Injecting compliance: A tightening regulatory grip on GLP-1 medicines?

What are GLP-1s?

Glucagon-like peptide-1 receptor agonists (GLP-1s) are peptides commonly prescribed for managing Type 2 Diabetes and obesity. They have become widely recognised as 'weight-loss' drugs. In the UK, there are several licensed GLP-1s including:

Semaglutide - Ozempic (T2D), Wegovy (obesity)
Liraglutide - Victoza (T2D), Saxenda (obesity)
Dulaglutide - Trulicity (T2D)
Tirzepatide - Mounjaro (T2D), Zepbound (obesity)

GLP-1s are prescription only medicines ("POMs") - meaning that patients will need a prescription from a healthcare professional to take them. Before issuing a prescription, the healthcare professional must hold a consultation to ensure that the medicine is suitable and the patient is aware of the risks and potential side effects associated with taking the medicine.

A lot of unregulated online sellers have started advertising and selling these medicines to the public, often using influencers, and without a consultation with a healthcare professional. Under the Human Medicines Regulations 2012 and the UK Committee of Advertising Practice ("CAP") Code advertising POMs to the public is strictly prohibited. However, clinics and pharmacies may provide factual, non-promotional information about POMs on their websites, provided this information is located within less prominent pages and complies fully with the CAP Advice. The Medicine and Healthcare products Regulatory Agency ("MHRA") has also uncovered sophisticated operations to make illicit, counterfeit GLP-1s available on the market.

Why is this situation troubling for the MHRA and wider government?

A licensed medicine in the UK has been independently assessed by the MHRA for quality, safety, and efficacy before it is allowed to be placed on the market. A counterfeit product therefore raises significant risks to public health and patient safety.

Also, if sellers are encouraging or influencing the general public to take POMs without an assessment from an appropriate healthcare provider, this could lead to patients having access to medicines that are unsuitable and could result in significant health issues, or even death.

Will we see more regulation?

The MHRA has been active in addressing the advertisement of POMs and taking enforcement action against suppliers of unlicensed weight-loss products:

The MHRA, in partnership with the Advertising Standards Authority ("ASA") and General Pharmaceutical Council ("GPhC"), jointly released an updated Enforcement Notice in September 2025, to reiterate the strict rules around the advertisement of POMs - with specific reference to medicines used for weight loss management.
As reported by the MHRA, in October 2025, the MHRA's Criminal Enforcement Unit dismantled what is believed to be the UK's first illicit weight-loss medicine manufacturing facility, raiding a warehouse in Northampton and seizing tens of thousands of empty injectable pens, raw chemical ingredients, and over 2,000 unlicensed retatrutide and tirzepatide pens ready for dispatch.
As also reported by the MHRA, a subsequent operation in early 2026 targeting properties in Lincolnshire and Nottinghamshire resulted in the seizure of a further 2,000 doses of unlicensed medicines, alongside manufacturing equipment, pharmaceutical ingredients, and commercial vehicles. Both operations formed part of a broader investigation into an organised criminal network, supported by police and Trading Standards. The pattern that is emerging is significant: the MHRA is pursuing not just individual bad actors but coordinated networks, and it is doing so with cross-agency resources. For businesses operating anywhere near the unlicensed end of this market - whether as platforms, prescribers, or investors - it is important to be aware of increasing risks.
Alongside its enforcement activity, the MHRA has been sharpening its public-facing messaging in ways that signal a more formalised prescriber guidance framework is likely to follow. In a press release issued in late December 2025, the MHRA -emphasised that GLP-1 medicines are prescription-only and should only ever be supplied following a proper clinical assessment by a qualified healthcare professional - a statement that, while not new in legal terms, represents a deliberate and public restatement of the rules at a moment when the regulator clearly feels they are being routinely circumvented. The reference to social media promotion "quick fix" marketing and unusually low pricing as red flags, points to a regulator that is increasingly focused on the prescribing environment, not just the manufacturing and supply chain.

We are also seeing other regulators focus in on this area. The ASA issued some specific advice on weight loss prescription medicines on 14 April 2026 which includes recent rulings relating to the advertisement of weight-loss medications. This gives guidance on what compliant marketing and claims within the inner pages of a clinic or pharmacy's website may look like. From these rulings, it is clear that criticism or negative images of weight gain and short-term promotional pricing for weight-loss medication with claims like "Run, don't walk", which create a sense of undue urgency, are likely to be regarded as socially irresponsible and must be avoided. Such decisions signal that regulatory scrutiny is widening beyond obvious advertising into subtler commercial tactics.

Given the scale of remote prescribing, the growth of online weight-loss platforms, the public interest in weight-loss products, and the potential risks to public safety in consuming incorrectly dosed or contaminated unlicensed products, the pressure on the MHRA and relevant professional bodies to take more targeted, GLP-1-specific actions is building. Here are some ideas on possible actions:

It would be consistent with the trajectory of advisory and enforcement activity to expect specific minimum clinical assessment standards for prescribers in this space to be strengthened and formalised in the next few years.
The MHRA has already been actively working with the ASA, but we expect that they will want to do more - we could see joint public awareness campaigns or training sessions for clinics on weight-loss marketing.
Increased monitoring and regulation (including more frequent inspections) of those involved in weight-loss medication supply chains to curb illicit activities.
Increased pressure at governmental and organisational level for social media sites to take greater action against online sellers.

Practical considerations for clinics and pharmacies:

Keep up to date - the MHRA has been actively releasing guidance specific to GLP-1 medicines, its dedicated GOV.UK page should be treated as a live resource rather than a one-time reference. The regulatory position in this area is evolving quickly, and clinics operating in this space cannot afford to treat compliance as a static exercise. Checking this page regularly and ensuring that internal policies reflect the most current MHRA position is a basic but essential step.
Clinics and pharmacies must ensure that peptides are sourced from MHRA- authorised suppliers. Given the enforcement activity already documented, sourcing from illicit or unlicensed manufacturers or distributors - whether knowingly or otherwise - presents significant regulatory and reputational risks.
Review your advertising strategy and content to ensure full compliance with the CAP Code and MHRA guidance.

The rules on promoting POMs and other medicines are strict, and the consequences of non-compliance are real. If you need support ensuring your marketing strategy meets the applicable requirements, please get in touch.

How we can help

In a market under increasing regulatory scrutiny, ensuring that the standards are being upheld across the sector is in everyone's interests. We have extensive experience on advising on regulatory issues in the context of peptides.

The regulatory landscape governing peptides is complex, and determining which regime applies to a given product is not always straightforward. Borderline classification questions - whether a product falls to be treated as a licensed medicine, an unlicensed medicine, or a cosmetic - can have significant commercial and regulatory consequences; getting that analysis wrong at the outset is costly. We have experience on advising clients on exactly these questions, helping businesses understand where their products sit before they reach the market.

For those already operating in this space, we have extensive experience advising on the full regulatory lifecycle of a product - from the requirements involved in prescribing, dispensing, and sourcing peptides, through to the practical steps needed to ensure ongoing compliance. That includes drafting bespoke agreements for dispensing and prescribing services in the GLP-1 context, where having the right contractual framework in place is as important as understanding the regulatory obligations themselves.

Additionally, if you have concerns about the conduct of other clinics or operators - whether in relation to unlicensed supply, non-compliant advertising, or broader regulatory breaches - please do not hesitate to contact us. We can advise on the appropriate route for raising complaints with the MHRA or Trading Standards and will support you through that process.

If you would like advice understanding the regulatory landscape relating to peptides, please get in touch with Andrew Andrews and Greta Cicchetti in our Regulatory Risk and Resolution team.