Every spring and summer, the congress season breathes energy into the pharmaceutical world—a moment brimming with anticipation for product progress, emerging data, and unbiased scientific interchange. Yet at every congress, a quiet tension surfaces: how do industry professionals champion transparency about pipeline assets without veering into the territory of promotion? Having stood on both sides of the compliance query—fielding questions as a final signatory and briefing booth teams as a medical lead—I know firsthand just how nuanced, and frankly how misunderstood, this challenge can be. The aim, contrary to rumour, isn’t to say 'no' to science, but to say 'yes' to transparent, defendable, and well-reasoned scientific communication—whatever the competitor at the next stand might think.
Why this matters now: The congress conundrum
Each congress season, scrutiny of medical booths intensifies. With updated ABPI 2025 congress guidance and rising expectations for transparency, exhibitors face a unique challenge: how to showcase scientific progress without crossing into promotion. The practical conflict is clear—medical teams want to communicate advances, yet the reasonable perception test on the congress floor can quickly turn transparency into a compliance risk.
Regulatory pressure has never been higher. The latest ABPI guidance states,
‘Proactive display of pipeline or pre-licence information is very likely to be considered promotional.’ – ABPI 2025 Congress & Events Guidance
This explicit language leaves little room for ambiguity. Most PMCPA cases do not arise from public complaints, but from competitor challenges—making competitor perception the real risk driver at medical congresses.
In practice, booth visitors—whether HCPs or industry peers—often conflate scientific updates with commercial intent. This makes the separation of science and promotion not just a regulatory requirement, but a matter of industry professionalism. As congress season scrutiny grows, exhibitor guidelines must evolve to ensure medical booth compliance is not only achieved, but clearly PMCPA defendable in the face of peer interpretation and competitor scrutiny.
Defendable transparency: Defining purpose, not promotion
Defendable transparency in scientific communication means sharing information with a clear, legitimate purpose—never as a proxy for promotion. True transparency in medical marketing is an asset when it supports investigator recruitment, research partnering, or disease awareness, rather than showcasing assets or hinting at future launches. The PMCPA emphasise accuracy, balance, and the importance of clear separation between medical and promotional content, with relevance to the attending audience at the core.
Proactive visual displays—such as pipeline timelines or ‘coming soon’ posters—risk creating a promotional impression, regardless of whether the asset is in phase 2 or phase 3. The key risk driver is not the phase, but the format and context of the information. For me:
‘The principle is defendability, not avoidance. PMCPA recognises the value of purposeful, factual scientific exchange.’
Purposeful transparency is about sharing genuine scientific advances, not pre-emptive product marketing. This requires robust separation between medical and promotional messaging—physically, visually, and conversationally. Documentation of intent, rationale, and process is essential; it provides the evidence needed in any PMCPA investigation. Ultimately, transparency is positive when it is factual, reactive, and audience-appropriate, not when it blurs into promotion.
The perception test: Managing risk with Intent, Audience, Format, and Context
PMCPA compliance hinges on the ‘reasonable perception’ test: not just what is shared, but how, to whom, and in what setting. Every element—intent, audience, format, and context—shapes risk. I always stress to teams,
‘How we communicate matters as much as what we communicate—especially when competitors are watching.’
To manage risk, we must:
Document scientific rationale for any pipeline discussion.
Restrict access to HCP-only areas where possible.
Use reactive, non-visual formats (e.g., 1:1 medical responses) instead of proactive displays.
Ensure booth and staff separation from commercial activities—attire and branding cues matter.
Pipeline availability (reactively) - have it available and readily accessible if requested - such as on an ipad or printed summary (proactively sharing it on a large screen or graphic should be avoided)
Most PMCPA breaches at congresses stem from misperceived intent or blurred lines between medical and promotional spaces. A robust, well-documented compliance framework is essential for defendability.
Factor | Lower Risk | Higher Risk |
|---|---|---|
Intent | Documented scientific need | Unclear or commercial rationale |
Audience | HCP-only, gated | Open, public-facing |
Format | Reactive, verbal, non-visual | Proactive, visual displays |
Context | Separate, neutral design | Integrated, branded, or close to promo stand |
Beyond proactive displays: Alternatives for legitimate investigator recruitment
Investigator recruitment is a bona fide R&D activity, but the channel and format are critical to maintaining a PMCPA-defendable compliance framework. The ABPI guidance is clear: public-facing, proactive displays—even with disclaimers such as “For Investigator Use Only”—rarely neutralise the perception of promotion. my message is,
“Investigator engagement is critical for science—but must never be window dressing for commercial objectives.”
Effective investigator recruitment strategies should prioritise right channel selection and clear separation from general booth promotion. Defendable alternatives include:
Targeted 1:1 investigator meetings—pre-arranged, invitation-only, and documented.
Closed investigator briefing sessions—segregated from the main booth, with controlled access for qualified HCPs.
Factual medical information responses—provided reactively and only upon unsolicited request, with all queries and responses logged.
General booth wall messaging or visual pipeline displays, even with disclaimers, are insufficient if the overall impression remains promotional. The PMCPA consistently judge on perception, not intent or wording alone. Best practice is to document all investigator outreach, ensuring legitimate scientific exchange is separated from open booth activity and handled through compliant, controlled channels.
Design decisions: Keeping medical booths fact-based and PMCPA-safe
Effective booth design is the first line of defence for medical booth compliance. To meet PMCPA-defendable standards and uphold industry professionalism, every element must reinforce factual, non-promotional scientific communication. The best practice is to use only product-neutral educational visuals—such as mechanism of disease diagrams or therapy area science—avoiding any reference to pipeline timelines, investigational assets, or future indications. Physical separation between medical and promotional spaces, with distinct branding and staff, is essential. This clear divide reduces perception risk and supports a credible scientific environment.
Booth signage should invite dialogue: ‘Medical information available on request’—never pre-emptively display answers or pipeline data. QR codes, digital screens, or printed materials must not link to pipeline or pre-licence content. All design choices, from colour palettes to animations, should avoid commercial cues that echo promotional campaigns. Staff must be thoroughly briefed, with scripts for documenting and responding to unsolicited queries, ensuring every interaction is factual and balanced. Design approvals and the rationale for content decisions should be formally documented.
‘A compliant booth is first and foremost a credible scientific space—never an advert in disguise.’ – Dr Anzal Qurbain
Practical design rules and robust staff protocols are vital exhibitor guidelines for maintaining medical booth compliance and ensuring all scientific communication remains PMCPA-defendable.
Documentation and the defendable framework: Making the code work in your favour
Robust documentation is the backbone of medical booth compliance and the most effective way to make transparency PMCPA-defendable. The PMCPA consistently upholds documented intent and evidence when assessing cases.
“Our industry’s best line of defence is our evidence of professionalism and intent.”
To convert good practice into defendable practice, every element of your booth should have a written scientific rationale. This means clearly outlining why each piece of information is present, ensuring it serves a legitimate scientific purpose. Maintain up-to-date staff briefing records, unsolicited request logs, and response templates. These materials keep responses factual, balanced, and proportional—essential for transparency in medical marketing.
All design approval decisions must be recorded, including the reasoning behind rejecting or amending elements that could create a promotional impression. This level of documentation for compliance demonstrates high standards and supports your position if challenged.
Prepare a written rationale for all booth content
Keep staff training and briefing records accessible
Log unsolicited requests and responses
Document design approval decisions and risk assessments
Companies with thorough documentation see fewer sustained or escalated complaints. Accessible, current paperwork throughout congress season is not just best practice—it is your compliance framework and your shield in any PMCPA case.
My Mentor’s View: Coaching confident, defendable transparency
As final signatories, our leadership sets the tone for industry professionalism and the compliance framework that underpins medical booth compliance. Coaching teams towards confident, defendable transparency is not about instilling fear or defaulting to blanket prohibitions. Instead, it is about guiding colleagues to see compliance as a mark of professional credibility—an enabler of legitimate scientific exchange, not a barrier. We must encourage teams to articulate the rationale behind every decision, ensuring each element of the booth setup is factual, purposeful, and defensible under the reasonable perception test. This means challenging risk-averse mindsets and moving beyond boilerplate disclaimers, focusing instead on evidence, intent, and clear separation of science from promotion.
Mentoring future signatories is about instilling habits of evidence, reason, and professional pride. By championing transparency with purpose, we empower teams to communicate confidently and compliantly, even under scrutiny. The question we should always ask is: would this approach stand up to competitor review or a complaint? When we lead with intent and reflection, we protect both our company’s credibility and the broader reputation of the industry. Defendable transparency is not just a compliance requirement—it is a standard of excellence that starts at the top.
‘Mentoring future leaders is about instilling habits of evidence, reason, and professional pride.'
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