially triage complaints to ensure that they fit within its jurisdiction.
Matters falling outside its jurisdiction will be referred to other regulators where appropriate.
Frivolous or vexatious complaints may be disregarded, and complaints will be prioritised according to the seriousness of allegations and the relevant regulatory risks noted.
Where non-compliance is verified through the investigation process, Council will initially work with the pharmacy business owner to remedy the relevant issue. Failure to remedy the issue may result in compliance actions such as refusal of an application, conditions being applied, or suspension or cancellation of the licence.