Victorian Pharmacy Authority

Circular No. 39 - Dec 2025

In this Circular

• Chair's Message
• The VPA moves to a new office in Parkville 
• Special focus
  
  • New digital system
  • Preparing for changes to application processes
  • Guidance on pharmacy business ownership, proprietary interests and undue influence​​​​​
• Office Closure
• Recent panel hearings
• For Information
  • AHPRA registration renewal - implications of lapsed registration for proprietors
  • A message from the Victorian Aboriginal Health Service
  • A message from Transport Victoria - new resources on medicinal cannabis and driving
• Resources
• Members of the Victorian Pharmacy Authority
• VPA Staff

Chair's message

The VPA has moved to Level 8, 369 Royale Parade, Parkville. The office relocation and digital transformation will coincide with a change to a contemporary logo. Stakeholders can expect a new look for the VPA in the new year.

The VPA has also developed a guidance document to help stakeholders understand the requirements of the Pharmacy Regulation Act 2010 in relation to pharmacy business ownership, proprietary interests and undue influence.

This circular includes a case study on a recent inspection. Inspections continue to play a critical role in promoting
and monitoring compliance with the regulatory framework. 

We remind proprietors to renew their AHPRA registration by 31 December given the significant implications of a lapsed registration on a licensee’s eligibility to hold a licence to carry on a pharmacy business. 

On behalf of the Authority members and staff, I wish you a happy and safe festive season and best wishes for the new year. 

David McConville
Chair, Victorian Pharmacy Authority

The VPA moves to a new office in Parkville

The VPA recently moved to a new office at Level 8, 369 Royal Parade, Parkville, next to Monash University Parkville campus, home to the Faculty of Pharmacy and Pharmaceutical Sciences, and the office of the Pharmaceutical Society of Australia Victorian Branch.

The new office provides additional space and facilities to support VPA’s growing team and enhanced stakeholder engagement. We look forward to welcoming stakeholders to the Parkville office and launching the VPA’s new logo in the new year.

The VPA’s telephone number (03) 9653 1700 and email
address enquiries@pharmacy.vic.gov.au have not changed.

Special focus

New digital system

The VPA is embarking on a digital transformation with the implementation of a new system to support its licensing, registration, annual renewals and inspection functions. 

The benefits of the new system will include improved efficiency and reduced regulatory burden on licensees and applicants through streamlined application processes and improving workflow. It will offer an improved user interface making it easier for licensees and applicants to interact with the VPA. It will also optimise data management, analysis and reporting so that the VPA can perform its regulatory functions more effectively and more efficiently.

The VPA will be preparing for its implementation in the new year and anticipates that it will be ready to be launched mid-2026. The VPA will continue to keep stakeholders informed and prepared for the new system.

Special focus

Preparing for changes to application processes

The VPA has undertaken a range of activities to support its digital transformation. These activities include reviewing and revising application forms and covering letters, with a focus on identifying opportunities to simplify and standardise application and approval processes prior to going digital.

We plan to implement some improvements gradually to minimise their impact on stakeholders. These include:

• simplified licensing and registration
  processes
• improved cover letters to communicate with applicants about approval processes, clearly setting out requirements and next steps.

Other changes to licence applications

The VPA grants licences and registers pharmacy premises prior to conducting an inspection of the pharmacy to permit pharmacy businesses to commence operation without delay. For this reason, it is imperative that licensees ensure pharmacy premises are constructed in accordance with approved plans and operated in accordance with the requirements of the Act, VPA Standards and good pharmacy practice.

Sometimes, following a change of ownership, inspections reveal that the facilities and layout of the pharmacy do not support the services provided by the new licensee(s). This may happen for example when a new owner starts a pharmacy service like the provision of medicinal cannabis in a pharmacy which has not been set up to support the service.

Before granting a licence, the Act requires the Authority to be satisfied that the facilities, equipment, security, management and operation of the pharmacy business at the premises comply with good pharmacy practice and relevant requirements in the Schedule to the Act.

To determine whether the pharmacy is capable of supporting the services that the applicant intends to provide at the premises, the VPA may require applicants to provide:

• a list of the pharmacy services they intend to provide at the pharmacy from when the pharmacy commences operation under new ownership
• a copy of a pharmacy floor plan showing the perimeter and layout of the pharmacy, including the dispensary. The floor plan does not have to be commissioned by a professional for this purpose, and
  applicants/purchasers may wish to request a copy of a current floor plan from the vendor.

The above information is currently being requested on a case-by-case basis, usually where risks have been identified following the initial assessment of an application. The VPA is considering making these standard licence application requirements and incorporating them into application forms in the future.

The VPA will consult with stakeholders prior to implementing any significant changes and welcomes feedback on application processes at any time.

Special focus

Guidance on pharmacy business ownership, proprietary interests and undue influence

The VPA is committed to protecting the public and the integrity of the pharmacy regulation regime by ensuring that all Victorian pharmacies are owned, operated and controlled only by registered pharmacists in accordance with the Act.

The VPA has developed a guidance document to better inform licensees, applicants and other stakeholders including franchisors on the requirements of the Act which relate to pharmacy business ownership, proprietary interests and undue influence.

Pharmacy proprietors must ensure they are not entering into commercial arrangements
that:

• contravene the requirements in the Act regarding ownership and proprietary interests; and
• may be void under the "undue influence" provisions in the Act.

To support pharmacists and stakeholders to ensure compliance, the guidance:

• outlines relevant sections of the Act
• provides examples of commercial arrangements that may contravene the ownership and proprietary interest provisions of the Act 
• highlights commercial arrangements involving “undue influence” that are of particular concern to the VPA (“priority control provisions”) including commercial arrangements where the VPA may apply extra scrutiny 
• outlines VPA’s approach to compliance and enforcement.

The Guidance aims to better equip applicants and licensees to identify provisions in agreements which may be void/unenforceable. It includes examples of provisions that may give a third-party undue influence over the pharmacy business, how to identify these provisions and how they may cause harm and impact public safety.

The VPA recommends that pharmacists regularly consider this Guidance, especially when applying for a licence to carry on a pharmacy business and before making any changes to pharmacy commercial arrangements. 

This Guidance is available on the VPA website here.

Office closure

The VPA’s office will close at 5.00pm on Tuesday 23 December 2025 and re-open at 9.00am on Monday 5 January 2026. We wish you a happy and safe festive season.

Recent panel hearings

The VPA conducted 13 panel hearings between August and November 2025 into allegations that licensees failed to meet their responsibilities to comply with the Act and VPA Standards. 

Determinations of the panels were as follows:

• 7 hearings resulted in licensees being reprimanded
• 6 hearings resulted
  in licensees being cautioned
• 6 hearings resulted in conditions being imposed on a licence or premises registration (in these cases, the conditions required a reinspection of the pharmacy subject to the site reinspection fee).

Case study
The VPA inspector found that staff were left in the pharmacy without a supervising pharmacist.

The dose administration aid room containing scheduled medicines did not have full motion sensor coverage as it only covered the back of the room. Moreover, the pharmacist regularly and usually in charge (PRUIC) could not locate the relevant policies and procedures for the services provided by the pharmacy, such as dose administration aid policies and procedures. There were further contraventions of the VPA Standards.

The licensee was reprimanded for failure to comply with the Act and VPA Standards. A condition was imposed on the registration of the pharmacy premises requiring
an unannounced re-inspection of the pharmacy to be undertaken at the licensee’s cost. 

Lessons for licensees

• A pharmacy must be personally supervised by a registered pharmacist at all times it is open for business (s30(1) of the Act). This is an offence provision.
• There can be no access to the dispensary of the pharmacy except under the direct supervision of a registered pharmacist (clause 4 of
  the Schedule to the Act).
• The registered premises must be fitted with a functional-24 hour monitored intrusion detector alarm which covers all areas where medicines and poisons are kept (standard 2.3.3(b) of the VPA Standards).
• The licensee must ensure that policies and procedures are clearly documented, easily accessible, regularly reviewed and updated as part of the effective governance arrangements (standard 1.4.2 of the VPA Standards)

For information

AHPRA registration renewal – implications of lapsed registration for proprietors

Registered pharmacists need to renew their AHPRA registration annually. Pharmacists who do not apply to renew their registration with AHPRA by 31 December 2025 (end of late period) will have lapsed registration and will not be able to practise.

A pharmacist licensee whose registration as a pharmacist lapsed is no longer eligible to own or have a proprietary interest in a pharmacy business and their licence may be revoked. If the registration of a pharmacist director or shareholder of a company licensee lapsed, the VPA may revoke the company licence.

Pharmacists who
own or have a proprietary interest in a Victorian pharmacy are reminded to check their registration status and renew their registration if they have not already done so. Pharmacists can check their registration details and expiry date on the AHPRA Register of practitioners.

For information

A message from the Victorian Aboriginal Health Service

The Victorian Aboriginal Health Service (VAHS) invites pharmacists who are involved in, or connected to, the delivery of opioid pharmacotherapy to take part in the following survey. 

The survey is part of a project, led by VAHS, which aims to design a culturally safe, Aboriginal-led model of opioid pharmacotherapy (opioid dependence treatment) in Victoria. It asks about your role, experiences and perspectives on opioid pharmacotherapy. 

You can access the survey here. Please forward this survey to other pharmacists who may be involved in delivering a pharmacotherapy service. 

For information

A message from Transport Victoria - new resources on medicinal cannabis & driving

New resources support your conversations about safe driving

Whether you dispense medicinal cannabis in your practice or you are seeking to manage patients who are taking medicinal cannabis dispensed elsewhere, it is important to consider the implications for patient safety, including the risks associated with driving. 

Transport Victoria has released a resource package for clinicians on managing medicinal cannabis in the context of driving. The resources help pharmacists give consistent, risk-based advice.

The clinical resource outlines the range of factors that influence impairment due to THC to help you individualise your advice, including potential drug interactions. 

The accompanying patient factsheet and poster support your conversations with patients, noting that, while recent legislative change provides magistrates with discretion on licence sanctions when a patient holds a valid prescription, driving with any detectable amount of THC remains illegal in Victoria. 

The resources are available on the Transport Victoria website here.

Resources

Supporting key learnings from recent inspections and areas of high risk, licensees and pharmacists may wish to refer to the following resources. Resources are not limited to the list below and pharmacists are encouraged to review other relevant resources as required.

VPA resources

• VPA Standards here
• VPA Guidelines here
• VPA Self Audit form here
• VPA Managing Schedule 8 poisons – a reference guide for pharmacists here
• VPA Commercial arrangement guidance here

S8 management

• Drugs, Poisons and Controlled Substances Regulations 2017 here
• Medicines and Poisons Regulation guidance document Management of Schedule 8 poisons here
• Medicines and Poisons Regulation guidance document Refrigerated storage for Schedule 8 medicines (in Victoria) here
• Pharmacotherapy policy in Victoria here
• Pharmacotherapy self-assessment – for pharmacists providing ORT here
• Pharmaceutical Society of Australia opioid replacement therapy training program and long-acting injectable buprenorphine training here

Vaccination

• Victorian Pharmacist-Administered Vaccination Program Guidelines and Secretary Approval: Pharmacist Immuniser here
• Victorian COVID-19 Vaccination Guidelines here
• National Vaccine Storage Guidelines ‘Strive for 5’ here

Other resources

• Pharmacy Board of Australia Guidelines on compounding medicines here
• Joint statement on compounded medicines – Pharmacy Board of Australia and Medical Board of Australia here
• Therapeutic Goods Administration (TGA) GMP information for manufacturers of compounded medicines and DAAs here
• TGA Medicinal cannabis hub here
• TGA Medicinal cannabis - guidance documents here
• TGA Advertising guidance for businesses involved with medicinal cannabis products here
• Pharmacy Board of Australia statement on Medicinal cannabis supply here
• Medicines and Poisons Regulation guidance document Dispensing medicines here
• Pharmacy Board of Australia Guidelines for dispensing of medicines here
  Pharmacy Board of Australia Guidelines for proprietor pharmacists here
• Pharmacy Board of Australia's Guidelines on practice-specific issues here
• Pharmacy Board of Australia Guidelines on practice-specific issues - Guideline 1 (List of reference texts for pharmacists) here
• Pharmacy Board of Australia Guidelines on dose administration aids and staged supply of dispensed medicines here
• Pharmaceutical Society of Australia Guidelines for Pharmacists Providing Dose Administration Aid Services here
• Pharmaceutical Society of Australia Professional Practice
  Standards 2023 here
• Pharmaceutical Society of Australia Clinical Governance Principles for Pharmacy Services here

Members of the Victorian Pharmacy Authority

Mr David McConville, Chair (Pharmacist member)
Ms Regina Cowie (Pharmacist member)
Ms Jane Hill (Community member)
Ms Elizabeth Kennedy (Lawyer member)
Mr Brendon Moar (Pharmacist member)
Mr Adam Stormont (Pharmacist member)

VPA Staff

Registrar: Mr Aaron Bawden
Chief Finance Officer: Ms Koshala Nadanakumar
Senior Pharmacist: Ms Jessica Webster
Administration Officer: Ms Helen Newett
Licensing and Registration Officer: Ms Jane Davison
Governance and Risk Officer: Dr Jill Snell (Pharmacist)
Project and Engagement Officer: Ms Maggie Bassily (Pharmacist)
Project and Engagement Officer: Ms Tran To (Pharmacist)
Authorised Officer: Ms Karen La (Pharmacist)
Authorised Officer: Mr Scott Savage (Pharmacist)
Authorised Officer: Ms Denise van den Bosch (Pharmacist)
Authorised Officer: Ms Annie Luu (Pharmacist)

The VPA Circular is a document issued by the Victoria Pharmacy Authority (VPA) in Australia. It provides important information and updates to pharmacy licensees and stakeholders. You can review this circular and previous circulars on the VPA website here.