Detect unlicensed e-pharmacies · Keep licensed e-pharmacies compliant with PCN

Methodology

Legal basis

MedGate is the gatekeeper for online medicine: the register of who may lawfully sell medicines online, and who may not. It assesses Nigerian e-pharmacy websites against the Electronic Pharmacy Regulations 2026, made under the Pharmacy Council of Nigeria Act 2022, together with the Nigeria Data Protection Act 2023. The framework mirrors the registration, display, prescription-handling and cross-border provisions of those instruments.

Assessment is limited to publicly available website content. It does not inspect premises, stock, dispensing records or PCN registers, and it is not a legal determination.

The checklist

  • 1. No controlled substances offered for sale

    high severityweight 18

    Site text scanned for tramadol above 100mg, codeine-containing cough syrup and benzodiazepines offered for sale.

    Reg. 23, Electronic Pharmacy Regulations 2026 (Dangerous Drugs Act exclusion)

  • 2. Valid-prescription declaration on homepage

    high severityweight 18

    Homepage must declare that prescription-only medicines are dispensed solely on a valid prescription from a licensed provider.

    Reg. 12, Electronic Pharmacy Regulations 2026

  • 3. PCN logo or mark displayed

    medium severityweight 10

    Pharmacy Council of Nigeria logo or identification displayed on the homepage.

    Reg. 12, Electronic Pharmacy Regulations 2026

  • 4. Pharmacy licence number displayed

    medium severityweight 10

    A PCN premises/pharmacy licence number is published on the site.

    Reg. 12, Electronic Pharmacy Regulations 2026

  • 5. EPSP registration number displayed

    medium severityweight 10

    Electronic Pharmaceutical Service Provider registration number published on the site.

    Reg. 12, Electronic Pharmacy Regulations 2026

  • 6. Prescription upload or verification mechanism

    medium severityweight 10

    A mechanism to upload or verify a prescription before dispensing is present.

    Reg. 20, Electronic Pharmacy Regulations 2026

  • 7. Superintendent Pharmacist named (one-e-pharmacy cap)

    medium severityweight 10

    Superintendent Pharmacist named on the site. Flagged if the same name is recorded against more than one operator in the register.

    Reg. 34(4), Electronic Pharmacy Regulations 2026

  • 8. Privacy policy / NDPA compliance statement

    low severityweight 5

    A privacy policy or data protection statement is published.

    Nigeria Data Protection Act 2023

  • 9. Physical Nigerian address and contact details

    low severityweight 5

    A verifiable Nigerian premises address and contact details are listed.

    Reg. 12, Electronic Pharmacy Regulations 2026

  • 10. No cross-border sales language

    low severityweight 5

    Site does not advertise shipping or dispensing of medicines outside Nigeria.

    Cross-border prohibition, Electronic Pharmacy Regulations 2026

  • 11. Dedicated prescription / Rx-upload page

    medium severityweight 10

    A dedicated prescription upload or verification page is reachable from the site, not only a homepage mention.

    Regs. 20 & 22, Electronic Pharmacy Regulations 2026

  • 12. Delivery policy published (Good Distribution Practices)

    medium severityweight 10

    A delivery or shipping policy page is published describing how medicines are transported.

    Reg. 29, Electronic Pharmacy Regulations 2026 (Good Distribution Practices)

  • 13. Returns / refunds policy published

    medium severityweight 10

    A returns, refunds or recall policy page is published.

    Reg. 29, Electronic Pharmacy Regulations 2026 (Good Distribution Practices)

  • 14. Terms and conditions published

    low severityweight 5

    Terms and conditions of service are published on the site.

    Reg. 12, Electronic Pharmacy Regulations 2026

  • 15. About / contact page with Nigerian premises details

    low severityweight 5

    An about or contact page is reachable and carries Nigerian premises and contact details.

    Reg. 12, Electronic Pharmacy Regulations 2026

Scoring and tiers

Each check carries a weight by severity: high 18, medium 10, low 5. The score is the weighted proportion of passed checks, expressed out of 100. Checks returned as undetermined are excluded from the denominator so an operator is never penalised for a check the scanner could not evaluate.

  • Good — score of 75 or above with no high-severity failure.
  • Bad — score between 40 and 74, or minor gaps.
  • Ugly — score below 40, or any high-severity failure.
  • Unscored — no completed scan yet, or the site was unreachable.

Automated results are published as indicative and labelled “pending analyst review” until an analyst confirms them. Analysts may override any individual check, and the scan record retains both the automated and the overridden value.

Penalties referenced in dossiers

  • PCN Act 2022, s.54(1): Operating an unregistered pharmacy: fine of NGN 2,500,000 or imprisonment for two years, or both.
  • PCN Act 2022, s.52(4): Offence by a body corporate: fine of not less than NGN 5,000,000.
  • PCN Act 2022, s.55: General penalty for contraventions where no specific penalty is provided.

Findings reflect automated test browsing of publicly accessible storefronts and analyst review as of the capture date. Test purchases stop at add-to-cart; no order is ever placed and no payment is made. Results are indicative, subject to analyst review, and do not constitute a legal determination by the Pharmacy Council of Nigeria or any other authority. Corrections are welcome via the dispute form.

Disclaimer. Findings reflect automated test browsing of publicly accessible storefronts and analyst review as of the capture date. Test purchases stop at add-to-cart; no order is ever placed and no payment is made. Results are indicative, subject to analyst review, and do not constitute a legal determination by the Pharmacy Council of Nigeria or any other authority. Corrections are welcome via the dispute form.

Monitoring framework based on Nigeria's Electronic Pharmacy Regulations 2026, made under the Pharmacy Council of Nigeria Act 2022, and the Nigeria Data Protection Act 2023.

Powered by DPI Platforms PBC