The German pharmacy reform has been law since 2 July 2026. The debate around it has been loud, the trade press has covered every stage of it, and a good deal of what circulates about it is either out of date or was never in the statute at all. Some of the loudest claims describe the December 2025 cabinet draft rather than the law that was actually passed.
This guide sets out what the Apothekenversorgung-Weiterentwicklungsgesetz, known as the ApoVWG, really does. It covers who may carry out the venöse Blutentnahme, what the ärztliche Schulung requires, which deadlines are running and who they bind, what changed about pharmacy pay and what did not, and where the reform quietly opens a new service line for pharmacies that want one. Every legal point here comes from the promulgated text in the Bundesgesetzblatt, and the sources are listed at the end.
One note on names before starting. The official short name carries no linking s. It is the Apothekenversorgung-Weiterentwicklungsgesetz, and the full title is Gesetz zur Weiterentwicklung der Apothekenversorgung. The variants Apothekenreformgesetz and Apothekenversorgungs-Weiterentwicklungsgesetz appear widely in secondary coverage, and neither is the name in the Bundesgesetzblatt.
What is the ApoVWG and when did it come into force?
The ApoVWG is the law that reworks how pharmacies in Germany are allowed to operate and what they are allowed to offer. It was signed on 26 June 2026, published on 1 July 2026 in Bundesgesetzblatt 2026 Teil I Nr. 195, and came into force on 2 July 2026.
Not all of it started on that date. Article 9 of the law staggers four blocks of provisions. The Notdienst rules follow on 1 October 2026, the restructuring of the Arzneimittelpreisverordnung follows on 1 January 2027, and one further provision starts on a date the Bundesministerium für Gesundheit has still to announce in the Bundesanzeiger. The parts that matter most for a pharmacy planning a diagnostics service, meaning the new § 11c Apothekengesetz and the amendments to the Apothekenbetriebsordnung, have been in force since 2 July 2026.
That distinction matters commercially. A pharmacy does not have to wait for anything to start offering the venöse Blutentnahme. The legal basis is already live. Readers who want the short version first can start with our explainer on what the ApoVWG actually is.
Who may carry out the venöse Blutentnahme in a pharmacy?
Under § 11c Apothekengesetz, the venöse Blutentnahme may be carried out by an approbierter Apotheker, meaning a licensed pharmacist, and only under three conditions at once. The pharmacist must have completed an ärztliche Schulung, meaning training delivered by a physician, with successful completion confirmed. The blood draw must be carried out for a public pharmacy whose staff the pharmacist belongs to. The person having blood drawn must have reached the age of 18.
The law also limits the draw to diagnostic purposes only. The venous route is not the only way to collect a sample, and we set the two against each other in our comparison of capillary and venous blood collection.
Delegation exists but is narrow. A qualified pharmacist may delegate the puncture itself, and nothing else, to a person in the praktische Ausbildung zum Apotheker, known as a Pharmazeut im Praktikum or PhiP, under supervision and only once that person has completed an ärztliche Schulung of their own. Aufklärung, Anamnese and obtaining consent may never be delegated to anyone. Our post on the consent form for a pharmacy blood test covers that step in practice.
Pharmazeutisch-technische Assistenten, the PTA, may not carry out the venöse Blutentnahme, and the puncture may not be delegated to them either. Under § 35b Apothekenbetriebsordnung the wider pharmaceutical staff may support the preparation and the documentation around the blood draw, provided they are adequately qualified and regularly trained, and that training has to be documented.
This is the single most misreported point in the whole reform, so it is worth stating the contrast plainly. On vaccination, § 20c Infektionsschutzgesetz expressly allows delegation of the injection to PTA, Pharmazieingenieure and PhiP. On the venöse Blutentnahme, it does not. PTA may vaccinate. PTA may not draw blood. Trade coverage has repeatedly merged the two rules, and a pharmacy that plans its rota on the merged version will plan it wrong. Our separate article on what PTA may and may not do under the ApoVWG goes through the team split in more detail. Who is allowed to do what across the whole team, including the PhiP and the wider pharmaceutical staff, is set out in our post on the roles allowed to draw blood in a pharmacy.
What does the ärztliche Schulung involve and when does the Mustercurriculum arrive?
The statute sets out what the ärztliche Schulung has to cover. Under § 11c Absatz 2 the required content is carrying out the blood draw including Aufklärung, taking an Anamnese that rules out conditions which would make a draw inadvisable, and obtaining consent, together with hygiene, handling complications, and the relevant legal rules including patient rights. The law allows the training to be delivered digitally where that is possible.
The Bundesapothekerkammer develops the Mustercurriculum in cooperation with the Bundesärztekammer, and the deadline is 2 November 2026. There are in fact two curricula for blood draws, one for the pharmacist training and one for the training that lets a PhiP take on the puncture. A third curriculum, for delegated vaccine administration, is due the same day.
A widespread misunderstanding is worth correcting here. The Mustercurriculum is not a legal precondition for offering blood draws. The statutory requirement is a completed ärztliche Schulung, and § 11c has been in force since July. The Mustercurriculum will standardise what that training contains, which is useful, but a pharmacy that waits for November is waiting for something the law does not ask it to wait for.
What does a pharmacy need in place before the first blood draw?
Four things, and none of them is exotic.
A suitable room comes first. Under the Apothekenbetriebsordnung the room has to be adequately equipped, it may not be used for anything else while a blood draw is taking place, and it has to protect the privacy of the person having blood drawn. Our walkthrough of setting up the blood draw room covers how pharmacies meet that in practice.
Written Standardarbeitsanweisungen come second. The SOP for blood draws has to sit inside the pharmacy's quality management system under § 35b Apothekenbetriebsordnung, covering preparation, Aufklärung and consent, the Anamnese and the circumstances in which no draw takes place, carrying out the draw, documentation and hygiene. Our template post on the blood draw SOP for a pharmacy sets out those sections one by one.
Notification of the authority comes third, and this one has a hard timing rule. The pharmacy leader has to notify the competent state authority at least one week before starting blood draws, and again at least one week before any change to the procedure or to the rooms used.
A route to an accredited laboratory comes fourth. The law regulates who may take the sample, not who analyses it, so the Präanalytik, the transport and the laboratory relationship are commercial questions the pharmacy has to answer for itself. The difference this makes to the result is covered in our comparison of a self test against an accredited laboratory analysis. What quality assurance the pharmacy itself has to run is covered in our post on quality assurance for pharmacy blood tests.
None of these depends on the Mustercurriculum, and all four can be prepared now.
Which deadlines are running and who do they bind?
The reform generated a long list of dates, and most published summaries mix up two very different kinds. Some deadlines bind national bodies such as the Bundesapothekerkammer or the GKV-Spitzenverband. Only a few bind an individual pharmacy. The table separates them.
ApoVWG deadlines and who each one binds
| Date |
What has to happen |
Who it binds |
| Already in force |
Notification of the state authority at least one week before the first venöse Blutentnahme |
The individual pharmacy |
| 1 September 2026 |
Standardarbeitsanweisungen for the new pharmazeutische Dienstleistungen |
Bundesapothekerkammer, not individual pharmacies |
| 2 October 2026 |
Vaccination contract agreed, otherwise the Schiedsstelle decides |
GKV-Spitzenverband and ABDA |
| 1 November 2026 |
pDL agreement including remuneration, otherwise the Schiedsstelle decides |
ABDA and GKV-Spitzenverband |
| 2 November 2026 |
Mustercurricula for the ärztliche Schulung on blood draws |
Bundesapothekerkammer with the Bundesärztekammer |
| 1 January 2027 |
Billing of pharmazeutische Dienstleistungen to the health insurers begins |
The individual pharmacy |
Reading the right-hand column is the useful part. The 1 September 2026 date is frequently reported as an SOP deadline for pharmacies, and it is not. It binds the Bundesapothekerkammer. An individual pharmacy has no dated SOP deadline at all. What it has is a content obligation in its quality management system and the one-week notification before the first draw.
What changes for pharmazeutische Dienstleistungen?
The reform rewrites § 129 Absatz 5e Sozialgesetzbuch V and names ten pharmazeutische Dienstleistungen directly in statute, where the catalogue used to be purely contractual. The ten include counselling with risk-adapted measurement of risk factors such as blood values and blood pressure, brief-intervention counselling on tobacco-related illness, the erweiterte Medikationsberatung bei Polymedikation, pharmazeutisches Medikationsmanagement for complex and for newly prescribed long-term medication, care for transplant patients and for patients on oral antitumour therapy, extended instruction in inhalation and injection technique, and standardised risk assessment for high blood pressure.
Three structural changes sit alongside the list. A doctor can now prescribe a pDL. For the two Medikationsmanagement services the pharmacy has to coordinate with the treating physician beforehand, and our post on the rules for working with local doctors covers how that cooperation is set up. Results have to go into the elektronische Patientenakte once that is technically possible, and the pharmacy has to notify physicians electronically through a secure procedure.
The first item on that list is the one worth reading twice. A counselling service built on risk-adapted measurement of blood values is now a named pharmazeutische Dienstleistung, which puts diagnostics at the centre of the pharmacy's service catalogue rather than at its edge. Billing to the health insurers begins on 1 January 2027, and the remuneration is still being negotiated. Our article on how the erweiterte Medikationsberatung works as a pDL covers the process end to end. Which measurements a pharmacy can already run at the counter is covered in our post on point of care testing in the pharmacy.
What did the ApoVWG change about pharmacy pay and what did it not?
This is where the most confident published claims are the least reliable, so it is worth being precise.
The increase in the Fixum did not come from the ApoVWG. It came from a separate instrument, the Dritte Verordnung zur Änderung der Arzneimittelpreisverordnung of 9 June 2026, published as Bundesgesetzblatt 2026 Teil I Nr. 173. That ordinance raised the Fixum from 8,35 Euro to 9,00 Euro on 1 July 2026 and raises it again to 9,50 Euro on 1 January 2027. The 8,35 Euro figure had stood since 2013.
What the ApoVWG itself does to § 3 Arzneimittelpreisverordnung is narrower. From 1 January 2027 it merges the 21 Cent Notdienst surcharge and the 20 Cent surcharge that financed pharmazeutische Dienstleistungen into a single 41 Cent Notdienst surcharge, which leaves the per-pack total unchanged at that step. It also suspends that surcharge for an interim period, because emergency services are financed from the existing fund until the Bundesministerium für Gesundheit announces the quarter in which that arrangement ends.
Three things the ApoVWG does not do are worth stating, because each of them circulates as though it did. It introduces no Kombimodell. It does not touch the three percent component of the Rx surcharge. It does not change the Apothekenabschlag. The proposal to raise the Apothekenabschlag from 1,77 Euro to 2,07 Euro that ABDA attacked publicly was a separate matter and is not in this law. Our post on what actually changed about the Fixum in 2026 goes through the arithmetic.
The practical reading for a pharmacy owner is unglamorous. Dispensing revenue improved by 65 Cent per pack in July and improves by another 50 Cent in January, against operating costs that ABDA puts 65 percent higher than when the Fixum was last set. The reform's own answer to that gap is not the Fixum. It is the service catalogue, and alongside the pDL there is the privately paid layer covered in our guide to which Selbstzahlerleistungen a pharmacy may offer. How such a service is priced and how VAT applies to it is covered in our post on pricing a pharmacy blood test and its VAT treatment, and the low prices advertised by drugstore chains are put in context in our post on cheap drugstore blood tests and pharmacy pricing.
What does the reform change about vaccinations?
Pharmacists may now vaccinate with all non-live vaccines, rather than only against influenza and COVID-19. The limits are unchanged in shape: adults from 18, for a public pharmacy the pharmacist belongs to, and after a confirmed ärztliche Schulung. Pharmacists trained under the previous rules may continue with influenza and SARS-CoV-2 vaccinations without further training, and may extend to other non-live vaccines after an Ergänzungsschulung.
Administration of the vaccine may be delegated to PhiP, to pharmazeutisch-technische Assistenten and to Pharmazieingenieure, under supervision and after their own ärztliche Schulung. Aufklärung, Anamnese, consent and the Impfdokumentation may not be delegated. The vaccination contract and the remuneration were still under negotiation when this article was written, with a deadline of 2 October 2026. Our post on vaccinating in the pharmacy in 2026 goes through the practical side.
What does the ApoVWG not do?
Two claims come up often enough that a pharmacy planning its next two years should know they are wrong.
The law does not permit Telepharmazie. The word does not appear in the statute at all, and there is no general authorisation for remotely supervised pharmacies or video-supervised branches. Our post on what the ApoVWG says about Telepharmazie sets out what is and is not allowed.
The law does not permit pharmacist-free operation as a general rule. It restates the opposite: under § 3 Apothekenbetriebsordnung a pharmacy may only be open and operating when a pharmacist, an authorised deputy, or a specifically permitted PTA under the § 29 Apothekengesetz trial is present. That trial is narrow and time-limited. It allows the pharmacy leader to be absent for up to 20 days a year and no more than 10 consecutive days, only on individual application, only where no other pharmacy is within 6 kilometres, only with an experienced PTA who has worked unsupervised in that pharmacy for at least three years, and only until 31 December 2031. It is excluded for a Hauptapotheke and for pharmacies doing patient-individual Verblisterung or parenteral preparation.
What the law does open up is the Zweigapotheke. Under the rewritten § 16 Apothekengesetz a Zweigapotheke is permitted in a remote place where medicine supply is markedly restricted, as a rule where the road distance to the nearest pharmacy exceeds 6 kilometres or public transport access during normal opening hours is typically restricted. A pharmacy may operate up to two of them in addition to its permitted Filialapotheken, on a ten-year renewable permit.
The far-reaching version of pharmacist-free operation that drew heavy criticism in December 2025 belonged to the cabinet draft. It did not survive into the statute.
What are the main criticisms of the reform?
The opposition to the venöse Blutentnahme in pharmacies came mainly from the laboratory sector and from doctors' organisations, and a pharmacy building a diagnostics offering will meet these arguments locally, so they are worth knowing accurately.
ALM e.V., the association of accredited medical laboratories, called blood draws in pharmacies neither appropriate nor necessary, arguing that a venöse Blutentnahme is not an isolated technical service but part of a medical and physician-led diagnostic process, and that Germany already has comprehensive quality-assured laboratory structures. The Deutsche Gesellschaft für Klinische Chemie und Laboratoriumsmedizin joined that criticism.
The Kassenärztliche Bundesvereinigung objected on the ground of the Arztvorbehalt, arguing that pharmacists are excellent pharmaceutical scientists but do not have medical training, and warning that patients will arrive at practices with results that need physician interpretation. The Bundesärztekammer made a related argument about clinical decision-making. The AOK-Bundesverband warned against building parallel structures alongside unified treatment pathways.
ABDA, from the pharmacy side, welcomed the strengthened role but criticised the delay in adjusting pharmacy pay, and described the eventual ordinance as half-hearted.
These positions are worth taking seriously rather than dismissing, and the practical answer to most of them is the same: the pharmacy collects and contextualises values, the accredited laboratory analyses them, and medical interpretation stays with the physician. A pharmacy that communicates that division clearly is on solid ground. Our piece on the criticisms set against the opportunities weighs both sides at more length. What happens when a value comes back outside the reference range is covered in our post on an abnormal blood result in the pharmacy.
How does blood diagnostics fit into the new service catalogue?
Reading the reform as a whole, the direction is consistent. Dispensing revenue rises slightly and remains under pressure. The service catalogue expands, and the services that expand fastest are the ones that involve measurement, counselling and follow-up. The first named pharmazeutische Dienstleistung is built on measured risk factors. The venöse Blutentnahme became legal in July. Both point at the same capability.
It is also the capability that mail order cannot copy, which is the argument set out in our post on where the local pharmacy beats mail order. The gap between the legal permission and a working offering is operational rather than legal. A pharmacy needs a laboratory relationship, sound Präanalytik and sample logistics, a way to deliver results that a customer can actually read, and a clean line between measurement and medical interpretation. Our post on what a blood draw earns per hour puts numbers on that, and our post on how much staff time an appointment takes covers the time it costs. Talking a customer through a result without straying into diagnosis is the subject of our post on explaining blood values without diagnosing.
Aniva supplies that infrastructure for local pharmacies, including the accredited laboratory, the sample logistics, the result report and the customer-facing app. The pharmacy owns the customer relationship and the appointment. Standard markers are usually back within 10 days, and special analyses such as genetics take around two weeks. Details are on the page for Aniva for pharmacies, and a walkthrough of the setup can be arranged through a short intro call.
Frequently asked questions
When did the ApoVWG come into force?
The ApoVWG came into force on 2 July 2026, the day after it was published in Bundesgesetzblatt 2026 Teil I Nr. 195 on 1 July 2026. It was signed on 26 June 2026. Four blocks of provisions start later, on 1 October 2026, on 1 January 2027, and on a date the Bundesministerium für Gesundheit has still to announce.
May pharmazeutisch-technische Assistenten carry out the venöse Blutentnahme?
No. Under § 11c Apothekengesetz the venöse Blutentnahme is reserved for licensed pharmacists who have completed an ärztliche Schulung. The puncture may be delegated only to a Pharmazeut im Praktikum, under supervision and after their own ärztliche Schulung. PTA may support preparation and documentation. They may, separately, administer vaccines under § 20c Infektionsschutzgesetz, which is a different rule and a common source of confusion.
Does a pharmacy have to wait for the Mustercurriculum before offering blood draws?
No. The statutory requirement is a completed ärztliche Schulung, and § 11c Apothekengesetz has been in force since 2 July 2026. The Bundesapothekerkammer develops the Mustercurriculum with the Bundesärztekammer by 2 November 2026, and it will standardise the content of that training, but it is not a precondition for starting.
What has to be in place before the first venöse Blutentnahme?
A suitable room that is not used for anything else during the draw and that protects privacy, written Standardarbeitsanweisungen inside the quality management system under § 35b Apothekenbetriebsordnung, notification of the competent state authority at least one week beforehand, and a working relationship with an accredited laboratory for the analysis.
Did the ApoVWG raise the Fixum?
No. The increase from 8,35 Euro to 9,00 Euro on 1 July 2026, and to 9,50 Euro on 1 January 2027, came from the Dritte Verordnung zur Änderung der Arzneimittelpreisverordnung of 9 June 2026, published as Bundesgesetzblatt 2026 Teil I Nr. 173. What the ApoVWG changes is the merger of the Notdienst and pDL surcharges into a single 41 Cent Notdienst surcharge from 1 January 2027.
Does the ApoVWG allow Telepharmazie or pharmacies without a pharmacist present?
No. The word Telepharmazie does not appear in the law, and § 3 Apothekenbetriebsordnung restates that a pharmacy may only operate with a pharmacist or an authorised deputy present. The only exception is the narrow § 29 Apothekengesetz trial, which allows a PTA to maintain operations for up to 20 days a year under strict conditions and runs until 31 December 2031.
Terms explained quickly
- ApoVWG is the Apothekenversorgung-Weiterentwicklungsgesetz, the law reworking pharmacy supply in Germany, in force since 2 July 2026.
- Venöse Blutentnahme is the drawing of blood from a vein, which the ApoVWG permits trained pharmacists to carry out for diagnostic purposes.
- Ärztliche Schulung is the physician-delivered training that a pharmacist must complete before carrying out a venöse Blutentnahme.
- Mustercurriculum is the model curriculum for that training, developed by the Bundesapothekerkammer with the Bundesärztekammer and due by 2 November 2026.
- Pharmazeutische Dienstleistung, abbreviated pDL, is a pharmacy service regulated in § 129 Sozialgesetzbuch V and financed separately from the dispensing margin.
- Fixum is the fixed fee a pharmacy earns per prescription pack, raised to 9,00 Euro on 1 July 2026 by a separate ordinance rather than by the ApoVWG.
- Präanalytik is everything that happens to a sample between collection and analysis, including handling, storage and transport.
- Zweigapotheke is a branch pharmacy permitted in a remote location under the rewritten § 16 Apothekengesetz.
Each of these terms has its own entry with the statutory detail in the Aniva pharmacy glossary.
Sources
For pharmacies
Aniva provides the complete blood diagnostics infrastructure for the local pharmacy, covering the accredited laboratory, the sample logistics, the result report and the customer app. Details are on the page for Aniva for pharmacies.
As of 14 August 2026, based on the promulgated text in Bundesgesetzblatt 2026 Teil I Nr. 195. Aniva Health editorial team, no warranty. This article is general information and not legal advice. Please check with your Landesapothekerkammer before starting a new service.
