Health professionals – including doctors, nurses, and pharmacists – are regulated under the Health Practitioners Competence Assurance Act 2003.
This Act created 18 regulatory authorities, including New Zealand’s Pharmacy Council, with the job of protecting public health and safety.
They do this by making sure practitioners are competent and fit to practise, handling registration, issuing annual practising certificates (APCs), and stepping in with disciplinary action if needed.
The Ministry asked for feedback from healthcare professionals on four main areas:
- Making sure regulation puts patients first
- Making regulation simpler and more efficient
- Tailoring regulation to the level of risk involved
- Making sure regulation is ready for the future
We provided a strong submission, calling for a patient-focused, forward-looking approach that cuts unnecessary bureaucracy and enables pharmacists to work to their full clinical potential.
Our submission focused on several key areas:
- Making it easier to recognise overseas trained pharmacists
- Lowering APC fees and removing unnecessary duplication in regulation
- Expanding pharmacist prescribing rights in line with the UK and Australia
- Introducing modular scopes for services such as point-of-care testing and minor ailment management
- Ensuring regulation supports rather than hinders workforce sustainability, innovation, and better access to care
- Keeping profession-specific governance in any merged regulatory model, to protect medicine access and uphold pharmacy standards.
Recognition process for overseas-trained pharmacists
At the moment, internationally qualified pharmacists face complex, expensive, and slow processes to enter our health system. These delays and barriers have knock-on effects for patients, as workforce shortages and underused skills can affect access to care.
We believe these processes need to be simplified. That includes faster recognition of overseas qualifications, clear return-topractice pathways for pharmacists re-entering the profession, and alternative entry points for people with strong foundational skills who could be trained into pharmacy support roles.
Any changes should focus on risk, cultural safety, and proven competency – not just ticking off set time requirements or complicated steps. Patient safety remains crucial, so bridging programmes, supervised practice, and targeted upskilling should be used to ensure pharmacists meet New Zealand standards without unnecessary delays.
APC fees and avoiding duplication
Merging regulators could help cut back-office duplication and reduce APC fees, which are currently high for smaller professions like pharmacy.
High fees have already led some part-time pharmacists to leave the profession, worsening workforce shortages and making it harder for patients to get care.
We’re also concerned there aren’t enough safeguards to stop fees from climbing too quickly. In fact, pharmacist APC fees have risen by 20 percent over the past two years.
Expanding pharmacist prescribing rights
Right now, the willingness to broaden scopes of practice varies between regulators. Patients would benefit from a more proactive and consistent approach that allows all health professionals – including pharmacists – to work at the top of their skill set.
In countries like the UK, Canada, and Australia, it’s common for autonomous pharmacist prescribers to work independently in community pharmacies.
In New Zealand, however, pharmacist prescribers must be part of a collaborative health team, which limits the potential for improving access and health outcomes.
Modular scopes for services
We think regulation can be flexible while still keeping patient safety front and centre.
Options include:
Risk-based regulation: Higher-risk activities would require full registration, while lower-risk roles might only need basic certification or supervision.
Micro-credentialling and modular scopes: Formal recognition of skills like minor ailment treatment and pointof-care testing, so the workforce can adapt more easily.
Pilot programmes: Short-term, closely monitored trials of new roles or services to test their safety and effectiveness before making permanent changes.
Supportive regulation
Overly cautious regulation is slowing down much-needed innovation and making it harder to redesign services in a way that meets patient needs.
In a pressured health system, regulators need to be more agile and supportive of new care models – including pharmacist-led services like point-of-care testing, minor ailment prescribing, and digital triage – especially when pharmacists are already trained and working within evidence-based frameworks.
If regulators focus only on avoiding risk, they can unintentionally limit patient access, increase costs, and push professionals out of the system due to burnout or frustration with bureaucracy.
A balanced approach is needed – one that takes into account workforce capacity, equitable access, and evolving care models that reflect what communities actually need.
Profession-specific governance
We support creating a shared regulatory framework to reduce duplication and costs. However, it’s vital that each profession keeps authority over its own scopes of practice, standards, and safety requirements – especially in highrisk areas like medicine management.
You can read our full submission at www.pgnz.org.nz
