Cyprus

The proviso to article 15(1) of the Pharmacy and Poisons Law, Cap. 254, states that no person may own more than one pharmacy, or hold or benefit from more than 51% of the share capital of more than one company carrying on a pharmacy business.

This is not a soft anti-concentration rule of the kind Poland or Portugal operate. It is a hard cap of one. The only exception disapplies it for pharmacies owned by the trade unions PEO, SEK and DEOK operating as non-profits for their members. A transitional grace period for those in breach when Law 145(I)/2000 commenced expired around 2015.

The market shows exactly what you would expect: 615 privately owned pharmacies, and therefore roughly 615 separate owners, plus 19 in health centres and public hospitals, all contracted to the Health Insurance Organisation as of 2023. There is no lawful route to a pharmacy chain in Cyprus, and so no route to the vertically integrated telehealth-plus-pharmacy model that works in Germany or the Netherlands.

The corporate gateway in article 16(1)(a) does permit a company to carry on the business without being registered as a pharmacist, provided the business is under the personal direction and control of a pharmacist. But article 16(1)(b) allows that company to describe itself as a pharmacy only if the controlling pharmacist sits on the board and holds at least 51% of the share capital. A retail pharmacy that may not call itself a pharmacy is not a business.

Part IIB of Cap. 254, articles 19ΣΤ to 19H, was inserted by Law 128(I)/2014 to transpose article 85c of Directive 2001/83/EC. Unlike Malta, Cyprus did transpose it. Article 19Z(1) then sets six cumulative conditions for offering a medicine at a distance, and condition (στ) reads: δεν απαιτείται η προσκόμιση συνταγής για το εν λόγω φαρμακευτικό προϊόν. No prescription is required for the medicinal product in question.

So distance selling of prescription medicines is unlawful. Condition (ε) additionally ties distance selling to a registered pharmacy under article 15, which means whoever does it is a single-outlet operator by definition.

The published list of authorised distance sellers could not be located on the Ministry of Health site, so it is not known whether any Cypriot pharmacy has in fact notified.

Article 32(1) of Cap. 254 permits a pharmacist to supply a prescription medicine only where either a signed prescription in printed form is presented, or an electronic prescription is retrieved through the software of the OAY, the Health Insurance Organisation that runs GESY.

Read that carefully, because it is more restrictive than it first appears. The only electronic prescriptions a Cypriot pharmacy may dispense are those inside the state system, which requires a GESY-contracted prescriber. A private telehealth platform’s own digitally signed prescription satisfies neither limb. There is no third route.

And the cross-border route is paper. Cyprus Pharmaceutical Services state that no pharmacist supplies a prescription medicine from another member state’s doctor unless a signed prescription in printed form is presented, carrying the Directive 2012/52/EU particulars. So a patient must physically hand over a wet-signed sheet.

That is workable for a hybrid clinic model and incompatible with a digital funnel. It is materially tighter than Malta, where digitally signed electronic prescriptions are accepted generally and article 81(3) imposes no printed-form requirement.

All four brands, Ozempic, Wegovy, Mounjaro and Saxenda, are on the Cypriot human medicinal products register and return results under the register’s price-list filter, so they are lawfully available for self-pay purchase. That is a different question from reimbursement.

GESY runs two positive lists set by the Health Insurance Organisation, with external reference pricing for new medicines and internal reference pricing where generics compete. Beneficiaries pay a flat 1 euro copayment for the cheapest generic equivalent and the difference if they want the brand. Whether any GLP-1 sits on the positive list, and whether obesity is a covered indication, could not be established: the GESY site is a single-page application that cannot be read without a browser.

The structural point stands regardless. The public share of pharmaceutical spending in Cyprus reached 71%, which is high, and pharmaceuticals took 17% of total health spending against an EU average of 13%. A high public share means a proportionally small self-pay pool, which is the opposite of the Maltese picture.