HCP vs Public: ABPI Audience Rules for Pharma Social Media

The single most common compliance error in pharma social media is a misjudged audience. Under the ABPI Code of Practice 2021, promotion of prescription-only medicines is permitted to healthcare professionals (HCPs) and prohibited to the public. The catch is that on social media, audience is determined by who can actually see the post — not by who you intended to reach.

Why Audience Is Defined by Reach, Not Intent

In a printed detail aid, the audience is clear: you hand it to an HCP. On social, a public profile, an open group, or a boosted post has no such control. The Code treats open reach as public-facing, regardless of the copy's intent.

The practical consequence: if your content could reasonably be seen by someone who is not an HCP, treat it as public content.

What You Can Do on Public Accounts

Public-facing channels still allow valuable activity, as long as it stays within the rules:

• Disease awareness content that does not identify a specific medicine.
• Corporate, company and general health information.
• Public-interest content such as health campaigns and awareness days.
• Content that directs the public to speak with their doctor.

What You Cannot Do on Public Accounts

Promotional content for prescription-only medicines is off-limits on open, public accounts. That includes:

• Promoting a specific product, molecule, or brand.
• Showing pack shots or product imagery.
• Using a handle, hashtag, or image that maps one-to-one to a product.
• Boosting or paying to amplify promotional content to a non-verified audience.

Controlled HCP Channels

You can promote to HCPs where reach is genuinely restricted and verifiable:

• Gated LinkedIn groups restricted to verified HCP members.
• Targeted advertising where the audience is HCP-verified.
• Closed professional platforms that authenticate healthcare professionals.
• Direct communications to individual HCPs on their professional channels.

The Amplification Trap

Your compliance can be undone by the behaviour of others. Employee reshares, KOL reposts, and community shares can extend an HCP-targeted post into public reach.

Manage this by briefing employees, agreeing the scope of any KOL or influencer activity, and logging approvals as part of the same MLR review as the original content.

How RegScribe Helps

RegScribe lets you choose the audience — HCP or public — for every brief, and drafts copy that respects the line between the two. It is a drafting aid, not a substitute for review, but starting from the right audience frame keeps your social content on the right side of the Code.