On 6 May 2026, the Irish Health Products Regulatory Authority (“HPRA”) published a new dedicated webpage titled “Promoting medicines to the public on social media”, setting out clear information on the laws that apply to advertising human medicines to the public in Ireland. By publishing a dedicated webpage on this topic, the HPRA has sent a clear signal that the online promotion of medicines, and social media advertising in particular, is now firmly on its regulatory agenda. 

This follows a period of significant and increasing, regulatory activity in this space. In our piece for the International Bar Association (“IBA”), we examined the growing regulatory focus on the promotion of medicinal products on social media in Ireland and across the EU, including, in particular challenges arising from the online promotion of GLP-1 receptor agonists (“GLP-1s”). We noted that the HPRA had removed or amended 456 web addresses linked to GLP-1 products between January and November 2024, which was more than double the number removed or amended in the previous year. The launch of this new webpage reinforces that the HPRA’s focus on this area is continuing to intensify.  

Applicable Law

In Ireland, the Medicinal Products (Control of Advertising) Regulations 2007, as amended (the “Regulations”) set out the legal rules for advertising human medicines. The HPRA is the competent authority responsible for checking whether individuals and businesses are following these rules, and takes action where needed, including by reporting or removing online content. 

Under the Regulations “advertising” is defined broadly as any information or activity ‘designed to promote the prescription, supply, sale or consumption’ of a medicine. This definition includes advertising medicines to the public online, including on websites and social media platforms. Anyone who advertises or promotes a medicine in Ireland, whether through traditional media (such as print, broadcast and outdoor) or online media must adhere to this provision. As emphasised by the HPRA in the 6 May webpage the rules also capture businesses offering services that may lead to the prescription and supply of a medicine. This specifically includes services involving prescription-only medicines containing botulinum toxin (commonly known as Botox), semaglutide and tirzepatide (both of which are active ingredients found in a number of widely used weight-loss and diabetes medicines). 

Key Rules to Remember 

The Regulations apply broadly to all those involved in the promotion of medicines in Ireland, and the HPRA’s new webpage highlights a number of key rules in this regard: 

• Unauthorised or unregistered medicines: It is prohibited to advertise or promote any human medicine that is not authorised or registered in Ireland. 

• Prescription-only medicines (“POMs”): It is prohibited to advertise or promote POMs to the public in Ireland. This applies to all media formats, including traditional and online, and to all promotional activities. 

• Free samples: Advertising law does not allow free samples of medicines to be provided to anyone who is not legally authorised to prescribe that medicine, and specific regulatory rules apply when supplying free samples. 

• Endorsements: When medicines are advertised to the public, they must not include recommendations from scientists, health professionals, or persons with celebrity status. 

• Non-prescription medicines: Some non-prescription medicines may be advertised to the public, but only where the advertising is based on the medicine’s Summary of Product Characteristics (“SPC”), promotes the rational use of the medicine objectively and without exaggeration, is not misleading and otherwise complies fully with the Regulations. 

Practical Implications 

The HPRA’s decision to create a dedicated resource on this topic reflects the growing prominence of social media advertising in the medicines sector and the increasing regulatory attention it is attracting. Companies that advertise or promote medicines in the Irish market, whether through their own channels or through third parties, should ensure their social media activities and compliance policies are kept under regular review. 

As we highlighted in our IBA piece, the scope of what constitutes “promotion” can extend beyond a company’s official channels. Liking, sharing, and commenting on posts could all potentially constitute promotion in this context. 

The message from the HPRA is clear. Those operating in the Irish medicines market must ensure that robust, well-understood social media policies are in place and actively enforced and that all employees are familiar with the restrictions that apply to the promotion of prescription-only medications. 

For more information, please contact our Life Sciences Group.