Vaccine Movement
As you make plans for Winter 2026, we wanted to reiterate that the updated guidance on vaccine movement, shared in Bulletin Issue 286 5th May 2026 and Issue 293: 22nd June 2026, relates to all vaccines.
To confirm the movement of all vaccines (including Covid-19 and Flu) is not permitted outside of the same legal entity or without a Wholesale Distribution Authorisation Licence. For example, for General Practice this means that movement of vaccines within a PCN is no longer permissible.
Full details and relevant links are below for ease of reference:
Please be advised of the amendment to the Human Medicines (Amendment) Regulation 2026 and its impact on vaccine movement as below:
- Vaccines (as Prescription Only Medicines) are governed by The Human Medicines Regulations 2012, which require that they can only be distributed from one organisation to another where the supplying organisation holds a Wholesale Distribution Authorisation (WDA) license.
- An organisation is permitted to move vaccines within its own sites, for example a GP Practice can move vaccine from their main site to a branch surgery, or a Trust can move vaccine between its hospital sites.
- Community Pharmacies that are part of the same legal entity are also permitted, under the HMRs, to distribute vaccines, however it should be noted that the specification for pharmacy contractors specifically states that ‘COVID-19 vaccines are allocated to the pharmacy contractor and the pharmacy premises and must not be shared with other providers providing a similar vaccination service ….. without the express prior consent of the Commissioner’.
- Distribution of COVID-19 vaccine by organisations without a WDA (through the process known as Mutual Aid) was permitted under a temporary amendment to Regulation 19. This regulation was revised and made permanent on 1st April 2026 and now only allows for distribution under specific conditions, as described in the regulations The Human Medicines (Amendment) Regulations 2026. These conditions facilitate access to vaccine for the population in exceptional circumstances and are not intended to be used to reduce waste.
- If vaccination has occurred following non-permitted movement:
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- where the vaccine has been transported in line with the conditions set out in the Marketing Authorisation (complete, intact packs and maintenance of cold chain), this would not be considered off label and there would be no requirement to notify the individuals vaccinated.
- any distribution of vaccine where storage/handling has not been in line with the Marketing Authorisation should be considered an incident and reported to ICARS (england.swicars@nhs.net).
- where storage/handling has not been in line with the Marketing Authorisation providers must ensure that lessons are captured and steps taken to prevent any further movement of vaccines outside of permitted routes