Requirements: what a pharmacy needs before it may vaccinate

Four conditions have to hold before a pharmacy may vaccinate, and § 2(3a) of the Apothekenbetriebsordnung, the German regulation on running a pharmacy, sets all four: trained pharmacists for the explanation, the history and the consent, those same pharmacists or people they supervise for the injection, a suitable room with the equipment it takes, and public liability insurance that covers harm from the vaccination. A deadline comes on top. The notification reaches the supervisory authority at the latest a week before the first vaccination. What the extension of 2 July 2026 permits at all is the subject of vaccination as a pharmacy service.

The training

Under § 20c(1) sentence 1 IfSG a pharmacist may vaccinate who has been trained by a doctor and had that participation confirmed as successful, who belongs to the staff of a public pharmacy, and who vaccinates people aged 18 and over. Subsection 2 fixes what the training covers: carrying out the vaccination, including the explanation, the history, the vaccination advice and the consent, the contraindications of the particular vaccination, and the emergency measures for an acute reaction to it.

For flu and COVID-19 the curriculum of the Bundesapothekerkammer and the Bundesärztekammer is in place. The ABDA puts it at 14 training hours of 45 minutes: private study, one theory part on each of the two pathogens, one theory part on carrying the vaccination out, and practical training. Anyone without a valid first-aid qualification takes the first-aid part as well. The state chambers of pharmacists are among those offering the training.

For the newly added vaccinations the curriculum is still missing. § 20c(3) IfSG gives the Bundesapothekerkammer until 2 September 2026 for it, together with the Bundesärztekammer and alongside a second curriculum for the supplementary training. On 1 September 2026 the ABDA still listed both as being agreed. Where it can be done, the training may be held digitally.

Whoever is already trained does not start over. Under § 20c(1) sentence 2 IfSG, anyone who completed the training required until 1 July 2026 may give the flu and COVID-19 vaccinations without further training. For the remaining inactivated vaccines the supplementary training comes on top.

The room

What it takes is a suitable room including a waiting area, with the equipment needed to carry vaccinations out. § 35a(3) ApBetrO draws three lines around it: using the room must not disturb the proper running of the pharmacy, while a vaccination is under way the room serves no other purpose, and unauthorised access to pharmacy-only medicines, starting materials and chemicals has to be ruled out.

It need not be a separate room in the sense of the Raumeinheit. Under § 4(1) sentence 2 no. 5 ApBetrO every operating room has to be reachable without leaving the pharmacy, and § 4(4) no. 4 ApBetrO exempts rooms used for vaccinations from exactly that. The same provision replaces it with a softer line: the room has to lie reasonably close to the other operating rooms.

A pharmacy that only vaccinates on visits needs no such room. § 2(3a) sentence 1 no. 3 ApBetrO takes that case out.

The notification to the authority

A deadline stands in front of the first vaccination. Under § 2(3a) sentence 2 ApBetrO the head of the pharmacy notifies the responsible authority that it will carry out vaccinations and, unless it vaccinates only on visits, of the rooms intended for them, at the latest a week before vaccinations begin.

The same week applies again later. Where something about the vaccinations or the rooms changes, sentence 3 requires notice at the latest a week before it is put into effect. What your supervisory authority expects in it is a question for that authority, because the federal states handle it differently.

Insurance and quality management

§ 2(3a) sentence 1 no. 4 ApBetrO requires public liability insurance for the pharmacy that covers possible harm from carrying out the vaccinations. Whether an existing policy does that is a question for the insurer.

The procedures belong in the quality management system under § 2a ApBetrO. § 35a(1) ApBetrO lists what has to be fixed there: preparing the vaccination, the explanation and the consent, the history and the decision when not to vaccinate, administering the vaccine, the documentation, hygiene measures including the hygienic conduct of everyone involved, and the report where harm beyond the usual extent of a vaccination reaction is suspected.

The report to the Robert Koch-Institut

Whoever vaccinates reports. Under § 13(5) IfSG the bodies and people responsible for carrying out vaccinations transmit data to the Robert Koch-Institut for vaccination surveillance and to the Paul-Ehrlich-Institut for pharmacovigilance, at intervals those two set. What goes across is pseudonymised, among it the month and year of birth, sex, postcode and the date of the vaccination.

The route is DEMIS, the German electronic reporting and information system for infection protection. The Bundesapothekerkammer names two ways there in its guideline: for a pharmacy using the profession’s own GEDISA portal for the vaccination, the report is generated once the vaccination data are entered, and otherwise the pharmacy connects to DEMIS itself.

Who besides the pharmacist may vaccinate

Administering the vaccine can be delegated under § 20c(4) IfSG to people in practical training to become a pharmacist, to pharmaceutical technical assistants and to pharmaceutical engineers. What that takes is training by a doctor of their own with participation confirmed, and the supervision of the delegating pharmacist. The explanation, the history, the consent and the vaccination record under § 22 IfSG stay with that pharmacist.

For this training § 20c(4) sentence 4 IfSG sets 2 November 2026, and until then the model curriculum is missing here too. The pharmaceutical staff of the pharmacy may help regardless: under § 35a(2) ApBetrO with the preparation and the documentation, where they are sufficiently qualified and trained regularly. Those training measures have to be documented.

With all of it in place, what is left are the appointments that fill the vaccination hours. How a pharmacy gets listed and takes bookings online is set out under becoming a listed pharmacy.