Critical Analysis of Draft National Pharmacy Commission Bill 2026

The proposed National Pharmacy Commission Bill seeks to replace the Pharmacy Act, 1948, with a modern regulatory structure. Although the reform is overdue and several provisions could improve education, registration and accountability, the second draft contains serious concerns relating to regulatory independence, federal balance, professional representation, the National Exit Test, disciplinary control, prescribing authority, data privacy and legislative drafting

New Delhi (ABC Live–DSLA): The Ministry of Health and Family Welfare released the second draft of the National Pharmacy Commission Bill, 2026 on 1 July 2026. Moreover, the Ministry invited members of the public and other stakeholders to submit comments within one month. The Bill proposes to establish a National Pharmacy Commission and repeal the Pharmacy Act, 1948.

The proposed reform has a valid policy purpose. India needs a pharmacy law that addresses modern education, professional competence, digital registration, institutional quality, patient safety, research and emerging clinical roles. However, the current draft is not yet ready for introduction in Parliament.

Although the Bill creates a broad regulatory system, it also concentrates appointment, policy, appellate and supersession powers in the Central Government. Furthermore, it leaves several important rights, duties and safeguards to future rules and regulations.

The Bill follows several features of the National Medical Commission Act, 2019, the National Dental Commission Act, 2023 and the National Nursing and Midwifery Commission Act, 2023. Nevertheless, pharmacy includes diploma, degree, community, hospital, clinical, industrial, regulatory, teaching and research streams. Therefore, Parliament must adapt the regulatory model to the distinct requirements of the pharmacy profession.

Key Findings

• First, replacing the 1948 framework is justified. However, the proposed Commission may remain too dependent on the Central Government.
• Second, four specialised boards could improve regulatory focus. Nevertheless, their jurisdictions and decision-making powers require clearer separation.
• Third, the National Exit Test combines licensing, registration and postgraduate selection, even though these functions require different assessment standards.
• Moreover, the Bill does not adequately distinguish Diploma in Pharmacy and Bachelor of Pharmacy pathways.
• In addition, the National Register can improve professional verification. However, publishing residential addresses may create privacy and security risks.
• Furthermore, the draft reduces direct elected professional representation at State and national levels.
• Significantly, the regulation-making provision refers to limited prescribing authority without creating a clear substantive right to prescribe.
• Meanwhile, the institutional approval provisions contain conflicting timelines and uncertain decision-making authority.
• Finally, numerous drafting errors and incorrect references require a complete legislative review.

Critical Assessment Dashboard

What the National Pharmacy Commission Bill Proposes

The Bill would dissolve the Pharmacy Council of India and establish a National Pharmacy Commission consisting of a Chairperson, 15 ex officio members and 13 part-time members.

In addition, it would create four specialised boards:

1. Pharmacy Education Board for the Modern System of Medicine;
2. Pharmacy Education Board for the Indian System of Medicine and Homoeopathy;
3. Pharmacy Assessment and Rating Board; and
4. Pharmacy Ethics and Registration Board.

Furthermore, the proposed framework would introduce:

• a National Exit Test for licensing and registration;
• a live National Register linked with State Registers;
• assessment and rating of pharmacy institutions;
• separate educational boards for modern and Ayush-related pharmacy;
• standards for curriculum, faculty and infrastructure;
• common counselling for postgraduate admission;
• disciplinary and ethical mechanisms;
• recognition and screening of foreign qualifications;
• regulation of the professional scope of practice; and
• a transitional Board of Governors before the new Commission becomes operational.

Consequently, the Bill goes far beyond changing the regulator’s name. Instead, it attempts to redesign pharmacy education, registration, licensing and professional governance.

Positive Features of the Draft Bill

Specialised Boards Could Improve Regulatory Focus

The four-board model separates curriculum development from institutional assessment and professional registration. Therefore, one authority would no longer control every regulatory stage.

For example, the two Education Boards would determine educational standards, curriculum, faculty requirements, infrastructure and annual disclosure norms. Meanwhile, the Assessment and Rating Board would inspect, assess and rate institutions. Similarly, the Ethics and Registration Board would manage registration, professional conduct and grievances.

This functional separation can improve specialisation. Moreover, it may reduce conflicts between curriculum development, inspection and enforcement.

However, the benefit will arise only when the law clearly separates the powers of each board. At present, some provisions still overlap. Therefore, the Bill should define which body recommends, which body decides and which body hears appeals.

ABC Live’s critical analysis of the NITI Aayog School Education Report 2026 also explains why educational reform must measure learning quality rather than merely institutional expansion. Similarly, the pharmacy regulator should assess competence and educational outcomes, not only buildings, laboratories and paperwork.

A Live National Register Can Improve Verification

The Bill directs the Pharmacy Ethics and Registration Board to maintain an online National Register. Moreover, State Registers must communicate electronically with the national system so that changes automatically appear in both systems.

As a result, a properly designed register could allow patients, employers, hospitals, courts and regulators to verify:

• registration status;
• recognised qualifications;
• licensing status;
• permitted area of practice;
• disciplinary restrictions; and
• renewal validity.

Furthermore, electronic synchronisation could reduce duplicate registrations, outdated entries and verification delays.

Nevertheless, the system must include strong correction rights. For example, a pharmacist should be able to challenge an incorrect qualification entry, renewal date or disciplinary notation. Likewise, the Commission should record every change through a secure audit trail.

ABC Live examined similar issues concerning centralised digital records in its critical analysis of the IFSCA Draft KYC–KRA Integration Circular 2026. In that context, ABC Live found that a central register requires correction rights, access controls, audit trails and clear responsibility for inaccurate entries. Accordingly, the pharmacy register must include the same safeguards.

Institutional Ratings Could Strengthen Accountability

The Assessment and Rating Board may conduct inspections, empanel independent rating agencies, undertake unannounced assessments and publish assessment documents. In addition, it may issue warnings, impose monetary penalties, reduce student intake, stop admissions or recommend withdrawal of recognition.

Therefore, these powers could help address:

• inadequate laboratories;
• paper-only faculty appointments;
• weak practical training;
• misleading institutional disclosures;
• poor attendance systems; and
• colleges operating without sufficient teaching resources.

Moreover, the draft requires objectivity, fairness, transparency and compliance with natural justice during assessment.

Nevertheless, outsourced inspection agencies must follow strict conflict-of-interest and disclosure rules. Otherwise, outsourcing may simply transfer regulatory discretion from public officials to private agencies.

Therefore, the Bill should require inspection agencies to disclose:

• ownership;
• clients;
• institutional links;
• financial interests;
• methodology;
• inspection teams; and
• reasons for every rating.

Students Receive Transitional Protection

Students already enrolled when the legislation commences may complete their courses under the existing syllabus and examination arrangements. Furthermore, an institution whose recognition lapses must continue to maintain minimum standards until admitted students finish their studies.

Therefore, this protection is important because students should not carry the full cost of regulatory failure attributable to an institution or public authority.

However, the Bill should go further. For instance, it should require an alternative institution, special examination arrangement or compensation mechanism where a college closes or loses its ability to teach.

Moreover, students should receive advance notice before the regulator stops admissions or withdraws recognition. As a result, they would have time to seek transfer, financial assistance or academic relief.

Audit and Parliamentary Reporting Are Positive Safeguards

The Bill establishes a National Pharmacy Commission Fund. Moreover, it places the Commission’s accounts under the audit jurisdiction of the Comptroller and Auditor-General of India. Additionally, the Central Government must place the audit and annual reports before Parliament.

These provisions create a basic accountability structure. However, financial audit cannot substitute for regulatory transparency.

Therefore, the law must also require publication of:

• inspection findings;
• regulatory decisions;
• conflict disclosures;
• institutional penalties;
• pending appeals;
• disposal timelines; and
• performance indicators.

Excessive Central Government Control

Although the Commission would have a separate statutory identity, the Central Government would exercise substantial control over its composition and operations.

The Government would appoint the Chairperson, Secretary, board presidents and several members. Moreover, the Health Secretary would chair the principal Search-cum-Selection Committee. Other members of that committee would also largely come from government institutions or receive Central Government nomination.

Furthermore, the Government could:

• issue binding policy directions;
• decide conclusively whether a question concerns policy;
• direct State Governments;
• demand reports and information;
• supersede the Commission;
• appoint persons to perform its functions during supersession; and
• extend the supersession period.

Government supervision remains necessary because Parliament creates the regulator and public money supports it. Nevertheless, combined control over appointments, policy directions, appeals, finances and supersession may weaken functional independence.

Moreover, the Government’s decision on whether a matter constitutes policy would be final under the draft. Consequently, the distinction between legitimate policy supervision and interference in regulatory decisions may become blurred.

Similarly, ABC Live identified institutional-control concerns in its critical analysis of the Data Security Council of India. Technical expertise, by itself, does not remove the need for independent oversight, citizen representation and public accountability.

Reforms Needed to Protect Independence

Therefore, the Bill should:

• include independent experts in every search committee;
• require public advertisement of vacancies;
• publish eligibility and selection criteria;
• disclose shortlisted candidates;
• record reasons for final appointments;
• restrict policy directions to clearly defined national policy matters;
• publish all written directions;
• require parliamentary review of prolonged supersession; and
• expressly preserve judicial review.

In addition, the Central Government should not use general policy directions to influence individual inspections, institutional approvals, disciplinary cases or appeals.

Moreover, any supersession order should identify the exact failures, supporting evidence and corrective roadmap. Consequently, Parliament and the public would be able to assess whether supersession was necessary.

Asset and Interest Declarations Must Be Public

The draft requires the Chairperson and members to declare assets, liabilities and professional or commercial engagements. However, it requires them to submit those declarations only to the Central Government.

By contrast, the National Medical Commission Act, 2019 provides a stronger public-disclosure model.

The pharmacy regulator will decide matters affecting private colleges, public universities, pharmaceutical companies, inspection agencies, professional associations and foreign institutions. Therefore, private disclosure to the Government does not provide enough assurance against regulatory capture.

Consequently, the Bill should require publication of:

• assets and liabilities;
• institutional affiliations;
• research grants;
• consultancy work;
• commercial interests;
• close-family interests in regulated bodies; and
• recusals from particular proceedings.

Moreover, members should update those disclosures annually and whenever a material change occurs. Similarly, the Commission should publish a register of recusals so that stakeholders can see whether conflicted members took part in a decision.

Professional and State Representation May Decline

The Pharmacy Act, 1948 gives each State representation in the Central Council through a registered pharmacist elected by the State Council. It also provides for six members elected by registered pharmacists to each State Pharmacy Council.

By contrast, the proposed State Pharmacy Council would include only four persons elected by pharmacists. Meanwhile, the State Government would nominate its Chairperson and several other members.

At the national level, State participation would largely operate through six zones and biennial rotation. Consequently, many States may lack direct representation on the Commission at a particular time.

Rotation may keep the Commission manageable. However, it may also weaken continuous participation by States with different educational, industrial and public-health conditions.

For example, States with large pharmaceutical industries may face different regulatory questions from States with shortages of community pharmacists. Similarly, remote and rural regions may need different educational and workforce policies.

Representation That the Bill Should Guarantee

Therefore, the Commission should include meaningful representation from:

• State Pharmacy Councils;
• community pharmacists;
• hospital pharmacists;
• clinical pharmacists;
• pharmacy educators;
• industrial pharmacy;
• regulatory affairs;
• public-health pharmacy;
• rural healthcare;
• patient organisations;
• women pharmacy professionals; and
• early-career professionals.

Industry knowledge is necessary. Nevertheless, industry representatives should not dominate decisions concerning professional ethics, educational recognition or patient-facing practice.

Moreover, the Bill should provide transparent nomination criteria. As a result, appointments would reflect professional diversity rather than institutional influence.

The Pharmacy Advisory Council Is Too Weak

The Bill describes the Advisory Council as the main platform through which States and Union Territories may raise concerns. However, the Council can only advise the Commission. Moreover, it must meet only twice a year.

Therefore, the Council may become a consultation forum without meaningful influence.

To address this weakness, the law should require the Commission to:

• respond in writing to formal recommendations;
• publish Advisory Council minutes;
• explain why it rejected any major recommendation;
• hold additional meetings when a minimum number of States request one; and
• consult the Council before making regulations that affect State Councils.

In addition, the Advisory Council should receive a statutory right to place dissenting views in the Commission’s annual report. Consequently, Parliament would receive both the Commission’s position and the concerns raised by States.

The National Exit Test Requires Fundamental Redesign

Section 11 proposes a common final-year examination for diploma and bachelor’s pharmacy students. The proposed test would determine eligibility for a licence, enrolment in the National or State Register and admission to postgraduate pharmacy education.

Although a national competency standard can improve public confidence, the present design combines different courses and different regulatory purposes.

Diploma and Degree Pathways Are Not Identical

Diploma in Pharmacy and Bachelor of Pharmacy programmes differ in course duration, curriculum depth, laboratory work, industrial content, research exposure and expected employment roles.

Therefore, one identical examination may not fairly assess both groups.

Instead, the Bill should provide:

• a common patient-safety and ethics component;
• separate diploma and degree modules;
• practical skill assessments;
• course-specific competence standards; and
• clear rules for candidates progressing from one qualification to another.

Moreover, the law should clarify whether the examination will assess dispensing, counselling, pharmacology, clinical judgement, industrial skills or all of these areas.

Otherwise, colleges may teach only for the examination rather than for the full range of professional competence.

Licensing and Postgraduate Ranking Serve Different Purposes

A licensing examination decides whether a candidate has the minimum competence needed for safe practice. By contrast, a postgraduate entrance examination ranks candidates competing for limited seats.

Consequently, the same test should not automatically perform both functions.

For example, a candidate may satisfy the safe-practice standard but receive a lower competitive rank. Similarly, strong theoretical performance may not establish practical competence in dispensing, patient counselling or medicine-safety procedures.

Therefore, the Bill should separate the licensing threshold from postgraduate ranking.

Moreover, candidates should receive separate scores for theoretical knowledge, practical competence and postgraduate ranking. As a result, one weak component would not distort every professional outcome.

Existing D.Pharm Exit Examination Rules Need Harmonisation

The Pharmacy Council of India has already issued the Diploma in Pharmacy Exit Examination Regulations, 2022. Those regulations link the D.Pharm exit examination with eligibility for enrolment and practice.

Therefore, the Bill must clarify whether it will:

• repeal those regulations;
• preserve them temporarily;
• absorb them into the National Exit Test;
• exempt particular batches; or
• create a separate examination for degree graduates.

Without such clarity, students may face overlapping examinations or inconsistent licensing conditions.

Moreover, the transitional rules should identify the exact academic batch from which the new test will apply. Consequently, students can make informed academic and financial decisions.

Examination Safeguards Are Missing

The Bill does not establish clear statutory principles concerning:

• number of attempts;
• frequency of examinations;
• language options;
• disability accommodations;
• practical assessment;
• internships;
• rechecking;
• review of results;
• examination security;
• treatment of failed candidates; and
• transitional batches.

Moreover, the test may become operational at any time within five years from the commencement of the Act.

Consequently, the law should require advance notice, pilot testing and transition rules.

ABC Live’s report, Explained: How India Can Make Leak-Proof Examinations, explains why high-stakes examinations require encrypted systems, vendor audits, candidate remedies, secure evaluation and clear accountability. Therefore, these safeguards will become equally important for the National Exit Test.

“Practice of Pharmacy” Needs a Clear Definition

The draft defines pharmacy broadly to include professional practice, education, industrial pharmacy, regulatory pharmacy and related activities. However, it does not clearly define what constitutes the practice of pharmacy.

This omission becomes serious because section 28 prohibits unregistered persons from practising pharmacy and permits imprisonment for up to one year, a fine of up to ?5 lakh, or both.

A criminal restriction must use clear language. Otherwise, uncertainty may arise over whether registration is mandatory for:

• pharmaceutical manufacturing;
• quality assurance;
• medical writing;
• regulatory affairs;
• clinical research;
• pharmacovigilance;
• drug-safety analysis;
• academic research;
• wholesale distribution; or
• non-dispensing industrial employment.

Therefore, the Bill should separately define:

• patient-facing pharmacy practice;
• dispensing;
• clinical pharmacy;
• hospital pharmacy;
• community pharmacy;
• industrial pharmacy;
• academic and research functions; and
• regulatory or administrative work.

Additionally, the law should link each category with suitable qualification, registration and licensing requirements.

As a result, professionals would know whether they require a practice licence, a professional registration or only an educational qualification.

Prescribing Authority Cannot Be Created Indirectly

The Education Boards may regulate the standards and scope of practice of registered pharmacy professionals.

However, the regulation-making provision later refers to “limited prescribing authority.”

This wording raises a central legal question: Does the Bill intend to allow some pharmacists to prescribe medicines?

The existing Pharmacy Practice Regulations, 2015 largely frame the pharmacist’s role around pharmacy services and dispensing against a medical prescription.

Therefore, if Parliament intends to create limited prescribing powers, the primary Act must expressly state:

• eligibility requirements;
• additional qualifications;
• permitted medicines;
• approved clinical conditions;
• supervision arrangements;
• referral duties;
• patient-consent rules;
• documentation requirements;
• professional indemnity;
• complaint procedures; and
• liability for harmful prescriptions.

A regulation-making clause should not create a major clinical power that the substantive law does not clearly grant.

Consequently, the Government should either remove the phrase or place a complete prescribing framework in the Bill.

Moreover, the Government should consult medical, nursing, pharmacy, patient-safety and public-health bodies before creating any prescribing role. Otherwise, overlapping professional powers may cause legal disputes and patient-safety risks.

The Disciplinary Framework Is Uneven

The Pharmacy Ethics and Registration Board would regulate professional conduct, manage grievances and hear appeals from State Pharmacy Councils.

However, section 25 states that a State Pharmacy Council may take disciplinary action where a State Act confers that power. Consequently, different States may develop different enforcement systems.

For example, one State Council may conduct full disciplinary proceedings, while another may lack the required State legislation. Meanwhile, the national board may handle complaints in some jurisdictions. As a result, similar misconduct may attract different procedures and sanctions.

The Bill also leaves the meaning of professional or ethical misconduct largely to future regulations. Therefore, pharmacists and complainants cannot yet know the complete disciplinary standard.

A Better Disciplinary Model

Accordingly, the legislation should establish:

1. an independent complaint-screening process;
2. a separate investigation unit;
3. an adjudicatory panel independent of investigators;
4. a clear list of possible sanctions;
5. interim suspension standards;
6. complainant participation;
7. reasoned and published decisions;
8. whistleblower protection;
9. rules for restoration of registration; and
10. an appeal to an independent tribunal or designated court.

Similarly, ABC Live’s critical analysis of RBI’s Internal Ombudsman Directions 2026 explains why an internal grievance system requires functional independence, reasoned decisions and a credible external remedy.

Moreover, complainants should receive written reasons when the regulator closes a case. Consequently, complaint disposal would become transparent and reviewable.

Institutional Permission Provisions Contradict Each Other

Section 22 states that no new institution, course or seat increase may proceed without permission from an Accreditation Committee. However, applicants must submit proposals to the Pharmacy Assessment and Rating Board, which appears to approve or reject them.

Therefore, the Bill does not clearly identify the final decision-maker.

Furthermore:

• the Board receives six months to decide;
• an applicant may appeal when the Board takes no decision within three months; and
• a second appeal lies to the Central Government.

These timelines cannot operate together. Consequently, the Bill must either reduce the original decision period to three months or allow the delay appeal only after six months.

Moreover, the second appeal to the Central Government further increases executive control. Therefore, Parliament should consider an independent appellate tribunal instead.

Alternatively, the Bill could create a specialised education-regulation appellate panel. In either case, the appeal body should publish reasoned decisions within a fixed period.

Institutional Penalties Need Proportionality

The Assessment and Rating Board may impose a penalty ranging from one-tenth to five times the total amount charged for a complete student batch.

Strong penalties can deter persistent non-compliance. However, the Bill does not specify:

• categories of violations;
• factors for calculating penalties;
• aggravating circumstances;
• mitigating circumstances;
• treatment of repeat violations;
• maximum absolute caps;
• student compensation; or
• use of money recovered through penalties.

Consequently, similar violations could attract widely different financial consequences.

Therefore, the law should distinguish between administrative errors, disclosure failures, infrastructure deficiencies, deliberate fraud and threats to student or patient safety.

In addition, part of the penalty should support affected students where an institution’s misconduct causes academic or financial harm.

Moreover, the institution should receive a corrective-action timeline before the regulator stops admissions, except where immediate action is necessary to protect students or patients.

Tuition-Fee Regulation Is Too Broad

The Commission may prescribe the maximum tuition fee payable for various categories of pharmacy education.

However, the Bill does not explain:

• whether the power covers every private institution;
• whether it applies to all seats;
• whether State fee committees will continue;
• how the regulator will calculate reasonable costs;
• whether institutions may appeal;
• how scholarships will operate; or
• whether cross-subsidisation will remain permissible.

By comparison, the National Medical Commission Act, 2019 places a defined statutory limit on the scope of the Commission’s fee-guideline power.

Therefore, the pharmacy Bill should state the scope, factors and appeal mechanism in the primary law rather than leaving the entire system to regulations.

Moreover, the Commission should publish the data and methodology used to calculate fee limits. Consequently, institutions, students and courts could examine whether the fee structure remains fair.

The National Register Raises Data-Protection Concerns

The draft requires the National Register to contain the professional’s name, address, recognised qualifications and other prescribed information. Moreover, it makes the register publicly accessible.

A public register serves a legitimate verification purpose. Nevertheless, publishing a residential address may expose professionals to:

• identity misuse;
• unwanted profiling;
• harassment;
• physical-security risks; and
• commercial data harvesting.

The Digital Personal Data Protection Act, 2023 provides India’s statutory framework for processing digital personal data. Therefore, the Commission must limit public disclosure to information necessary for professional verification.

The portal should display:

• registration number;
• professional name;
• qualification;
• registration status;
• State Council;
• professional or workplace address;
• area of practice;
• renewal date; and
• applicable disciplinary restrictions.

However, it should not automatically display a home address, identity documents, personal telephone number or private email address.

Similarly, ABC Live has examined public-interest data questions in Why Census 2027 Is India’s Biggest Data Privacy Test and its critical analysis of the Data Security Council of India. Both reports emphasise data minimisation, cybersecurity and institutional accountability.

Accordingly, the Commission should conduct regular security audits. Moreover, it should notify affected professionals whenever a data breach occurs.

The Bill Needs Stronger Transparency Duties

The Bill requires institutions to maintain websites and allows the regulator to publish assessment documents. These measures are useful.

However, it does not impose an equally strong duty on the Commission to publish:

• meeting agendas;
• minutes;
• voting records;
• reasons for decisions;
• inspection reports;
• inspection-agency contracts;
• conflict declarations;
• appeals and outcomes;
• disciplinary orders;
• performance indicators; and
• regulation-making consultation reports.

Moreover, a court may take cognisance of an offence only upon a written complaint from an authorised regulatory officer.

Therefore, students, patients, whistleblowers or employees may depend entirely on the regulator’s willingness to authorise prosecution.

Consequently, the Bill should create:

• a statutory complaint portal;
• written reasons for closing complaints;
• review of refusal to prosecute;
• whistleblower protection;
• time limits for action; and
• public reporting of complaint outcomes.

In addition, the Commission should publish annual data on complaints received, closed, pending and upheld. As a result, Parliament could measure the regulator’s enforcement performance.

Major Drafting Errors in the Bill

The second draft contains several internal contradictions and inaccurate references.

For example, the regulation-making provision refers to boards under section 11, although section 12 constitutes the boards.

These defects are not merely typographical. Instead, incorrect cross-references can create procedural disputes, litigation and regulatory delay.

Therefore, the Ministry should send the Bill for a complete legislative-counsel review before presenting it to Parliament.

Moreover, the Ministry should publish a revised comparison table showing changes between the first and second drafts. Consequently, stakeholders could understand which concerns were accepted and which remain unresolved.

Transition From the Pharmacy Council of India Needs a Roadmap

The Bill proposes a transitional Board of Governors for one year or until the National Pharmacy Commission becomes operational, whichever occurs first. Afterward, it would dissolve the Pharmacy Council of India and transfer its assets and liabilities to the Commission.

Existing permissions, registrations and recognised qualifications would continue. Similarly, existing State and Joint State Pharmacy Councils would operate until States establish new Councils.

However, the Bill does not fully address:

• pending college applications;
• incomplete inspections;
• pending appeals;
• existing disciplinary complaints;
• ongoing litigation;
• historical records;
• employee pensions and benefits;
• database migration;
• institutional fees already paid;
• contractual obligations; and
• qualifications without fixed expiry dates.

Furthermore, regular Pharmacy Council of India employees would continue for only one year. The Commission would then determine whether to retain them through performance appraisal.

Therefore, the transition must protect employee rights, institutional memory, student interests and continuity of pending proceedings.

Moreover, the Government should publish a transition schedule before commencing the Act. Similarly, it should identify which authority will decide pending matters during each stage.

As a result, applicants, students, professionals and employees would know where their cases stand.

Reforms Required Before Parliament Considers the Bill

Legal and Drafting Reforms

First, the Ministry should:

• define the practice of pharmacy;
• clarify institutional approval authority;
• harmonise all statutory timelines;
• correct every cross-reference;
• clarify foreign-graduate registration;
• remove ambiguous institutional names;
• reconcile existing exit-examination regulations;
• define the legal basis of prescribing authority; and
• revise the removal-of-difficulties clause.

Governance Reforms

Second, the Bill should:

• make selection processes public;
• include independent search-committee members;
• publish asset and interest declarations;
• guarantee meaningful State participation;
• preserve adequate elected professional representation;
• include patient and public-health representatives;
• restrict executive directions;
• publish reasons for supersession; and
• provide independent appellate review.

National Exit Test Reforms

Third, the law should:

• separate diploma and degree pathways;
• separate licensing from postgraduate ranking;
• include practical competence;
• protect transitional batches;
• provide multiple annual attempts;
• include disability and language safeguards;
• provide result-review mechanisms; and
• establish examination-security standards.

Registration and Data Reforms

Fourth, the Commission should:

• publish only necessary professional information;
• exclude residential addresses from public display;
• establish correction rights;
• maintain audit trails;
• issue breach notifications;
• specify access controls;
• conduct periodic cybersecurity audits; and
• create penalties for unauthorised register access.

Patient-Centred Pharmacy Reforms

Finally, the Bill should directly address:

• community pharmacy standards;
• hospital pharmacy services;
• patient counselling;
• medication review;
• pharmacovigilance;
• antimicrobial stewardship;
• prescription-error reporting;
• continuing professional development;
• rural pharmacy services; and
• cooperation among pharmacists, doctors, nurses and allied health professionals.

Similarly, ABC Live’s critical analysis of the NDCT Amendments 2026 found that pharmaceutical reform must balance faster regulatory processes with patient protection, transparency and scientific credibility.

ABC Live Overall Assessment

The National Pharmacy Commission Bill, 2026 makes a strong case for replacing an outdated regulatory framework.

Its specialised boards, digital register, competency-based curriculum, institutional ratings, student protections and enforcement powers provide a useful foundation.

However, the present draft gives the Central Government extensive control. Moreover, it reduces direct professional representation, leaves the National Exit Test under-designed and creates uncertainty around prescribing authority and professional scope.

Furthermore, the Bill delegates too many essential questions to future regulations. Its contradictory timelines and incorrect references also weaken legal certainty.

Therefore, the central question is not whether India needs a National Pharmacy Commission. India clearly needs a modern, transparent and accountable pharmacy regulator.

Instead, the real question is whether Parliament will create a regulator that remains:

• professionally credible;
• institutionally independent;
• federally balanced;
• patient-centred;
• transparent;
• digitally secure; and
• operationally workable.

At present, the Bill moves in the right direction. Nevertheless, it requires substantial revision before it can meet that standard.

How We Verified

ABC Live and DSLA reviewed:

• the Ministry of Health and Family Welfare’s second draft of the National Pharmacy Commission Bill, 2026;
• the existing Pharmacy Act, 1948;
• the proposed Commission and board structure;
• the National Exit Test provisions;
• registration and disciplinary clauses;
• institutional approval and penalty mechanisms;
• the National Medical Commission Act, 2019;
• the National Dental Commission Act, 2023;
• the National Nursing and Midwifery Commission Act, 2023;
• the Digital Personal Data Protection Act, 2023;
• Pharmacy Council of India regulations; and
• related ABC Live reports on regulatory independence, examinations, data protection and pharmaceutical governance.

Sources and Resources

1. Draft National Pharmacy Commission Bill, 2026 and Public Notice — official document released for stakeholder consultation.
2. Pharmacy Act, 1948 — India Code
3. National Medical Commission Act, 2019 — India Code
4. National Dental Commission Act, 2023 — India Code
5. National Nursing and Midwifery Commission Act, 2023 — India Code
6. Digital Personal Data Protection Act, 2023 — India Code
7. Bharatiya Sakshya Adhiniyam, 2023 — India Code
8. Bharatiya Nyaya Sanhita, 2023 — India Code
9. Diploma in Pharmacy Exit Examination Regulations, 2022 — Pharmacy Council of India
10. Pharmacy Practice Regulations, 2015 — Pharmacy Council of India
11. Course-Wise Pharmacy Regulations — Pharmacy Council of India
12. Guidelines for Hospital and Community Pharmacists — Pharmacy Council of India

Related ABC Live Reports

• Critical Analysis of NDCT Amendments 2026
• Explained: How India Can Make Leak-Proof Examinations
• Critical Analysis of the Data Security Council of India
• Explained: Why Census 2027 Is India’s Biggest Data Privacy Test
• Critical Analysis of IFSCA Draft KYC–KRA Integration Circular 2026
• Critical Analysis of RBI’s Internal Ombudsman Directions 2026
• Critical Analysis of NITI Aayog School Education Report 2026

ABC Live–DSLA Note

Dinesh Singh Law Associates provided statutory research, regulatory comparison and legal review support. Meanwhile, ABC Live retained editorial responsibility for the analysis, findings and public-interest recommendations.

ABC Live — Making Complex Public Issues Simple.