Netherlands

Dutch law separates the pharmacy business from the pharmacy licence. Ownership of the operating company is not restricted to pharmacists: a B.V. with foreign, non-pharmacist shareholders is entirely standard. What the law requires is one BIG-registered gevestigd apotheker per pharmacy, entered in the IGJ register, carrying full clinical responsibility 24/7.

The market proves the point. Around 83% of Dutch pharmacies are chain or franchise-affiliated. BENU (~482 pharmacies) sits under Brocacef, majority-owned by Germany's PHOENIX Group. DocMorris has dispensed out of Heerlen for years. Nationale Apotheek B.V. runs as a pure online pharmacy dispensing Wegovy nationally.

The practical constraint is not legal, it is human: finding a BIG-registered pharmacist willing to put their name, personally and permanently, on a high-volume cross-border GLP-1 operation.

• Incorporate a B.V. via KvK; medicines with a Dutch marketing authorisation carry 9% VAT, not 21%.
• Secure a BIG-registered pharmacist as gevestigd apotheker and register them with IGJ under art. 61 lid 5 Geneesmiddelenwet.
• File the Wtza toelatingsvergunning with CIBG, €725. Pharmacies are exempt from the separate meldplicht; an internal supervisory board kicks in above 50 care staff.
• Stand up Wkkgz machinery: quality system, a disputes body, six-week complaint response, incident reporting to IGJ.
• Register on aanbiedersmedicijnen.nl and display the EU common logo before selling anything online. Omitting this is part of what earned Dokteronline its €114,000 fine.
• Buy from a licensed wholesaler (Mosadex, Brocacef, Alliance). A dispensing pharmacy does not need its own €1,700 + €1,600/yr groothandelsvergunning, worth confirming with Farmatec directly.
• Build NEN 7510 data security, Wabvpz consent and logging, and 20-year WGBO record retention.

Buying an existing pharmacy is the cleaner route. There is a real broker market, Brookz, Het Apotheekloket, Pharmaconnect, NFA Fondsen, with four standard transfer structures including instalment purchase over 10–21 years. Actual prices sit behind paid industry reports.

Article 67 of the Geneesmiddelenwet has prohibited internet prescribing to a patient the prescriber has never met, does not know, or whose medication history they cannot access, since 2007. It has never been repealed. The COVID-era exemption expired on 1 June 2022.

What exists instead is the Beleidsregel voorschrijven via internet (Staatscourant 2023, 10521, 11 April 2023): a formal non-enforcement policy under which IGJ will not enforce article 67 provided (a) a physical examination is not medically necessary to the prescribing decision, and (b) the prescriber has and consults the patient's up-to-date medication history. Video, audio and chat all count. Telephone alone and fax do not.

A bill currently before the Tweede Kamer (36.716) amends article 62, not 67. No replacement for article 67 has been introduced. A future minister can withdraw the policy with a Staatscourant notice.

27 February 2026: the consumer programme Kassa exposed a platform called Goodweigh dispensing Ozempic off questionnaire-only consults through an affiliated pharmacy. IGJ on the record: in the Netherlands, a new patient must always be phoned or seen. That single sentence is incompatible with how every platform in this market actually runs intake.

1 July 2025: IGJ ordered Prime Pharmacy B.V. (Venlo) to stop dispensing to Dutch patients entirely: no identity verification of new patients, no documented risk assessment, no check of concurrent medication, no pharmacist access, no final dispensing check, no adverse-effect follow-up. Lifted a week later once the pharmacy committed in writing to stop. Prime Pharmacy is one of the busiest multi-brand fulfilment pharmacies in the country.

2025: IGJ confirmed it is investigating roughly ten online prescription-service companies, several using foreign doctors who never meet Dutch patients. Complaints roughly doubled year on year, explicitly linked to weight-loss drugs.

30 June 2021: the Raad van State upheld €114,000 of fines against Dokteronline's Curaçao-based operator, rejecting the "we are just an intermediary like Booking.com" defence and establishing that Dutch medicines law reaches a foreign entity targeting Dutch consumers.

The "NL pharmacy serves all of Europe" idea is mostly wrong. Per ABDA, only 7 of 27 EU member states permit mail order of prescription medicines at all: Germany, Denmark, Estonia, Finland, Malta, the Netherlands and Sweden. Everywhere else the destination country closes the door regardless of what the Dutch pharmacy is licensed to do.

Germany is the prize and the reason Venlo and Heerlen exist, it needs a §11a ApoG mail-order authorisation and listing on the BfArM Versandhandels-Register. Austria is categorically closed. France, Belgium and Ireland are absent from the permitted list. The UK is a third country post-Brexit and should be treated as infeasible without separate UK importer licensing.

IGJ enforcement here is unusually expansive. As reported by NOS on 18 August 2026, the inspectorate has issued roughly twenty fines between 2023 and 2025 against Dutch newspapers and magazines, NRC, Volkskrant, AD, De Telegraaf, De Stentor, Flair, for articles about Ozempic, Wegovy and Mounjaro, ruled to constitute unlawful public advertising of prescription medicines. DPG Media titles were fined €51,000 and €48,450 in named instances. Media reporting notes that IGJ gives no clear guidance on how such coverage should be written to stay compliant.

If editorial coverage is being fined, assume a brand's own consumer-facing content has no headroom at all.