I still remember the LinkedIn post that landed in my inbox at 7:30 a.m. — a well-meaning disease-awareness graphic shared by a global team, liked by an employee in the UK, and suddenly a compliance red flag. As an ABPI Final Signatory who has worked through PMCPA cases, that morning crystallised something I often tell teams: social media isn't low risk because content is 'non-promotional' — it's high risk because of how perception and network effects work online.
The LinkedIn ‘like’ that became a case study
I still remember the moment a “safe” LinkedIn post stopped being safe. It was a global disease-awareness graphic—no brand, no product, no call to prescribe. It went live from a non-UK page and looked like standard public health content.
Then a UK colleague hit Like. Another reshared it with a supportive comment. Suddenly, that global content had a UK footprint, a UK employee signal, and a UK audience pathway. Not long after, it was referenced in a PMCPA query. That’s when teams realise: non-promotional on paper can become promotional in effect on social media platforms.
Askanzal - “I’ve seen a single casual ‘like’ transform a benign post into a regulatory headache — perception always wins online.”
Under the ABPI Code, judgement is perception-based, not intention-based. As I say:
The PMCPA looks at how content reaches and influences audiences, not the intent.
This is exactly why the PMCPA published social media guidance (FAQs) on 1 June 2023, and why the ABPI Code update in 2024 matters: digital behaviour is assessed cumulatively.
Likes, shares, hashtags, links, and “helpful” comments can reframe context.
Press releases shared socially can become indirect promotion.
“Educational” posts can drive patient/HCP pull—and trigger scrutiny.
My social media guidance as a Final Signatory: pause before you engage. Ask, “How could this look to the public, competitors, or the PMCPA?” Follow AskAnzal for weekly real-world ABPI insights.
Why social media is uniquely high risk under the ABPI Code
As an ABPI Final Signatory, I see the same myth repeat: “It’s non-promotional, so it’s low risk.” On social, non-promotional ≠ safe. We know that promotion of prescription medicines to the public is NOT allowed — and social platforms blur public, patients and HCPs in seconds.
Small actions can become indirect promotion
“Innocent” behaviour is often the trigger: likes, shares, comments, hashtags, tags and links. Companies are responsible for linked, tagged or hashtagged content, and employee personal use can fall under pharma compliance when tied to company activity.
AskAnzal: “On social, a post is never truly isolated — every hashtag and link can anchor it to promotional intent
PMCPA risk is cumulative, not single-post
UK employees liking a global product post can “localise” it under the ABPI Code.
Disease awareness on LinkedIn can drift into indirect promotion if it drives patient/HCP pull.
Press releases shared socially can look like product messaging when amplified by staff.
“Educational” posts + a link + a hashtag can create a promotional pathway.
Regulatory Affairs Lead: “Indirect promotion, not direct advertising, is where many PMCPA cases now begin.”
Before posting (or liking), ask: who will see this, what does it lead to, and what story does the digital trail tell? Compliant social is possible—follow AskAnzal for weekly, real-world ABPI Code guidance.
How 'innocent' actions trigger breaches — examples & PMCPA patterns
As an ABPI Final Signatory, I see the same myth every week: “It’s non-promotional, so it’s safe.” On social media, perception beats intention. A post can start as neutral and become promotional material through reach, context, and cumulative behaviour.
PMCPA guidance: indirect promotion is the usual trigger
Most PMCPA guidance cases aren’t about obvious ads. They’re about likes, comments, reshares, and hashtags tagging that turn a general message into targeted promotion.
Employees liking global posts: a US brand post + UK staff engagement can look like UK promotion of a POM.
Disease awareness on LinkedIn: “educational” content that nudges HCP or patient pull (links to brand sites, “ask your doctor”) is a classic trap.
Press releases shared socially: audience matters. A corporate update can be judged promotional once amplified to the public.
Hashtags: a disease tag plus brand-adjacent phrasing can function like a claim, even without a product name.
Regulatory Affairs Lead: "I’ve reviewed cases where a press release reposted on social media was judged promotional because of the audience it reached."
AskAnzal: "A seemingly educational post that drives patient or HCP pull is a classic indirect-promotion trap."
Non-promotional content may not need certification, but it still needs risk review, and monitoring for adverse events, and fast correction routes (within limits). Social is judged as a pattern.
Why perception matters — cumulative digital behaviour and judgement
As an ABPI Final Signatory, I see the same trap: teams treat “non-promotional” social posts as low risk. Under the ABPI Code (and PMCPA practice), perception beats intention in digital communications. A post is judged by how it could reasonably land with HCPs, patients, and the public—especially once it’s amplified.
Social media is uniquely high risk because regulators look at patterns, not single moments. A like here, a hashtag there, a link to a press release, and suddenly the cumulative story looks like product pull.
Employees liking a global post that names a medicine
Disease awareness on LinkedIn that “just happens” to mirror your brand narrative
A press release reshared with a wink and a CTA
“Educational” content that drives patient or HCP enquiries
Digital behaviour is no longer judged in isolation; the pattern matters."
Context is everything: platform, audience, timing, and who engages. That’s why monitoring and documentation matter—your rationale, approvals, and screenshots can be the difference between clarity and a case.
AskAnzal: "Good documentation and a clear rationale often win the day when questions arrive — not silence."
Think before you post, like, or share: non-promotional ≠ safe. Compliant social is possible if done correctly
Practical guidance: what teams should do before posting, liking or sharing
As an ABPI Final Signatory, I treat “non-promotional” as a label, not a risk rating. On social media, perception beats intention: a like on a global brand post, a LinkedIn disease-awareness graphic, or a press release shared with a product hashtag can look like indirect promotion in a PMCPA complaint.
Quick pre-post checklist (pharma compliance + social media guidance)
Audience: UK public or HCP? Could it be read as product pull?
Certification need: Yes, as it is aimed at the public
Links/hashtags: Do they route to product pages, claims, or unbalanced benefit?
Employee engagement: Clear social media policy on liking/sharing global content; no “helpful” amplification.
Adverse events: Set procedures for content monitoring and AE capture/escalation.
Roles, records, and third parties
Decide who reviews, who documents the rationale, and who monitors comments and resharing. Remember: companies can be liable for third-party content posted on their behalf—so certification policies must be clear.
AskAnzal: “Pragmatic controls — not paralysis — are the answer: a short checklist, clear roles, and fast monitoring.”
Regulatory Affairs Lead: “Training employees to treat every corporate post as potentially reportable reduces accidental exposure.”
Social media judgement is cumulative: every tap leaves a trail.
So what? Accountability, judgement and an AskAnzal view
As an ABPI Final Signatory, I see why “non-promotional” feels safer. But on social media, perception beats intention. Under the ABPI Code (and PMCPA social media FAQs, 1 June 2023), risk is judged by what the public, HCPs, and competitors see—and how it lands cumulatively.
“Innocent” actions can tip into indirect promotion: employees liking a global post about a medicine, a LinkedIn disease awareness post that nudges “ask your doctor” about our product, a press release reshared with a product hashtag, or an “educational” thread that drives patient/HCP pull via links. One post may be fine; the pattern can be the breach—especially after ABPI Code guidance raised expectations on monitoring and governance for pharmaceutical companies.
Likes/shares/comments can look like endorsement.
Hashtags/links can create a promotional trail.
Employee engagement can turn global content into UK-facing promotion.
Good documentation and rationale beat silence. If you must correct misinformation on POMs, it’s allowed only in limited conditions—be factual, non-promotional, and record why you engaged.
AskAnzal: “Social media is not the enemy — poor judgement is. With simple rules, compliant social is achievable.”
Compliant social media is possible with guardrails, certification, and active monitoring. I help teams bridge marketing ambition and ABPI Code reality—follow AskAnzal for weekly, real-world ABPI insights.
Wild cards: a quote and a hypothetical scenario
A global campaign can feel safe until a local engagement pulls it into a different legal frame.
As an ABPI Final Signatory, that line lands because it describes the real risk on global digital channels: the post isn’t the only “material”. The platform behaviour around it becomes the material too. Under the ABPI Code, perception beats intention. A like can look like endorsement. A share can look like a call to action. A hashtag can act like a claim. That’s why “non-promotional” never equals “safe” on social.
Here’s the messy hypothetical:
Global launches a disease awareness campaign with #BackToLife. In the UK, that phrase is already associated with a specific medicine class. A UK employee likes the post, tags an NHS contact, and adds “Great outcomes in practice.” Now the algorithm pushes it to UK HCPs. Someone screenshots it and complains. Suddenly you’re facing regulatory hurdles, an ABPI review, and a PMCPA case built on indirect promotion—created cumulatively by a hashtag, a tag, and employee engagement.
My social media guidance is simple: treat every click as publishable, assume global content can become local, and pause before you amplify. Compliant social media is possible—but it needs judgement, not hope. Follow AskAnzal for weekly, real-world ABPI insights.