Introduction
The one pharmacist one pharmacy rule in Turkish law is one of the most important principles of pharmacy regulation in Turkey. It determines who may own a pharmacy, how many pharmacies a pharmacist may operate, whether pharmacy chains are allowed, whether investors may control pharmacies, and how professional responsibility is preserved in the medicine supply system.
Unlike many ordinary businesses, a pharmacy in Turkey is not treated simply as a retail store. It is legally regarded as a healthcare institution where medicines are supplied under the personal responsibility of a qualified pharmacist. This legal approach reflects public health concerns, patient safety, professional independence and the need to ensure that medicines are dispensed by competent professionals.
The core statutory rule is found in Law No. 6197 on Pharmacists and Pharmacies. Article 18 of Law No. 6197 provides that a pharmacist is prohibited from opening more than one pharmacy or undertaking the responsible management of more than one pharmacy. This is the legal foundation of the “one pharmacist one pharmacy” rule.
This rule has major consequences for Turkish pharmacy ownership. A pharmacist cannot legally open several pharmacies. A pharmacist cannot act as responsible manager for multiple pharmacies. A company cannot freely build a pharmacy chain by employing pharmacists as managers. A non-pharmacist investor cannot lawfully control multiple pharmacies through nominee pharmacists. Therefore, the rule is not merely a technical licensing provision; it is a structural principle of Turkish pharmacy law.
Legal Basis of the Rule
The main source of the rule is Article 18 of Law No. 6197 on Pharmacists and Pharmacies. The wording is direct: a pharmacist may not open more than one pharmacy or assume the responsible management of more than one pharmacy. The same law also defines pharmacy practice broadly as opening and operating pharmacies, pharmaceutical warehouses, medicine cabinets, laboratories and similar institutions, or acting as responsible manager in such institutions.
The Regulation on Pharmacists and Pharmacies supports this statutory structure. The regulation defines a pharmacy as a healthcare institution opened under the ownership and responsible management of a pharmacist. It also states that opening and operating a pharmacy and acting as responsible manager of a pharmaceutical warehouse require being a pharmacist.
These provisions show that Turkish pharmacy law does not separate pharmacy ownership from professional responsibility. The pharmacist is not only the investor or commercial owner. The pharmacist is also the responsible healthcare professional who must supervise medicine supply, patient counseling, prescription compliance and legal operation.
The rule is further connected to the broader purpose of the Regulation on Pharmacists and Pharmacies. The regulation expressly aims to determine pharmacists’ duties, powers and responsibilities and to regulate the opening, operation, relocation, transfer and closure of pharmacies, as well as pharmacy characteristics and pharmacy services.
Purpose of the One Pharmacist One Pharmacy Rule
The purpose of the one pharmacist one pharmacy rule is to protect the professional and public health nature of pharmacy practice. If one pharmacist were allowed to own or manage many pharmacies, the pharmacist’s actual supervision could become formal rather than real. Turkish law aims to prevent this.
A pharmacy is a place where prescription medicines, controlled products, medical supplies, health advice and patient-sensitive information are handled every day. The pharmacist must ensure that medicines are supplied safely, prescriptions are checked properly, patients are informed correctly and pharmaceutical products are stored under appropriate conditions.
The Regulation on Pharmacists and Pharmacies identifies several responsibilities of pharmacists, including helping patients use medicines and medical devices safely and effectively, ensuring safe and rational supply of non-prescription medicines and health products, protecting patient privacy, supporting rational drug use and supervising pharmacy employees and pharmacy interns.
These responsibilities require real presence, personal supervision and professional judgment. The one pharmacist one pharmacy rule makes sense in this context. It is designed to ensure that the pharmacist’s name on the license corresponds to actual professional responsibility, not merely formal ownership.
Why Pharmacies Are Not Ordinary Commercial Businesses
A pharmacy has a commercial side because it sells medicines and health-related products. However, Turkish law treats pharmacies as healthcare institutions because the subject of the activity directly concerns human health.
The Regulation on Pharmacists and Pharmacies defines “pharmacy” as a health service institution opened under the ownership and responsible management of a pharmacist. It also defines pharmacy practice as a health service involving the preparation and supply of medicines, monitoring of pharmacological effectiveness, safety and cost, quality assurance and patient information concerning medicine-related issues.
This legal definition is important. It means that the pharmacy owner is not merely a merchant. The owner-pharmacist performs a regulated healthcare function. The pharmacist must comply with professional ethics, administrative rules, prescription requirements, medicine tracking obligations, storage standards and inspection rules.
For this reason, ordinary commercial expansion logic cannot be directly applied to pharmacies in Turkey. A clothing store owner may open many branches. A restaurant company may operate several outlets. A supermarket chain may expand through corporate branches. However, a pharmacist cannot use the same model to create a chain of private pharmacies under Turkish law.
Consequences for Pharmacy Ownership
The one pharmacist one pharmacy rule creates a strict ownership model. A private pharmacy must be connected to one pharmacist who is both the owner and responsible manager. A pharmacist may not open a second pharmacy while already owning one. A pharmacist may not be appointed as responsible manager in another pharmacy while responsible for their own pharmacy.
This rule also prevents indirect multiple ownership. For example, a pharmacist cannot establish separate legal arrangements to control multiple pharmacies through relatives, employees or other pharmacists. If the pharmacist is effectively operating or controlling more than one pharmacy, the structure may conflict with the purpose of the law.
The rule also affects commercial partnerships. A pharmacist may not lawfully use a partnership arrangement to create a network of pharmacies where one pharmacist is the controlling professional behind several branches. Similarly, non-pharmacists cannot use multiple pharmacists as nominal owners to build a commercial pharmacy group.
The legal point is simple: pharmacy ownership in Turkey is not only about capital. It is about professional responsibility. The law requires that the person who owns and operates the pharmacy be a pharmacist and that this responsibility remain genuine.
Responsible Management and Personal Presence
The one pharmacist one pharmacy rule is closely connected to responsible management. The responsible pharmacist is not a symbolic figure. The pharmacist must be actively involved in the operation of the pharmacy.
The Regulation on Pharmacists and Pharmacies provides that, during the hours when the pharmacy provides service, the responsible pharmacist, and where applicable the second pharmacist and assistant pharmacist, must be physically present at their duties.
This rule reinforces the idea that the pharmacist’s professional role is practical and daily. A pharmacist who is responsible for several pharmacies could not realistically be present and supervise each pharmacy in the manner required by the regulation. The one pharmacist one pharmacy rule therefore prevents a mismatch between legal responsibility and actual control.
The regulation also addresses situations where the pharmacist must be absent. If the pharmacist is away from the pharmacy for more than 24 hours due to illness or another reason, notification must be made to the health authority. If the absence exceeds 15 days, a responsible manager must be appointed; otherwise, the pharmacy is closed.
These provisions show that Turkish law expects the pharmacist to be closely connected to the daily operation of the pharmacy. The pharmacy cannot be treated as a passive investment.
Relationship with Second Pharmacists and Assistant Pharmacists
The one pharmacist one pharmacy rule does not mean that only one pharmacist may work in a pharmacy. It means that one pharmacist cannot own or manage more than one pharmacy. A pharmacy may employ second pharmacists or assistant pharmacists where required or permitted.
The Regulation on Pharmacists and Pharmacies requires a second pharmacist in private pharmacies where annual prescription volume or annual turnover exceeds certain thresholds. It also states that additional second pharmacists may be required as those thresholds are exceeded, subject to regulatory limits.
The regulation also provides that pharmacists who wish to open a private pharmacy or act as responsible manager may be required to work for at least one year as an assistant pharmacist under the relevant conditions, with certain equivalent service situations recognized.
Therefore, the legal system distinguishes between ownership/responsible management and employment/support functions. A second pharmacist or assistant pharmacist may support professional service in a pharmacy, but this does not create a right for one pharmacist to own or manage several pharmacies.
Pharmacy Chains and Corporate Pharmacy Models
One of the most practical consequences of the one pharmacist one pharmacy rule is that traditional chain pharmacy models are generally incompatible with Turkish law. In some countries, large corporations operate pharmacy chains with multiple branches. In Turkey, however, private community pharmacy ownership is based on individual pharmacist ownership and responsible management.
Because one pharmacist cannot open more than one pharmacy, and because a private pharmacy must be owned and responsibly managed by a pharmacist, corporate pharmacy chains cannot be created in the ordinary retail sense. A company cannot simply open dozens of pharmacies and hire pharmacists as branch managers.
This is an important point for foreign investors. In many markets, healthcare retail investors expect to build scale through branch networks. In Turkey, the legal model limits this possibility. Investment structures must respect the pharmacist-centered system. Any model that places pharmacists as formal license holders while a company retains real control over the pharmacies may be exposed to serious legal risk.
Foreign Investors and the Rule
Foreign investors frequently ask whether they can invest in pharmacies in Turkey. The one pharmacist one pharmacy rule is one of the main reasons why this is difficult in the private community pharmacy sector.
A foreign investor who is not a pharmacist cannot directly own a private pharmacy. A foreign company cannot freely create a pharmacy chain. A non-pharmacist investor cannot lawfully control a pharmacy through a nominee pharmacist. Even a pharmacist cannot use their license to control more than one pharmacy.
Law No. 6197 also requires Turkish citizenship and pharmacy qualification for practicing pharmacy within Turkey. This citizenship and professional qualification framework must be considered together with the one pharmacist one pharmacy rule.
Foreign investors may still be active in other areas of the pharmaceutical sector, such as pharmaceutical companies, distribution, medical devices, cosmetics, regulatory consultancy, health technologies or logistics, subject to separate rules. However, private pharmacy ownership is a special and restrictive field.
Sham Ownership and Muvazaa Risk
The one pharmacist one pharmacy rule is closely linked to muvazaa, meaning sham ownership. Sham ownership occurs when the official license holder appears to be a pharmacist, but the real owner or controller is someone else.
The Regulation on Pharmacists and Pharmacies contains a specific muvazaa assessment mechanism. After an opening or relocation application is notified to the relevant chamber of pharmacists, the chamber may prepare a sham ownership assessment report within 15 business days and submit it to the provincial health directorate with concrete information and documents. The provincial health directorate must then decide within the regulatory time frame. If either the health directorate or the chamber alleges sham ownership, the matter is evaluated by a Sham Ownership Assessment Commission.
The regulation also allows sham ownership assessment for pharmacies already in operation where there is suspicion of sham ownership. In such cases, the matter may be evaluated by the commission and, where appropriate, sent to the institution for inspection by inspectors.
This is highly significant. A pharmacy may face scrutiny not only at the opening stage but also after it begins operating. Therefore, a legally risky structure may not become safe simply because the pharmacy initially obtained a license.
Examples of Risky Structures
Several structures may create risk under the one pharmacist one pharmacy rule and sham ownership principles.
The first risky structure is a non-pharmacist investor who pays all capital, receives the profit, controls the bank accounts and leaves the pharmacist as a formal license holder. This may be viewed as an attempt to bypass pharmacist ownership rules.
The second risky structure is a company that controls purchasing, employees, pricing, marketing, payment systems and operational decisions of multiple pharmacies while different pharmacists appear as separate owners. This may create a chain-like structure contrary to the pharmacist-based model.
The third risky structure is a family arrangement in which one pharmacist is used as the legal face of a pharmacy, while another family member or businessperson controls the operation.
The fourth risky structure is a loan or consultancy agreement that is drafted so broadly that the lender or consultant effectively controls the pharmacy.
The fifth risky structure is a transfer agreement where the buyer pharmacist does not genuinely take over the business, and the seller or a third party continues to control the pharmacy.
The key question is not only who appears on the license. The legal question is who actually controls the pharmacy, who bears the professional responsibility, who receives the economic benefit and whether the arrangement respects the statutory purpose.
Pharmacy Transfer and the One Pharmacy Rule
The one pharmacist one pharmacy rule also affects pharmacy transfer. A pharmacy may be transferred only to a person who is legally entitled to operate it. If the buyer is already the owner or responsible manager of another pharmacy, the transfer may conflict with Article 18 of Law No. 6197.
The Regulation on Pharmacists and Pharmacies regulates pharmacy transfer, relocation and licensing procedures. It provides that the transfer of a pharmacy to another pharmacist is carried out through a report prepared in the presence of an official appointed by the provincial health directorate and an official from the chamber of pharmacists.
Therefore, pharmacy transfer is not merely a private commercial sale. It is an administrative and professional process. The buyer’s eligibility, the absence of sham ownership, the pharmacy’s license status, premises, stock, SGK-related risks and operational records should be reviewed before transfer.
A transfer agreement that ignores the one pharmacist one pharmacy rule may be commercially signed but legally unenforceable or administratively impossible. For this reason, every pharmacy transfer must be structured with licensing conditions and regulatory approval in mind.
Relocation, Population Criteria and EYS
The one pharmacist one pharmacy rule should also be understood together with population-based pharmacy planning. Even a pharmacist who owns only one pharmacy cannot open or relocate a pharmacy freely without considering population and placement rules.
The Regulation on Pharmacists and Pharmacies provides that the number of private pharmacies is regulated according to district population on the basis of at least one pharmacy per 3,500 people. The same regulation states that the population criterion is not applied to relocations within the same district and that one pharmacy may be opened in a settlement with no pharmacy regardless of population, subject to the relocation limitation stated in the regulation.
The regulation further provides that the institution determines and announces every year, three times per year, the districts where pharmacies may be opened and the number of pharmacies that may be opened, using population data published by the Turkish Statistical Institute.
This system means that Turkish pharmacy law applies both ownership restrictions and location restrictions. A pharmacist must comply with the one pharmacy rule, but must also comply with quota, placement and premises rules when opening or relocating a pharmacy.
Exceptions and Temporary Responsible Management
The one pharmacist one pharmacy rule is strict, but Turkish law recognizes limited situations where temporary responsible management may be necessary. These situations should not be confused with ownership of multiple pharmacies.
Law No. 6197 provides that civil servants and soldiers cannot open pharmacies or act as responsible managers, but it also recognizes limited temporary arrangements where a pharmacy owner is called for military service or elected to certain offices.
The Regulation on Pharmacists and Pharmacies similarly provides that a pharmacy owner and responsible manager who is called to military service, or who undertakes certain specified duties such as parliamentary office, mayoral office or Turkish Pharmacists’ Association Presidential Board membership, appoints a responsible manager during that period. The regulation also contains rules on postgraduate education and whether responsible management appointment is required.
These rules do not allow a pharmacist to run several pharmacies. They are temporary or special arrangements designed to preserve lawful operation of an existing pharmacy during justified absence.
Inheritance and Heirs
Inheritance is another area where the one pharmacist one pharmacy rule may require careful analysis. When a pharmacist dies, the pharmacy may not simply continue indefinitely as an ordinary inherited business if the heirs are not pharmacists.
Law No. 6197 contains special provisions for situations involving death, legal incapacity and heirs. Depending on the heirs and statutory conditions, the pharmacy may be operated temporarily through a responsible manager or may need to be liquidated or transferred within the legal framework.
The policy is clear: inheritance may protect family and estate interests for a limited period, but it does not permanently transform a private pharmacy into a non-pharmacist family business. Ultimately, pharmacy operation must return to the pharmacist-based legal model.
Compliance Obligations Connected to the Rule
The one pharmacist one pharmacy rule also supports broader compliance obligations. Since the pharmacist is personally connected to the pharmacy, the pharmacist must ensure compliance with medicine tracking, prescription rules and professional service standards.
The Regulation on Pharmacists and Pharmacies requires pharmacies to use the medicine tracking system for transactions such as purchase, sale, return, exchange, destruction of expired or deteriorated medicines and related notifications.
The regulation also sets rules on prescriptions. It requires specific information on prescriptions, recognizes different prescription types, restricts prescriptions received through inappropriate channels such as fax, phone, courier or intermediaries, and prohibits pharmacists from engaging in open or hidden cooperation with institutions, physicians or third parties to collect or direct prescriptions.
These obligations show why personal pharmacist responsibility matters. The pharmacist is expected to control the legality and safety of pharmacy operations. A passive investor model would weaken that responsibility.
Legal Consequences of Violating the Rule
Violating the one pharmacist one pharmacy rule may lead to serious consequences. Depending on the facts, possible consequences may include refusal of a pharmacy license, rejection of transfer or relocation, sham ownership investigation, administrative sanctions, disciplinary proceedings, suspension or cancellation-related measures, contractual invalidity or disputes between investors and pharmacists.
Law No. 6197 also contains penal provisions for opening regulated pharmacy-related institutions without a license or by persons not entitled to practice pharmacy. While the exact legal consequence depends on the conduct, unauthorized or deceptive pharmacy operations can create significant administrative and criminal exposure.
In practice, the most dangerous risk is hidden ownership. A pharmacist who lends their name to a pharmacy may bear professional and legal responsibility without having real control. An investor who attempts to control a pharmacy indirectly may lose the expected commercial benefit and face serious legal disputes. A buyer who ignores the rule may sign a transfer agreement that cannot be implemented.
Practical Checklist for Pharmacists
A pharmacist should consider the following compliance questions before opening, transferring, relocating or investing in any pharmacy-related structure:
Is the pharmacist already the owner or responsible manager of another pharmacy?
Will the pharmacist genuinely own and manage the pharmacy?
Is there any third party who controls capital, profit, stock, bank accounts, employees or commercial decisions?
Is the pharmacy opening or relocation subject to EYS and population criteria?
Has the pharmacist obtained the required license through the provincial health directorate and governorate procedure?
Is the pharmacy premises suitable under the Regulation on Pharmacists and Pharmacies?
Are second pharmacist or assistant pharmacist obligations triggered?
Will the pharmacist be physically present during service hours as required by the regulation?
Are all medicine tracking, prescription and record-keeping obligations properly organized?
Could the arrangement be interpreted as sham ownership by the chamber of pharmacists or provincial health directorate?
These questions should be answered before signing a lease, transfer protocol, investment agreement, loan agreement or consultancy contract.
Practical Checklist for Investors
Investors should approach Turkish pharmacy law with caution. The most important point is that a private pharmacy cannot be treated like an ordinary retail investment. The one pharmacist one pharmacy rule prevents chain ownership and multiple branch control through one pharmacist.
An investor should avoid nominee pharmacist structures. Loan, lease, supply, service and consultancy agreements must not give the investor real control over the pharmacy. Any profit-sharing, management authority, bank account control or mandatory purchasing arrangement should be reviewed carefully.
Investors who wish to participate in the broader Turkish pharmaceutical market may consider legally different areas such as pharmaceutical companies, logistics, medical devices, cosmetics, software, regulatory consultancy or wholesale structures, subject to their own licensing requirements. Private community pharmacy ownership is a much narrower and more restrictive field.
Frequently Asked Questions
Can one pharmacist own two pharmacies in Turkey?
No. Article 18 of Law No. 6197 prohibits a pharmacist from opening more than one pharmacy or assuming responsible management of more than one pharmacy.
Can a company open a chain of pharmacies in Turkey?
As a general rule, no. Private pharmacies are opened under the ownership and responsible management of a pharmacist, and one pharmacist cannot own or manage multiple pharmacies. This makes ordinary corporate pharmacy chain models incompatible with Turkish pharmacy law.
Can a pharmacist employ another pharmacist and open a second pharmacy?
No. Employing another pharmacist does not allow the first pharmacist to own or control a second pharmacy. Second pharmacists and assistant pharmacists may work in a pharmacy, but ownership and responsible management remain subject to the one pharmacy rule.
Can a non-pharmacist investor finance a pharmacy?
Financing arrangements must be reviewed carefully. If the financing gives the investor real ownership or control, the structure may be treated as sham ownership. Turkish pharmacy law contains a specific muvazaa assessment mechanism for suspected sham ownership.
Can a pharmacy be temporarily managed by another pharmacist?
In limited circumstances, yes. Turkish law allows responsible manager appointment in certain cases such as illness, long absence, military service or specified public/professional duties. These are temporary or special arrangements and do not create a right to own multiple pharmacies.
Conclusion
The one pharmacist one pharmacy rule in Turkish law is a cornerstone of pharmacy regulation. It is based on Article 18 of Law No. 6197, which prohibits a pharmacist from opening more than one pharmacy or assuming responsible management of more than one pharmacy.
The rule reflects the Turkish legal policy that pharmacy services must be personally supervised by qualified pharmacists. A pharmacy is not merely a commercial store; it is a healthcare institution where medicine safety, patient counseling, prescription compliance, storage standards, medicine tracking and professional ethics are essential.
The rule has major practical effects. It prevents multiple pharmacy ownership by one pharmacist. It restricts corporate pharmacy chain models. It makes nominee pharmacist structures risky. It protects the independence of the pharmacist. It also supports the administrative mechanisms used to detect sham ownership.
For pharmacists, the rule means that pharmacy ownership must be genuine, personal and professionally supervised. For investors, it means that private pharmacy ownership in Turkey cannot be structured like ordinary retail investment. For buyers and sellers of pharmacies, it means that every transfer must be reviewed in light of pharmacist eligibility, responsible management and sham ownership risk.
A legally secure pharmacy structure in Turkey must comply not only with commercial expectations but also with Law No. 6197, the Regulation on Pharmacists and Pharmacies, EYS rules, population criteria, licensing procedures and professional ethics. In Turkish pharmacy law, the identity and responsibility of the pharmacist are not formal details; they are the foundation of the entire system.
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