Relocating a Pharmacy: What Happens to the Operating License

Changing a pharmacy’s location is always a strategic business decision. The reasons for relocation can range from the end of a lease and unreasonable rent hikes to opening a more promising location near new medical centers. In some cases, relocation is forced by the need to move a business from frontline areas to protect both assets and employees.

But moving a pharmacy is very different from moving a coffee shop or clothing store. You cannot simply pack up the displays and inventory over the weekend and reopen elsewhere. Pharmacy operations in Ukraine are strictly regulated, and any change of location is subject to regulatory requirements and oversight by the State Service of Ukraine on Medicines and Drugs Control.

For pharmacy owners, one of the biggest concerns when relocating is what happens to the existing license. Does the business have to cancel its current license and go through the entire pharmacy licensing process again? How long will the paperwork take, and what can be done to keep business downtime to a minimum?

A mistake at any stage, whether it is an incorrectly prepared notification or a new location that fails to meet the licensing requirements, can leave the pharmacy closed for weeks or even months and result in significant lost revenue

The Key Legal Rule: New License or Changes to the Existing License?

There is still a common misconception among both new entrepreneurs and experienced pharmacy owners that moving to a new address means cancelling the existing license and applying for a new one. Legally, that is not how it works.

A license for the retail sale of medicinal products is issued to the business entity, whether a legal entity or an individual entrepreneur, rather than to a particular building. The business entity remains the same; only the place where the business operates changes. As a result, you do not need to obtain a new pharmacy license. Instead, the existing license records must be updated. In practice, this involves two steps:

1. Add the new address, meaning the new place of business, to the licensing register.
2. Remove the old address from the register if the previous pharmacy is being permanently closed.

The pharmacy cannot start selling medicines at the new location until the new address has been officially added to the licensing register. This is confirmed by a decision of the State Service of Ukraine on Medicines and Drugs Control on amending the information in the licensing register in connection with establishing a new place of business for the retail sale of medicinal products. The decision is published on the regulator’s website.

This applies even if the new premises are fully renovated, furnished, and stocked with medicines. Starting sales before the new location is officially added to the register may be treated as unlicensed pharmaceutical activity and can lead to significant fines and confiscation of the revenue and medicines.

This is why a pharmacy relocation needs to be planned carefully from a legal and operational perspective. The paperwork for the new address should be submitted well in advance so that the regulatory approval is in place by the time the new pharmacy is ready to open.

Requirements for New Pharmacy Premises

One of the costliest mistakes a pharmacy owner can make is signing a lease, investing heavily in renovations, and only then checking the Licensing Conditions. If the new premises do not meet the requirements of the State Service of Ukraine on Medicines and Drugs Control, you will not be able to add the new location to your license, and the money spent on rent and renovations may be wasted. That is why, before signing a lease, you should thoroughly assess the property to make sure it is suitable for use as a pharmacy. The following parameters are particularly important.

Pharmacy Premises Areas and Layout

The pharmacy premises must be isolated and have a separate entrance, except for pharmacies located in shopping centers, hospitals, hotels, airports, railway stations, health resorts, and similar facilities. The premises must also include the following required areas:

• a sales area where customers are served;
• a storage room for pharmaceutical stock;
• a staff room;
• a restroom with a washbasin.

You must also provide a designated area or cabinet for storing cleaning equipment and protective work clothing.

Minimum Pharmacy Floor Area

The law sets different minimum floor area requirements depending on the type of settlement where the pharmacy is located:

Accessibility Requirements Under Ukrainian Building Standards

The State Service of Ukraine on Medicines and Drugs Control pays close attention to whether pharmacy premises are accessible to people with reduced mobility, including wheelchair users and parents with strollers.

The pharmacy entrance must have a ramp with an appropriate slope in accordance with the applicable Ukrainian building standards (DBN) and a non-slip surface. If the building’s design makes it impossible to install a ramp, other measures must be provided to ensure accessible entry for people with reduced mobility in compliance with the DBN requirements. These may include a stairlift or lifting platform. The key requirement is to have documentary confirmation from a certified specialist that the premises meet the applicable accessibility requirements. Simply installing a call button for staff instead of providing accessible entry is no longer sufficient and may result in the licensing application being refused.

Read more on the topic: Accessibility of Healthcare Facilities and Pharmacies for Persons with Disabilities: Legal Requirements

Pharmacy Microclimate, Ventilation and Utilities

The pharmacy premises must have access to a centralized water supply, sewerage, and heating. Particular attention should be paid to ventilation. It must provide adequate air exchange to ensure that the storage rooms maintain the temperature and humidity levels required for the proper storage of medicines. All monitoring devices, including thermometers and hygrometers, must be certified and undergo regular calibration.

Read more on the topic: Pharmacy Premises Requirements: How to Prepare for Securing a State Medicines Service License

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Changing a Pharmacy Address: Step-by-Step Guide

To make sure relocating a pharmacy does not turn into a mess and the State Service of Ukraine on Medicines and Drugs Control approves the documents without delays, the relocation process should be planned as a clear sequence of steps. Getting the order wrong can result in fines for operating without the required documents or leave you paying rent and taxes for two locations longer than necessary.

Step 1: Prepare the Documents and Sign the Lease

Once the premises have passed the initial assessment, you can sign the lease or formalize ownership of the property. At this stage, you should also engage a certified architect or specialist to obtain official confirmation that the premises are accessible to people with reduced mobility, including an assessment of the ramp or entrance. A detailed floor plan should also be prepared, showing all required areas.

Step 2: Equip the New Location

Complete the renovations, install pharmacy furniture and refrigeration equipment, provide certified devices for monitoring temperature and humidity, and make sure the ventilation system is properly set up. The pharmacy should be fully ready to operate before the documents are submitted to the State Service, as the regulator may inspect the premises and verify that their actual condition matches the information provided in the application.

Step 3: Submit a Notification of Changes to the State Service

Prepare and submit a notification of changes to the licensing information together with details confirming the availability of the required material and technical resources at the new address. The documents can be submitted electronically through the Diia portal or directly to the State Service.

Step 4: Wait for the Decision and Have the New Address Added to the Register

The State Service reviews the documents (within up to 10 business days) and decides whether to add the new address to the licensing register. Once the new address has been officially added, you can legally move the pharmacy’s inventory, set up the cash register (RRO), and open the new location to customers.

Step 5: Close the Old Location

Once the new pharmacy is operating, the previous location can be formally removed from the license. To do this, you submit an application to the State Service requesting that the old address be removed from the licensing register because operations at that location have ceased. This should be done only after all medicines and equipment have been removed from the old premises.

Important practical tip: Do not request removal of the old address at the same time as you submit the documents for the new location. It is generally more practical to keep both locations listed on the license for a short period. This gives you time to move the remaining medicines from the old pharmacy to the new one without unnecessary pressure, documenting the transfer as an internal movement of inventory between the company’s business units.

You might also like: Amending a Pharmacy License: How to Avoid Fines and Revocation

Key Risks and Common Mistakes When Relocating a Pharmacy

Even experienced pharmacy operators can make mistakes when relocating a pharmacy, and those mistakes can lead to regulatory refusals or significant financial losses. Licensing requirements in the pharmaceutical sector are particularly strict, so overlooking even a minor detail can have serious consequences.

Here are some of the key pitfalls:

1. Starting sales too early. The most serious mistake is opening the new pharmacy and processing sales as soon as you have “simply submitted” the documents to the State Service. Filing the application does not give you the right to start operating from the new location.
   
   Until the regulator issues an official decision and the new address appears in the electronic register of license holders, any sales activity at the new location may be treated as unlicensed activity. This can result in fines and the confiscation of medicines, equipment, raw materials, or funds obtained as a result of the violation.
   
   
2. Taking accessibility requirements too lightly. Trying to save money on an assessment of the ramp or lifting platform is one of the common reasons for licensing problems. Entrepreneurs often purchase a standard metal ramp or install a call button for staff, assuming that this is enough. In practice, inspectors may check the ramp slope, the width of the access route, the presence of handrails at two levels on both sides, and the size of the turning area in front of the entrance.
   
   If a certified expert provides an inaccurate assessment and an inspection or photographic evidence reveals that the premises do not comply with the applicable DBN requirements, the application may be refused.
   
   
3. The actual layout does not match the submitted information. The information on the material and technical resources must clearly describe how the premises are organized, including the location of the storage room, the area for receiving medicines, and the safe for controlled medicines. A common mistake is to submit one floor plan and then change it during the renovation by moving a wall or combining rooms.
   
   If an inspection reveals discrepancies between the documents and the actual layout, the licensing process may be delayed until the deficiencies are corrected.
   
   
4. Ignoring temperature requirements during transportation. Relocating a pharmacy is not simply a matter of moving boxes from one address to another. Medicines must be kept within the required storage conditions during transportation as well. This is particularly important for insulin, vaccines, and other temperature-sensitive medicines that require an uninterrupted cold chain.
   
   Transporting such medicines in an ordinary delivery vehicle without appropriate temperature-controlled containers or refrigeration equipment may constitute a serious breach of the Licensing Conditions and, if documented, could put the pharmacy license at risk.

Please note! Another common trap is renting premises that previously housed a pharmacy. Entrepreneurs may assume that because the location has already been used as a pharmacy, it will automatically meet the current requirements. However, the Licensing Conditions are regularly updated. Premises that passed an inspection five years ago may no longer meet current accessibility or layout requirements. There is also a practical issue with measuring the floor area. If the required area is measured along the internal surfaces of the walls, adding drywall partitions during renovation can reduce the usable area by several centimeters. For example, this could reduce a sales area from the required 18 sq. m. to 17.5 sq. m., creating a compliance issue.

You might also like: New Requirements of the State Service on Medicines: What Pharmacy and Pharmaceutical Licensees Must Submit by November 2026

Legal Support for Relocating a Pharmacy and Updating Its License

Relocating a pharmacy is too costly to risk over paperwork mistakes or an incorrectly designed ramp. While you focus on renovating the new premises, marketing the new location, and managing the logistics, our lawyers can take care of the regulatory paperwork and help ensure a smooth legal transition.

We provide comprehensive support designed to minimize business downtime:

• Preliminary legal audit of the premises (before you sign the lease). Our specialists assess the property’s key parameters, including its floor area, layout, required zones, and accessibility, to determine whether it meets the current Licensing Conditions and help you avoid committing to unsuitable premises.
• Drafting and reviewing contracts. We can prepare a lease agreement with clear safeguards for your business and properly document the internal transfer of inventory between locations, helping prevent questions from the tax authorities or the State Service.
• Preparing and submitting the licensing documents. We prepare the information on the material and technical resources and submit the application to the State Service. Our specialists know which details require particular attention to help ensure that the documents are accepted without unnecessary delays.
• Support during inspections. If the State Service conducts a pre-licensing inspection at the new location, we prepare your staff, provide guidance before the inspection, and assist throughout the regulator’s visit.
• Properly closing the old location. We arrange for the previous address to be removed from the licensing register at the right time, helping you avoid unnecessary administrative costs and disruptions.

Every pharmacy relocation is different. The new premises, documentation, and potential risks can vary from case to case, so there is no one-size-fits-all solution. Contact us today to discuss your situation. We will assess the specifics of your relocation, determine the appropriate sequence of steps, and help you complete the pharmacy relocation process without unnecessary delays or legal risks.