Severe sanctions issued more often in Great Britain than the United States – research

A major new study comparing pharmacy disciplinary decisions in Great Britain and the United States has found that regulators in Great Britain are significantly more likely to impose severe sanctions on pharmacy professionals than their American counterparts.

The research, published in the International Journal of Pharmacy Practice, analysed more than 22,000 disciplinary cases spanning a ten-year period up to June 2025. Researchers examined 21,561 cases from the United States and 1,868 from Great Britain, comparing the sanctions imposed on pharmacists and pharmacy technicians facing regulatory action.

According to the study, 79% of cases in Great Britain resulted in what researchers classified as severe sanctions, including suspension or removal from the register, compared with just 38% of cases in the United States. Meanwhile, less severe outcomes such as warnings and conditions were more common in the US system.

The findings mirror earlier research into medical regulation, which identified a similar pattern whereby UK regulators tend to impose stricter disciplinary outcomes than equivalent bodies in the United States. The authors said the latest analysis suggests the difference is not unique to medicine and may instead reflect broader structural and procedural differences in professional regulation.

Researchers used statistical analysis to compare disciplinary outcomes across both jurisdictions, grouping sanctions into four categories: warnings, conditions, suspension and erasure. The results showed a statistically significant difference in sanction severity between the two regulatory systems.

Writing in the journal, the authors concluded that their findings raise important questions about regulatory design and accountability. They argued that while professional self-regulation remains an important feature of healthcare regulation, there is growing evidence that regulatory structures can have a substantial impact on disciplinary outcomes.

The study has potential relevance for ongoing debates about proportionality, consistency and public protection within professional regulation, including the operation of the General Pharmaceutical Council’s fitness to practise framework in Great Britain.

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