Changing Pharmacy Core Hours: What Owners Need to Know
For many pharmacy owners, opening hours are no longer just an operational detail. They affect staffing, overheads, patient access, and long term sustainability. But changing a pharmacy’s core hours is not simply a business decision. It is a regulatory process, and the strength of the application matters.
Under the NHS pharmaceutical services framework, a pharmacy’s opening hours can include both core opening hoursand supplementary opening hours. Core opening hours are the hours a pharmacy is required to provide pharmaceutical services under its NHS terms of service. Supplementary opening hours are hours provided in addition to those core hours. In many cases, changes to supplementary hours can be made by notifying NHS England, whereas changes to core hours require a formal application.
Why pharmacy core hours applications matter
Applications to change pharmacy core hours are assessed carefully because decision makers are not only considering the pharmacy’s position, but also the impact on local patient access and pharmaceutical service provision. A contractor can apply to change the days or times of core opening hours either by reducing the total number of hours or by keeping the same total number of hours while changing when those hours are provided.
That means a strong application must do more than explain why a business wants to change its opening hours. It needs to show how the proposed arrangement fits within the local landscape and how patients will continue to have appropriate access to pharmaceutical services.
What changed in 2023
The 2023 regulations changed the old approach to core hours applications. Before these changes, the regulatory test was more onerous and many applications struggled to succeed. The 2023 reforms moved away from the earlier focus on demonstrating changing patient need. Instead, applicants now need to show either that the existing level of service provision can continue to be maintained, or, where that is not necessary or realistically achievable, that a sustainable level of adequate service provision will be maintained.
The 2023 changes also confirmed that supplementary opening hours could, in many situations, proceed by way of notification rather than a full application. In practice, this created more scope for contractors to put forward structured, evidence based core hours applications, particularly where they could show that local provision would remain adequate or sustainable.
What changed again in 2025
The 2025 regulations, which took effect from 23 June 2025, introduced a further route for some applications. For certain cases where the total number of core hours stays the same, the applicant must now state whether they want the application determined under the existing paragraph 24(1) basis or under the newer paragraph 26(2ZB) basis.
The explanatory material to the 2025 changes says that the newer route allows an additional test focused on overall benefit to patients. In simple terms, the question is whether patients are more likely to access the pharmacy during the proposed alternative core hours than under the current arrangement. This is an important development because it means the way an application is framed, and the legal route chosen, now matters even more.
Why some pharmacy core hours applications still fail
Even with a more flexible regulatory framework, not every application succeeds. In practice, refusals still happen where there is weak evidence, a poor explanation of patient access, insufficient attention to nearby pharmacy provision, or supporting statements that do not engage properly with the way ICBs and appeal bodies assess these cases.
Recent NHS Resolution decisions also show that core hours applications often turn on detailed questions about alternative provision, accessibility, and whether the proposed change still supports an adequate level of pharmaceutical service in the area.
What a strong application should address
A well prepared core hours application should be built around evidence rather than assertion. Depending on the facts, that may include local provision, accessibility, patient demand at different times, and how the proposal fits the relevant legal test. Where a pharmacy is seeking to change the distribution of hours rather than simply reduce them, the application also needs to be clear about which regulatory basis it relies on.
There is no one size fits all approach. A pharmacy in a densely served urban area may need to make a very different case from one where access to other providers is more limited. This is one reason many contractors seek wider pharmacy regulatory support before submitting an application.
How NorthRx can help
At NorthRx Consulting, we support pharmacy owners with core and supplementary hours changes by helping them assess the right route, prepare the necessary evidence, and present a clear, compliant case. Where needed, we can also review draft applications before submission so that weaknesses are identified early.
If you are considering changing your pharmacy’s core hours, the key issue is not simply whether the business would benefit. It is whether the proposed change can be justified under the current regulatory framework and evidenced properly. Get in touch to discuss your position or book a free consultation to explore the best route forward.