The pharmacy as a “light version of a family doctor’s office”?
On December 17, 2025, the Federal Cabinet approved the draft bill. Following its referral to the Bundesrat and the Bundestag, the legislative process is now at an advanced stage. The following overview outlines the specific changes the reform proposes and explains why it is the subject of controversy.
Dispensing of Rx Drugs Without a Prescription, Sections 48a, 48b AMG (new)
The potentially most significant change is that certain prescription medications may in the future be dispensed without a (medical or dental) prescription. This is intended to facilitate follow-up care for chronic conditions.
The other scenario is the presence of an acute, uncomplicated illness. However, this still requires the issuance of a statutory regulation by the Federal Ministry of Health. This must specify the conditions (illnesses, patient groups, counseling requirements, etc.).
Expanded Vaccination Options
The draft provides that pharmacies will be permitted to use inactivated vaccines in the future. Medical training will be conducted in this regard. The expansion of these vaccination authorities will also be taken into account in reimbursement negotiations so that the vaccinations are eligible for reimbursement.
Accordingly, vaccinations against the flu, COVID-19, and TBE will be possible in the future. Currently, pharmacists are authorized to administer flu vaccines to patients aged 18 and older, and COVID-19 vaccines to patients aged 12 and older.
Testing Options
According to Section 72 of SGB XI, a physician’s authorization is required for the administration of point-of-care rapid tests. This requirement is being partially lifted. Additionally, amendments to the German Law on the Advertising of Medicinal Products (Heilmittelwerbegesetz) will expand advertising for in vitro diagnostics intended for self-use, thereby allowing pharmacists to advertise testing outside of professional circles.
During the pandemic, COVID-19 tests were common in pharmacies; this is now set to be expanded to include adenovirus, influenza, norovirus, RSV, and rotavirus. The aim is to break chains of infection more quickly.
Blood collection
For example, to monitor drug effects, standard blood draws from a vein are to be permitted, though only for adults. Until now, this has been subject to a physician’s approval, a requirement that would thus be waived.
Preventive Care
There is a right to prevention of common diseases such as cardiovascular diseases, diabetes, and tobacco-related diseases. In the future, pharmacies are to work on the early detection of significant disease risks; this will constitute a pharmaceutical service. To date, preventive activities by pharmacists are already possible.
Further development of pharmaceutical services, improvement of collaboration among healthcare professions
Pharmaceutical services will be defined by law. Their implementation and results are to be documented in the electronic health record in the future. Likewise, the treating physician is to be informed about the pharmaceutical services provided. It is also planned that pharmaceutical
services may also be prescribed by physicians.
Since the passage of the Local Pharmacy Strengthening Act, these services have already been available for conditions such as high blood pressure, inhaled medications, polypharmacy, oral cancer therapy, and organ transplantation.
Alternative Medications
If a specific prescription medication is not in stock when a prescription is filled, the dispensing of alternatives should be made easier. Until now, pharmacies have had to order these if they are still available from wholesalers. This is intended to reduce the burden on pharmacies and facilitate patient care.
Administrative Regulations
The draft also contains regulations that pertain solely to internal pharmacy operations. Among other things, experienced pharmacy technicians (PTAs) will be permitted to temporarily act as pharmacy managers. This is intended to prevent disruptions in public care, particularly in rural areas. However, this provision applies for a maximum of 20 days, of which no more than ten days may be consecutive. This requires official approval as well as a practical trial period.
Pharmacies are also now to be able to set their own opening hours to adapt them to actual demand.
Criticism
The draft has faced significant criticism, particularly from the medical community. There are calls for greater caution in prescribing medications and therapies, arguing that these should not simply be handed over to unauthorized parties. Such an erosion of medical authority is deemed unacceptable. The assumption of medical tasks by pharmacies risks fragmenting outpatient care and does not result in a reduction of the medical workload.
Although Sections 48a and 48b of the German Medicines Act (AMG) exclude active ingredients with a high potential for abuse, responsibility for indication, therapy monitoring, and cost-effectiveness—which originally lies with physicians—is being outsourced.
This concern regarding a risk to patients cannot be dispelled by a brief medical practice course. Likewise, the economic advantages may create perverse incentives for pharmacies. The focus must be on the indication and its appropriate treatment, not on a financial advantage.
There is also debate over whether the federal government even has the authority to enact a legislative change that would override the physician-only requirement. Complications may also arise from professional regulations that differ under state law, making uniform nationwide care impossible.
The German Medical Association further clarifies: “Medical activities do not belong in a pharmacy. From the outset, the German Medical Association has criticized the Pharmacy Care Development Act for undermining this principle. The position remains: Anyone who performs diagnostic and therapeutic tasks must be trained to do so.”
Pharmacists’ associations welcome the planned changes, but caution that only financially sound businesses can provide these services.
The planned pharmacy reform goes far beyond providing economic relief for pharmacies. With expanded powers in drug dispensing, prevention, diagnostics, and vaccination, pharmacies are expected to assume a significantly more active role in outpatient healthcare in the future. While proponents see this as an important contribution to ensuring comprehensive care coverage, critics warn of a shift in medical competencies and potential risks to the quality of treatment.
Regardless of how individual measures are evaluated, the ApoVWG is likely to bring about lasting changes in collaboration among healthcare professions. As things stand, the legislative process is expected to be concluded in the coming months. However, whether the reform will actually achieve its ambitious goals will only become clear once it is implemented in practice.