The rules for blood and the rules for vaccines are not the same rules, and that asymmetry is where the German trade press goes wrong. A PTA (pharmazeutisch-technische Assistentin) may administer a vaccine in a German pharmacy, but a PTA may not perform a venöse Blutentnahme (venous blood draw) at any level of supervision.
Only an approbierter Apotheker may draw blood, after a confirmed ärztliche Schulung (training delivered and confirmed by a doctor). The puncture alone may be delegated to a PhiP (Pharmazeut im Praktikum) under supervision, and only after that PhiP has their own ärztliche Schulung. Aufklärung (patient information), Anamnese (medical history) and consent never move to anyone else, in either service.
That permission arrived with the Apothekenversorgung-Weiterentwicklungsgesetz, full name Gesetz zur Weiterentwicklung der Apothekenversorgung, from here on the ApoVWG, in force since 2 July 2026. The question is no longer whether a pharmacy may do this but who may do which part.
The two rules come from two different statutes
The vaccination permission lives in § 20c of the Infektionsschutzgesetz (IfSG), which began as a narrow flu and COVID-19 model project. Because it grew out of a supervised model in which pharmacists ran the appointment and trained staff gave the dose, delegation was built in early. § 20c Abs. 4 IfSG names pharmazeutisch-technische Assistenten and Pharmazieingenieure as the people who may be given the administration of the dose, under supervision and after confirmed training.
The blood draw permission lives in § 11c of the Apothekengesetz (ApoG) and is new. It was drafted in 2026 against a live argument about the Arztvorbehalt, the reservation of certain acts to doctors, with laboratory medicine associations objecting. The legislature answered by keeping the circle of permitted people small, which is why the statute names the approbierter Apotheker, allows the puncture to go to a PhiP under supervision, and stops there.
Who may do each step of a blood draw or vaccination
| Step | Approbierter Apotheker | PhiP | PTA |
|---|
| Aufklärung and consent | Yes, and it stays personal | No, never delegated | No, never delegated |
|---|
| Anamnese before the appointment | Yes, and it stays personal | No, never delegated | No, never delegated |
|---|
| The venöse Blutentnahme puncture | Yes, after a confirmed ärztliche Schulung | Yes, supervised, after their own ärztliche Schulung | No, at any level of supervision |
|---|
| Sample handling and Präanalytik | Yes, responsibility stays here | Yes, supervised | Yes, supporting role |
|---|
| Documentation of the blood draw | Yes, responsibility stays here | Yes, supervised | Yes, supporting, under ApBetrO § 35b Abs. 2 |
|---|
| Administering a vaccine dose | Yes, after § 20c IfSG training | Not named in § 20c Abs. 4 IfSG | Yes, under § 20c Abs. 4 IfSG, supervised and trained |
|---|
The Präanalytik and documentation rows are where a PTA takes real load off the pharmacist, because ApBetrO § 35b Abs. 2 allows a PTA to support preparation and documentation.
An ärztliche Schulung belongs to a person not a pharmacy
An ärztliche Schulung is training in the knowledge, the ability and the practical skill needed for the venöse Blutentnahme, delivered under medical direction and confirmed as successfully completed. The confirmation carries the legal weight, because § 11c ApoG asks for completion rather than attendance.
The training attaches to the individual and not to the Betriebsstätte. A trained Inhaber does not cover a PhiP, and a second location inherits nothing from the first. Everyone who performs the puncture carries their own confirmed ärztliche Schulung, which makes this a budget line and a diary problem.
The Mustercurricula in November do not block the first blood draw
Two blood draw Mustercurricula are due by 2 November 2026, one for the pharmacist training and one for the delegation to a PhiP, developed by the Bundesapothekerkammer with the Bundesärztekammer. The vaccination curricula are due by 2 September 2026.
What those deadlines mean is the fact most pharmacies get wrong, and it costs them months. A Mustercurriculum is not a precondition for drawing blood, because § 11c ApoG has been in force since 2 July 2026 and the statute asks for a completed ärztliche Schulung. Pharmacies waiting for November are choosing to wait.
The operational duties do apply from the first appointment. A suitable room is needed that is not used for anything else during the draw, privacy is assured, Standardarbeitsanweisungen are held in the QMS under ApBetrO § 35b Abs. 1, and the pharmacy notifies the state authority at least one week before starting. The 1 September 2026 SOP deadline that circulates in the trade press binds the Bundesapothekerkammer and not individual pharmacies.
Three limits sit on top of the personnel rules
§ 11c ApoG carries three further boundaries that shape the appointment book. The venöse Blutentnahme is limited to people aged 18 or over, it has to serve a diagnostic purpose, and it happens only in the pharmacist's own öffentliche Apotheke.
Each is harder than it first looks. A parent who wants a teenager tested does not get an appointment, and an event stand or a customer's home is not the place for the draw. How broadly the diagnostic purpose requirement reads for a self-pay panel with no clinical question is [team to confirm] with the responsible chamber.
The rota changes when only approbierte staff may draw blood
An aposcope survey found that 66 percent of pharmacies say they have no people for extra services, which bites hardest for a blood draw service. A blood draw appointment is pharmacist time end to end, from the Aufklärung and the Anamnese through the consent, the puncture or the supervision of a PhiP, and the sign off on documentation. A PhiP helps only where the pharmacy has one who holds their own ärztliche Schulung, and a PhiP is a temporary presence by definition.
A vaccination appointment behaves differently, because a PTA can carry the administration while the pharmacist handles the conversation. That is why a vaccination service fits an existing rota and a blood draw service does not. Most pharmacies that go ahead use booked appointment blocks, a few fixed slots a week with a trained pharmacist away from the Handverkauf. Capacity scales with trained approbierte heads and nothing else.
The § 29 ApoG PTA trial answers a different question
The trial under § 29 ApoG lets an experienced PTA hold a rural pharmacy open temporarily, subject to long professional experience plus three years at that pharmacy, a cap of 20 days a year, and a location test. It runs to 31 December 2031.
It is easy to read that as a general widening of what a PTA may do, and it is not. A PTA covering under § 29 ApoG still may not perform a venöse Blutentnahme, because § 11c ApoG names who may draw blood and the § 29 trial does not amend it. The post on whether a PTA may draw blood covers that question on its own.
Questions pharmacy owners ask about blood draw roles
May a PTA draw blood if an Apotheker is supervising?
No. § 11c ApoG names the approbierter Apotheker and allows the puncture to go only to a PhiP under supervision, so a PTA sits outside that circle. A PTA may support preparation and documentation under ApBetrO § 35b Abs. 2, which is not the venöse Blutentnahme itself.
Does a pharmacy have to wait for the Mustercurriculum before the first blood draw?
No. § 11c ApoG has been in force since 2 July 2026 and the statute asks for a completed ärztliche Schulung, not a published Mustercurriculum. The two blood draw curricula are due by 2 November 2026 but do not gate the start.
If the Inhaber has done the ärztliche Schulung is the PhiP covered?
No. The training attaches to the person, so a PhiP performing the puncture needs their own confirmed ärztliche Schulung even where the supervising pharmacist holds one. The same applies to every angestellter Apotheker who will draw blood.
Why may a PTA give a vaccine but not draw blood?
The two permissions sit in different statutes. § 20c Abs. 4 IfSG lets a pharmacist delegate administration of a vaccine dose to a PTA under supervision and after training, while § 11c ApoG allows delegation of the puncture only to a PhiP. Aufklärung, Anamnese and consent stay with the pharmacist in both cases.
Can the pharmacy draw blood from a 17 year old with parental consent?
No. § 11c ApoG limits the venöse Blutentnahme to people aged 18 or over, and parental consent does not change that limit. The age boundary is a hard rule rather than a documentation question.
What a pharmacy does next
A pharmacy weighing this up usually starts by counting approbierte heads rather than total heads, because that number sets the ceiling on the service. From there the sequence is finding an ärztliche Schulung that issues a confirmation, writing the Standardarbeitsanweisungen into the QMS, identifying the room, and notifying the state authority at least one week before the first appointment. The post on vaccination in the pharmacy covers the parallel track and the plain summary of the ApoVWG covers what else changed.
This article is general information about German pharmacy law and business practice, not legal advice. The responsible chamber or a lawyer decides individual cases.
