The pharmacy reform law (ApoVWG) has been in force since 2 July 2026 and is being discussed controversially. This article sets the most important criticisms against the new opportunities for pharmacies soberly, without favouring one side.
Why is the pharmacy reform criticised?
Criticism of the ApoVWG is aimed above all at additional red tape from new standard operating procedures, open liability questions around the venous blood draw, and the worry that staff and space are tight for new tasks in many pharmacies. Supporters, by contrast, see new revenue sources and a sharper care profile.
The debate does not run along a single camp. Even pharmacies that welcome new services in principle voice reservations about implementation deadlines or about who carries the additional responsibility in the team. The following sections sort the individual arguments, each based on what the law actually rules.
Which criticisms of the ApoVWG are named specifically?
The criticisms named most often are the organisational effort from new standard operating procedures, unresolved details on liability for the venous blood draw, the staffing needed for training, and the worry that smaller pharmacies will find it harder to keep up than large chain groups.
The overview below collects the criticisms that come up most often, so they can be weighed against what the reform actually opens up.
The main criticisms of the reform
| Criticism |
Description |
| Red tape |
New standard operating procedures (SOP) have to be written within two months of entry into force. |
| Liability |
For the venous blood draw, liability questions still have to be settled in everyday practice, for example with the business liability insurer. |
| Staffing effort |
Only licensed pharmacists may draw venous blood after training, pharmacy technicians (PTA) are not provided for. |
| Unequal starting positions |
Larger pharmacies or groups can often rearrange space and staff more easily than small single pharmacies. |
| Open pay |
The five new pharmaceutical services are still in price negotiation, so a reliable revenue frame is missing so far. |
What opportunities does the reform offer pharmacies?
The reform widens the pharmacy's range of services with the venous blood draw after training and with five new pharmaceutical services. That can strengthen pharmacies as a low-threshold health location, create additional reasons for advice, and deepen the bond with regular customers.
Capillary measurements, for example with systems like Tasso+, are already possible today within established offerings and need no venous training. Pharmacies can use them to gather first experience with blood testing as a reason for advice even before the model curriculum is finished, independently of any later step up to the venous draw.
How do the red tape burden and the new income relate to each other?
The red tape burden arises in the short term through deadlines for SOP, training and pay negotiation. New income from the venous blood draw or from pharmaceutical services, on the other hand, depends on what each pharmacy offers and can only be quantified reliably once the pay negotiations are concluded.
The pDL pay pot stood at around 537 million euros as of March 2026 for ten services in total, five of them with fixed prices already and five under negotiation. How that plays out for a single pharmacy depends on which services it offers and how many patients it reaches. A blanket statement on profitability can only be made seriously once the pay for the new services is settled.
How can pharmacies deal with the uncertainty?
Pharmacies can prepare organisationally without waiting on every open question. It makes sense to take early stock of your own space and team, watch the deadlines as they run, and settle liability and data protection questions with legal advice.
- Keep the deadlines in view: SOP, model curriculum and pay negotiation all run from 2 July 2026.
- Settle team and roles early, since the venous draw stays reserved for licensed pharmacists.
- Clarify liability questions in advance with your business liability insurer and legal advice.
- Gather experience with capillary offerings, which are already possible today without venous training.
- Wait for the pay of the new pDL before communicating fixed revenue expectations.
Is the criticism of the reform justified?
Part of the criticism concerns real deadlines and open points built into the law, for example the pay for new services that is still outstanding. Other worries, such as practical feasibility in small pharmacies, can only be assessed conclusively once the model curriculum is published and there is first experience from practice.
For a sober assessment it is worth looking at primary sources such as the Federal Ministry of Health and the ABDA rather than relying on mood alone. Aniva is not a vaccination provider and does not offer legal advice. We deliver the diagnostic infrastructure with which pharmacies can run blood testing as part of their offering, from sample logistics through to an understandable result report.
Frequently asked questions
Is the ApoVWG final or can something still change?
The ApoVWG has been in force since 2 July 2026. Individual implementation details, for example the pay for the five new pharmaceutical services, are only negotiated over the following months. The law itself stands, the practical shape follows step by step through the set deadlines.
Do pharmacies have to offer the new services?
No. The ApoVWG opens up the legal option for the venous blood draw after training and for new pharmaceutical services, but it obliges no individual pharmacy to take it up. Whether and to what extent a pharmacy uses the offering remains a business decision on site.
Who is liable if something goes wrong during a pharmacy blood draw?
Liability questions around the venous blood draw still have to be settled in detail in everyday practice, among other things through the pharmacy's business liability insurance. The basic requirement is the doctor-led training per the model curriculum, which is due by 2 November 2026 at the latest. Pharmacies should clarify specific liability questions in advance with legal advice.
Does the reform put small pharmacies at a disadvantage against large chain groups?
That is one of the criticisms named, but it cannot be quantified across the board. Larger groups can often adapt space and staff more flexibly, while smaller pharmacies often score on personal customer loyalty. How that plays out day to day will only show with the practical implementation of the new rules.
Does the new pharmacy service replace a visit to the doctor?
No. A blood test in the pharmacy delivers measured values, not a diagnosis. Reference ranges count as orienting guide values and depend on the lab. A single value always belongs in the medical context, the pharmacy informs and refers on when results are unusual.
Terms explained quickly
- ApoVWG is the Apothekenversorgung-Weiterentwicklungsgesetz, the pharmacy reform law in force since 2 July 2026, which among other things re-rules the venous blood draw and pharmaceutical services in pharmacies.
- Pharmaceutical services (pDL) are paid services by the pharmacy beyond dispensing medicines, in future ten in total, eight of them without a doctor's prescription.
- Model curriculum is the training frame produced by the Federal Chamber of Pharmacists and the German Medical Association for the venous blood draw, due by 2 November 2026 at the latest.
- Arbitration body is the instance that decides within twelve weeks if there is no agreement on the pay for new services.
- Capillary measurement is blood collection from the finest vessels, for example with systems like Tasso+, already possible today within established offerings.
Sources
For pharmacies
Aniva provides the complete blood diagnostics infrastructure for the local pharmacy, including the lab, the result, the app report and the logistics. Learn more at Aniva for pharmacies and in the ApoVWG guide.
As of 4 August 2026. Aniva Health editorial team, no warranty. This article is not legal advice. Please check with your state pharmacists' chamber and your business liability insurer before you start.
